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HomeMy WebLinkAbout07-1979 MILSTEAD & ASSOCIATES, LLC BY: Pina S. Wertzberger, Esquire ID No. 77274 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Nationstar Mortgage, LLC f/k/a Centex Home Equity Company, LLC 350 Highland Drive Lewisville, TX 75067, Plaintiff, Vs. Ian C. Sorkin 1 Goldenrod Drive Carlisle, PA 17013, and Renee M. Sorkin 1 Goldenrod Drive Carlisle, PA 17013, Defendants. {00160453} Attorney for Plaintiff File: 9.04377 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: ©~ r 1 7 7 I a s, l ~~~~ CIVIL ACTION MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Notice to Defend 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 {00160453} **+~,t~,rtt~,irt****,r*x~,~r~x~**+tir~r~ne~tyrt~,t~x~**,r*,~rnr~cr~xr,~~r+t~r~~ryrt~t~t~r******x~r~***,tert~+tyrdr~ririe*,t*****,iee~ NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debtor copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. {00160453} MILSTEAD & ASSOCIATES, LLC BY:Pina S. Wertzberger, Esquire ID No. 77274 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Nationstar Mortgage, LLC f/k/a Centex Home Equity Company, LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff, Vs. Ian C. Sorkin 1 Goldenrod Drive Carlisle, PA 17013, and Renee M. Sorkin 1 Goldenrod Drive Carlisle, PA 17013, Defendants. Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, Nationstar Mortgage, LLC f/k/a Centex Home Equity Company, LLC f/k/a Centex Home Equity Company, LLC (the "Plaintiff'), is a Delaware corporation registered to conduct business in the Commonwealth of Pennsylvania and having an office and place of business at 350 Highland Drive, Lewisville, TX 75067. 2. Defendants, Ian C. Sorkin and Renee M. Sorkin, (collectively, the "Defendants"), are adult individuals and are the real owners of the premises hereinafter described. 3. Ian C. Sorkin, Defendant, resides at 1 Goldenrod Drive, Carlisle, PA 17013. Renee M. Sorkin, Defendant, resides at 1 Goldenrod Drive, Carlisle, PA 17013. {00160453} 4.On February 22, 2005, in consideration of a loan in the principal amount of $146,672.00, the Defendants executed and delivered to Centex Home Equity Company, LLC a note (the "Note") with interest thereon at 8.54 percent per annum, payable as to the principal and interest in equal monthly installments of $1131.95 commencing April 1, 2005. 5. To secure the obligations under the Note, the Defendants executed and delivered to Centex Home Equity Company, LLC a mortgage (the "Mortgage") dated February 22, 2005, recorded on March 15, 2005 in the Department of Records in and for the County of Cumberland under Mortgage Book 1900, Page 93. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated herein by reference. 6. The Mortgage secures the following real property (the "Mortgaged Premises"): 1 Goldenrod Drive, Carlisle, PA 17013. A legal description of the Mortgaged Premises is attached hereto as Exhibit "A" and made a part hereof. 7. The Defendants are in default of their obligations pursuant to the Note and Mortgage because payments of principal and interest due July 1, 2005, and monthly thereafter are due and have not been paid, whereby the whole balance of principal and all interest due thereon have become due and payable forthwith together with late charges, escrow deficit (if any) and costs of collection including title search fees and reasonable attorney's fees. 8. The following amounts are due on the Mortgage and Note: Balance of Principal ....................., Accrued but Unpaid Interest from 6/1/05 to 4/5/07 @ 8.54% per annum ($34.25 per diem) .......................... Accrued Late Charges ................... .........$146,405.72 ........... $23,084.50 ................ $283.00 Corporate Advance ...........................................$20.00 Escrow Advance ............................................ (-$37.62) Title Search Fees ............................................$350.00 Deferred Late Charges ........................................$0.00 {00160453} Reasonable Attorney's Fees ........................$1,250.00 TOTAL as of 04/05/2007 ........................$171,355.60 Plus, the following amounts accrued after Apri15, 2007: Interest at the Rate of 8.54 per cent per annum ($34.25 per diem); Late Charges of $56.60 per month. 9. Plaintiff has complied fully with Act No. 91 (35 P.S.'1680.401(c) of the 1983 Session of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the Defendants at 1 Goldenrod Drive, Carlisle, PA 17013 as well as to address of residences as listed in paragraph 3 of this document on September 16, 2005, the notice pursuant to § 403-C of Act 91, and the applicable time periods therein have expired. True and correct copies of such notices are attached hereto as Exhibit "B" and made apart hereof. WHEREFORE, Plaintiff demands an in rem judgment against the Defendants for foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 8, namely, $171,355.60, plus the following amounts accruing after Apri15, 2007, to the date of judgment: (a) interest of $34.25 per day, (b) late charges of $56.60 per month, (c) plus interest at the legal rate allowed on judgments after the date of judgment, (d) additional attorney's fees (if any) hereafter incurred, (e) and costs of suit. LSTEAD & SOCIATES, LLC Pina S. Wertzberger, Esq e Attorney for Plaintiff {00160453} VERIFICATION I, Pina S. Wertzberger, hereby certify that I am an Attorney for Plaintiff and am authorized to make this verification on Plaintiff's behalf. I verify that the facts and