Loading...
HomeMy WebLinkAbout02-3816MARK 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 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. :COURT OF COMMON PLEAS :CIVIL DIVISION Cumberland County David E. Mangold Carolyn A. Mangold = NO. 920 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISo Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 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 /s/ 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: Option One Mortgage Corporation Assignments of Record to: First Union National Bank, as Trustee Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 920 West Trindle Road MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Silver Springs COUNTY: Cumberland DATE EXECUTED: 09/24/97 DATE RECORDED: 09/30/97 BOOK: 1407 PAGE: 715 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 07/30/02: Principal of debt due and unpaid Interest at 10.575 from 10/01/01 to 07/30/02 (the per diem interest accruing on this debt is $52.98 and that sum should be added each day after 07/30/02) Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $150.29 and that sum should be added on the first of each month after 07/30/02) Late Charges (monthly late charge of 102.56 should be added in accordance with the terms of the note each month after 07/30/02) Other Fees Attorneys Fees (anticipated and actual to 5t of principal) TOTAL $181,377.22 15,938.82 250.00 280.00 (375.35) 205.56 1,297.04 9,068.86 $208,042.15 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $208,042.15 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 1303 Township of SSilve(2S certain tracts of real estate situate in the Pennsylvania, being improve County Of Cumberland and State of other outbuildings, bounded and deascribed as dwelling h a , se an wit; TRACT NO. I. BEGINNING at a stone at the corner of land now or formerly of H. M. Bare; thence by land now or formerly of Clayton Coover, South 18 degrees 30 minutes East, four hundred forty-two and two tenths (442.2) Feet to an iron pin in the degreeso30 minutesdWest# along feet sto t an 7iron pin; thence by, Tract No. 2, hereinafter described, north 18 degrees 30 minutes West, four hundred thirty-nine and seven tenths (439,7) feet to a atone; thence by land now or formerly of H. M. Bare, North 70 degrees East, one hundred live (105) ;feet to a stone at the place of BEGINNING. CONTAINING one (1) acre and ten (10) perches. TRACTS NO. 2; BEGINNING at an iron pin in the Trindle Road at the southwest corner of Tract Igo. 1, hereinabove described; thence along said Tract No. 1, forth 18 degrees 30 minutes West, four hundred thirty-nine and seven tenths (439.7) feet to a stone at the corner of lands now or formerly of H. M. Bare; thence along lands of the same, South 70 degrees West, ten (lo) feet tp an iron pin; thence along lands now or formerly of Abram R. Longenecker and wife, South 18 degrees 30 minutes East, four hundred thirty-nine and two tenths (439.2) feet to a point in the Trindl Bas e Road; thence along said Road, North 71 degrees 30 minutes t, ten (10) feet to an iron pin in said Road,'at the place of BEGINNING. CONTAINING sixteen (16) perches of land. O C W E N February 14, 2002 '0001156423` - David E. Mangold 920 W Trindle Road Mechanicsburg, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the. default is provided in the attached pages.. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works.. To see if HEMAP can hell) you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice. If you have any Questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (versons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area The local bar association may be able to help you find a lawyer. . La Notificaion en adjunto es de sums importancia, pues afecta su derecho a continuar viviendo en so rasa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mercionado arriba Puedes ser elegible pars un prestamo por el programs llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salver su rasa de la perdida del derecho a redimir su hipowa HOMEOWNER'S NAME(S) David E. Mangold PROPERTY ADDRESS: 920 West Trindle Rd Mechanicsburg, PA 17055-0000 LOAN ACCOUNT 30999726 CURRENT SERVICER Ocwen Federal Bank FSB You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Acf'). You may be eligible for emergency mortgage assistance: if your default has been caused by circumstances beyond your control, you have a reasonable prospect of being able to pay your mortgage payments and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notice. T? ust occur within the next thirty (30) days. -IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE T BRING YOUR CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counselin¢ agencies for the county in which your property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this 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 Homeowners' Emergency Mortgage Assistance Fund In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that additional 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 Agency of its decision oz 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 AM apply for Emergency Mortgage Assbtance) HOW TO CURE YOUR MORTGAGE DEFAULT(Brina it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at 920 West Trindle Rd. Mechanicsburg, PA 17055-0000 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due (a) 4 Payments @ $1,859.61 $7,438.44 (b) Late charge(s) : $.00 (c) Other charge(s)`. NSF & Advances $.00 (d) Less: Credit Balance $.00 (e) Total amount required as of 02/13/2002: $7,438.44 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable) HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date