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HomeMy WebLinkAbout07-0306UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS 10500 Barkley, Suite 102 :CIVIL DIVISION Overland Park, KS 66212 :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Michael J. Leone =NO. 07-306 Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Michael J. Leone and Kelley J. Leone for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest Per Complaint From 1/17/07 to 3/13/07 Late charges per Complaint From 1/17/07 to 3/13/07 TOTAL I hereby certify that (1) the addresses of the are as shown above, and (2) that notice has been Rule 237.1, a copy of which is attached hereto. OFFICES, DAMAGES ARE HEREBY ASSESSED AS DATE : - gel 13 Z,G?LS7 $15,902.41 138.88 7.43 $16,048.72 Plaintiff and Defendant given in accordance with .C. Mark J. Udren, ESQUIRE Attorney for Plaintiff IND GATED PRO - PRO THY UDRSN T-kw OFFICES P. C. ATTORNIN FOR PLAINTIFF HY: Nark J. Udron, Esquire ATPY I.D. NO. 04301 WOODCREST CORPORATE CENTER 111 HOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003 856-669-5400 i en Charter One Bank, N.A. Plaintiff a V. Michael J. Leone Kelley J. Leone = Defendant(B) TO: Kelleyy J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 DATE of Notice: March 2, 2007 COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-306 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 / 800-990-9108 / NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, B LAM FIRM IS DESeM TO BE A DEBT COLLSC R AND THIS IS AN ATTZKPT TO COL CT A DEBT. ANY INFORMATION OBTAINED WXLL 31tUSED-MR THAT PWIDER. Wo crest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAN OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 NOODCRSST CORPORATE CENTER 111 NOODCRSST ROAD, SUITS 200 CSERRY BILL, NJ 08003 856-669-5400 plea inva r n.com charter one Bank, N.A. plaintiff v. Michael J. Leone Kelley J. Leone e Defendant(s) TO: Michael J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-306 DATE of Notice: March 2, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENDER 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. " T NLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT H4VE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANT USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO FABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRhCTICES , THIS LAN FIRM IS DEEMED TO aS A DEBT COLLS R THIS IS AN ATTZKPT COLLECT A DEBT. ANY INFORMATION OBTAINED NILLt? U1020 FOR TRAT PURPOSR. ? R R V • v\.ai Vaa, YV?Y?iv Wo rest Corporate Center 111 oodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Michael J. Leone Kelley J. Leone Defendant (s) ::NO. 07-306 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS COUNTY OF CAMDEN THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Michael J. Leone Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Kelley J. Leone Age: Over 18 ` Residence: As captioned abo Employment: Unknown Na MARK J. 0Q8 P9, ESQ. Ti e: ATTORNEY FOR PLAINTIFF Sworn to and subscribed Co any: UDREN LAW OFFICES, P.C. before me this 13th day of March, 2007. ary blic Verbal Confirmation of Service of Complaint Date: Spoke with: Defendant(s): ?? --? • Leuoa.s served on-191-4- at: Defendant(s): - as served on a` at: Defendant(s): was served on at: Are there any additional fees due? Yes 0 If so how much?_$ twJ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION €Cumberland County v. ::MORTGAGE FORECLOSURE Michael J. Leone €NO. 07-306 Kelley J. Leone Defendant(s) To: Michael J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren,.Esquire ATTY I.D. NO..04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. ;MORTGAGE FORECLOSURE Michael J. Leone Kelley J. Leone :NO. 07-306 Defendant(s) To: Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment J'C Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 1 J V ? rJ CA) RV ?. i UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA Plaintiff V. Michael J. Leone Kelley J. Leone Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-306 PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $16,048.72 Interest From 3/14/07 228.16 to Date of Sale 6/13/07 Ongoing Per Diem of 2.48 to actual date of sale including if sale is held at a later date (Costs to be added) UDREN LAW OFFICES, P.C. M rk J. ESQUIRE TORNEY FOR PLAINTIFF