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HomeMy WebLinkAbout02-3948MARK 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 9600 Great Hills Trail, Suite 200W Austin, TX 78759 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION .Cumberland County V. Ralph Charles Crone 1311 Old Willow Mill Road NO. qq? Mechanicsburg, PA 17055 .3 a ?.7U Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 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: Eastern Savings Bank FSB Assignments of Record to: Olympus Servicing, LP f/k/a Calmco Servicing LP 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 anoearina nn f A i rl Me ,-r. -- w: _v 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: 1311 Old Willow Mill MUNICIPALITY/TOWNSHIP/BOROUGH: Silver Spring Township COUNTY: Cumberland DATE EXECUTED: 4/11/00 DATE RECORDED: 4/24/00 BOOK: 1607 PAGE: 747 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 8/01/02: Principal of debt due and unpaid $162,285.39 Interest at 15.508 from 12/17/00 to 8/01/02 (the per diem interest accruing on this debt is $67.36 and that sum should be added each day after 8/01/02) 39,938.54 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) 1,413.00 Late Charges (monthly late charge of $103.71 should be added in accordance with the terms of the note each month after 8/01/02) 3,007.59 Fees Assessed 2085.40 Unapplied Funds (207.39) Attorneys Fees (anticipated and actual to 5% of principal) 8,114.27 TOTAL $217,166.80 7. The attorneys 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 Sheriffs 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 $217,166.80 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren,\ESQUIRE MARK J. UDREN ASSOCIATES Attorney for P1 intiff Attorney I.D. No. 04302 ALL that certain lot of ground situate in silver Spring Township Cumberland County, Pennsylvania, being Lot No. 5 o a ubfuvision plan praparmd for ceorgetta X. Crone by WhittooC and jiartma Registered Engineers, and rooorded in the Office of the Recorder o= Deeds for Cumberland county in Plan Hook 60, page 23o, bounded and described as follows: 880INNING at a point on the Western side of old Nillov Mill Road, as it appears on maid Plan, which point is also' en the dividing lino between Lots Nom. 4 and 5 on said .Plan; thence along said dividing lino, North 79 degrees 25 minutes West 401.72 teat to a point; thence continuing along said dividing line, North 2 degrees 4 2 minutes 40 seconds East 32-6.66 fast to a point on Sine of.land now or vice, thence lalong saidt line eo clavmer,d SoHall uth L89 degrees h17 sLinuto West 370. Cost prop now oroformerl40 of y B Smith$ thane along in lira of f Smuty North 82 degreas 43 minutes Last 301.05 sa a said lend of emib 25 thetas continuing along said land of Smith, south 79 degrees point, mt 490.25 feat to a point on the Western right-of-way line ofu ra Old New sy is Roadg thence along said Western right-otway line, i agrees 45 minutes 20 seconds Past a distance of 75 feet to a point on the dividing line between Late ?Tos, 4 and 5 of said .,Plan, the Place of BEGINNING. CONTnYNiNG 177,817,94 square cast., 4.0821 acres.' Together with the night to use a .25 foot Wide rfght-of-way across the northern portion of Lot No. 4, the center line of which continues along the dividing line between Lob Nos. 2 and 4 and Lots Non. 2 and 3 on the Subdivision Plan to the Western side of old willow Hill Road. rT BEINo the name promises which Georgetta K. Crone, single person, Gy byp hor dead dated February 5, 19910 and recorded in the Recorder o"k eda office in and for Cumberland County, Pennsylvania' in Deed Book Y, volume 34, Page ;046, granted and conveyed unto Ralph Charles Crone and Sandra L. Crone, his wife, Grantors herein. Calmco Servicing L.P.- P.O. Box 202710 Austin, Texas 78720-2710 Phone ( 800) 379-6398/Fax ( 512) 349-8515 December 12, 2000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME ;FROM FORECLOSURE :RALPH CHARLES CRONE 1311 OLD WILLOW MILL ROAD MECHANICSBURG, PA 19055 This is an official notice that Ihe mortgage on your home is in default anii the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save Your home. This Notice explains how the prooram works. Tg.?ge if HEIVIAP can I belI2, you must ME T WITH XCONSUIVIER CREDIT COUNSE I LING AGENC WITHIN 30 DAYS OF.1 HL: DATE OF THIS NQTICE. Take this Notice with you wheg yovirneet with the' =ounseiinci Agency. qurCount gre listed at the end Or this Notice. If vou have any questi g, you may call the Pennsylvania Housing Finan e Agency toll freg at 1-800-342-2397. (Persons with impaired hearing can call 1717) 780?11869), This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help:you find a lawyer. LA NOTIFICACION 'EN kDJLINtb ES DE SUMA IMPORTANCTA, PUGS AFECTA SU .DERECHO A CONTINUAR VIVIF,NDO EN SU CASA. SI NO COMPRF.NDF.. EL: CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA-TRADUCCION INMEDITAMENTG LLAMANDO ESTA AGENCIA;.(PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL :NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN.PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTGCA. EXHIBIT / Ask .Act 91 Notice Ralph Crone Page 3 of 5 APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 1311 Old Willow Mill Road, Mechanicsburg, within Cumberland County, PA 17055, IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the.following amounts are now past due: Payments of $ 2,074.23 per month due from SEPTEMBER 17, 2000 , through the date of this letter (a total of 3 months) and each month thereafter. Accrued Late Charges due after the fifteenth day of the month through the date of this letter and each month thereafter. Fees $ 6,222.69 $ 207.42 $ 381.13 TOTAL AMOUNT DUE: $ 6,811.24 Act 9 1Notice Ralph Crone Page 4 or 5 HOW To CURE THE 0 FAULT -- You may cure the default within THIRTY (30) DAYS of the date of this - notice BY PAYING THE TOTAL. AMOUNT PAST DUE TO THE LENDER,. WHICH IS $6,811.24, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money, order made payable and sent to, Calmco Servicing L.P., P.O. Box 202710, Austin, Texas, 78720-2710. IF YOU DO NOT CURE THE DEFAULT- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lenderever'rf they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY:period;:you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue .you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - if you have not cured the default withimthe THIRTY (30) DAY period and foreclosure proceedings have begun, you stilf.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 or other charges then due, reasonable attorney's 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 -1t is estimated that the earliest date that such a Shenff s Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale: Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. .'HOW TO CONTACT THE LENDER Calmco Servicing, LP P,O: Box 202710, Austin,.Texas 78750 Phone: (800) 379-6398 /Fax: (512) 349-8515 Contact: Loan Resolution Department CRAWFORD COUNTY Hooker T. Washington Center Greater Erie Community Action John F. Kennedy Center, Inc.' 1720 Holland Street Committee 2021 East 20th Street Erie, PA 16503 18 West 9th Street Erie, PA 16510 (814) 453-5744 Erie, PA 16501 .(814) 898-0400 PAX (814) 453-5749 (814) 459-4581 FAX (814) 898-1243 PAX (814) 456-0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue -Farrell, PA 16121 (412) 981-5310 CUM8ERLANn r^nnrrrv Urban League of Metropolitan - CCCS of Western Pennsylvania; Community Action Comm of the capital Harrisburg .Inc. Region N. 6th Street 2000 Linglestown Road 1514 Derry Street Harrisburg, PA 17101 - - Harrisburg, PA 17102 Harrisburg, PA 17104 (717)234-5925 , ,:.(717)541-1757 .(717)232-9757 FAX (717)234-9459 FAX (717) 234-2227 .. ` Adams County Housing Authority YWCA of Carlisle Financial Counseling Services of 139-143 Carlisle St. 301 G Street Franklin Gettysburg, PA 17325 Carlisle, PA 17013 , . 31 West 3rd Street (717)334-1518 (717) 243-3818 Waynesboro, PA 17268 ..,FAX (717) 334-8326 PAX (717) 731-9589 '- (717) 762-3285 DAUPHIN COUNTY -- - CCCS of Western Pennsylvania, Inc. Urban League of Metropolitan ...: Community Action Commission ' 2000 Linglestown Road Harrisburg. of the Capital Region Harrisburg, PA 17102 2107 N. 6th Street . -.1514 Derry Street . ' (717) 541-1757 . Harrisburg, PA 17101 .-Harrisburg PA 17104 (717)234-5925. (717)232-975T FAX (717) 234-9459 PAX (717) 234-2227 7000 1670 00 13 24 15 4201 POS CERTIFIED MAI • ? • O $ a L (Domestic Mail O"I N yy 3Z 3 Y; o ln su,,nce Covorage Provided) X61 C •u R C:3 ru n ' F: . R 3 V ( '? f ? t . ? 0 T p T A ""Stag" 5 , . ..,. 1 ? W .S r t.llfw. d.:e,. ` m R turn rt. r 'O ?t rno a nen; Rnyu .r j r t arY, I .. I r r i= ra p I-- 9nxi en peel e) vea -. __ ..._.-_..._? • p 1=3 [ C.x a ?m'?! ReC r i ?... _ i I coo 33 . N TOW POStage & F".9 `$ f'? C /rvri ? O S) IAO(NO C!P(1 FJ MIJC. -- -- --------------- - C3 ------ O ------ tY 41a1e. 21F.4 ._._ ....