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HomeMy WebLinkAbout08-1262UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS 577 Lamont Road =CIVIL DIVISION Elmhurst, IL 60126 Plaintiff "Cumberland County V. Leanne Beil, Executrix of the Estate of Joseph P. Beil NO. p$- la(,pA l?lYi( ?GrM 4 Briargate Road Mechanicsburg, PA 17050 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth. in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court.without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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 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 provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 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: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: HSBC Mortgage Services, Inc. Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the mortgage being foreclosed is as follows: MORTGAGED PREMISES: 4 Briargate Road MUNICIPALITY/TOWNSHIP/BOROUGH: Silver Spring Township COUNTY: Cumberland DATE EXECUTED: 10/24/05 DATE RECORDED: 10/31/05 BOOK: 1928 PAGE: 4542 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 2/12/08: Principal of debt due $184,881.65 Unpaid Interest at 7.25% from 7/1/07 to 2/12/08 (the per diem interest accruing on this debt is $36.72 and that sum should be added each day after 2/12/08) 8,335.44 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $222.71 and that sum should be added on the first of each month after 2/12/08) 300.18 Late Charges (monthly late charge of $64.12 should be added in accordance with the terms of the note each month after 2/12/08) 384.72 Other Fees 902.87 Uncollected Late Charges 64.12 Attorneys Fees (anticipated and actual to 50 of principal) 9,244.08 TOTAL $204,718.06 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 $204,718.06 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN F , P. C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -LOUIS A. SIMONI, ESQUIRE ALL THAT CERTAIN PIECE OR PARCEL OF PROPERTY LOCATED IN THE TOWNSHIP OF SILVER SPRING COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ON A CERTAIN MAP ENTITLED "PLAN OF KINGSBURY MANOR", DATED OCTOBER 26, 1973, SCALE 1" - 50", SILVER SPRING TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, ERNEST J. WALKER, R.D. #4, MECHANICSBURG, PENNSYLVANIA", WHICH MAP IS FILED IN PLAN BOOK 32, PAGE 68, IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY AND BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERLY SIDE OF BRIARGATE ROAD AS SHOWN ON THE ABOVE REFERENCED MAP AT THE SOUTHEAST CORNER OF LOT NO. 8; THENCE NORTH 23 DEGREES 56 MINUTES 18 SECONDS WEST ALONG LOT NO. 8, A DISTANCE OF 218.44 FEET TO A POINT AT THE NORTHEASTERN CORNER OF LOT NO.8 AS SHOWN ON THE ABOVE REFERENCED MAP; THENCE NORTH 65 DEGREES 56 MINUTES 05 SECONDS EAST, A DISTANCE OF 127.26 FEET TO A POINT ON THE WESTERLY SIDE OF LOT NO. 11 AS SHOWN ON THE ABOVE REFERENCED MAP; THENCE SOUTH 23 DEGREES 15 MINUTES 51 SECONDS EAST ALONG LOTS NOS. 10 AND 11 AS SHOWN ON THE SAID MAP, A DISTANCE OF 203.39 FEET TO A POINT ON THE NORTH SIDE OF BRIARGATE ROAD; THENCE SOUTH 55 DEGREES 11 MINUTES 00 SECONDS WEST, ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD, A DISTANCE OF 64.65 FEET TO A POINT ON THE NORTHERLY SIDE OF BRIARGATE ROAD; THENCE ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD ALONG THE CURVE TO THE RIGHT HAVING A RADIUS OF 175.00 FEET A DISTANCE OF 33.23 FEET TO A POINT ON THE NORTHERLY SIDE OF BRIARGATE ROAD; THENCE SOUTH 66 DEGREES 03 MINUTES 42 SECONDS WEST ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD, A DISTANCE OF 28.34 FEET TO THE POINT AND. PLACE OF BEGINNING. BEING ALL OF LOT NO.9 AS SHOWN ON THE ABOVE-REFERENCED MAP. SUBJECT TO RECORDED PROTECTIVE COVENANTS FOR KINGSBURG MANOR RECORDED IN MISC. BOOK 236, PAGE 318, IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY. SUBJECT NEVERTHELESS, TO A 20 FOOT WIDE SEWER EASEMENT AS SHOWN ON SAID ABOVE DESCRIBED PLAN. HAVING THEREON ERECTED A TWO (2) STORY SINGLE FAMILY DWELLING NUMBERED AS 4 BRIARGATE ROAD, MECHANICSBURG. HSBC <D 636 Grand Regency Blvd Brandon, FL 33510 1,10 1111111111111111111 71067112169003680802 a 0166399 0000DO171 009N"14 0060110 617 Joseph P Beil 4 Briar Gate Rd Mechanicsburg PA 17050 -3178 q (t/f 11141111411111,111 1 1111 11111116114 111141111,111114111111111411 1019(1007 DEMAND LETTER (NOTICE TO CURE DEFAULT) COMBINED ACT 91/ACT 6 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 I? the attached pages. The HOMEOWNER' S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address and phone number of the consumer credit counseling agencies serving your county are listed at the end of this notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at (800) 342-2397. Persons with impaired hearing may 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 an attorney. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE AL LLAMAR A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCINADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER' S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A HOMEOWNER' S NAME(S): JOSEPH P BEIL PROPERTY ADDRESS: 4 BRIARGATE RD MECHANICSBURG PA 17050-3178 ACCOUNT NUMBER: 0011945052 CURRENT LENDER/SERVICER: HSBC Mortgage Services HOMEOWNER' S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER' S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTAGE '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 meet with one of the credit consumer counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the day of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the country in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner' s Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner' s Emergency Mortgage Assistance Program Application with on of the designated consumer credit counseling agencies listed atthe end of this Notice. Only consumer credit counseling agencies have the application s for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. You application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. + 0166199 000000171 n9NnS3 OOL0110 617 YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you will still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) I? NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your iT- property located at: 4 BRIARGATE RD MECHANICSBURG PA 17050-3178 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS. You are due and owing approximately $1282.49 a month. You are past due since 08/0112007. Other fees may have also accrued on your account. TOTAL AMOUNT PAST DUE: $7715.12 HOW TO CURE THE DEFAULT -You may cure this default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7715.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier scheck, certified check or money order made payable and sent to: HSBC Mortgage Services P.O. Box 17580 Baltimore, MD 21297 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgage property . + 0166199 000000171 01MM13 0060310 617 IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney' sfees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorneys' fees actually incurred by the lender, even if they exceed $50.00. Any attomey' s fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney' sfees. 