c? g 10 (7, D ' ? -71 a C c c C? d ~ ~ h (9z) h / I I I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-306 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHARTER ONE BANK, NA, Plaintiff (s) From MICHAEL J. LEONE AND KELLEY J. LEONE (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 $16,048.72 L.L. $.50 Interest FROM 3/14/07 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $2.48 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $228.16 Atty's Comm % Atty Paid $133.92 Plaintiff Paid Due Prothy $1.00 Other Costs Date: MARCH 13, 2007 Prothonotary (Seal) Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST ROAD, SUITE 200 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Michael J. Leone :NO. 07-306 Kelley J. Leone Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is. ( ) An FHA insured mortgage ( ) Non-owner occupied ( } Vacant ( x ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. LAW OFFICES, P.C. Mark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF ?? ??.:. ,? J ? -... ...-? a $ e ? ? ,.:i ? e...d .'.Ar„1 , . -? '`; r ,?. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA ':COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION Cumberland County V. :MORTGAGE FORECLOSURE Michael J. Leone NO. 07-306 Kelley J. Leone Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Charter One Bank, NA, 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: 1110 Florabunda Lane, (Upper Allen Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of the last recorded holder of every mortgage of record: Name Address Charter One Bank, NA 10500 Barkley, Suite 102 Overland Park, KS 66212 Mortgage Electronic Address to Follow Registration Systems as nominee for First NLC Financial Services, LLC 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1110 Florabunda Lane (Upper Allen Township) Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P. DATED: March 13, 2007 Mark J. Udren, ESQ. Attorney for Plaintiff .:i _ , UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Michael J. Leone :NO. 07-306 Kelley J. Leone Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michael J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Your house (real estate) at 1110 Florabunda Lane, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $16,048.72, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) A e YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ?' ? ?? ;! ?' x __, : : {? _ _...__ r:.i . .?..} - ??. , . , _, UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA Plaintiff V. Michael J. Leone Kelley J. Leone Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 07-306 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Your house (real estate) at 1110 Florabunda Lane, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 131 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $16,048.72, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions treasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Charter One Bank, N.A. Overland Park, KS 66212 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Michael J. Leone Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Defendant(s) U. C-l41 NO. O'7 - 3b... el %, 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las 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 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/a Assignments of Record to: N/a Recording Date: N/a 2. Defendant (s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 1110 Florabunda Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Allen Township COUNTY: Cumberland DATE EXECUTED: 7/22/99 DATE RECORDED: 7/26/99 BOOK: 1559 PAGE: 614 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 1/16/07: Principal of debt due $9,006.69 Unpaid Interest at 10.0% from 1/12/04 to 1/16/07 (the per diem interest accruing on this debt is $2.48 and that sum should be added each day after 1/16/07) 579.21 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthly late charge of $7.43 should be added in accordance with the terms of the note each month after 1/16/07) 61.51 Recoverable Advance 4,400.00 Reasonable Attorneys Fees 1,250.00 TOTAL $15,902.41 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 $15,902.41 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. U ren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 PPwPP- AM