__. it - .. ? .. • V E R I F I C A T I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren ESQUIRE MARK J. UDREN & ASSOCIATES Ti- D O C SHERIFF'S RETURN - REGULAR CASE NO: 2002-03948 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND OLYMPUS SERVICING LP ET AL VS CRONE RALPH CHARLES 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 RALPH CHARLES the DEFENDANT , at 1514:00 HOURS, on the 23rd day of August , 2002 at 1311 OLD WILLOW MILL ROAD MECHANICSBURG, PA 17055 by handing to RALPH CRONE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 13.80 Affidavit .00 Surcharge 10.00 .00 41.80 Sworn and Subscribed to before me this Sd. day of '0-V G. .2(%D A.D. othonotary ' So Answers: R. Thomas Kline 08/26/2002 MARK UDREN By: Deputy Sheriff 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County =MORTGAGE FORECLOSURE Plaintiff V. Ralph Charles Crone NO. 02-3948 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSF'SSMFNT OF DAMAG_KS TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest Per Complaint From 8/2/02 to 9/27/02 Late charges per Complaint From 8/2/02 to 9/27/02 Escrow payment per Complaint From 8/2/02 to 9/27/02 $217,166.80 3,839.52 207.42 SL-O_0 TOTAL $22.1 213 74 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. j I J. UDREN & ASSOCIATES c dren, ESQUIRE Attor for Plaintiff DAMAGES ARE HEREBY ASSESSED AS IND7?ATED DATE : CL? PRO PROTHY MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Olympus Servicing, LP f/k/a Calmco Servicing LP Plaintiff V. Ralph Charles Crone Defendant(s) DATED: September 16, 2002 TO: Ralph Charles Crone 1311 Old Willow Moll Road Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3948 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Moll Road Mechanicsburg, PA 17055 Defendant(s) MORTGAGE FORECLOSURE NO. 02-3948 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Ov (Zf rS e COUNTY OF SS CCt m oC e,.? 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 Ralph Charles Over 18 As captioned Unknown Sworn to and subscribed before me this Z7 day imin, YIMO Q. 611,11 ary Puz is Crone above ar ?.C?dr?a, ?S ) Company p, C'f KW JEW 71- 0 r? r V X11 UST' r ~ y C c.? «rn c.n 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff v. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 02-3948 PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $221,213-7-4 Interest From September 28, 2002 10,710.24 to Date of Sale Marshy 2003 Per diem @$67.36 (Costs to be added) $_ MARK J. UDREN & ASSOCIATES rk ?ff. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ti olr T y? N ^6 6\ (? 1 ? ? -0 ? ? ? C N d jr, r, l i t ? ? c^A 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 02-3948 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. C J. UDREN & ASSOCIATES rk Udren, ESQUIRE ATTORNEY FOR PLAINTIFF C) O c:'I' , r O C;c, ' - o 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS .CIVIL DIVISION :Cumberland County Plaintiff v. MORTGAGE FORECLOSURE Ralph Charles Crone NO. 02-3948 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Olympus Servicing, LP f/k/a Calmco Servicing LP, 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: 1311 Old Willow Mill Road, Mechanicsburg, (Silver Spring Twp) PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ralph Charles Crone 1311 Old Willow Mill Road 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 Unemployment Compensation Fund Bell Atlantic - Pennsylvania Inc 16th Floor, L&I Bldg Harrisburg, PA 17121 1717 Arch St., 20th Floor Philadelphia, PA 19103 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. PNC Bank NA 539 South Fourth Ave., Louisville, KY 40202 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 1311 Old Willow Mill Road Mechanicsburg, (Silver Spring Twp) 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: September 27, 2002 MARK J. UDREN & ASSOCIATES Lprok UdrenESQ. rney for Plaintiff ? ?? ?_- „? -?, t,,.., -? f??fi., ? ;..r r_'.. i ?"_ • !'1 ; e `v ? -' - ? ?:? w ";rn L ?-i (T ? 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County -MORTGAGE FORECLOSURE Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 NO. 02-3948 Defendant(s) NOTICE-07- SHERIFF.! S_SALF OY-REAL_PROY-ERTY TO: Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Your house (real estate) at 1311 Old Willow Mill Road, Mechanicsburg, (Silver Spring Twp) PA 17055 is, scheduled to be sold at the Sheriff's Sale on March 5, 2003, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $221,213.74, 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 O?ER'_S__RIGHTS Yo-?7 AV BF?BLES?PRFVFNTSHL4-SHER?FFIS-SArE To prevent this Sheriff's sale, you must take immediate_aot;L03L: 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: 1.8rz6L4H2S.9 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- SAY-.TILL_-BE-AELE .TO_SAS7Z--Y9IIB-PROPERTY-AND-.-COU-HBXE -OTHER-RIGHTS EVER- F THE SHERIFF'S-SALE__D_OES._ TAKE_PIACE- 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 n 3 J r.? ti =7 v. ;% '? 27 yam' .? i?rt' cn -< WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3948 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OLYMPUS SERVICING, LP F/K/A CALMCO SERVICING LP Plaintiff (s) From RALPH CHARLES CRONE, 1311 OLD WILLOW MILL ROAD, MECHANICSBURG, PA 17055 (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 $221,213.74 L.L. $.50 Interest FROM 9/28/02 TO DATE OF SALE 3/5/03 PER DIEM @$67.36 - $10,710.24 Any's Comm % Due Prothy $1.00 Atty Paid $118.80 Other Costs Plaintiff Paid Date: OCTOBER 2, 2002 CURTIS R. LONG Prothonota/r, (Seal) By: Lt?