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' SSALE -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 sSale. You may do so by paying the total amount past due, plus any late or other charges due, reasonable attomey sfees and costs connected with the foreclosure sale and any other costs connected with the Sheriff sSale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF' S SALE DATE - It is estimated that the earliest date that such a Sheriff sSale of the mortgaged property could be held would be approximately five months from the date of this Notice. A notice of the actual date of the Sheriff sSale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER : Name of Lender: HSBC Mortgage Services Address: 636 Grand Regency Blvd., Brandon, FL 33510 Phone Number: 800-3656730 Fax Number: 813571-8680 Contact Information: Loss Mitigation Department EFFECT OF SHERIFF' SSALE -You should realize that a Sherif sSale will end your ownership of the mortgaged property and your right to occupy lt. If you continue to live in the property after the Sherif sSale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You _X_ may or _X_ 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 attorney' sfees and costs are paid prior to or al the sale and that the other requirements of the mortgage are satisfied. + 0366199 000000171 09MMS3 0060130 617 YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAYOFF THIS DEBT. - TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING 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 THE RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF 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. no' FOR CONSUMER CREDIT COUNSELING AGENCIES -SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgement and mail you a copy of such judgement or verification. You are also advised this information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this notice, this office will provide you with the name and address of the original creditor. Although we have requested that you make payment or provide a valid reason for nonpayment, you still have the right to make a written request, within thirty days of your receipt of this notice, for more information about the debt. Your rights are described further, hereinafter. THE PURPOSE OF THIS COMMUNICATION ISTO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ENCLOSURE: Validation of Debt Notice + 0166199 000000171 09N0S3 0060110 617 Validation of Debt Notice Pursuant to the Fair Debt Collection Practice Act (FDCPA) (15 USC 1692), a consumer debtor is required to be sent the following notice: (1) unless the consumer, within thirty (30) days after receipt of this notice, disputes the validity of the debt or any portion thereof, the debt will be assumed to be valid by the debt collector; (2) if the consumer notes the debt collector in writing within the thirty (30) day period that the debt or any portion thereof is disputed, the debt collector will obtain verification of the debt or a copy of a judgement against the consumer and copy of such verification or judgement will be mailed to the consumer by the debt collector; and (3) upon the consumer' swritten request within the thirty (30) day period, the debt collector will provide the consumer with the name and address of the original creditor, if different from the current creditor. Our demand for immediate payment does not eliminate your right to dispute this debt within thirty (30) days of receipt of this notice. If you choose to do so, we are required by law to cease our collection efforts until we have mailed the disputed information to you. Although we have requested that you make payment or provide a valid reason for nonpayment, you still have the right to make a written request, within thirty (30) days of your receipt of this notice, for more information about the debt. Your rights are described further, hereinafter. THIS NOTICE AND LETTER ARE AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. The Federal Trade Commission has ruled that the FDCPA does not preclude the institution of legal action prior to the expiration of the thirty (30) day period. Acceptance of funds and reinstatement of the mortgage are both subject to verification by HSBC Mortgage Services. Please note that HSBC Mortgage Services may proceed with foreclosure and that fees, costs and / or advances by the mortgagee may be due in addition to the sum quoted above. Please note further that any funds tendered will be subject to verification and correctness before the matter is concluded. Please feel free to contact HSBC Mortgage Services upon receipt of this notice should have any questions or concerns. Date: 12/19/2007 HSBC Mortgage Services 636 Grand Regency Blvd. Brandon, FL 33510 (800) 365-6730 www.hsbanortgageservioes.com ? 0166199 000000171 0IRMS3 0060110 617 V E R _IF I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she 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/she 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/her 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. OFFICES P.C. L. UDREN BY: ' ff Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE 90 ?o d t 'b S ? I 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01262 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS BEIL LEANNE ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ID=TT T.V7\NT-NT7 T'VW' n7 7CTAT7 07 TOg7PTT P RRTT, but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT JOSEPH P BEIL 4 BRIARGATE ROAD NOT FOUND , as to BEIL LEANNE EXEC OF ESTATE OF MECHANICSBURG, PA 17050 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: So answers:, J; Docketing 18.00] Service 9.60 Not Found 5.00 r R. Thomas II1ne Surcharge 10.00 Sheriff of Cumberland County 42.60,--' UDREN LAW OFFICE 03/20/2008 .3/xy'/0g ?x? Sworn and Subscribed to b fore me this day of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-01262 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS BEIL LEANNE ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland Coun.ty,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT.- MORT FORE was served upon PITT T RANTNF FXFC OF FSTATF OF 70SFPR P BEIL the DEFENDANT , at 1650:00 HOURS, on the 19th day of March 2008 at 22 ROYAL PALM ROAD MECHANICSBURG, PA 17050 REBECCA BEIL, DAUGHTER 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 6.00 Service 9.60 Affidavit .00 So Answers: Surcharge 10.00 R. Thomas Kline .00 25.60? 03/20/2008 UDREN LAW OFFICES 31.I 7 f v? ? ??_'? Sworn and Subscibed to By: before me this day Deputy Sheriff of A. D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Dleadinas@udren.com Plaintiff :CIVIL DIVISION :Cumberland County V. Leanne Beil, Executrix of the Estate of Joseph P. Beil :NO. 08-1262 Civil Term Defendant(s) HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with UDREN LAW OFFICES, P.C. regard to the captioned matter. DATED: April 22, 2008 BY: Attorneys for/Alaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE V E R I F I C A T I O N The undersigned, as Attorney in Fact for of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by Plaintiff in the. ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904. relating to unsworn falsification to authorities. Date: Name: Title: Attorne mFact Company: HSBC Mortgage Services, Inc. Leanne Beil, Executrix of the Estate of Joseph P. Beil Loan #0011945052 MJU #08020182 =F , rQ Nx G.11 ? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. !COURT OF COMMON PLEAS 577 Lamont Road -,CIVIL DIVISION Elmhurst, IL 60126 :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the Estate ':NO. 08-1262 Civil Term of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 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) Leanne Beil, Executrix of the Estate of Joseph P. Beil 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 $204,718.06 Interest Per Complaint 2,570.40 From 2/13/08 to 4/22/083 Late charges per Complaint 192.36 From 2/13/08 to 4/22/083 Escrow payment per Complaint 445.42 From 2/13/08 to 4/22/083 TOTAL $207,926.24 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY,-- ?-? I / " , Attorneys DbY Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICAT D DATE: f Dev ? Ole - R PRO Y UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE,.ESQUIRE - ID #34576 ALAN M. NINATO, ESQUIRE - ID #75860 CHANDRA M. ARKRKA, ESQUIRE - ID #203437 WOODCREST C09PORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 nleadingsan dren _enm HSBC Mortgage Services, Inc. Plaintiff V. Leanne Beil, Executrix of the Estate of Joseph P. Beil Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 08-1262 Civil Term TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil c/o Lowell Gates Esq, 1013 Mumma Road Lemoyne, PA 17043 DATE of Notice: April 9, 2008 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 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 O 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 O 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 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Mark en, squire Stuart Winneg, Esquire Lorraine Doyle, Esquire Alan M. Minato, Esquire Chandra M. Arkema, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG,,BSQUIRE - ID #45362 LORRAiINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO ESQUIRE.- ID #75860 CHANDRA M. ARK$MA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 HSBC Mortgage Services, Inc. Plaintiff V. Leanne Beil, Executrix of the Estate of Joseph P. Beil Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 08-1262 Civil Term TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil 22 Royal Palm Road Mechanicsburg, PA 17050 DATE of Notice: April 9, 2008 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 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 TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO RviMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O 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 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. az J. ren, squire Stuart Winneg, Esquire Lorraine Doyle, Esquire Alan M. Minato, Esquire Chandra M. Arkema, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302. STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE', ESQUIRE - ID #34576 ALAN M. NINAT01 ESQUIRE - ID #75860 CI3ANDRA M. AR1C , ESQUIRE - ID #203437 WOODCREST CO RATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HELL, NJ 08003 856-669-5400 PleadingelAndren-rom HSBC Mortgage Services, Inc. Plaintiff V. Leanne Beil, Executrix of the Estate of Joseph P. Beil Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 08-1262 Civil Term TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 DATE of Notice: April 9, 2008 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 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 O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, I1vIPORTANTES. 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 O 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 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -mar . U en, squire Stuart Winneg, Esquire Lorraine Doyle, Esquire Alan M. Minato, Esquire Chandra M. Arkema, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 SHERIFF'S RETURN - REGULAR CASE NO: 2008-01262 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS BEIL LEANNE ET AL NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BEIL LEANNE EXEC OF ESTATE OF JOSEPH P BEIL the DEFENDANT , at 1650:00 HOURS, on the 19th day of March 2008 at 22 ROYAL PALM ROAD MECHANICSBURG, PA 17050 REBECCA BEIL. DAUGHTER 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 6.00 Service 9.60 Affidavit .00 Surcharge 10.00 Sworn and Subscibed to .00 25.60 before me this day of , A. D. So Answers: R. Thomas Kline 03/20/2008 UDREN LAW OFFICES By: Deputy Sheriff SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-01262 P COMMONTWEAL•TH OF PENNSYLVANIA COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS BEIL LEANNE ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named BEIL LEANNE EXEC OF ESTATE 0: unable to locate Her in his COMPLAINT - MORT FORE , the within named DEFENDANT JOSEPH P BEIL 4 BRIARGATE ROAD I NOT FOUND , as to BEIL LEANNE EXEC OF ESTATE OF MECHANICSBURG, PA 17050 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge -,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and DEFENDANT JOSEPH P BEIL but was bailiwick. He therefore returns the So answers: 18.00 9.60 ? 5.00 R_ Thomas KI-Ine 10.00 Sheriff of Cumberrland County .00 42.60 UDREN LAW OFFICE 03/20/2.008 Sworn and Subscribed to before me this day of A. D.' UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - STUART WINNEG, ESQUIRE - LORRAINE DOYLE, ESQUIRE ALAN M. MINAT , ESQUIRE CHANDRA M. AR?FMA, ESQUZ LOUIS A. SIMONI, ESQUIRE ID #04302 ID #45362 - ID #34576 - ID #75860 RJk - ID #203437 - ID #200869 ATTORNEY FOR PLAINTIFF WOODCREST-CORPORATE CENTER 111 WOODCREST'ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 HSBC Mortgage Services, Inc. 577 Lamont Road Elmhurst, IL 60126 Plaintiff V. Leanne Beil, Executrix of the Estate of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT STATE OF COUNTY OF 4G COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 0q_ A 4) C, i V i 1 OF NON-MILITARY SERVICE SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant : Age: Residence: Employment: Leanne Beil, Bei1 Over 18 As captioned Unknown Swo to and subscribed be ore me-this - day o/f =Ao , 20ca. Public Executrix of the Estate of Joseph P. above Name : l I m' .Title: Attor?iey in Fact Company: HSBC Mortgage Services, Inc. Matthew Allan Baneszewskl ;...N NOTARY PUBLIC - WNNESOTA MY COMMISSION EXPIRES JAN. 31, 2011 ("1 7 j Q =r N c: -71 ?? UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART W11 NEE __-ESQUIRE___-.. ID__ #45.3-62__ LORRAINE DOYiLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. AIRKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 --- SS£=6b9-54tT6-- - --- P-leadings@udren.com ATTORNEY FOR PLAINTIFF HSBC Mortgage Services, Inc. Plaintiff V. COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Leanne Beil, Executrix of the Estate of Joseph P. Beil Defendant(s) NO. 08-1262 Civil Term TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil 22 Royal Palm Road Mechanicsburg, PA 17050 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. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, USQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 856-669-5400 _ ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY_ HILL, NJ_8003-3620 FOR PLAINTIFF HSBC Mortgage Services, Inc. 577 Lamont Road Elmhurst, IL 60126 Plaintiff V. Leanne Beil, Executrix of the Estate of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 Defendant (s) :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County ;MORTGAGE FORECLOSURE :NO. 08-1262 Civil Term 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) Leanne Beil, Executrix of the Estate of Joseph P. Beil 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 $204,718.06 Interest Per Complaint 2,570.40 From 2/13/08 to 4/22/083 Late charges per Complaint 192.36 _ From 2/13/08 to 4/22/083 Escrow payment per Complaint 445.42 From 2/13/08 to 4/22/083 TOTAL $207,926.24 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. Attorneys f-46?- Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO P OTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEQ, ESQUIRE- ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINA?0, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. ':COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the Estate of Joseph P. Beil ::NO. 08-1262 Civil Term Defendant(s) TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil c/o Lowell Gates Esq. 1013 Mumma Road Lemoyne, PA 17043 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. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonotary 1s/ &ia-jrz - ?4 -vn 27 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 MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMAi, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS 577 Lamont Road :CIVIL DIVISION Elmhurst, IL 60126 :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the Estate :NO. 08-1262 Civil Term of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 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) Leanne Beil, Executrix of the Estate of Joseph P. Beil 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 $204,718.06 Interest Per Complaint 2;570.40 From 2/13/08 to 4/22/083 Late charges per Complaint 192.36 From 2/13/08 to 4/22/083 Escrow payment per Complaint 445.42 From 2/13/08 to 4/22/083 TOTAL $207,926.24 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY -o Attorneys fc46?- Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HER8BY ASSESSED AS INDICATED DATE: - - - - - PRO HY - UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCRESt ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. =COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 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. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonotary 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 of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 Defendant(s) HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS 577 Lamont Road :CIVIL DIVISION Elmhurst, IL 60126 ::Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the Estate :NO. 08-1262 Civil Term UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576- ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com 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) Leanne Beil, Executrix of the Estate of Joseph P. Beil 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 $204,718.06 Interest Per Complaint 2,570.40 From 2/13/08 to 4/22/083 Late charges per Complaint - 192.36 From 2/13/08 to 4/22/083 Escrow payment per Complaint 445.42 From 2/13/08 to 4/22/083 TOTAL $207,926.24 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY?- Attorneys Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO PROTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEQ, ESQUIRE - ID #45362 LORRAINE DOY E, ESQUIRE - ID #34576 ALAN M. MINA O, ESQUIRE - ID #75860 CHANDRA M. A EMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. ::COURT OF COMMON PLEAS Plaintiff 'CIVIL DIVISION V. :Cumberland County .MORTGAGE FORECLOSURE Leanne Beil, Executrix of the ::NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $207,926.24 Interest From 4/23/08 4,920.48 to Date of Sale September 3, 2008 Ongoing Per Diem of 36.72 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. BY :-4,-, - Attorneys Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE :i. . 4A, W o G 00 90 vri WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1262 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC MORTGAGE SERVICES, INC., Plaintiff (s) From LEANNE' BEIL, EXECUTRIX OF THE ESTATE OF JOSEPH P. BEIL (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 $207,926.24 L.L. $.50 Interest FROM 4/23/08 TO DATE OF SALE 9/3/08 - ONGOING PER DIEM OF $36.72 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $4,920.48 Atty's Comm % Atty Paid $187.20 Plaintiff Paid Date: APRIL 22, 2008 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs LcYuLy Name LORRAINE DOYLE, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOOjDCREST ROAD, SUITE 200 CHERRY HILL, NJ J08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. AAKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, 'NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :.COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County ::MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorneys for,intiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE C.s L7 ,;r-: t UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOY E, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 HSBC Mortgage Services, Inc., 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: 4 Briargate Road Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Leanne Beil, Executrix of the Estate of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 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 HSBC Mortgage] Services, the last recorded holder of every mortgage Address Inc. 577 Lamont Road Elmhurst, IL 60126 f Mortgage Electronic Registration Systems, Inc. Manufacturers and Traders Trust Company, (The "Bank") Pramco III, LLC P.O. Box 2026 Flint, MI 48501-2026 One M & T Plaza, Buffalo, NY 14240 ATTN: Office of General Council 230 Crosskeys Office Park, Fairport, NY 14450 5. Name and address of every other person who has any record lien on the property: Name Address Bureau of Compliance Dept. 280946, Harrisburg, PA 17128 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17103 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St. Carlisle, PA 17103 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 4 Briargate Road Mechanicsburg, PA 17050 Lowell Gates Esq. 1013 Mumma Rd, Lemoyne, PA 17403 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: April 22, 2008 UDREN LAW OFFICES, P.C.l? Attorneys fo aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE C":+ r.a - 11 L ,) l._/ 1, ?_ ?.u ?-? +?' N f i? ti /? ? V t.^ -t .. f I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WTE , ESQUIRE - ID #45362 LORRAINE Y E, ESQUIRE - ID #34576 ALAN M. MINA O, ESQUIRE - ID #75860 CHANDRA M. EMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCRES ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. Plaintiff V. Leanne Beil, Executrix of the Estate of Joseph P. Beil Defendant(s) :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County :MORTGAGE FORECLOSURE NO. 08-1262 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil 4 Briargate Road Mechanicsburg, PA 17050 Your house (real estate) at 4 Briargate Road, Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on September 3, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $207,926.24, 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. l 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.) r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN XF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. Youtmay 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 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 ?a ti ?T' (r:` ` ? ` 7 ?