MM Mb p3am as peel al land sluts in vpW a" Ion lkwambtp. Cmabw. b and described as ftlums i to vLt: commys- pp,??3.vsesiy?T lacer ?saH?? at a Dow% in %be m"q*G= Lum of "atibaa" ZMM (60 toot wi,drt). wds3ss3 said paint is in the 4minism lie bstvwft WW 29 and 24 ass the bM&iM&"r maatimned piast 69 LatsI tbww& %itf"fVe (SS) seoauf+ Zut, 75 north SLOty too) degrees ?i t ? minutes U mentic"A PIM of zeds; tbance amt to a ?t at comber of Trot 22 Oft tbG ?? ass 0" P UM' ? yllM fill extending Lima U& divibiab lie MUNIM L*! i at at Occow b# met dsc lea iessC ?g f mi rntss five (S) ae? cream, i!e fret to s ? the di?ris? 11 on the beminattAw mostS?OS?!d p? of ?ratsl Cbumcs! m? lift ve. x,551 Idle betw"m Cuter 33 abd li oD aid t104 $09" "OW ? ? Minot" fLM_VAVS t'j5t seers Vent, 7S gee+lf to a ?'t at air of ? 24 as thr eft » ? ? ?` 7Geres; tbsmco ?4 t5s divisioa Um bates Iota 23 and 24 an " i'??r gomttti? ULIO (0) degr.?r?r foac (!) simtsaw U+o (5) 06000" East, ?4 f*c to a Paim in the ;leartheXIS Um of ! l.bmft LeoM almemeat'00". at the paint snd pig of Nmwxnw- dt UM f?, S an the PIM of aaaLAM `1 OW 7? "?Ob s*IA *Leib it MQAM% recorded in vhm 'land c TAO=dw • s aEf ivrs to rim ioels 27. ra" i6. Banc fewm and ambered s• Lilts Flwibm& L+t'!e, l6EllboLtD a lrtaa a. WIDER alit' SUS32M TO s74Ftsac't4. MS # eaeraa&OU P ?tio>? aAd o¦a?nsots Ise 10? " of r e ovd. October 25, 2006 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA D PORTANCIA., PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTMCACION OBTENGA UNA TRADUCCION INMEDTTAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO DHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMD EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PW i of7 EXHIBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Michael J Leone Kelley J Leone 1110 Florabunda Lane _ Mechanicsburg, PA 17055 800-9930034241 Charter One Bank F.S.B. Citizens Bank _ HOMEOWNERQS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOTT MAY BE F,T.TGTRT.F. FOR FINANCIAL AS.STSTANCF. WHICH CAN SAVE, VOTTR HOME FROM FORECLOSTTRF. AND HELP VOTT MAKR FITTTTRF. MORTC.AGF. PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERDS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE DACTO), 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 FOREV-1,01STTRE -- 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 Dface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS WETING MTTST OCCTTR WITHIN D B CONSTTMF.R CRFDff COTTNSELING AGF.NC_TF_S -. 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 namL-q,.qdfjmqqes and telephone numbers, of designated consumer credit counseling agencies for the county in which the prra. ' ' ate °re set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediate of your intentions. APPLICATTON 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 Page 2 of 7 face- to-face meeting. YOU MILT FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE. DF.FAITI.T -- The MORTGAGE debt held by the above lender on your property located at: 1110 Florabunda Lane Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $70.33 for July 12, 2006 = $7033 Monthly Payments of $7458 for August 12,2006--$74.58 Monthly Payments of $7650 for September 12, 2006,-$76.50 Month y Pavments of $74.02 for October 12.20KF474.02 Monthl?I.ete Charges of $7 43 for Tuly12, 2006 through September 12 2006 = $22.29 Other charges (explainhtemize): Other Uncollected Late Charges---$16.77 BPO Fee=$100.00 Appraisal Fe -300.00 TOTAL AMOUNT PAST DUES _$2X2_ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): NIA HOW TO CURE. THE. DF,FATTLT -- 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 IS1734,,49- PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaMents mutt mane either by narh, mshier'c rherk rerti A check or money order mane pya, hip and sent to* [Td n Law Offices, P.C:_ Wnnderest C:o=rs e '.n e 1 i i Wondered Rnad, Snite 2(1(1 Page 3 of 7 • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (71.7)234-5925 FAX (717) 234-9459 Community Action Comm of the Capita]. Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 7 of 7 ASSUMPTION OF MORTGA[TF -- You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 5 of 7 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 N different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of. it, until we obtain the information. that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 6 of 7 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTTTUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 5414670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 1.7325 (717) 334-151.8 FAX (717) 334-8326 Page 7 of 7 0 ?c ?y x t! J ?i C) _ o z. C) m p -r C o p m _v. oyCy70 w m C- m "' • ate. a An W TL20 69E6 'C000 OT90 900L Z o 8z° 00 m 00 ? ti U t z ? z ED m 0 r • x cu ? a?. N C B a -? m L U U- ` rm O"" C N- Y 6 ?- Q ? P U- c Na?E ?m _ r 0 W O ? to V 07 • m ¢ - (D 3L -00 m-0 a c , m « co E m ` • o G U_a o g<:14 ¢ , a ¦ ¦ .52 a Q E 6 u'l?U 0 PKP U ? C 130 c4c, r? ti C3 YT ,n m G' a O 13 rl co 0 -a C3 O M1 U E N a( F E ? 7 V '. 21 93 E bv:°'i:N r : ltC 0 a L° LL at LL LL IL F :: E? o a es ? $E U.20 69E6 TGOO OT90 9002 f V o C 7 n M M Z xov0 0 =row Zm0Mf o=>R. °o> 7 wS.7.mr z rr, x 0 0 L-i 0 r r?r? C3 M M ?- _0 cr -¦- A ' ?- a r ? ! 1, h920 69E6 TO DD OTWO 9004 ml ? N y W -O f ? ? Q 0 U z t _G a ? mU R ¢ E O Z m g ?¢ do -L? m m '?O 2` Q ?? ?. a m m ? m m ? a > a Edm m O W aL. ^ y v! VVpV?}? 'D O :C try' 7L. Y7 U Y c?a.c?a mam+'mm N Cl _0 C R y _? c E E U p D a? >•ms E E c ? ? o CL mQo ¦ ¦ ¦ N J n c Q .1 rr Ir n n 13 C3 ri to C3 .A C3 O r- $ u m 1 o ? v ? z ? i a y CV 4 q E F !T 1 1 ?. 4 .m Q C ¢ ? U o° a' 0 C\j it, .0 CD 0 L LL :az a ? ? is ;.:. ,v ? m ros d•p ? -? ?. iiYdn{' u. LL ? LL ? ia C:s m 'anus` m o m d v ¢c vu ? ?`m? h920 69E6 't000 0TWO 900L 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 UDREN LAW OFFICES, P.C. r?n v( OAK) rn -n _ ?i7t rQ i cto s y CASE NO: 2007-00306 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHARTER ONE BANK NA VS LEONE MICHAEL J ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon T Tnl1TTT'n T/f T nrVT VT T the DEFENDANT , at 2039:00 HOURS, on the at 1110 FLORABUNDA LANE MECHANICSBURG, PA 17055 KELLEY D LEONE, WIFE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.92 Affidavit .00 Surcharge 10.00 .00 4Iy?b 35.92 Sworn and Subscibed to before me this day of 7th day of February , 2007 So Answers: R. Thomas Kline 02/08/2007 UDREN LAW OFFICES By. Deputy S iff A. D. it SHERIFF'S RETURN - REGULAR CASE NO: 2007-00306 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND W CHARTER ONE BANK NA VS LEONE MICHAEL J ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LEONE KELLEY J the DEFENDANT , at 2039:00 HOURS, on the 7th day of February , 2007 at 1110 FLORABUNDA LANE MECHANICSBURG. PA 17055 KELLEY D LEONE by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge ;) 14 P -7 So Answers: 6.00 .00 .00 10.00 R. Thomas Kline .00 .716.00 02/08/2007 UDREN LAW OFFICES Sworn and Subscibed to before me this of By. 14 day Deputy Sh ff A. D. Charter One Bank, NA VS Michael J. Leone and Kelley J. Leone In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-306 Civil Term Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on March 22, 2007 at 2025 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants to wit: Michael J. Leone and Kelley J. Leone, by making known unto Kelley Leone, personally and adult in charge for Michael J. Leone, at 1110 Florabunda Lane, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Cpl. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on April 18, 2007 at 0930 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Michael J. Leone and Kelley J. Leone, located at 1110 Florabunda Lane, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Michael J. Leone and Kelley J. Leone, by regular mail to their last known address of 1110 Florabunda Lane, Mechanicsburg, PA 17055. These letters were mailed under the date of April 5, 2007 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of instruction from Attorney Mark J. Udren. Sheriffs Costs: Docketing 30.00 Poundage 106.04 Advertising 15.00 Posting Handbills 15.00 Mileage 21.12 Levy 15.00 Law Library .50 Prothonotary 1.00 Surcharge 30.00 Law Journal 431.00 Patriot News 445.01 Share Bills 16.17 $1,125.84 So Answer L. R. Thomas Kline, Sheriff BY CCU- - -, ' V Real Estate S rgeant y 01716q Q- ' ?iD 11 S 8'9 s'G /9,/i73 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark. J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION €Cumberland County V. :MORTGAGE FORECLOSURE 6 Michael J. Leone NO. 07-306 Kelley J. Leone De f endant (s) AFFIDAVIT PURSUANT TO,RULE 