/J n e r AO? ?_ Deputy REQUESTING PARTY: Name MARK J. UDREN ESQUIRE Address: 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856482-6900 Supreme Court ID No. 04302 MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Olympus Servicing, LP f/k/a 'COURT OF COMMON PLEAS Calmco Servicing LP :CIVIL DIVISION 338 Warminster Rd -Cumberland County Hatboro, PA 19040 = Plaintiff V. Ralph Charles Crone = 1311 Old Willow Mill Road :NO. 02-3948 Mechanicsburg, PA 17055 Defendant(s) AFFT 1 -71I, OF SER%1ICE PTPCAUNN7 TO Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the t 3129. imiles I set forth by Pa Rule C.P. This Affidavit is made subject to tl relating to unsworn falsification to Dated: February 22, 2003 BY: hen ies of 18 Pa.C.S. Section 4904 tho i ies. MAJI. J. TDREN & AS IATES Mae# J. U , Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTORNEY FOR BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Olympus Servicing, LP f/k/a ;COURT OF COMMON PLEAS Calmco Servicing LP :CIVIL DIVISION 338 Warminster Rd :Cumberland County Hatboro, PA 19040 Plaintiff :NO. 02-3948 V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) DATE: October 14, 2002 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL. PROP = OWNER(S): RALPH CHARLES CRONE PROPERTY: 1311 Old Willow Mill Road Mechanicsburg, (Silver Spring Twp) PA 17055 Improvements: RESIDENTIAL DWELLING PLAINTIFF The above. captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 5, 2003, at 10:00 A.M., at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. 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D A Olympus Servicing LP f/k/a In The Court of Common Pleas of Calmco Servicing LP Cumberland County, Pennsylvania VS Writ No. 2002-3948 Civil Term Ralph Charles Crone Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 25, 2002 at 3:57 o'clock PM, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Ralph Charles Crone, by making known unto Ralph Crone personally, at 1311 Old Willow Mill Rd., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Harold Weary, Deputy Sheriff, who being duly sworn according to law, states that on January 21, 2003 at 9:11 o'clock A.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 Ralph Charles Crone located at 1311 Old Willow Mill Rd., Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Ralph Charles Crone, by regular mail to his last known address of 1311 Old Willow Mill Road, Mechanicsburg, PA 17055. This letter was mailed under the date of January 22, 2003 and never returned to the Sheriff's Office. Sworn and subscribed to before me This day of So Answers: r-- C , e R. Thomas Kline, Sheriff BYI,?? Real Estate Deputy 2003, A.D. _Prothnnotary EXHIEN f 8 i ?'} ?i ?_l ?? ...? ?' "7,?' _ ? I`Fl [ a ` ::?J ' r-- {1 ? l .!? ?? _ ._ '"? ` ` ' u J <J ? ?S 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3948 SUGG79TTON OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Ralph Charles Crone has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on March 3, 2003, Bankrupt Case No. #03-01188. Mark J. Udr Z&qufre MARK J. UDR %91& ASSOCIATES Attorne for Plaintiff nos __ i_, r .0mr, Olympus Servicing, LP f/k/a Calmco Servicing LP VS Ralph Charles Crone In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3948 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Mark J. Udren. Sheriff s Costs: Docketing 30.00 Poundage 17.47 Surcharge 20.00 Law Library .50 Prothonotary 1.00 Mileage 12.42 Certified Mail 4.65 Levy 15.00 Posting Handbills 15.00 Advertising 15.00 Postpone Sale 20.00 Law Journal 414.20 Patriot News 300.55 Share of Bills 25.21 $ 891.00 paid by attorney 6/11/03 Sworn and subscribed to before me Sao Answe S.. This ?" day o1?J?,. R. Thomas Kline, Sheriff 2003, A.D. BYJod, Prothonotary Real Estat Deputy I.P cke 9) 10 RU,. i 3 9N1 THE PATRIOT NEWS THE SUNMY PATRIOT NEWS Prof of Publication Under Aci No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin;i ss JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. 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 'atriot-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 28th day(s) of January and the 4th and 11th day(s) of February 2003. 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 fa,:ts 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......1` plc:`,.