_ t?,, e ?r`?: ?.: ?_ ? }' , f ? ..C { UDREN LAW OFFICES,°P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNE, ESQUIRE - ID #45362 LORRAINE DOY E, ESQUIRE - ID #34576 ALAN M. MINA O, ESQUIRE - ID #75860 CHANDRA M. EMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCRES ROAD, SUITE 200 CHERRY HILL,INJ 08003-3620 856-669-5400 pleadings@uden.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) $OTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil c/o Lowell Gates Esq. 1013 Mumma Road Lemoyne, PA 17043 Your house (real estate) at 4 Briargate Road, Mechanicsburg, PA 17050 is schejduled to be sold at the Sheriff's Sale on September 3, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $207,926.24, '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.) 1 1. If ?he Sheriff's Sale is not stopped, your property will be sold to the highest idder. 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 g ossly inadequate compared to the value of your property. 3. Thelsale will go through only if the buyer pays the Sheriff the full amount duel,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 the 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 TARE1THIS 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 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 ? r,.? r?:? ???? r- °?' - ?; ;. - ?? a ..?.. r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDRENI, ESQUIRE - ID #04302 STUART WINNE , ESQUIRE - ID #45362 LORRAINE DOY E, ESQUIRE - ID #34576 ALAN M. MINA 0, ESQUIRE - ID #75860 CHANDRA M. KEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCRES ROAD, SUITE 200 CHERRY HILL, = 08003-3620 856-669-5400 pleadings@udr,en.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO Leanne Beil, Executrix of the Estate of Joseph P. Beil 22 Royal Palm Road Mechanic,sburgs, PA 17050 Your house (deal estate) at 4 Briargate Road, Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on September 3, 2008, at 110:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $207,926.24, obtained by Plaintiff above (the mortgagee) against you. If the Isale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLg 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.) 1. If ?he Sheriff's Sale isnot stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. Youll'',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 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 ALL THAT C RTAIN PIECE OR PARCEL OF PROPERTY LOCATED IN THE TOWNSHIP O SILVER SPRING COUNTY OF CUMBERLAND AND COMMONWE LTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED N A CERTAIN MAP ENTITLED "PLAN OF KINGSBURY MANOR", DATED OCT BER 26, 1973, SCALE 1" - 50", SILVER SPRING TOWNSHIP, CUMBERLA COUNTY, PENNSYLVANIA, ERNEST J. WALKER, R.D. #49 MECHANICS URG, PENNSYLVANIA", WHICH MAP IS FILED IN PLAN BOOK 32, PAGE 68, IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY AND BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERLY SIDE OF BRIARGATE ROAD AS SHOWN ON THE ABOVE REFERENCED MAP AT THE SOUTHEAST CORNER OF LOT NO. 8; THENCE NORTH 23 DEGREES 56 MINUTES 18 SECONDS WEST ALONG LOT NO. 8, A DISTANCE OF 218.44 FEET TO A POINT AT THE NORTHEASTERN CORNER OF LOT NO.8 AS SHOWN ON THE ABOVE REFERENCED MAP; THENCE NORTH 65 DEGREES 56 MINUTES 05 SECONDS EAST, A DISTANCE OF 127.26 FEET TO A POINT ON THE WESTERLY SIDE OF LOT NO. 11 AS SHOWN ON THE ABOVE REFERENCED MAP; THENCE SOUTH 23 DEGREES 15 MINUTES 51 SECONDS EAST ALONG LOTS NOS. 10 AND 11 AS SHOWN ON THE SAID MAP, A DISTANCE OF 203.39 FEET TO A POINT ON THE NORTH SIDE OF BRIARGATE ROAD; THENCE SOUTH 55 DEGREES 11 MINUTES 00 SECONDS NEST, ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD, A DISTANCE OF 64.65 FEET TO A POINT ON THE NORTHERLY SIDE OF BRIARGATE LOAD; THENCE ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD ALONG THE CURVE TO THE RIGHT HAVING A RADIUS OF 175.00 FEET A DISTANCE OF 33.23 FEET TO A POINT ON THE NORTHERLY SIDE OF BRIARGATE ROAD; THENCE SOUTH 66 DEGREES 03 MINUTES 42 SECONDS WEST ALONG THE NORTHERLY SIDE OF BRIA.RGATE ROAD, A DISTANCE OF 28.34 FEET TO THE POINT AND. PLACE OF BEGINNING. BEING ALL OF LOT NO.9 AS SHOWN ON THE ABOVE-REFERENCED MAP. SUBJECT TO RECORDED PROTECTIVE COVENANTS FOR KINGSBURG MANOR RECORDED IN MISC. BOOK 236, PAGE 318, IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY. SUBJECT NEVERTHELESS, TO A 20 FOOT WIDE SEWER EASEMENT AS SHOWN ON SAID ABOVE DESCRIBED PLAN. HAVING THEREON ERECTED A TWO (2) STORY SINGLE FAMILY DWELLING NUMBERED AS 4 BRIARGATE ROAD, MECHANICSBURG. BEING KNOWN IIAS: 4 Briargate Road Mechanicsburg, PA 17050 PROPERTY ID O.: 38-23-0571-037 TITLE TO SAID PREMISES IS VESTED IN JOSEPH P. BEIL, AS SOLE TENANT (DECEASED)BY DEED FROM JOSEPH P. BEIL AND LEANNE E. BEIL, HIS WIFE DATED 05/25/2001 RECORDED 06/07/2001 IN DEED BOOK 264 PAGE 424. 4 r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #7586U CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY`'HILL, NJ 08003-3620 856-669-5400 HSBC Mortgage Services, Inc. 'COURT OF COMMON PLEAS :CIVIL DIVISION Plaintiff :Cumberland County V. Leanne Beil, Executrix of the ::NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that they have served true and correct copies of the Notice of Sale upon the following person(s) named herein. at their last known address or their attorney of record. xxxxxx Regular First Class Mail xxxxxx Certified Mail other (certificate of mailing) Date Served: April 29, 2008 TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil c/o Lowell Gates, Esquire 1013 Mumma Road Lemoyne, PA 17043 UDREN LAW OFFICES, P.C. ?, BY: ._ -4 ?- Attorneys for,,V1 intif f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE --. 0 r Fj 0 0 r F1 No "'W 0 N M m ?. E FF--' N N ro w N (-t N- ? rt N 0 W N 0¢,N 0 X w N t-h (D WED 0 rt ?? D P- I'd N N- N Y 0 0 c j®v M M:* M z 0 z M C) 35 0 g o rn wonn`i0 5- 3D CERTIFIED MAIL. ??EC - rU j IlJ 90 CO For dcdive-ry U'U1 OFFICIAL USE CD; CD rq; ? r s °i° Ce0W Fee [/D ra ,? ` ` Postmark C3 C3 O ResMated ry Reg Fee ( WroM C3, C3 ? I ? Total Po$bW & Fees m!m TO Leanne Beil, Executrix .A I .0 of the Estate of Joseph P. Beil ,-.._._..._..Y._ r3 0: C3 or I p AXW. c/o Lowell Gates Esq. PO Box No. N - --° -- - °° 1013 Mumma Road ............... 1 Lemoyne, PA 17043 i N pia r y? C`-i.TGTW'RF 'L L tam ?? ? ? ? 1 6 to :7th 4#'F 7F?F?Cr:! ?; e )f r i I R ~? L408-000-ZO'06SL NSd ( 9002 i?gl'009E uuo? 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LL N m aa?cc i m R m h E E S •- N ? C7 ? O ? N h ? ? U ' o w v a m c H A E a ? e8?8H 2 4) E?Eo -cmi (/ALL 'x ?_Nri' o EE._o _ N 'a m _ m o_ o c ?mo?m O ? w N C fn LL E 2 o E m - m L ` N pL.. O voc mmn >. w C 6 m N W N Q' LL W N O S . N E'EL 'p t.r C 4 V ' mEo,:-Ea m V DOc m O ? c 9 p ' . X710 i A o mI c 0 m ? 