3129.1 Charter One Bank, NA, 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: 1110 Florabunda Lane, (Upper Allen Township) Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Michael J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address none 4. Name and address of of record: Name Charter One Bank, NA the last recorded holder of every mortgage Address 10500 Barkley, Suite 102 Overland Park, KS 66212 Mortgage Electronic Address to Follow Registration Systems as nominee for First NLC Financial Services, LLC f 5. Name and address of every other person who has any record lien on the property: Name Address none 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1110 Florabunda Lane (Upper Allen Township) Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P DATED: March 13, 2007 Mark J. Udren, ESQ. Attorney for Plaintiff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE Michael J. Leone ::NO. 07-306 Kelley.J. Leone Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Michael J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Your house (real estate) at 1110 Florabunda Lane, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $16,048.72, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-54.00. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland. County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAIR OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION ;Cumberland County V. MORTGAGE FORECLOSURE Michael J. Leone Kelley J. Leone Defendant(s) NO. 07-306 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Your house (real estate) at 1110 Florabunda Lane, (Upper Allen Township) Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on June 13, 2007, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $16,048.72, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 piea d' pazool at 1md ssitmorA in Unew JLI +saisamh4, CmdM Lmd fit, row"lwan" sros'a ?}I q wly b abded and dsscrLW as *Alm*. ft waft, *llg3tltt w .a at MAIM is vw *= um of rl=lbwM% mom 4 so foot wida), valsb t said Va akt is in ttw 4xisxa w lb* belosa:t Zow 23 and 24 an t!u b0r8420ftW l0 ttLaN*& 000 ad Wt s1 td OMM OXWOUN ,aloud VW =*L+JWft lind Of yUdbW da 3'+ Dew usstle &Low too) dsscass 9U.8-f ,ire (50) mime ti -ft" (35) snaginds asst, is dsat " n p *L bawbar of 1t 22 as the Wewia: lemum"d Pat at wwt %bows aat#adisg &Low the d bias up& b&UMW 22 W d 22 an acid ru& tlt aLk SUM It) des"H is gow tt? 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BEING KNOWN AS: 1110 FLORABUNDA LANE, (UPPER ALLEN TOWNSHIP) MECHANICSBURG, PA 17055 PROPERTY ID NO.: 42-31-2153-030 TITLE TO SAID PREMISES IS VESTED IN MICHAEL J. LEONE AND KELLEY J. LEONE, HUSBAND AND WIFE BY DEED FROM DAVID N. SAWYER AND LYDIA SAWYER, HUSBAND AND WIFE DATED 7 / 2 2 / 9 9 RECORDED 7 / 2 6 / 9 9 IN DEED BOOK 204 PAGE 592. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-306 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHARTER ONE BANK, NA, Plaintiff (s) From MICHAEL J. LEONE AND KELLEY J. LEONE (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 $16,048.72 L.L. $.50 Interest FROM 3/14/07 TO DATE OF SALE 6/13/07 - ONGOING PER DIEM OF $2.48 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $228.16 Atty's Comm % Atty Paid $133.92 Plaintiff Paid Date: MARCH 13, 2007 (Seal) Due Prothy $1.00 Other Costs Deputy REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST ROAD, SUITE 200 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 juvaotas elsg luo-a `L00Z `91 g3JRW :alUQ •uiataq paltuodioaui aouatOjat siql Xq put, 1itm sigl glim polU «V„ Iigiuxg uo poquosap XIinj atom `BtngsoiuvgoaW `aml Lpungt told 0111 st, pataguznu put umou}I Vd `,runoD puvltaquunD `digsumo L uollH taddn ui palmnis fqtadotd luat aql ui Isatajul s jutpuajap aql uodn painal JJitagS aqP LOOZ `9I 113'BW uO tlOI # OILS OWISH ILION t60Z N, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#104 i Sworn to and subscribed before me this 18th day of May 2007 A.D. nAUUnNWFA!