-..... COPY Sworr to and sub re this 14th dd v.6f FebrG SALE #6 REAL ESTATE SALE No. 6 Writ No. 2002-3948 Civil Term Olympus Servicing, LP f/k/a/ Calmco Servicing LP vs Ralph Charles Crone Atty: Mark J. Udren DESCRIPTION ALL that certain. lot of ground situate in Silver Spring Township, Cumberland County, Pennsylvania, being Lot No. 5 on a Subdivision Plan prepared fur Georgetta M. Crone by Whittock and Hannan, Registered Engineers and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 60, Page 130, bounded and described as follows: BEGINNING at a point on the Western side of Old Willow Mill Road, as it appears on said Plan, which point is also on the dividing line between Lots Nos. 4 and 5 on said Plan; thence along said dividing line, North 79 degrees 25 minutes west 402 72 feet to a point: thence continuing along Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 298.80 Probating same Notary Fee(s) $ 1.75 'rota) $ 300.55 Publisher's Rel.eipt 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. Notarial Seal ?- Terry L Russell, Notary Public FMCY,Commi:3sion ty Of HE msburg, Dauphin County Expires June 6, 2006 Member, Penn syNonia .Assrriation Of Notaries ro? ?ry 2003 A.D. ARY PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 By ....................................................... said dividing line, North &e j", 4- mmutcs seconds East 316.86 feet to a point on line of land now or formerly of Ernest Clawser, Sr., anti Nell L. Clawser, his wife; thence along said line of Ckvw, Soo* 19, dWws 17 minutes 40 seconds West 379.03 feet to a point in line of prop,ty now otformaiy of jay IL Smut iheace along said led of Smut, Noah 82' 43 mkRfts East 301.05 feet to a Wit: (I)OW cone ng along said land of Smith, Soutar 79 degmas 25 minutes East 490.25 feet to a point on the Western right-of-way line of Old Willow Mill Road; thence along said Western right-of-way tine. North 21 degrees 45 minutes 20 seconds East a distance of 75 feet to a point on the dividing line between Lots Nos. 4 and 5 of said plan, the place of BEGINNING. CONTAINING 177,817.94 square teet, 4.0821 acres. Together with the right to use a 25-foot- wide right-of-way across the Northern portion of Lot No. 4, the center line of which continues along the dividing line between Lots Nos. 2 and 4 and Lots Nos. 2 and 3 on the Subdivision Plan tc the Western side of Old Willow Mill Road. TITLE TO SAID PREMISES is vested in Ralph Charles Crone, by deed from Ralph Charles Crone and Sandra L. Crone, his wife, dated 3122; 96. recot&d 4/24100, in Deed Book 219. Pagc 796. PROPERTY IDNo . 38-14-0848-064 BEING KNOWN AS 1311 Old Willow Mit! Road, Mechanicsburg, PA 17055 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. _587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 31, FEBRUARY 7, 14, 2003 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. 6 Writ No. 2002-3948 Civil Olympus Servicing, LP f/k/a Calmeo Servicing LP vs. Ralph Charles Crone Atty.: Mark J. Udren ALL that certain lot of ground situate in Silver Spring Township. Cumberland County, Pennsylvania, being Lot No. 5 on a Subdivision Plan prepared for Georgetta M. Crone by Whittock and Hartman, Regis- tered Engineers, and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 60, Page 130, bounded and de- scribed as follows: BEGINNING at a point on the Western side of Old Willow Mill Road, as it appears on said Plan, which point is also on the dividing Editor WORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY. 2003 v <;ioiG/ r a3 K line between Lots Nos. 4 and 5 on said Plan; thence along said divid- ing line, North 79 degrees 25 min- utes West 402.72 feet to a point: thence continuing along said divid ing line, North 2 degrees 42 min- utes 40 seconds East 316.86 feet to a point on line of land now or formerly of Ernest Clawser, Sr., and Nell L. Clawser, his wife; thence along said line of Clawser, South 89 degrees 17 minutes 40 seconds West 370.03 feet to a point in line of property now or formerly of Jay H. South; thence along said land of Smith. North 82 degrees 43 min utes East 301.05 feet to a point; thence continuing along said land of Smith, South 79 degrees 25 min- utes East 490.25 feet to a point on the Western right-of-way line of Old Willow Mill Road; thence along said Western right-of-way line, North 21 degrees 45 minutes 20 seconds East a distance of 75 feet to a point on the dividing line between Lots Nos. 4 and 5 of said Plan, the Place of BEGINNING. CONTAINING 177,817.94 square feet, 4.0821 acres. Together with the right to use a 25 foot wide right-of- way across the Northern portion of Lot No. 4, the center line of which continues along the dividing line between Lots Nos. 2 and 4 and Lots Nos. 2 and 3 on the Subdivision Plan to the Western side of Old Willow Hill Road. TITLE TO SAID PREMISES IS VESTED IN RALPH CHARLES CRONE, BY DEED FROM RALPH CHARLES CRONE AND SANDRA L. CRONE, HIS WIFE, DATED 3/22/ 96. RECORDED 4/24/00. IN DEED BOOK 219. PAGE 796. PROPERTY ID NO.: 38-14-0848- 064. BEING KNOWN AS 1311 OLD WILLOW MILL ROAD. MECHANICS- BURG, PA 17055. Cj 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE :NO. 02-3948 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $221,213.74 Interest From 9-/28/02 22,571.._04 to Date of Sale December 10,2D03 Per diem @$67.36 (Costs to be added) $ MARK J. UDREN & ASSOCIATES Mark J. Udren, ES UI ATTO Y FOR PLAINTIFF p P C c C C O p ID T R y _l f a a CA ? 