ofthis letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $7,438.44, PLUS ANY MORTGAGE PAYMENTS AND LATE. CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577. Page three 30999726 IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, Oewen Federal Bank FSB also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-. The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30)DAY period, you will not be required to pay attorneys' fees OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges,. charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such sheriff s sale could be held is would be approximately five (5) 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. HOW TO CONTACT THE LENDER - Name of Lender: Ocwen Federal Bank FSB Address: 12650 Ingenuity Drive, Orlando, FL 32826 Telephone Number: (800) 746-2936 EFFECT OF SHERIFF'S SALE- You should realize that a sheriff's sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriffs sale, a lawsuit to remove you and your furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied YOU MAY ALSO HAVE THE RIGHT To sell the property to obtain money to pay off the mortgage debt, or borrower 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. (However, you arenot entitled to this right more than three times in a calendar year). To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted tinder the mortgage documents. To assert any other defense you believe you may have to such action by the leader. To seek protection under the federal bankruptcy law. b Page four 30999726 Ocwen Federal Bank FSB is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in writing at the below address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, if the original creditor is different from the current creditor Unless you dispute the debt within that 30 day period, we will assume that it is valid. Sincerely, Omen Federal Bank FSB Ocwen Federal Bank FSB, P.O. Box 24737, West Pahn Beach, FL 33416 Phone (800) 746-2936 } j OOWEN February 14, 2002 •0001156424' Carolyn A. Mangold 920 W Trindle Road Mechanicsburg, PA 17055 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to:foreelose. Specific information about the nature of the default is provided in the attached pages. IldPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY wnwN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of tlis Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll fret at 1-800-342-2397 (persons with impaired hearing can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area The local bar association may be able to helpyou find a lawyer. . La Notificaion en aeijunto es de suma importencia, pues afexta su derecho a continuar viviendo en su casa. Si no comprende d esontenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cagas al numero mercionado arriba. Puedes ser elegible pare un prestamo por el programs ilamado "Homeowners' Emergency Mortgage Assstanee Program" al cual puede salver an case de la perdida del derecho a redimir su hipotec& HOMEOWNER'S NAME(S) : Carolyn A. Mangold PROPERTY ADDRESS: 920 West Trindle Rd Mechanicsburg, PA 17055-0000 LOAN ACCOUNT 30999726 CURRENT SERVICER Ocwen Federal Bank FSB . You may be eligible for financial assistance which can save your home from foreclosure and he you make future mortgage payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (th; "Act"). You may be eligible for emergency mortgage assistance: if your default has been caused by circumstances beyond your control, you have a reasonable prospect of being able to pay your mortgage payments and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency: TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of the forecbsure on your mortgage for thirty (30) days from the daze of this Notice. During that time you must arrange and attend a "face-to-fag;" meeting. with one of the designated consumer counseling agencies listed at the end of this Notice. This meeting must occur wihin the next thirty (30) days. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRINGYOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Page two 30999726 CONSUMER CREDIT COUNSELING AGENCIES- If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this 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 Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance 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 completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION- Available fiends 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 you application. During that additional 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 Agency of its decision or 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 an sefi apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above tender on your property located at 920 West Trindle Rd. Mechanicsburg, PA 17055-0000 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the follbwing amounts are now past due (a) 4 Payments @ $1,859.61 $7,438.44 (b) Late charge(s) $.00 (c) Other charge(s): NSF & Advances $.60 (d) Less: Credit Balance $.00 (e) Total amount required as of 02/13/2002: $7,438.44 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable) : HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date oftlais letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $7,438.44, PLUS ANY MORTGAGE. PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THEZTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money ordermade payable to Ocwen Federal Bank FSB at PO BOX 514577, LOS ANGELES, CA 90051-4577. Page three 30999726 IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, Ocwen Federal Bank FSB also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-. The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the leader refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00.. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (30)DAY period, you will not be required to pay attorneys' fees. OTHER LENDER REMEDIES- The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE- If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE- It is estimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Ocwen Federal Bank FSB Address: 12650 Ingenuity Drive, Orlando, FL 32826 Telephone Number (800) 746-2936 EFFECT OF SHERIFF'S SALE- You should realize that a sheriffs 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 furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE- You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior m or at the sale and that the other requirements of the mortgage are satisfied YOU MAY ALSO HAVE THE RIGHT. To sell the property to obtain money to pay off the mortgage debt, or borrower 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. (However, you arenot entitled to this right more than three times in a calendar year). To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted incler 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 banlauptcy law. Page four 30999726 Ocwen Federal Bank FSB is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. If you notify us in writing at the below address within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you, upon your written request, verification of the debt or a copy of any judgment entered against you. 2) Provide to you, upon your written request, the name and address of your original creditor, if the original creditor is different from the current creditor Unless you dispute the debt within that 30 day period, we will assume that it is valid. Sincerely, Ocwen Federal Bank FSB Ocwen Federal Bank FSB, P.O. Box 24737, West Palm Beach, FL 33416 Phone (800) 746-2936 V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Al Mark YJ. ren, ESQUIRE MARK J. UDREN & ASSOCIATES N ? O 61 b v a G T ?= r,) J OD. .a T r'r 1 10(13 SHERIFF'S RETURN - REGULAR CASE NO: 2002-03816 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS MANGOLD DAVID E ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MANGOLD DAVID E the DEFENDANT , at 2116:00 HOURS, on the 20th day of Auaust , 2002 at 920 WEST TRINDLE ROAD MECHANICSBURG, PA 17055 by handing to MELODY MCCOMBS, GIRLFRIEND 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 6.21 Affidavit .00 Surcharge 10.00 .00 34.21 Sworn and Subscribed to before me this day of A aT. _ ?.. Z., A.D. nvP othonotary So Answers: R. Thomas Kline 08/22/20 MARK UDR By: SHERIFF'S RETURN - REGULAR CASE NO: 2002-03816 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS MANGOLD DAVID E ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon the MANGOLD CAROLYN A DEFENDANT , at 1957:00 HOURS, on the 21st day of August , 2002 at 1082 TUNBERRY CT MECHANICSBURG, PA 17055 by handing to CAROLYN LANDIS (MANGOLD) 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 6.00 Service 9.66 Affidavit .00 Surcharge 10.00 .00 25.66 Sworn and Subscribed to before me this day of !I nT-_O aUV _) A.D. L ?, ate. ; ? P othonotary So Answers: R. Thomas Kline 08/22/20 MARK UDR By: 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 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3816 BUGGXM-ION-OF --BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, David E. Mangold has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on May 30, 2003, Bankruptcy Case No. 03-03241. Mark J. Udren, Esquire MARK J. UDREN & ASSOCIATES Attorney for Plaintiff O ? w ^U 00 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 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE v. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 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) David E. Mangold and Carolyn A. Mangold 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 7/31/02 to 5/11/04 Late charges per Complaint From 7/31/02 to 5/11/04 Escrow payment per Complaint From 7/31/02 to 5/11/04 TOTAL $247,992.27 $208,042.15 34,489.98 2,153.76 3,306.38 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 attach hereto. UDREN LA I C. Mark J. Udren ESQUIR Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: /'Z,7Y .Jt')l JnO(-l IND ATED PR RO 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 06003 856-669-5400 First Union National Bank, as Trustee Plaintiff V. David E. Mangold Carolyn A. Mangold Defendant(s) TO: David E. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS € CIVIL DIVISION Cumberland County NO. 02-3816 DATE of Notice: April 29, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARR 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 600-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND,..7TTHIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL-,BE/USED FOR THAT PURPOSE. Mark J. Udren Esquire ' ? /s Woodcrest Corpor ,e Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 First Union National Bank, as Trustee Plaintiff V. David E. Mangold Carolyn A. Mangold Defendant(s) TO: Carolyn A. Mangold 1082 Tunberry CT Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS :CIVIL DIVISION : Cumberland County :NO. 02-3816 DATE of Notice: April 29, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME FOR 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 COLLECTO AND T S IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED:-4P LL HE'[JD FOR THAT PURPOSE. /s/ ,MarkZyV. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 1??Jrr(e Z 30 c ?77,726 X61 IN THE UN] TED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: David Eric Mangold Wachovia Bank, N.A. f/k/a First Union National Bank, as Trustee for the Structured Asset Securities Corporation Mortgage Pass- Through Certificates Series 1998-2 Movant VS. David Eric Mangold Debtor(s) and Charles J. DeHart, III, Esquire Trustee CHAPTER 13 CASE NO. 03-03241 MDF 11 U.S.C. SEC. 362 MOD tis r11 Tw, %L APR 2 0'=,' C1Mric 1 too Per -1 , Ift RESPONDENTS ORDER MODIFYING SECTION 362 AUTOMATIC STAY AND NOW, this ?pN-L ?iay of lap-0 20P-1L upon Motion of Movant above, it is ORDERED AND DECREED THAT: The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 U.S.C. 362, is modified with respect to premises: 920 West Trindle Road, Mechanicsburg, PA 17055 as to allow the Movant to foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises; and it is further ORDERED THAT: The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. / ' 44 0?&/IaA? BattRrup?y Judge ?k CC. Heidi R. Spivak, Esquire Marisa Joy Myers, Esquire UDREN LAW OFFICES, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Charles J. DeHart, III, Trustee P.O. Box 410 Hummelstown, PA 17036 Dorothy L. Mott, Esq. 125 State Street Harrisburg, PA 17101 David Eric Mangold 920 West Trindle Road Mechanicsburg, PA 17055 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 02-3816 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 Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Carolyn A. Mangold Over 18 As captioned above Unknown David E. Mangold Over 18 As captioned above Unknown Sworn to and subscribed before me this 11th day of May, 2004. Notary gubl?ic Name: Title: Company MARK JVIEN, ESQ. r V/\' ) ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. CARA STEARS NMWFi wGFNEWJERSEY Cnmwm ws,4116r 08 ? (J ? ? O 0 3 ? ? ? ?-? N r; ?'? ;? L _) CJ CP t 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 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $247,992.27 Interest From 5/12/04 6,357.60 to Date of Sale September 8, 2004 Per diem 0$52.98 (Costs to be added) $ UDREN LAW OFFICES, P.C. Mark J.'Udren,l ESQUIRE ATTORNEY FOR PLAINTIFF W I?^Ir ?i -4 \s 6 ?u ,p p „? c.Z - ? p p p °v A C 0 C c` /u 0 C r- d r? =; -I W G:l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3816 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST UNION NATIONAL BANK, AS TRUSTEE, Plaintiff (s) From DAVID E. MANGOLD AND CAROLYN A. MANGOLD (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 $247,992.27 L.L. $.50 Interest FROM 5/12/04 TO DATE OF SALE 9/8/04 -PER DIEM @$52.98 - $6,357.60 Any's Comm % Due Prothy $1.00 Any Paid $136.87 Other Costs Plaintiff Paid Date: MAY 20, 2004 CURTIS R. LONG Prothono o Gy?? (Seal) Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW FFICES, P.C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ... ? LL (i _? -.: "f i L. ?, 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 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 First Union National Bank, as Trustee, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 920 West Trindle Road, Mechanicsburg (Twp of Silver Spring), PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address David E. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Carolyn A. Mangold 1082 Tunberry Ct. Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 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 920 West Trindle Road Mechanicsburg (Twp of Silver Spring), PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: May 11, 2004 UDREN LAW OFFICES, P.C. \I\ ) Mark J. Udre- Attorney for Plaintiff r? c'? _ _ ?..? -i I ....? ` L. ,•11 -, t 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 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: David E. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Your house (real estate) at 920 West Trindle Road, Mechanicsburg (Twp of Silver Spring), PA 17055 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $247,992.27, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 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 TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 r?,? } ?1 + _:7 __? , f : ? . r: i ?_n UDREN LAW OFFICES, P.C. BY: Mark J. Udren ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. David E. Mangold Carolyn A. Mangold :NO. 02-3816 920 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) AMRNDED 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 Sheriffs 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 ;>e/Iforth by Pa Rule C.P. 3129. This Affidavit is made subject to the p relating to unsworn falsification to au Dated: August 3, 2004 BY: 1?eSF?ENILAW PaFICESS PtCon 4904 ate„ U. uu1L 11, msquire Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 First Union National Bank, as Trustee, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 920 West Trindle Road, Mechanicsburg (Twp of Silver Spring), PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address David E. Mangold 314 Brandy Lane Mechanicsburg PA 17055 Carolyn A. Mangold 1082 Tunberry Ct. Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Carolyn A Mangold 1082 Tunberry Court Mechanicsburg PA 17055 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 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 920 West Trindle Road Mechanicsburg (Twp of Silver Spring), PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false st}'tem is he n are made subject to the penalties of 18 Pa.C.S. $ec 9041 /reiating to unsworn falsification to authorities. I / CES, P DATED: August 3, 2004 Attorney for Plaintiff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) DATE: May 11, 2004 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3816 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): David E. Mangold and Carolyn A. Mangold PROPERTY: 920 West Trindle Road, Mechanicsburg (Twp of Silver Spring), PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on September 8, 2004, at 10:00 am, -at--t-Fe Commissioners Hearing Room, 2n F oor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished :by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A q LL m. ug` 6 q ` q q mV? O N DN C?? E m h m a =N ?f L E C l/JLL A Em cE Eonm?? ? ?N vywyma w .? yLL _?2 o_ 5 O W C N U ._ m ? y OL C E?a° Ec . -v d'IL y c c 2 NN a N U -am E'g O d a`a t `m -° ma m yo ENq x c? ' ^= = O y c 12E EA X! = N- S ?Rry V E N c Q U N Y ? a W 8 v y a a 9 m w d? c> OEO C m $ C ! > q E U C W x s W O q ? cao mE a 5 m m 8 n`° ui N am-M N N O m>= ? > m 'E - ° ? m rn33 ?rn °oW eyb U 2N'?? V CS = q MM 'v' S 9 r c ?mYSo?.E p n t oo_ NN.A ° a _ N l Of m n` kl, y.l ?:)1ri Cyr. • m_ X °_ ,i iULF' d m a° ? N9 m m U N NO N rn K ??UU c ???? N v a d a c E m m N m 2 v N m - v ? E U O 65 ? a p 0 d N 0 a m m 0 o v ' a d 7 N N O 2 0 H o (j UtlJ co y C Z 0 0- ? V 6? C y p N O a i m d N 1? Y. O q m , N ? N . N rn .N. C O. 002 0 o ? d c a ? _ O o U? 300- o a m `q d a aN .fn a a J OS `o N ¢ `o It US O ° EN ® Q 0 3 N .N. U C2 ?V1 ? y 0 m Z wos mM Ev c o m°1 ?3?U ma o° of c3 a? ?- UN F m ua a m z ? ? m a c E Q Z m m m a E m o a q d o U Q N N ? y ? a w a c Z¢ O N t?l < p d N M C ?[1 (O A N O) ! X rn m Z m 7 a LL r A W M O U. N HIBIT A LL Y a n b" o o E y K Ewt m._ n ? dNf y mot _ e 0 d m h m a 00.0 'v NLL `-_ ny o v ? ` Esmm °E 5 o r a m fL y - c m moQ ° o = S 0 0 ? d'IL _ , vm°SUa m E'.0 O m9Em W e m a m 0 ? E c V O F. ' w o yU c da E? o x' e« E E=5 Q,,. i a aWd @ Q U N 'Y "c m L N U a~OU 9 ? y N O= SC ? y c c> 5 - 5 12 _? m E ? ?? m$ x w E m 0 N N d o m¢ m ? J C 7 N `? W S T O 2 v Ira . = °mo ? 00 o ? m N= .. O O Q- v L Ew 5 ma ° . - a m o n 0?tt _ . >oE .cn ED 21 c 2 EX' - O d .?E"' .r ?dEE 0 ? 2 0 cv?? ? Y N _ ¢ "Sw m ?. w o ? o ma y yv - rnJOr m v y N O KsUU ???? m N o` 'c E a Q U U d d g a O r ? O O O O U ?' N ? N d d d a Z• E . , a N ° ? % ? a Li t f m c a N N M 0 fn N N U 0 N O 0 CL o N aO E O H N O y OV EZ a oa u a Q n a m R d m J 02 93r E c Z m -` 0 L Z a ? v y p ' ???U O mQ 10- K Ua . U N V d O N J d c ? n o Z c 0 m m9 o Ua Q E„ d Ja a c ZQO O N M V V7 N M t0 r 00 O H? C d IL _c 0 a m `o Y C w 4) CL H d d CL E 0 U d N LL m m m m LL n r m m E 0 LL U) 7 XfIBI A First Union National Bank, as Trustee VS David E. Mangold and Carolyn A. Mangold In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3816 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2004 at 8:56 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit:/David E. Mangold] by making known unto Amber Jetsay, adult in charge, at 314 Brandy Lane, Mechanicsburg, 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 July 09, 2004 at 9:17 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Carolyn A. Mangold, by making known unto Carolyn Mangold, personally, at 1082 Tunberry Court, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly swom according to law, states that on July 15, 2004 at 5:49 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 David E. Mangold and Carolyn A. Mangold located at 920 West Trindle Road, Mechanicsburg, 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: David E. Mangold, by regular mail to his last known address of 314 Brandy Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of July 16, 2004 and never returned to the Sheriffs Office. 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: Carolyn A. Mangold, by regular mail to her last known address of 1082 Tunbeny Court, Mechanicsburg, PA 17055. This letter was mailed under the date of July 16, 2004 and never returned to the Sheriffs Office. Sworn and subscribed to before me So Answers: e This day of%%a'a r? R. Thomas Kline, Sheriff 2004, A.D. Prothonotary By LL Real Est Deputy h.) GO O ? °° _i? Y1 .q t ? " ? ? f 1?1 '-??? i , i ? ll? ?i -1 17 r ? ?. ? l ? CJ !?r1 ? N 17 _ N ` COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I 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 Maynard F Bertolet is the grantee the same having been sold to said grantee on the 8th day of Seat A.D., 2004, under and by virtue of a writ Execution issued on the 20th day of May, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 3816, at the suit of First Union Natl Bk Tr against David E Mango d & Carolyn A is duly recorded in Sheriff's Deed Book No. 265, Page 4017. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this % day of , A.D2004 n Recorder of Deeds ' m zi First Union National Bank, as Trustee VS David E. Mangold and Carolyn A. Mangold In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3816 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2004 at 8:56 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: David E. Mangold, by making known unto Amber Jetsay, adult in charge, at 314 Brandy Lane, Mechanicsburg, 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 July 09, 2004 at 9:17 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Carolyn A. Mangold, by making known unto Carolyn Mangold, personally, at 1082 Tunberry Court, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2004 at 5:49 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 David E. Mangold and Carolyn A. Mangold located at 920 West Trindle Road, Mechanicsburg, 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: David E. Mangold, by regular mail to his last known address of 314 Brandy Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of July 16, 2004 and never returned to the Sheriffs Office. 