statements set forth in the forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S. ' 4904, relating to unsworn falsification to authorities. ,~ ~ VV~ Name: Pina. S. Wertzberg ,Esquire Title: Attorney {00160453} 90-01422622 SCHBDVLE "A" ALL TtlAT CERTAIN TRACT OIt IIARCEL OF LAND SITSD-TE LYING AMID HEING IN T88 TODQIffiHZP OF E~DDLESBR IN TElB COUNT! OR' G9M8ERLAND COTd~OTiNBALTBE OF PENN6YLVANIA BEING LOT NO 51 FINAL SOBDIVI9ION PLAN NO 1 POR TAS MEADONS AS RECORDED IN ccmmaRLOND C09NTR RBCOADEit or DElDa oFr~sCC rn PL1W 8001f 49 PAS 43 BEING THE SAlHi PROPERTY CON{IE2ED TO IAN C 90RAI9 AtID RENEE 60kKIN NgaBAND A3QD 1PIF'6 8af DCCD PROM &RIC 8 BOPaCI14 AND CHRtBTID L 90R2GtN SVBBAND AMID iPiEE R&COHDSD 02/16/2005 IN DS6D 500K 267 PAGE 2958 I!i THE OFFICE OF TH8 RBCORDL'R OF DEEDS OF COMBERLAIVD covaTS, ramNSZ~vANIa. TAR IDR 21050433055 EXHfBIT q ~~~ MDMI? EQUITY 7104 5400 2100 1118 7132 September 16, 2005 0003016002" lan C. Sorkin 1 Goldenrod Drive Carlisle, PA 17013 ~~~ ~ ~ ~ ~" ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can held you you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TH1S NOTICE Take this Notice with you when you meet with the counseline aeencv. The name address and phone number of Consumer Credit Counseling Aeencies serving vour coun~ are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Apencv toll free at 1-800-342-2397 (persons with ~moa~red hearme can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numeeo mencionado arriba. Puedes ser elegible pars un prestamo por el progrima llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su liipoteca. HOMEOWNER'S NAME(S) PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT SERVICER Ian C. Sorkin 1 Goldenrod Drive Carlisle, PA 17013 245107669 Centex Hone Equity Company You maybe elsible for fmancial assistance which can save your home from foreclosure and help you make future morteaee payments if you comply with the provision of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You tnay be eligible for emergency mortgage assistance: if your default has been caused by circumstances beyond your control, you have a reasonable prospect of being able to pay your mortgage payments and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Page two 245107669 TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated conswner counseling agencies listed at the end of this Notice. This meeting must occur within the next th' 30 da s. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you attend aface-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated conswner counseline agencies for the county in which xour property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency . Your application MUST be filed or postmarked within thirty (30} days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will he notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT !Brine it uo to date): NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at Goldenrod Drive Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 07/0112005: $4,104.06 (b) Late charge(s) : $226.40 (c) Other charge(s): NSF & Advances $20.00 (d) Less: Credit Balance $.00 (e) Total amount required as of 09/15/2005: $4,350.46 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS 54,350.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Centex Home Equity Company at 350 HIGHLAND DR., LEWISVILLE, TX 75067. 245107669 Page three IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the morteaee debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you tnay lose the chance to pay the mortgage in monthly installments. if full payment of the amount of default is not made within THIRTY (30) days of the letter date, Centex Home Equity Company also intends to instruct their attorneys to start a legal action to foreclose~on your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cure the default within the THIRTY (301 DAY period~.,vou will not be requved to pay attomevs' 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 Sheriffs Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sate and any other costs connected with the Sheriffs 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 sheriffs sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Centex Home Equity Company Lender: Address: 350 Highland Dr., Lewisville, TX 75067 Telephone t-888-850-9398 Number: EFFECT OF SHERIFF'S SALE -You should realize that a sheriff's sale would 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 furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO NAVE THE RIGHT • To sell the property to obtain money to pay off the mortgage debt, or borrower money from another lending institution to pay off this debt. • To have this default cured by any third party acting on your behalf. • To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a calendar year). • To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted 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. Page four 245107669 Centex Home Equity Company is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address above within the thirty day period that the debt, or any portion thereof, is disputed, we will: a) Provide to you verification of the debt or a copy of any judgment entered against you. b) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Centex Home Equity Company Centex Home Equity Company, LLC 350 Highland Dr., Lewisville, TX 75067 1-888-850-9398 M ~'i HDME ~LJITY 7104 5400 2100 1118 7149 September 16, 2005 *0003016003* Renee Sorkin 1 Goldenrod