_TH OF PENNSYLVANIA -- I?fotarial Seal t ferry L. Russell, Notary Public i City Of Harrisburg, Dauphin County . w Ly mmiss piresJune6,2010 Mom r. P n nia association of Notaries d W TARY PUBLIC Mt. IlSd? OR PY.41B 1.A1rB' ; t. ^Z 3 Z" CUMBERLAND COUNTY SHERIFF'S OFFICE W I AS, Iu1Aws'TowII` CUMBERLAND COUNTY COURTHOUSE WWAM AT A F6J*r K 1o`' wrl 1JWrQlr$MWf" LAW ? CARLISLE, PA. 17013 (Sb »'???it'Old'f ZBRK D1YL81Ilri L$liittT TES PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 20, 27, May 4, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 104 Writ No. 2007-306 Civil Charter One Bank, NA vs. Michael J. Leone and Kelley J. Leone Atty.: Mark Udren ALL THAT CERTAIN piece or parcel of land situate in Upper Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the northern line of Floribunda Lane (50 feet wide), which said point is in the division line between Lots 23 and 24 on the hereinafter mentioned Plan of Lots; thence extending along the northern line of Floribunda Lane, North eighty (80) degrees fifty- (SEA -inuih 89sfive, f551 see- " sa Marie Coyn, Editor SWORN TO AND SUBSCRIBED before me this 4 day of MU, 2007 _ R`?. _tL v U"' P"hljC G 3.i: "y THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Shannon D. Billhime, being duly sworn according to law, deposes and says: That she is a Staff Accountant with The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 18th and 25th day(s) of April and the 2nd day(s) of May 2007. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#104 i Sworn to and subscribed before me this 18th day of May 2007 A.D. Ntarlal Seal 4Cft4y erry L. Russell, Notary Public Of Harrisburg, Dauphin County mmiss Aires June 6, 2010 P n nia Association of Notarles 'o, TARY PUBLIC CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 M vocy-MWONZE a OIL Loo p AS LmOFf LAW inwow Ft 23 ffmwwE? so v ? TM - 24 ON T11 loft Fjo 2,2 N OF TW FOM '3 - AIS l?to cEINMO'B *vG Lk* l ' slisig g- ?oAND PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 20, 27, May 4, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. d?- SsMarie Coyn , Editor SWORN TO AND SUBSCRIBED before me this 4 ,_day of May, 2007 h!ic REAL ESTATE SALE NO. 104 Writ No. 2007-306 Civil Charter One Bank, NA vs. Michael J. Leone and Kelley J. Leone Atty.: Mark Udren ALL THAT CERTAIN piece or parcel of land situate in Upper Allen Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the northern line of Floribunda Lane (50 feet wide), which said point is in the division line between Lots 23 and 24 on the hereinafter mentioned Plan of Lots; thence extending along the northern line of Floribunda Lane, North eighty (80) degrees fifty- five (55) minutes fifty-five (55) sec- onds East, 75 feet to a point at cor- ner of Lot 22 on the hereinafter mentioned Plan of Lots; thence ex- tending along the division line be- tween Lots 22 and 23 on said Plan, North nine (9) degrees four (4) min- utes five (5) seconds West, 134 feet to a point at a comer of Lot 11 on the hereinafter mentioned Plan of Lots; thence extending along the division line between Lots 23 and 11 on said Plan, South eighty (80) degrees fifty-five (55) minutes W- five (55) seconds West, 75 feet to a point at corner of Lot 24 on the here- inafter meatloned Plan of Lots; thence extending along the division line between Lots 23 and 24 on said Plan, South nine (9) degrees four (4) minutes five (5) seconds East, 134 feet to a point in the northern line of Floribunda Lane aforemen- tioned, at the point and place of beginning. BEING Lot 23, Block B on the Plan of Section 1 of Rosegarden, which said Plan is recorded in the Cumberland County Recorder's Of- fice in Plan Book 27, Page 16. BEING known and numbered as 1110 Floribunda Lane, Mechanics- burg, Pennsylvania. Under and subject to restric- tions, covenants, conditions and easements as now appear of record. BEING KNOWN AS: 1110 FLORA- BUNDA LANE, (UPPER ALLEN TOWNSHIP) MECHANICSBURG, PA 17055. PROPERTY ID NO.: 42-31-2153- 030. TITLE TO SAID PREMISES IS VESTED IN Michael J. Leone and Kelley J. Leone, husband and wife by deed from David N. Sawyer and Lydia Sawyer, husband and wife dated 7/22/99 recorded 7/26/99 in Deed Book 204 Page 592. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Charter One Bank, NA 10500 Barkley, Suite 102 Overland Park, KS 66212 Plaintiff V. Michael J. Leone Kelley J. Leone 1110 Florabunda Lane Mechanicsburg, PA 17055 Defendant MOD s"sFy (# on back- TO THE PROTHONOTARY: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 07-306 Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: June 18. 2007 Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff t per cL4+ re$* ,a y --- j Z cn .. ? .... f? m ?