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: Carolyn A. Mangold, by regular mail to her last known address of 1082 Tunberry Court, Mechanicsburg, PA 17055. This letter was mailed under the date of July 16, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, lie exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 8, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $120,000.00 to Maynard F. Bertolet. It being the highest bid and best price received for the same, Maynard F. Bertolet of 920 West Trindle Road, Mechanicsburg, Pennsylvania 17055 being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $125,287.96. Sheriff s Costs: Docketing $30.00 Poundage 2400.00 Posting Bills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 26.64 Levy 30.00 Surcharge 40.00 Law Journal 353.75 Patriot News 319.06 Share of Bills 30.49 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 3395.94 Sworn and subscribed to before me So An This ,ZF' day of ?LIO ( y -R.-Thomas Kline, Sheriff 2004, A.D. P t onotary BY dY Real Este Deputy ,N 30 1' ? y9Ly9 I?G+L- • ?SLFG? SCHEDULE OF DISTRIBUTION SALE NO. 25 Date Filed: October 08, 2004 Writ No. 2002-3816 Civil Term First Union National Bank, as Trustee VS David E. Mangold and Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Sale Date: September 08, 2004 Buyer: Maynard F. Bertolet Bid Price: $120,000.00 Real Debt: $247,992.27 Interest: 6,357.60 Attorney's Costs: 136.87 Total: $254,486.74 DISTRIBUTION: Receipts: Cash on account (05/26/04): $ 1,500.00 Cash on account (09/08/04): 12,000.00 Cash on account (09/24/04): 113,287.96 Total Receipts: $126,787.96 TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 25 Held Wednesday, September 8, 2004 Date: September 8, 2004 TAXES: Receipts for all taxes for the years 2001 to 2003 inclusive. Taxes for the current year 2004. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2004, and recorded , 2004, in Cumberland County Deed Book , Page RECITAL: Being the same premises which David J. Carlin, widower, by deed dated February 12, 1987 and recorded February 13, 1987 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle Pennsylvania, in Deed Book "M," Volume 32, Page 612, granted and conveyed to David E. Mangold and Carolyn A. Mangold, his wife. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of West Trindle Road. 6. Mortgage given by David E. Mangold and Carolyn A. Mangold to Option One Mortgage Corporation dated September 24, 1997 and recorded September 30, 1997 in Mortgage Book 1407 Page 715 in the amount of $185,725.00. Said mortgage was assigned to First Union National Bank as Trustee by instrument recorded October 3, 2002 in Miscellaneous Record Book 690 Page 3430. Complaint in mortgage foreclosure filed by First Union National Bank as Plaintiff, against David E. Mangold and Carolyn A. Mangold, as Defendants, on August 8, 2002 in the Office of the Prothonotary of Cumberland County to File No. 2002-3816. Judgment in the amount of $247,992.27 entered May 20, 2004. 7. Judgment note in the amount of $400,000.00 entered by Carolyn A. Mangold as Plaintiff against David E. Mangold as Defendant on July 12, 2001 in the Office of the Prothonotary of Cumberland County to File No. 2001-4244. It is to be noted that said judgment is a lien on the real estate by virtue of the divorce between Carolyn A. Mangold and David E. Mangold granted July 11, 2001. 8. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau in the amount of $1,944.71 as of the date of this report. 9. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 10. Real estate taxes accruing on and after January 1, 2005 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Tilde Report shall not be valid or indi g until countersigned by an authorized signato . ber REAL ESTATE SALE NO. 25 19, my Writ Plo. 2002-3816 Civil in ten First Union National Bank, F, as Trustee vs. David E. Mangold and Carolyn A. Mangold Atty.: Mark J. Udren ALL THOSE TWO (2) certain tracts of reel estate situate in the Township of Silver Spring, County of Cumberland and State of Penn- sylvania, being improved with a brick dwelling house and other out- buildings, bounded and described ie as follows, to wit: ti- TRACT NO. 1: BEGINNING at a to stone at the corner of land now or °d formerly of F[. M. Bare; thence by ig land now or formerly of Clayton Y, Coover, South 18 degrees 30 min- re utes East, four hundred forty-two :)f and two tenths (442.2) feet to an d iron pin in the center of the Trinclle I Road; thence along said Road, South [- 71 degrees 30 minutes West, one )f hundred five (105) feet to an iron l- Pin; thence by Tract No. 2, herein- It after described, North 18 degrees 30 minutes West, four hundred thirty-nine and seven tenths (439.7) feet to a stone: thence by land now or formerly of H. M. Bare, North 70 degrees East, one hundred five (105) feet to a stone at the place of BEGINNING. CONTAINING one (1) acre and ten (10) perches. TRACTS NO. 2: BEGINNING at an iron pin in the Trindle Road at -- '' the southwest corner of Tract No. 1, hereinabove described; thence along said Tract No. 1, North 18 degrees 30 minutes West, four hun- dred thirty-nine and seven tenths (439.7) feet to a stone at the corner of lands now or formerly of H. M. Bare, thence along lands of the same, South 70 degrees West, ten (10) feet to an iron pin; thence along lands now or formerly of Abram R Longanecker and wife, South 18 degrees 30 minutes East, four hun- dred thirty-nine and two tenths (439.2) feet to a point in the Trindle Road; thence along said Road, North 71 degrees 30 minutes East, ten (10) feet to an iron Fein in said Road, at the place of BEGINNING. CONTAINING sixteen (16) perches of land. BEING KNOWN AS: 920 West Trindle Road, Mechanicsburg ('Itip, of Silver Spring), PA 17055. PROPERTY ID NO. 38-24-0781- 025. TITLE TO SAID :PREMISES IS VESTED IN David E. Mangold and Carolyn A. Mangold, his wife by Deed from David J. Carlin, widower dated 2/12/87 recorded 2/13/87 in Deed Book M32 Page 612. 