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 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF .COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 02-3948 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. MARK J. UDREN & ASS CI S Mark J. dren, E UI ATTORNE FOR PLAINTIFF n ? o sY } = cV !`i fJ .v L cx) M41M J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE 'NO. 02-3948 AFFIDAVIT PURSUANT TO RULE 3129.1 Olympus Servicing, LP f/k/a Calmco Servicing LP, 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: 1311 Old Willow Mill Road, Mechanicsburg, (Silver Spring Twp) PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Ralph Charles Crone 1311 Old Willow Mill Road 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 PNC Bank NA Unemployment Compensation Fund Bell Atlantic- Pennsylvannia Inc. 539 South Fourth Avenue, Louisville, KY 40202 C/O Frank Federman 2 Penn Center Plaza, Suite 900 Philadelphia, PA 19102 16th Floor, L&I Bldg., Harrisburg, PA 17121 1717 Arch St., 20th Floor, Philadelphia, PA 19103 /,r4'. Name and address of the last recorded holder of every mortgage of d y .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 1311 Old Willow Mill Road Mechanicsburg, (Silver Spring Twp) 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. MARK J. UDREN & ASSOCIATES DATED: August 7, 2003 rk J. Udren, Q. A for y for Plainti f C> r_-? C - C C7 .;. 11 ?,) - r fb R J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Olympus Servicing, LP f/k/a COURT OF COMMON PLEAS Calmco Servicing LP :CIVIL DIVISION 338 Warminster Rd :Cumberland County Hatboro, PA 19040 MORTGAGE FORECLOSURE Plaintiff V. Ralph Charles Crone 'NO. 02-3948 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) NOTICE-OF SHERIFF'S SATE OF FEAT, PROPERTY TO: Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Your house (real estate) at 1311 Old Willow Mill Road, Mechanicsburg, (Silver Spring Twp) PA 17055 is scheduled to be sold at the Sheriff's Sale on December 10, 2003, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $221,213.74, 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 ARLE TO PPRVF:NT THIS SHERIFF'S SATE To prevent this Sheriff's Sale, you must take inunediate 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) 482-6900. 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 RAVE OTHER RIGHTS EVEN IF?E SHERIFFS 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 LANYBR AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 I C? I r i n o n r_. `-= -, ?, . - --. - , ?. ? ? ?: -., . c? .__ 1 c ' _.. '> i' v -, i t v -? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3948 Civil CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OLYMPUS SERVICING, LP F/K/A CALMCO SERVICING LP, Plaintiff (s) From RALPH CHARLES CRONE (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $221,213.74 L.L. Interest FROM 9/28/02 TO DATE OF SALE 12/10/03 - PER DIEM @ $67.36 - $29,571.04 AtTy's Comm % Atty Paid $1022.30 Plaintiff Paid Date: AUGUST 27, 2003 (Seal) Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary ` Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: 1040 N. KINGS HIGHWAY SUITE 500 CHERRY HILL, NJ 08034 Attorney for: PLAINTIFF Telephone: 856-482-6900 Supreme Court ID No. 04302 57/-Mv? MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF Olympus Servicing, LP f/k/a COURT OF COMMON PLEAS Calmco Servicing LP :CIVIL DIVISION 338 Warminster Rd Cumberland County Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road :NO. 02-3948 Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that. 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time snits e forth by Pa Rule C.P. 3129. This Affidavit is made subject to the p naltie of 18 Pa.C.S. Section 4904 relating to unsworn falsification to au hori=i s. Dated: November 4, 2003 MARK UD N & OCIATES BY: Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Olympus Servicing, LP f/k/a Calmco Servicing LP 338 Warminster Rd Hatboro, PA 19040 Plaintiff V. Ralph Charles Crone 1311 Old Willow Mill Road Mechanicsburg, PA 17055 Defendant(s) DATE: November 3, 2003 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-3948 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF BEAT, PROPERTY OWNER(S): Ralph Charles Crone PROPERTY: 1311 Old Willow Mill Road Mechanicsburg, (Silver Spring Twp) PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 10 2003, at 10:00 A.M., at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. m ? ? 