6 t ? W U O F K y Ncl d 0 m.?- .. ?ly mcymt E E m'm v u WV?m ?.R23 k' ?? " .SEE E .? c ni .tJ ... 1)r -b. 5 __ °oa W c c $ c v? Y v c j P-' ?? E o o how ? it E c to C m mWnm3 m N 012 ? o 7 _ ro? E . Q> m a c c av o d C ' co%?c 0-2 'o m o Y N N m 5- m 4 t Utr ? ? m .9 4) W 2 Im? r a m S U ° E rn E N O d j a p ?mE? a y _ aUi y ? ? ? N U N E a R N LL O C W W o W e m a O ?d U Z 0 ? ? ? ? co E U) a E 2 Q ? J O v : O .O N V w E H M N E n o W cL y E o M ao* Q o W o ? a W CO N U. O O N C J U U) N N U) 0 cr U) N w a W Z V = a = m o WOW Z Q p p m ? ?3C) Q E c ch d w r m Z 0 o r-- . r J J r r N O m.0 C14 N 8 M a p 0E QZ o o o ID d C E ° cn ZaZ5 c 0 r CN M v LO Mo -? N M Q LO CO 1- O 0) r r-1 ri ro as H 0 x Li H w O 43 N A .d d 43 0 r-1 0 U 01 A +J q ?a ?i -ei \ O d? O? m ?4 r? N W n W 1+1 ?T4 W Qi c co L M U N co r O N O 00 O M a L a N w O 4- O O co N W N L 4- O X L U a> X W M N C C ca J r„? ca C `?- r< t':za +l ? ,,:? , s . , i1 ?? i -- ? ? CS1 t _ -;; '`s'. -v , ru r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS 577 Lamont Road :CIVIL DIVISION Elmhurst, IL 60126 :Cumberland County Plaintiff V. Leanne Beil, Executrix of the Estate of Joseph P. Beil :NO. 08-1262 Civil Term 4 Briargate Road Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULB 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: June 2, 2008 UDR Ph LAW OFF I CE P .. Ckm .. BY: afl JAA? ? Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 0 C?3 C- C= --n C7 C"~ C'a '-'f UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsOudren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 HSBC Mortgage Services, Inc., 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: 4 Briargate Road, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Leanne Beil, Executrix of the Estate of Joseph P. Beil 22 Royal Palm Road Mechanicsburg, PA 17050 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 HSBC Mortgage Services, Inc. 577 Lamont Road Elmhurst, IL 60126 Mortgage Electronic Registration Systems, Inc. P.O. Box 2026 Flint, MI 48501-2026 Manufacturers and Traders Trust Company, (The "Bank") Pramco III, LLC One M & T Plaza, Buffalo, NY 14240 ATTN: Office of General Council 230 Crosskeys Office Park, Fairport, NY 14450 6894 Pittsford-Palmyra Road 200 Crosskeys Office Park, Ste 230 Fairport, NY 14450 c/o Kalpin, Stewart, Meloff, Reiter & Stein PC 910 Harvest Drive, P.O. Box 3037 Blue Bell, PA 19422 5. Name and address of every other person who has any record lien on the property: Name Address Bureau of Compliance Dept. 280946, Harrisburg, PA 17128 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17103 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St. Carlisle, PA 17103 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 4 Briargate Road Mechanicsburg, PA 17050 Lowell Gates Esq. 1013 Mumma Rd, Lemoyne, PA 17403 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: May 30, 2008 UDREN LAW OFFICES, P.C. BY:G N IUTA ItIAX1 A AAAYAVLkA / Attorneys.for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF HSBC Mortgage Services, Inc. € COURT OF COMMON PLEAS Plaintiff € CIVIL DIVISION € Cumberland County V. Leanne Beil, Executrix of the Estate of Joseph P. Bell € NO. 08-1262 Civil Term Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Leanne Beil, Executrix of the Estate of Joseph P. Bell PROPERTY: 4 Briargate Road, Mechanicsburg, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on September 3. 2008, at 10:00 am, in the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, Pa. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A N .? y m qm G ? NLL H ? .T4+ o ar N N p 4D ?!y dN? O os 07 ^07 C R N N D 3 = _ N 5 °' oG 7 a? Q o Aq1 i r C?? y ? CCG YU 67 m QV N E c m °' L r 1 ?i C O C3 S, 6 0 • N ?C3 C] N N p?Z. w"O N z NJT 'Z W o l ,4 IL ci. o c tut i NNO E V ? uJ Y? z4 4 U-0 - z N od " ( N 3 '= p1 Z z v_ C ZQ at W Qp a OtS 4 o tp E ? h 6 mQ'1 ayp w Spp N m G IC! ? ?1 w ?J mw ?? ?46a ° ?m3mc c 0. ucl ?? ro s °o N 0 4D 1\4 1 o'SQ vm ?5_ o ? f.W8 °° c ri m ? 'Sc a?oEN v c ? rY m 0 n w rn c 0 LV- Id r y g w o O T N 4 ? r Q ro ? C: r st j V ?? C 04 N `m itoltvN j T N co ~t O mmo U. to < ? t0 fL to 6. o y C- N .i xq >> m cr) V o :1 - 0 G. U. I OC 6. us z ?zC' 3 c°o ?' oG QQ` m N ? U. 00 4ig to ?NN°' ° o a c'3 = o W d p7 yE J ? ? ?'j T ay ,d M C7 a N O m $ o ?? A U c m a r a °' O'T N ` r T 'r T N 1-o __l.! v to L ?ry Y U 1-4 N co V- O N O co O CD d H Q. H L Q- ( D (P H A ? w? y O m U ~ to A .. N W w a G) 0 W 06 A.- 61 4- N o d m a ? r ,0?• N c? T c ON ON '7+ s•+ s•+ d w r r M 0 w cn w Wl- O 7A O U N K W LO UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEN , ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 HSBC Mortgage Services, Inc. =COURT OF COMMON PLEAS € CIVIL DIVISION Plaintiff Cumberland County t - n-: Leanne Beil, Executrix of the NO. 08-1262 Civil Ted Estate of Joseph P. Beil , ;-„ De f endant (s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that they have served true and correct copies of the Notice of Sale upon the following person(s) named herein at their last known address -or their attorney of record. xxxxxx Regular First Class Mail xxxxxx Certified Mail Other (certificate of mailing) Date Served: April 29, 2008 TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil c/o Lowell Gates, Esquire 1013 Mumma Road Lemoyne, PA 17043 UDREN LAW OFFICES, P.C. BY: Attorneys for intiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE "-XHBIT g UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST-CORPORATE CENTER Ill WOODCREST ROAD, SUITE 2-00 CHERRY HILL, NJ 08003-3620 856-669-5400 HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS :CIVIL DIVISION Plaintiff :Cumberland County V. Leanne Beil, Executrix of the NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant (s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that they have served true and correct copies of the Notice of Sale upon the following person(s) named herein- at their last known address -or their attorney of record. xxxxxx Regular First Class Mail xxxxxx Certified Mail Other (certificate of mailing) Date Served: April 29, 2008 TO: Leanne Beil, Executrix of the Estate of Joseph P. Beil c/o Lowell Gates, Esquire 1013 Mumma Road Lemoyne, PA 17043 UDREN LAW OFFICES, P.C. BY: Attorneys for intiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORR.AINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE EXHIBIT B o or ro a ?' rn O d v ? oro 9y IA ? cr aW. OC o a co to 1-h M .a n W u G o - ro i O v y i '? rn o -04 lop v rrn- 0 :r :r l Poetw s -1 C,6j"d F" ?_ 0`1° _? ©'i, Q tMraav? pn y . . ? n Tow Posy & Fe" c/o r.+?""" I n pp gox Na lol H?'' , 4 ?t ?S t,t I Uri k ? ® 1 Wk l r EXNIBYI' B n ?F L406.000-EOO?L NBd ??kf1900Z i?N'OOB6 ?J Sd •IUlMml as beAem uega 11 po wd pee idlesw ipp wS UYJvodwl 4 md" Asm 0" pw{m app wend wa4wd 9' wwawd A4 saw m op -pre"lusam as , a! tdpow pn pooeJ M uo VW490d 8;1 ¦ Row"Jopto xA Lw eeeopsw eta wm Jo 4W eye ?M?pV ? 10 awe an (4 pew eq bew 6?eeAeP `eel Mu"Ppe ue JOA ¦ ei As= pew pwew jwA uo wwweod osdsn a Wpm emqpvb s ja Apps an a WOp cti •.PeMK1beN wpoeli `?" eoso wu eeropu3 *ew a•apd?e vpe p?a.pp+e`«p?a t«es vu? sd) e?u,a?a? a4eeepguoed wswoww rd 4mm p Jowa ep ,d o4 eq ?ewu UNM 9,9% ¦ see* 19ORMW ? 'MW P"M ? 