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 First Union National Bank, as -:COURT OF COMMON PLEAS Trustee :CIVIL DIVISION 12650 Ingenuity Drive :Cumberland County Orlando, FL 32826 :MORTGAGE FORECLOSURE Plaintiff V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 First Union National Bank, as Trustee, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property, located at: 920 West Trindle Road, Mechanicsburg (Twp of Silver Spring), PA 17055 1. Name and address of owner(s) or reputed owner(s): Name Address David E. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Carolyn A. Mangold 1082 Tunberry Ct. Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold.: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 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 Section 13 N. Hanover St., Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, Dept. 280946 Department of Revenue 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 920 West Trindle Road Mechanicsburg (Twp of Silver Spring), PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN ::,AW OFFICES, P.C. DATED: May 11, 2004 nc)ns. ) Mark J. Udren, ESQ. 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 First Union National Bank, as :COURT OF COMMON PLEAS Trustee :CIVIL DIVISION 12650 Ingenuity Drive :Cumberland County Orlando, FL 32826 :MORTGAGE FORECLOSURE Plaintiff V. David E. Mangold :NO. 02-3816 Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Carolyn A. Mangold 1082 Tunberry Ct. Mechanicsburg, PA 17055 Your house (real estate) at 920 West Trindle Road, Mechanicsburg (Twp of Silver Spring), PA 17055 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $247,992.27, 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)-669-5,100. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgmt?nt 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 856-482- 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 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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 First Union National Bank, as Trustee 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CumberlarLd County MORTGAGE FORECLOSURE V. David E. Mangold Carolyn A. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 NO. 02-3816 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: David E. Mangold 920 West Trindle Road Mechanicsburg, PA 17055 Your house (real estate) at 920 West Trindle Road, Mechanicsburg (Twp of Silver Spring), PA 17055 is scheduled to be sold at the Sheriff's Sale on September 8, 2004, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $247,992.27,, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the v?)lue 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 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 Assoc=.ation 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 =W0 (2) certain tracts of real estate situate in the Township of Silver Spring, County pf Cumberland and State of Pennsylvania, being improved with a brick duelling house and other outbuildings, bounded and described as follows, to wit: TRACT No. 1. BEGINNING at a stone at the corner of land now or formerly of H. M. Bare; thence by land now or formerly of Clayton Coover, South 19 degrees 30 minutes East, four hundred forty-two and two tenths (442.2) feet to an iron pin in the center of the Trindle Road; thence along said Road, South 71 degrees 30 minutes West, one hundred fives (105) feet to an iron pin; thence bye Tract No. 2, here=inafter described, North 18 degrees 30 minutes West, four hundred thirty-nine and seven tenths (439.7) feet to a stone; thence by land now or :Cormeeriy of H. M. Bare, North 70 degrees East, one hundred five (105) feet to a stone at the place of BEGINNING. CONTAINING one (1) acre -and ten (10) perches. TRACTS NO. 2: BEGINNING at an iron pin in the Trindle Road at the southwest.corner of Tract No. 1, hereinabove described; thence along sai$ Tract No. 1, North 18 degrees 30 minutes West, four hundred thirty-nine and seven tenths (439.7) feet to a stone at the corner of lands now or formerly of U., M. Bare; thence along lands of the same, South 70 degrees West, ten (10) feet tQ ! an iron pin; thence along lands now or fori%e:rly of Abram R. Longanecker and wife, South 16 degrees 30 minutes Sast, four hundred thirty-nine and two tenths (439.2) feet to a point in the Trindle Road; thence along said Road, North 71 degrees 30 minutes ! East, ten (10) feet to an iron pin in said Road, *at the place of BEGINNING. CONTAINING sixteen (16) perches of land. BEING KNOWN AS: 920 WEST TRINDLE ROAD, MECHANICSBURG (TWP. OF SILVER SPRING), PA 17055 PROPERTY ID NO. 38-24-0781-025 TITLE TO SAID PREMISES IS VESTED IN DAVID E. MANGOLD AND CAROLYN A. MANGOLD, HIS WIFE BY DEED FROM DAVID J. CARLIN, WIDOWER DATED 2/12/87 RECORDED 2/13/87 IN DEED BOOK M32 PAGE 612 WRIT OF EXECUTION anti/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3816 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST UNION NATIONAL BANK, AS TRUSTEE, Plaintiff (s) From DAVID E. MANGOLD AND CAROLYN A. MANGOLD (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 $247,992.27 L.L. $.50 Interest FROM 5/12/04 TO DATE OF SALE 9/8/04 - PER DIEM @S52.98 - $6,357.60 Atty's Comm % Due Prothy $1.01) Atty Paid $136.87 Other Costs Plaintiff Paid Date: MAY 20, 2004 CURTIS R. LONG Proth o (Seal) B ' f U/ Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale #25 On June 10, 2004 the sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as 920 West Trindle Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 10, 2004 Byrd 1 ?VI Real EsDuty 'm3d THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 27th day(s) of July and the 3rd and 10th day(s) of August 2004. 