4T Y fN LL o ?j LL m O ?'L^ C E n a`o u e `m °uo 40 a x? m ? w A__=s>v e2 c?a c L) WOO x m 0 n p1 m 'm ? O m mm w m E ac¢E LL 3 m. o. ze5df o a a ti ?• Z Tv'? ?y7. 77tf?1yypp ppn a?G'^ E0.6'AONfl • 7J t1J ?d•J •11 ??....?, / Z Y?'IZ ? ti a? ma o m U S o aao s m ° U SN V U N _ c ? g m `- rn L d' c N S m `w .? Q m _ a? y o c? m m 'Sa n c< .? ?` > °m = n rn^, Q i u v m m m m vZi LY ? f ° 9 1p '} 3 OS O O U O mt C LL LL P i h bZ y O$ C e?-fn C Ca°m Q OOG m Qm w n `m N 1 op e' m aN m? m w. N rn 0, OLL C3 cY2 a fi? Eo °? ma N ?25 o S ? 9?= aQ ?O m? F d z ? O `o KQ m a c5 W Z Za ?lL 8 oa 8? c a N mo= Z EE E:E m^ m 4? m? 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E W e S C 0 9 a m E W Y? m a „ O O a_ E ° ?m z ? g ,R a F m m lL og ?n cc ,, T V O E ?y LL FJ / F Olumpus Servicing, LP fikia Cahnco Servicing LP VS Ralph Charles Crone In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3948 Civil Tenn Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 10, 2003 at 9:33 o'clock AM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Ralph Charles Crone, by making known unto Ralph Crone, personally, at 1311 Old Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2003 at 8:54 o'clock A.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 Ralph Charles Crone located at 1311 Old Willow Mill Rd., 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 one of the within named defendants, to wit: Ralph Charles Crone, by regular mail to his last known address of 1311 Old Willow Mill Rd., Mechanicsburg, PA 17055. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me This day of 2003, A.D. Prothonotary f`qA R. Thomas Kline, Sheriff BY, Real state eputy n © ?fii V: -3 1 i N 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which CSFB Series 2002-NP 14 is the grantee the same having been sold to said grantee on the 10th day of Dec A.D., 2003, under and by virtue of a writ Execution issued on the 27 day of Aug us!, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Tenn, 2002 Number 3948, at the suit of Olympus Servicing LP against Ralph Charles Crone is duly recorded in Sheriff's Deed Book No. 261, Page 4781. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of ? , A.D2004 l 1 O'?corder of Deeds paeorenelDnAr QmbOnA?ut? ttiM4M Ip CamiYYanE?pYatntfintMloodgtd.Mn too! Olumpus Servicing, LP fk/a Calmco Servicing LP VS Ralph Charles Crone In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3948 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 10, 2003 at 9:33 o'clock AM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Ralph Charles Crone, by making known unto Ralph Crone, personally, at 1311 Old Willow Mill Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2003 at 8:54 o'clock A.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 Ralph Charles Crone located at 1311 Old Willow Mill Rd., 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 one of the within named defendants, to wit: Ralph Charles Crone, by regular mail to his last known address of 1311 Old Willow Mill Rd., Mechanicsburg, PA 17055. This letter was mailed under the date of October 8, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 10, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark J. Udren for LaSalle Bank National Association, as Trustee of CSFB Series 2002-NP14. It being the highest bid and best price received for the same, LaSalle Bank National association, as Trustee of CSFB Series 2002-NP14 of 3815 South West Temple, Salt Lake City, UT 84115, being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $877.35, it being costs. Sheriffs Costs: Docketing $30.00 Poundage 17.20 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 13.80 Levy 15.00 Surcharge 20.00 Law Journal 353.75 Patriot News 263.20 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 877.35 Sworn and subscribed to before me er'g' This J'- day of ?A2u u l-J R. Thomas Kline, Sheriff 2004, A.D.? -t _ P othonotary B" tS'Ovu Real Estat Deputy 3D. 47 a"k-d ILA, 1, v Q,P- y`taG6 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 Assi. 