HomeMy WebLinkAbout02-4357MARK J. UDREN & ASSOCIATES
BY= Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
Wells Fargo Bank Minnesota,
N.A., as Trustee for
registered holders of Option
One Mortgage Loan Trust 2001-
A, Asset Backed Certificates,
Series 2001-A
P.O. Box 57038
Irvine, CA 92619-7038
Plaintiff
Teresa L. Noel
150 Mountain View Road
Shippensburg, PA 17257
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
i CIVIL DIVISION
Cumberland County
NO. -
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 CA~'NOT 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. Mace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
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: Wells Fargo Bank Minnesota, N.A., as
Trustee for registered holders of Option One Mortgage Loan Trust
2001-A, Asset Backed Certificates, Series 2001-A
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
The information regarding the Mortgage being
follows:
MORTGAGED PREMISES: 150 Mountain View Road
MUNICIPALITY/TOWNSHIP/BOROUGH:
COUNTY: Cumberland
DATE EXECUTED: 11/29/00
DATE RECORDED: 11/30/00 BOOK:
foreclosed is as
South Newton Township
1655 PAGE: 50
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.
refuses
(a)
(b)
8/22/02:
After demand, the Defendant(s) continues to fail or
to comply with the terms of the Mortgage as follows:
by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
by failing or refusing to pay other charges, if any,
indicated below.
The following amounts are due on the said Mortgage as of
Principal of debt due and unpaid
Interest at 10.3%*
from 5/1/02
to 8/22/02
(the per diem interest accruing on
this debt is $28.97 and that sum
should be added each day after
8/22/02)
$102,667.43
3,281.07
Title Report
250.00
Court Costs (anticipated, excluding
Sheriff's Sale costs)
280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $130.67 and that sum should
be added on the first of each
month after 8/22/02)
(812.91)
Late Charqes
(monthly Iate charge of $56.36
should be added in accordance
with the terms of the note
each month after 8/22/02)
338.16
Suspense Balance
Other Fees Due
Penalty Interest
(739.76)
48.00
4,216.31
Attorneys Fees (anticipated and actual
to 5% of principal)
5,133.37
TOTAL
$114,661.67
*The Interest Rate is subject to adjustment as more fully
set forth in the Note and Mortgage.
7. The attorney's fee set forth above are in conformity with
the mortgage documents and Pennsylvania law, and will be collected
in the event of a third party purchaser at Sheriff's Sale. If the
mortgage is reinstated prior to the sale, reasonable attorney's
fees will be charged in accordance with the reduction provisions of
Act 6, if applicable.
8. The 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 $114,661.67 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
ALL THAT CERTAIN LOT OR PARCEL OF GROUND SITUATED IN SOUTH NEWTON TOWNSHIp,
~CDMBERLAND COUNTY, PENNSYLVANIA, AND BEIN~ DESIGNATED AS LOT NO. 4 ON TEE
SUBDIVISION PLAN PREPARED BY WILBUR H. CLIFTON, REGISTERED SURVEYOR, DATED OCTOBER
23, 1979, FOR RODNEy E. ABy, AND RECORDED iMMEDIATELY PRIOR H~RETO IN CUMBERLAND
COUNTY PLAN BOOK 37, PAGE 35, AS FOLLOWS=
BEGINNING AT A POINT IN THE CENTER LINE OF MOUNTAIN VIEW ROAD (T-321) (33 FEET
WIDE) AT A POINT SITUATED .040 MILES SOU~H OF PENNSYLVANIA LEGISLATIVE ROUTE 21008~
THENCE FROM SAID BEGINNING POINT BY THE CENTER LINE OF MOUNTAIN VIEW ROAD, SOUTH 15
DEGREES 00 MINUTES 00 SECONDS WEST 200.00 FEET TO A SPIKE IN SAID ROAD~ THENCE BY
OTHER PROPERTY NOW OR FORMERLy OF RODNEY E. ADY AND DEBRA ~ ADy, HUSBAND AND
WIFE, THE FOLLOWING TWO COURSES AND DISTANCES~ (1) SOUTH 80 DEGREES 42 MINUTES 47
SECONDS WEST 386.00 FEET TO AN IRON PIN~ (2) NORTH 15 DEGREES 00 MINUTES 00
SECONDS EAST 200.00 FEET TO AN IRON PIN~ THENCE BY PROPERTY NOW OR FORMERLY OF
RODNDy E. ABy AND DEBP. A ANN ABy, HUSBA/~D AND WIFE, AND PROPERTY NOW OR FORMeRLy OF
RICHARD W. BEECHER, NORTH 80 DEGREES 42 MINUTES 47 SECONDS EAST 386.00 FEET TO A
SPIKE IN THE CENTER OF MOUNTAIN VIEW ROAD, THE PLACE OF BEGINNING. CONTAININ~ 1.615
ACRES.
UNDER AND SUBJECT TO BUILDING LINES SET FORTH ON SAID PLAN.
ww'#,optiononemortgage.com
May 02, 2002
Teresa L Noel
150 Mountain View Rd
Shippensburg, PA 17257-9662
OPTION ONE
M O R T G A G E
Start Hem. Finish Here.
Homeowners Name: Teresa L Noel
Property Address: 150 Mount View Rd, Shippensburg PA 17257
Loan Account No.: 390722-7
Original Lender: OPTION ONE MORTGAGE
Current Lender/Servicer: Option One Mortgage Corporation
HOMEOWNER'S
EMERGENcy MORTGAGE ASSISTANCE PROGRAM
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 PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to
a temporary stay of foreclosure on your mortgage for thirty (30)
days from the date of this Notice. During that time you must
arrange and attend a "face-to-face" meeting with one of the
designated consumer credit counseling agencies listed at the end
of this Notice.
THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CAT.T,~D "HOW TO CURE
YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO
DATE.
OP171
EXHIBIT A
Corporate Offices · 3 Ada · Irvine · California · 92618-2304
P.O. Box 57041 · Irvine · California ' 92619-7041 · 800.326.1500 · Fax 949.784.6032
w~vw.optiononemortgaga.com
Re: Loan No. 390722-7
OPTION ONE
M O R T G A G E
Start Here. Finish Here.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the
consumer credit counseling agencies listed at the end of this Notice,
the lender may NOT take action against you for thirty (30) days after
the date of this meeting. The names, addresses and telephone numbers
of designated consumer credit counseling a.qencies for the county in
which the property is located are set forth at the end of this Notice,
or you 'may contact HUD directly at 800-569-4287 or visit the HUD
website at www.hud.gov/offices/hsg/sfh/hcc/hccprofl4.cfm. It is only
necessary to schedule one face-to-face meeting. Advise your lender
immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the reasons set forth later in this Notice (see following pages for
specific information about the nature of your default.) If you have
tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program
Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will
assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATIONPROMPTLY. 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.
OP171
Corporate Offices · 3 Ada · Irvine. California · 92618-2304
P.O. Box 57041 ' Irvine · California * 92619-7041 · 800.326.1500 ° Fax 949.784.6032
www.optiononamortgage.com
Re: Loan No. 390722-7 OPTIONONE
MORTGAGE
***********************************************************--***--
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
your property located at:
150 Mount View Rd, Shippensburq PA 17257
IS SERIOUSLY IN DEFAULT because:
lender on
months and the following amounts are now past due:
(a) Monthly payments: 1 MONTHS @ $ 1,070.08
2 MONTHS @ $ 1,070.08
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
$ 3210.24
(b) Previous late char~es; $ 112.72
(c) Other charges; Escrow, Inspection,
NSF checks $ 48.00
(d) Other provisions of the mortgage obligation,
if any $
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED
AS OF THIS DATE $ 3370.96
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30)
days of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE
TO THE LENDER WHICH IS $3370.96, 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 send to:
Overnight Mail Address
3 Ada
Il-vine, Ca. 92618
Western Union Quick Collect
Pay to: Option One Mortgage Corporation
Code City: Option, Ca
You can cure any other default by taking the following action within
thirty (30) days of the date of this letter. (Do not use if not
(applicable.)
OP172
Corporate Offices · 3 Ada · Irvine · California · 92618.2304
P.O. Box 57041 ' Irvine ° California ° 92619-7041 ' 800.326.1500 ° Fax 949.784.6032
www.optiononernortgage.com
OPTION
M O R T G A G E
Re: Loan No. 390722-7
S~ H~. Finish Hem.
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 riqhts 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 uDon your
mortgaged Droperty.
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 brings legal proceedings against you, you will still be required
to pay the reasonable attorney's fees that were actually incurred, up
to $50.00. However, if legal proceedings are started against you, you
will have to pay all reasonable attorney's fees actually incurred by the
lender even if they exceed $50.00. Any attorney's fees will be added to
the amount you owe the lender, which may also include other reasonable
costs. If 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 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 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 - It is estimated that the
earliest date that such a Sheriff's Sale of the mortgaged property
could be held would be approximately (7) SEVEN 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.
0P173
Corporate Offices ' 3 Ada ' Irvine · California · 92618-2304
P.O. Box 57041 ' Irvine ° California ' 92619-7041 ' 800.326.1500 · Fax 949.784.6032
www.optiononemortgage.com
Re: Loan No. 390722-7
OPTION ONE
M 0 R T G A 6 E
Start Here. F~nish Here.
HOW TO CONTACT THE LENDER:
Name of Lender:
Address:
Attn:
Address:
Phone Number:
Fax Number:
Contact Person:
Office hours:
Option One Mortgage Corporation
7515 Irvine Center Drive
Kerry Delahunty
Irvine, CA. 92618
800-326-1500, Ext. 8001
949-784-6033
ADAM PINEDA EXT.48004
Monday through Thursday 7:00 a.m.
Friday 7:00 a.m. to 6:00 p.m. PST.
to 9:00 p.m. PST
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 Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could
be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) sell
or transfer your home to a buyer or transferee who will assume the
mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the
other requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT TO:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURED THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAT THREE TIMES IN ~
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BAIqKRUPTCY LAW.
OP174
Corporate Offices ' 3 Ada · Irvine · California · 92618-2304
P.O. Box 57041 ' Irvine ' California ' 92619-7041 ' 800.326.t500 · Fax 949.784.6032
.................................................... · e..N..'.~.dv ~ee4$
VERIFICATION
this statement herein
Pa.C.S. Section 4904
authorities.
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
is made subject to the penalties of 18
relating to unsworn falsification to
Mark J. Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
SHERIFF
CASE NO: 2002-04357 P
COMMONWEALTH OF pENNSYLVANIA
COUNTY OF CUMBERIJkND
WELLS FARGO BANK MINNESOTA
VS
NOEL TERESA L
BRYAN WARD
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT FORE
NOEL TERESA L
S RETURN - REGULAR
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
DEFENDANT at 1612:00 HOURS, on the 12th day of September, 2002
at 150 MOUNTAIN VIEW ROAI}
SHIPPENSBURG, PA 17257 by handing to
CHARLES NOEL
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 9.66
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
37.66 09/13/2002
MARK UDREN
Sworn and Subscribed to before
me this ~z~- day of
~~ ~ A.D.
~ /Prothonotar~
By:
Sheriff