Drive Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEM_A~ can helgyou you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the counseline aeencv. The name address and phone nutnber of Consumer Credit Counseling, Agencies servingyouur county are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housine Finance Aeenev toll free at 1 800 342 2397 (persons wtth ~mnaired heanna can call 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de sumo importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency} sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa Ilamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvor su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) PROPERTY ADDRESS: LOAN ACCOUNT NUMBER: CURRENT SERVICER Renee Sorkin I Goldenrod Drive Carlisle, PA 17013 245107669 Centex Home Equity Company You may be eligible for financial assistance which can save your home from foreclosure and help you make future morteaee ~avments if you comply with the provision of the Homeowners' 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, you have a reasonable prospect of being able to pay your mortgage payments and if you tneet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Page two 245107669 - ., TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notice. This meeting must occur within the next thirty (301 days IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you attend aface-to-face -neeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer counseling agencies for the county in which your proeertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender irmnediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency . Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at Goldenrod Drive Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 07/Ol/2005: $4,104.06 (b) Late charge(s) : $226.40 (c) Other charge(s): NSF & Advances $20.00 (d) Less: Credit Balance $.00 (e) Total amount required as of 09/l5/2005: $4,350.46 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS 54,350.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Centex Home Equity Company at 350 HIGHLAND DR., LEWISVILLE, TX 75067. -- ,. Page three 245107669 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the morteaee debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. if full payment of the amount of default is not made within THIRTY (30) days of the letter date, Centex Home Equity Company also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the ]ender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. if you cure the default within the THIRTY (30) DAY period you will not be reauired to pay attorneys' fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such sheriff's sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any tune exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Centex Home Equity Company Lender: Address: 350 Highland Dr., Lewisville, TX 75067 Telephone 1-888-850-9398 Number: EFFECT OF SHERIFF'S SALE -You should realize that a sheriff's sale would 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 furniture and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding pa}nnents, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT • To sell the property to obtain money to pay off the mortgage debt, or borrower money from another lending institution to pay off this debt. • To have this default cured by any third party acting on your behalf. • To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three tunes in a 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 tnay have to such action by the lender. • To seek protection under the federal bankruptcy law. -' ,,, Page four 245107669 Centex Home Equity Company is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address above within the thirty day period that the debt, or any portion thereof, is disputed, we will: a) Provide to you verification of the debt or a copy of any judgment entered against you. b) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Centex Hotne Equity Company Centex Home Equity Company, LLC 350 Highland Dr., Lewisville, TX 75067 1-888-850-9398 ,•. ,~ HDM~ QU1TY September 16, 2005 "0003016004'' Ian C. Sorkin 1 Goldenrod Drive Carlisle, PA 17013 EXHIBIT B ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can hel~you you must MEET WITH A CONSL}MER CREDIT COUNSELING AGENCY W1TH1N 30 DAYS OF THE DATE OP THIS NOTICE Take this Notice with you when you meet with the counseling aeencv. The name address and phone number of Consumer Credit Counseling Agencies servingyour county are listed at the end of this Notice. If you have any~uestions you max call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (persons with impaired hearing can call 717-780-(8691. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de suma importancia, pues afecta su derecho a continuer viviendo en su case. Si no comprende el contenido de esta notiftcion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible pare un prestamo por et programa Ilamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salver su case de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) PROPERTY ADDRESS LOAN ACCOUNT NUMBER: CURRENT SERVICER lan C. Sorkin 1 Goldenrod Drive Carlisle, PA ]7013 245107669 Centex Home Equity Company You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortsa¢e p@vtnents if you comply with the provision of the Homeowners' 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, 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. Page two 245107669 -~ TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notice. phis meeting tnust occur within the next th' 30 da s. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP O DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - if you attend aface-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names addresses and tel~hone numbers of designated conswner counseline agencies for the county in which your properiv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this fender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). if you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the progra-n and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency . Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH 1N 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 Pe~msylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at Goldenrod Drive Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 07/01/2005: $4,104.06 (b) Late charge(s) : $226.40 (c) Other charge(s); NSF & Advances $20.00 (d) Less: Credit Balance $.00 (e} Total amount required as of 09/15/2005: $4,350.46 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days frotn the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS 54,350.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Centex Home Equity Company at 350 HIGHLAND DR., LEWISVILLE, TX 75067. - r Page three 245107669 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its ri t to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, Centex Home Equity Company also intends to instruct their attorneys to start a legal action to foreclose upon yow mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include their reasonable costs. If you cwe the default within the THIRTY (30) DAY period Xou will not be required to pay attorneys' fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance, and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs 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 sheriffs sale could be held is would be approximately five (5) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Centex Home Equity Company Lender: Address: 3S0 Highland Dr., Lewisville, TX 75067 Telephone 1-888-850-9398 Number: EFFECT OF SHERIFF'S SALE -You should realize that a sheriff's sale would end your ownership of the mortgaged property and yaw right to occupy it. if you continue to live in the property after the sheriff s sale, a lawsuit to remove you and yow furniture and other belongings could be started by the lender at any time, ASSUMPTION OF MORTGAGE -You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT • To sell the properly to obtain money to pay off the mortgage debt, or borrower money from another lending institution to pay off this debt. • To have this default cured by any third party acting on you-• behalf. • To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a calendar year). • To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted 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. • .r Page four 245107669 Centex Home Equity Company is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid if you notify us in writing at the address above within the thirty day period that the debt, or any portion thereof, is disputed, we will: a) Provide to you verification of the debt or a copy of any judgment entered against you. b) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Centex Home Equity Company Centex Home Equity Company, LLC 350 Highland Dr., Lewisville, TX 75067 1-888-850.9398 ~ _~ H4iME QUITY September 16, 2005 `0003016005" Renee Sorkin 1 Goldenrod Drive Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE FOUR The Homeowners' Emergency Mortgage Assistance Program (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help you you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the counseling_a eg ncv The name address and~hone number of Consumer Credit CounselingAeencies serving_vour counri are listed at the end of this Notice. If you have anyguestions you may call the Penncvtvania Housing Finance Agency toll free at I-800-342-2397 (persons with impaired hearine can tali 717-780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. La Notificaion en adjunto es de soma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificion obtenga una traduccion immediatamente Ilamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible pars un prestamo por el programs Ilamado "Homeowners' Emergency Mortgage Assistance Program" al coal puede salvar su casa de la perdida del derecho a redimir su hipoteca. HOMEOWNER'S NAME(S) : Renee Sorkin PROPERTY ADDRESS: 1 Goldenrod Drive Carlisle, PA 17013 LOAN ACCOUNT NUMBER: 24S 107669 CURRENT SERVICER Centex Home Equity Company You may be eligible for financial assistance which can save your home from foreclosure and help you make future mortgage navments if you comply with the provision of the Homeowners' 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, 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. Page two 245107669 ~ u, ,t TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer counseling agencies listed at the end of this Notice. This meeting must occur within the next thirh+_(30) davs. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you attend aface-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer counseling agencies for the county in which your properiy is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. You should advise this lender iimnediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency . Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER. TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing finance Agency has sixty (60) days to make a decision after it receives you application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to dateZ NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at Goldenrod Drive Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 07/01/2005: $4,104.06 (b) Late charge(s) : $226.40 (c) Other charge(s): NSF & Advances $20.00 (d) Less: Credit Balance $.00 (e) Total amount required as of 09/1$/2005: $4,350.46 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (if applicable): HOW TO CURE THE DEFAULT- You may cure this default within THIRTY (30) days from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO LENDER, WHICH IS $4,350.46, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable to Centex Home Equity Compairy at 350 HIGHLAND DR., LEWISVILLE, TX 75067. ~ al. ~ Page three 24S 107f69 IF YOU DO NOT CURE THE DEFAULT - if you do not cure the default within THIRTY (30) days of this letter date, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the chance to pay the mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) days of the letter date, Centex Home Equity Company also intends to instruct their attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before they begin legal proceedings against you, you will have to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees actually incurred even if they are over $50.00. Any attorney's fees will be added to the atnount you owe the lender, which may also include their reasonable costs. If you cove the default within the THIRTY (30) DAY period, you will not be required to pay.attorne,Ys' 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 coved 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 Sheriffs Sale. You may do so by paying the total amount then past due plus any late charges, charges then due, reasonable attorneys' fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such sheriffs sale could be held is would be approximately five (5) months froth the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Centex Home Equity Company Lender: Address: 350 Highland Dr., Lewisville, TX 75067 Telephone 1-888-850-9398 Number: EFFECT OF SHERIFF'S SALE -You should realize that a sheriffs sale would end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the sheriffs sale, a lawsuit to remove you and yow furnitwe and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorneys' fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT • To sell the property to obtain money to pay off the mortgage debt, or borrower money from another lending institution to pay off this debt. • To have this default cured by any third party acting on your behalf. • To have the mortgage restored to the same position as if no default had occurred. (However, you are not entitled to this right more than three times in a calendar year). • To assert the nonexistence of a default in any foreclosure proceeding or any other lawsuit instituted 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. ~, ~ 245107669 Page four Centex Home Equity Company is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the address above within the thirty day period that the debt, or any portion thereof, is disputed, we will: a) Provide to you verification of the debt or a copy of any judgment entered against you. b) Provide to you the name and address of your original creditor, if the original creditor is different from the current creditor. Sincerely, Centex Home Equity Company Centex Home Equity Company, LLC 350 Highland Dr., Lewisville, TX 75067 1-888-850-9398 t-~ *~.~ ~ ~ <7 n ~ ~, ~ U ~ ~ N l 3 n~ U MILSTEAD & ASSOCIATES, LLC BY: Pina S. Wertzberger, Esquire ID No. 77274 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Nationstar Mortgage, LLC f/Wa Centex Home Equity Company, LLC, Attorney for Plaintiff File 9.04377 COURT OF COMMON PLEAS CUMBERLAND COUNTY P1ainNff, Vs. No.: 07-1979 Civil Term Ian C. Sorkin, Praecine to Dismiss the Mortgage Foreclosure Action without Preiudice and Renee M. Sorkin, Defendant(s). TO THE PROTHONOTARY: Kindly dismiss the above captioned Mortgage Foreclosure Complaint without Prejudice. LS jT~E & ASS CIATES, LLC ~~ ' Pina S. Wertz rger, Es uire Attorney ID No. 77274 t~ ~ C7 -rt -,-, ~<<, n c.... s ~_ ~ ~ ~= c~ _~ ~-. -~ - .. ~ -^~ ~~~,~, .~ -.S SHERIFF'S RETURN - REGULAR CASE NO: 2007-01979 P +~~ .._ ~ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONSTAR MORTGAGE LLC VS SORKIN IAN C ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SORKIN IAN C the DEFENDANT at 1830:00 HOURS, on the 25th day of April 2007 at 1 GOLDENROD DRIVE CARLISLE, PA 17013 by handing to IAN SORKIN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.72 Affidavit .00 Surcharge 10.00 1j'l z3~~ 7 .00 ~.. 3 4. 7 2 Sworn and Subscibed to before me this day So Answers: ~ '. .~, .--~ R. Thomas Kline 04/26/2007 MILSTEAD & ASSOCIATES Deputy Sheriff of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-01979 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONSTAR MORTGAGE LLC VS SORKIN IAN C ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ClII?uT1~7 RF'T~T~'~' M the DEFENDANT at 1830:00 HOURS, on the 25th day of April 2007 at 1 GOLDENROD DRIVE CARLISLE, PA 17013 by handing to IAN SORKIN, SPOUSE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 ~Ia~'b ~ ~ ,~ 16.0 0 Sworn and Subscibed to before me this day So Answers: rr ~ ~~~. `; ~ ~' R. Thomas Kline 04j26j2007 MILSTEAD & ASSOCIATES By. Deputy Sheriff of A.D.