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 28th day(s) of October and the 4th and 11th day(s) of November 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ---"° COPY Sworn a s s 19th day of NoveMi Ir 2003 A.D. S A L E #36 Notanal Seal l Terry L. Russell, Notary P!'C ?,- REAL ESTATE SALE No. 36 City Of Harrisburg, Dauphin r Writ No. 2002-3948 My Commission Expires June 6, 2006 N ARY PUBLIC Civil Term olumpus Servicing, LP Member, Pennsylvania Association Of Nomycommission expires June 6, 2006 F/kla Calm co Serv lcing LP ??y vs Ralph Charles Crone CUMBERLAND COUNTY SHERIFFS OFFICE AV-1: Mark J. Udren CUMBERLAND COUNTY COURTHOUSE DESCRIPTION ALL THAT CERTAIN lot of ground situate in CARLISLE, PA. 17013 Silver Spring Township, Cumberland County, Pennsylvania, being Lot No. 5 on a Subdivision Plan prepared for Cvorgetta M. Crone by Statement of Advertising Costs Whittock and Hartman, Registered Engineers, and recorded in the Office of the Recorder of Deeds To THE PATRIOT-NEWS CO., Dr. for Cumberland County in Plan Book 60, Page For publishing the notice or publication attached 130, bounded and described as follows: BEGINNING at a point on the Western side of hereto on the above stated dates Old Willow Mill Road, as it appears on said Plan, Total which point is also on the dividing line between $ 263.20 Lots Nos. 4 and 5 on said Plan; thence along said dividing line, North 79 degrees 25 minutes West 402.72 feet to a point; thence continuing along Publisher's Receipt for Advertising Coat 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 said dividing ARC. :vorth : degrees 4i minutes 4c seconds East 316.86 feet to a point on line of land now or formerly of Ernest Clawser, Sr., and Nell L. Clawser, his wife; thence along said line 0 Clawser, South 89 degrees 17 minutes 40 seconds West 370.03 feet to a point in line of property now or formerly of Jay H. Smith; thence along said land of Smith, North 82 degrees 43 minutes East 301.05 feet to a point; thence continuing along said land of Smith, South 79 degrees 25 minutes, East 490.25 feet to a point on the Western right- of-way line of Old Willow Mill toad; thence along said Western right-of-way line, North 21 degrees 45 minutes 20 seconds. East a distance of75 feet to a point on the dividing line between Lots Nos. 4 and 5 of said Plan, the Place of BEGINNING. CONTAINING 377,817.94 square feet, 4.082! acres. Together with the right to use a 25-foot wide right-of-way across the Northern Portion of Lot No. 4, the center line of which continues along the dividing line between Lots Nos. 2 and 4 and Lots Nos. 2 and 3 on the Subdivision Plan to the Western side of Old Willow Mill Road. BEING KNOWN AS: 1311 Old Willow Mill Road. Mechanicsburg (Silver Spring Twp.) PA 17055. PROPERTY ID NO.: 38-14-0848-064. TITLE TO SAID PREMISES is vested in Ralph Crtonee and Sand6 L.C rroone, histwifeRal , d dated 312? 1 96 recorded 4124100 Book 219 Page 796. 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: OCTOBER 17, 24, 31, 2003 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. 36 Writ No. 2002-3948 Civil Olumpus Servicing, LP, f/k/a Calmco Servicing LP vs. Ralph Charles Crone Atty.: Mark J. Udren ALL that certain lot of ground sit- uate in Silver Spring Township, Cumberland County, Pennsylvania, being Lot No. 5 on a Subdivision Plan prepared for Georgetta M. Crone by Whittock and Hartman, Registered Engineers, and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 60, Page 130, bounded and described as follows: BEGINNING at a point on the, Western side of Old Willow Mill Road. as it appears on said Plan, which point is also on the dividing line between Lots Nos. 4 and 5 on said Plan: thence along said divid- i i7 e Coyne, Edit r SWORN TO AND SUBSCRIBED before me this 31 day of OCTOBER, 2003 NOTARIAL SEAL V rMyCLC800C TS E. SWDER, Notary Public lisle Boro, Cumberland County mmiss ion Expires March 5, 2005 ing line, North 79 degrees 25 min- utes West 402.72 feet to a point: thence continuing along said divid- ing line, North 2 degrees 42 min- utes 40 seconds East 316.86 feet to a point on line of land now or formerly of Ernest Clawser. Sr., and Nell L. Clawser, his wife; thence along said line of Clawser, South 89 degrees 17 minutes 40 seconds West 370.03 feet to a point in line of property now or formerly ,f Jay H. Smith: thence along said land of" Smith, North 82 degrees 43 mirn- utes East 301.05 feet to a point; thence continuing along said land of Smith, South 79 degrees 25 min- utes East 490.25 feet to a point on the Western right-of-way line of Old Willow Mill Road; thence along said Western right-of way line, North 21 degrees 45 minutes 20 seconds East a distance of 75 feet to a point on the dividing line between Lots Nos. 4 and 5 of said Plan, the Place of BEGINNING. CONTAINING 177,817.94 square feet 4.0821 acres. Together with the right to use a 25 foot wide right- of-way across the Northern portion of Lot No. 4, the center line of which continues along the dividing line between Lots Nos. 2 and 4 and Lots Nos. 2 and 3 on the Subdivision Plan to the Western side of Old Willow Mill Road. BEING KNOWN AS: 1311 Old Willow Mill Road, Mechanicsburg (Silver Spring Twp.), PA 17055. PROPERTY ID NO.: 38-14-0848- 064. TITLE TO SAID PREMISES IS VESTED IN Ralph Charles Crone by Deed from Ralph Charles Crone and Sandra L. Crone, his wife dated 3/ 22/96 recorded 4/24/00 Book 219 Page 796.