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 ............ ?1. ............................ COPY Sworn to subscribed before in is 23rd day ofAbgust ?04 A.D. S A L E #25 NOTaRi?i s , Terry L. Russell, Notary ?? REAL ESTATE SALE No. 25 Gly of Harrisburg, Douphin Writ No. 2002-3816 My commission Expires June 6, 2006 NOT Y PUBLIC Civil Term Member, Penns IveniaAssociation ssion expires June 6, 2006 First Union National Bank, y As Trustee Va CUMBERLAND COUNTY SHERIFFS OFFICE David E. Mangold and Carolyn A. Mangold CUMBERLAND COUNTY COURTHOUSE Atty: Mark J. Udren CARLISLE, PA. 17013 DESCRIPTION ALL THOSE Two (2) certain tracts of real Statement of Advertising Costs estate situate in the Township of Silver Spring, County of Cumberland and State of Petmsyl- vania, being improved with a brick dwelling To THE PATRIOT-NEWS CO. house and other out-buildings, bounded and For publishing the notice or publication attached described as follows, to wit: TRACT NO. 1: BEGINNING at a stone at hereto on the above stated dates 319.06 the comer of land now or formerly of H. M. Bare; thence by land now or formerly of Clay-ton Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... Coover, South 18 c.grees "j nunates Last, Your hundred forty-two and two-tenths (442.2) feet to an iron pin in the center of the Trindle Road:. thence along said Road, Srntth 71 degrees 30 min- utes West, one hundred five (105) feet to an iron pin, thence by Tract No. 2, hereinafter described, North 18 degrees 30 minutes West, four hundred thirty-nine and seven-tenths (439.7) feet to a stone; thence by land now or formerly of H. M Bare, North 70 degrees East, one hundred five (105) feet to a stone at the place of BEGINNING' CONTAINING one (1) acre and ten perches, TRACT NO. 2: BEGINNING at an iron pin 11 in the Trindle Road at the southwest comer or Tract No. 1, hereinabove described; thence along said Tract No. 1, North 18 degrees 30 minutes West, four hundred thirty-nine and seven tentbS (439.7) feet to a stone at the comer of lands nose or formerly of H. M. Bare; thence along lands Ul the same, south 70 degrees West, ten (10) feet u an iron pin; thence along lands now rioer formerly 1 R Abram R. Longenecker a degrees 30 minutes East, four hundred thirty-nin, and two-tenths (439.2) feet to a point in the Trindle Road; thence along said Road, North 11 all nor, degrees 30 minutes East, ten n of BEGINNING. pin in said Road, at the p ties of land. CONTAINING sixteen (16) perches BEING KNOWN AS- 920 WestTriFlee Road, Mechanicsburg (Twp of Silver prig)' 17055. PROPERTY ID NO.: 38.24-0781-025. TITLE TO SAID premises is vested in David E. Mangold and Carolyn A. Mangold, his wife, by Deed from David J. Carlin, widower, dated 2/11 87 recorded 2(13/87 in Deed Book M32 Page 612. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 16, 23, 30, 2004 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. 25 Writ No. 2002-3816 Civil First Union National Bank, as Trustee VS. David E. Mangold and Carolyn A. Mangold Atty.: Mark J. Udren ALL THOSE TWO (2) certain tracts of real estate situate in the Township of Silver Spring, County of Cumberland and State of Penn- sylvania, being improved with a brick dwelling house and other out- buildings, bounded and described as follows, to wit: TRACT NO. 1: BEGINNING at a stone at the corner of land now or formerly of H. M. Bare; thence by land now or formerly of Clayton Coover, South 18 degrees 30 min- utes East, four hundred forty-two and two tenths (442.2) feet to an iron pin in the center of the Trindle Road; thence along said Road, South 71 decree.- 'W minute- We-t. nne (Loa' Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 30 day of JULY 2004 NOMp41'AIYSEAL U LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005 hundred five (105) feet to an iron pin; thence by Tract No. 2, herein- after described, North 18 degrees 30 minutes West, four hundred thirty-nine and seven tenths (439.7) feet to a stone; thence by land now or formerly of H. M. Bare, North 70 degrees East, one hundred five (105) feet to a stone at the place of BEGINNING. CONTAINING one (1) acre and ten (10) perches. TRACTS NO. 2: BEGINNING at an iron pin in the Trindle Road at the southwest corner of Tract No. 1, hereinabove described; thence along said Tract No. 1, North 18 degrees 30 minutes West, four hun- dred thirty-nine and seven tenths (439.7) feet to a stone at the corner of lands now or formerly of H. M. Bare; thence along lands of the same, South 70 degrees West, ten (10) feet to an iron pin; thence along lands now or formerly of Abram R. Longanecker and wife, South 18 degrees 30 minutes East, four hun- dred thirty-nine and two tenths (439.2) feet to a point in the Trindle Road; thence along said Road, North 71 degrees 30 minutes East, ten (10) feet to an iron pin in said Road, at the place of BEGINNING. CONTAINING sixteen (16) perches of land. BEING KNOWN AS: 920 West Trindle Road, Mechanicsburg (Twp. of Silver Spring), PA 17055. PROPERTY ID NO. 38-24-0781- 025. TITLE TO SAID PREMISES IS VESTED IN David E. Mangold and Carolyn A. Mangold, his wife by Deed from David J. Carlin, widower dated 2/12/87 recorded 2/13/87 in Deed Book M32 Page 612. ?/J' I