0paspord 301AONd8 paoml 81 30Vd3A?OO nsN • 'pw PWPRU04 P seep Am A4 "*Wm JOU " MW P ¦ eMNI 4MM JD"MO-WW LW pm*pm e4 AM Asw MW pw>Ao ¦ :¦Mpt9¦MN M" CM M4 +W1eSWAOdanAgW"AmMppP eiV ¦ wwdMw ireA x4 joWjop~ V ¦ As= cumew V ¦ 3oplud clew 091WO3 Y EXHIBIT B = m to LL a O m w ? ro N LL r Ix m c y o m tl! p LL m ? x d so Q v ???p c amp N U Q ? Cl) ? rn U s m ? 3 ? N O ? G .. o• ?i a o ?'m 1 rn Vn ?Q =U Om •e d ? 0 ? m 7 to ? % LL Q ? ? Q 0 d d C w 'c d ' DO ? ? ? Q w m o a E m t • a d J U 0 D N O poi as N UrW..e? a r E d?C Q a ?L to W p" .? c :E ? m cn c 0 mO v ire 5 O F,. J Z m ;; N gpG? _ x us ` ? m , V? In's ?ppp= ? 0 CD pOt? a £ m J J z T m w w A ? 2 " O t4 I E si ate,, E?? aw ?m °c° E E. .E m til ? c o N co p n ?' m p W N mEoQ O C{G$ m W '? [• y 9 ` ry co 0 0 ? t O ? ? c o E 'F4• _ o ? ?ct Cr m?, °r $ $9 c v v 'S w ? Q1 m m? N s? ? M ? W Q ? m N ? Af a .? m O Q i 7 am? g n rn 00o=gym oo=?c? H 'w?i?v10? d y L W 2 W c!2 010 i% ^ Y+ mmIEI N 12 d o r { W ? , o O = v r III . m W a tp ? y y (D 0 L +r ? O n°. o? r o-2 O in g Via. N •O 'm 1n J O G T N - ? r T T .? Ur, ti OD ExHIBIT B N cr) X m O al U 4 K W w r- d r m 0 (D w c cn r- 04 f7 Mn C=- r ril .? - ? - t F? r i t Tf ? ., , rn COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which HSBC Mortgage Ser Inc is the grantee the same having been sold to said grantee on the 3rd day of September A.D., 202008, under and by virtue of a writ Execution issued on the 22nd day of April, A.D., 202008. out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 1262, at the suit of HSBC Mortgage Ser Inc against Joseph P Beil extrix is duly recorded as Instrument Number 200835303. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 0 day of A.D. -Z?e order of Deeds a400OW d Ondc Cun"Amd county, cvWg, PA * ONWWI i0o E*m Ow Fba MM*Y Of Jm. 2010 HSBC Mortgage Services, Inc. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Leanne Beil, Executrix of the Estate of Writ No. 2008-1262 Civil Term Joseph P. Beil Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2008 at 0800 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Leanne Beil, Executrix of the Estate of Joseph P. Beil, by making known unto Leanne Bed personally, at 22 Royal Palm Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copies of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 12, 2008 at 0843 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 Leanne Beil, Executrix of the Estate of Joseph P. Beil located at 22 Royal Palm Road, 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 defendant, to wit: Leanne Beil, Executrix of the Estate of Joseph P. Beil by regular mail to her last known address of 22 Royal Palm Road, Mechanicsburg, PA 17050. This letter was mailed under the date of July 2, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 3, 2008 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren, on behalf of Household Finance Consumer Discount Company. It being the highest bid and best price received for the same, Household Finance Consumer Discount Company, of 636 Grand Regency Blvd., Brandon, FL 33510, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $1,390.81. Sheriff s Costs: Docketing $30.00 Poundage 27.27 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 48.00 Auctioneer 10.00 Law Library .50 Prothonotary 2.00 Mileage 16.00 Levy 15.00 Surcharge 20.00 Law Journal 521.00 dam" Patriot News 578.90 -U? Share of Bills 17.64 pv h °? Distribution of Proceeds 25.00 Sn Sheriffs Deed 49.50 $1,105.37 l??p3f o??-? Cn- 44?? & -? 14G P9' So Answers: R. Thomas Kline, Sheriff BY"J ,4Y Real Estate rgeant UDRE,N LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF `MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. -MIFfA?B, -3VI1tE Ib #'y5860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 HSBC Mortgage Services, Inc., 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: 4 Briargate Road Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Leanne Beil, Executrix of the Estate of Joseph'P. Beil 4 Briargate Road Mechanicsburg, PA 17050 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 HSBC Mortgage Services, Inc. 577 Lamont Road Elmhurst, IL 60126 Mortgage Electronic. P.O. Box 2026- 'Registration Systems, Flint, MI 48501-2026 Inc. __ ___ Mnufaeturers and--Traders One -M & T Plaza, Buffalo, --NY--1-42-40 _ Trust Company, (The'"Bank") ATTN: Office of General Council Pramco III, LLC 230 Crosskeys Office Park, Fairport, NY 14450 5. Name and address of every other person who has any record lien on the property: Name- Address Bureau of Compliance Dept. 280946, Harrisburg, PA 17128 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Sq., Carlisle, PA 17103 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover St. Carlisle, PA 17103 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 4 Briargate Road Mechanicsburg, PA 17050 Lowell Gates Esq. 1013 Mumma Rd, Lemoyne, PA 17403 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: April 22, 2008 UDREN LAW OFFICES, P.C. BY:? "eq ' Attorneys fo aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE FOR PLAINTIFF-.-- HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Leanne Beil, Executrix of the :NO. 08-1262 Civil Term Estate of Joseph P. Beil Defendant(s) UDRZN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LDRRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CBANDRA M. ARKEMA, ESQUIRE - ID #203437 WDODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsoudren.com NOTICE OF SHERIFF'S SALE OF REAL PROPERTY T0: Leanne Beil, Executrix of the Estate of Joseph P. Beil 22 Royal Palm Road Mechanicsburgs, PA 17050 Your house (real estate) at 4 Briargate Road, Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on September 3, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $207,926.24, 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.) N '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_-Sheri-f f -'-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 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 ALL THAT CERTAIN PIECE OR PARCEL OF PROPERTY LOCATED IN THE TOWNSHIP OF SILVER SPRING COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED ON A CERTAIN MAP ENTITLED "PLAN OF KINGSBURY MANOR", DATED OCTOBER 26,1973, SCALE 1" - 50", SILVER SPRING TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, ERNEST J. WALKER, R.D. #4, MECHANICSBURG, PENNSYLVANIA", WHICH MAP IS FILED IN PLAN BOOK 32, PAGE 68, IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY AND BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERLY SIDE OF BRIARGATE ROAD AS SHOWN ON THE ABOVE REFERENCED MAP AT THE SOUTHEAST CORNER OF LOT NO. 8; THENCE NORTH 23 DEGREES 56 MINUTES 18 SECONDS WEST ALONG LOT NO. 8, A DISTANCE OF 218.44 FEET TO A POINT AT THE NORTHEASTERN CORNER OF LOT NO.8 AS SHOWN ON THE ABOVE REFERENCED MAP; THENCE NORTH 65 DEGREES 56 MINUTES 05 SECONDS EAST, A DISTANCE OF 127.26 FEET TO A POINT ON THE WESTERLY SIDE OF LOT NO. 11 AS SHOWN ON THE ABOVE REFERENCED MAP; THENCE SOUTH 23 DEGREES 15 MINUTES 51 SECONDS EAST ALONG LOTS NOS. 10 AND 11 AS SHOWN ON THE SAID MAP, A DISTANCE OF 203.39 FEET TO A POINT ON THE NORTH SIDE OF BRIARGATE ROAD; THENCE SOUTH 55 DEGREES 11 MINUTES 00 SECONDS WEST, ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD, A DISTANCE OF 64.65 FEET TO A POINT ON THE NORTHERLY SIDE OF . BRIARGATE ROAD; THENCE ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD ALONG THE CURVE TO THE RIGHT HAVING A RADIUS OF 175.00 FEET A DISTANCE OF 33.23 FEET TO A POINT ON THE NORTHERLY SIDE OF BRIARGATE ROAD; THENCE SOUTH 66 DEGREES 03 MINUTES 42 SECONDS WEST ALONG THE NORTHERLY SIDE OF BRIARGATE ROAD, A DISTANCE OF 28.34 FEET TO THE PONT AND. PLACE OF BEGINNING. BEING ALL OF LOT NO.9 AS SHOWN ON THE ABOVE-REFERENCED MAP. SUBJECT TO RECORDED PROTECTIVE COVENANTS FOR KINGSBURG MANOR RECORDED IN MISC. BOOK 236, PAGE 318, IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY. SUBJECT NEVERTHELESS, TO A 20 FOOT WIDE SEWER EASEMENT AS SHOWN ON SAID ABOVE DESCRIBED PLAN. HAVING THEREON ERECTED A TWO (2) STORY SINGLE FAMILY DWELLING NUMBERED AS 4 BRIARGATE ROAD, MECHANICSBURG. BEING KNOWN AS: 4 Briargate Road Mechanicsburg, PA 17050 PROPERTY ID NO.: 38-23-0571-037 TITLE TO SAID PREMISES IS VESTED IN JOSEPH P. BEIL, AS SOLE TENANT (DECEASED) BY DEED FROM JOSEPH P. BEIL AND LEANNE E. BEIL, HIS WIFE DATED 05/25/2001 RECORDED 06/07/2001 IN DEED BOOK 264 PAGE 424. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1262 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC MORTGAGE SERVICES, INC., Plaintiff (s) From LEANNE BEIL, EXECUTRIX OF THE ESTATE OF JOSEPH P. BEIL (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 $207,926.24 L.L. $.50 Interest FROM 4/23/08 TO DATE OF SALE 9/3/08 - ONGOING PER DIEM OF $36.72 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $4,920.48 Atty's Comm % Atty Paid $187.20 Plaintiff Paid Date: APRIL 22, 2008 (Seal) Due Prothy $2.00 Other Costs iieputy REQUESTING PARTY: Name LORRAINE DOYLE, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER I I I WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ J08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 Real Estate Sale #12 On May 2, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA cta Known and numbered as 4 Briargate Road, Mechanicsburg more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 2, 2008 By: \j _ , Lti Real Est to Sergeant Z i X01 d C Z bdtl 8002 ' -The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE the Patriot News Now you know CARLISLE PA 17013 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 Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 This ad ran on the date(s) shown below: 07/23/08 07/30/08 J 14 1 /`lid 08/06/08 Sworn to an ubscrib fore m this ay of August, 2008 A.D. r Notary Public COMMONWEALTH _OF_ PENNSYLVANIA 40twtN s" &WHO L K WW, NoWy Public C Y aMio %W^ I &4ft counq I* CM M W Soft Nov. 20, 2091 McMK, Pannsyh?06 Alud0on of Nobwft Real Estate Sals No. 12 Writ No. 2008-1282 Clvil Tenn HSBC Mortgage services, Inc. vs Leanne WI, Executrix of the Estate of Joseph P. Bail Attorney Mark Udren LEGAL DESCRIPTION ALL THAT CERTAIN PIECE OR PARCEL OF PROPERTY LOCATED IN THE TOWNSHIP OF SILVER SPRING COUNTY OF CUMBERLAND ANDCOMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED ANDDESCRIBED -ON A CERTAIN MAPENTiTLED "PLAN OF KINGSBURY MANOR", DATED OCTOBER 26, 1973, SCALE I" - 50", SILVER SPRING TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, ERNEST I. WALKER, R.D. f4, MECHANICSBURG, PENNSYLVANIA", WHICH MAP IS FILED IN PLANBOOK 32, PAGE68, IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY ANDBEING MORE PARTICULARLY BOUNDED ANDDESCRIBED AS FOLLOWS: BECrIl RW AT A POINT ON THE NOkLY SIDEOF BRIARGATE ROADAS SHOWN ON THE ABOVE REFERENCED MAPAT THE SOUTHEAST CORNER OF LO?INO.8; THENCE NORTH 23 DEGREES 56 MINUTES IS SECONDS WEST ALONG LOTNO.8, A DISTANCE OF 218.44 FEET TO A POINT AT THE NORTHEASTERN CORNER OF LOTNO.'8 AS SHOWN ON THE ABOVE REFERENCED MAPTHENCE NORTH 65 DEGREES 56 MINUTES05 SECONDS EAST, A DISTANCE ')F 127.25 FEET TO A POINT ON THE WESTERLYSIDEOF LOTNO. 11 AS SHOWN ON THE ABOVE REFERENCED MAPTHENCE SOUTH 23 DEGREES 15 MINUTES 51 SECONDS EAST ALONG LOTS NOS. 10 ANDI I AS SHOWN ON THE SAID MAP, A DISTANCE OF 203.39 FEET TO A POINT ON THE NORTH SIDEOF BRIARGATE ROADTHENCE SOUTH 55 DEGREES 11 MINUTES 00 SECONDS WEST, ALONG THE NORTHERLY SIDEOF BRIARGATE ROAD, A DISTANCE OF 64.65 FEET TO A POINT ON THE NORTHERLY SIDEOF BRIARGATE ROADTHENCE ALONG THE NORTHERLY SIDEOF BRIARGATE ROADALONG THE CURVE TO THE RIGHT HAVING A RADIUS OF 175.00 FEET A DISTANCE OF 33.23 FEET TO A POINT ON THE NORTHERLY SIDEOF BRIARGATE ROADTHENCE SOUTH 66 DEGREES 03 MINUTES 42 SECONDS WEST ALONG THE NORTHERLY SIDEOF BRIARGATE ROAD, A DISTANCE OF 28.34 FEET TO THE POINT ANDPLACE OF BEGINNING. BEING ALIAF LOTNO. 9 AS SHOWN ON THE ABOVE-REFERENCED MAP. SUBJECT TO RECORDED PROTECTIVE COVENANTS FOR KINGSBURG MANOR RECORDED IN MISC. BOOK 236, PAGE318, IN THE OFFICE OF THE RECORDER OF DEEDSFORCUMBERLANDCOUNTY. SUBJECT NEVERTHELESS, TO A 20 FOOTWIDESEWER EASEMENT AS SHOWN ON SAID ABOVE DESCRIBED PLAN. HAVING THEREON ERECTED A TWO (2) STORY SINGLE FAMILY DWELLING NUMBERED AS 4 BRIARGATE ROAD, MECHANICSBURG. BEING KNOWN AS: 4 Briargate Road, Mechanicsburg. PA17050 PROPERTY ID NO.: 38-23-0571-037 iTLE TO SAID PREMISES IS VESTED IN JOSEPH P. BELL, AS SOLE TENANT (DECEASED) BY DEED FROM JOSEPH P. BELL AND LEANNE E. BEII., HIS WIFE DATED 05125/2001 RECORDED 06/07!2001 IN DEED BOOK 264 PAGE424. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 18, July 25, and August 1, 2008 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. 6-?? a Marie Coyne, r SWORN TO AND SUBSCRIBED before me this day of August. 20008 GEC. Notary NOWIAL SEAL DlIOUN A COLUNS Notary PUb#C CAkW IM, CUMUMANp COUNTY MY CemlrMM &Pk t Apt 28.2010 Writ No. 2008-1262 Civil HSBC Mortgage Services, Inc. vs. Leanne Beil, Executrix of k the Estate of Joseph P. Beil Atty.: Mark Udren ALL THAT CERTAIN piece or parcel of qty 1 ttt the of .p ° r spy County and C:*ealth bounded and de gibed on particularly map entitled aPlan of Kingsbury; Manor", dated October 26, 1973, scale 1 "-50", Silver Spring Township,; Cumberland County, Pennsylvania Ernest J. Walker, R.D. #4, Mechan-, icsburg, Pennsylvania", which map, is filed in Plan Book 32, Page 68, inI the Office of the Recorder of Deeds for, Cumberland County and being more particularly bounded and described as follows: BEGINNIAu at a point on the northerly side of Briargate Road as shown on the above referenced map at the southeast corner of Lot No. 8; thence North 23 degrees 56 minutes 18 seconds West along Lot No. 8, a distance of 218.44 feet to a point at the northeastern corner of Lot No. 8 as shown on the above referenced map; thence North 65 degrees 56 minutes 05 seconds East, a distance of 127.26 feet to a point on the westerly side of Lot No. 11 as shown on the above referenced map; thence South 23 degrees 15 minutes 51 seconds East along Lots Nos. 10 and 11 as shown on the said map, a distance of 203.39 feet to a point on the north side of Briargate Road; thence South 55 degrees 11 minutes 00 seconds West, along the northerly side of Briargate Road, a distance of 64.65 feet to a point on the northerly side of Briargate Road; thence along the northerly side of Briargate Road along the curve to the right having a radius of 175.00 feet a distance of 33.23 feet to a point on the northerly side of Briargate Road; thence South 66 degrees 03 minutes 42 seconds West along the northerly side of Briargate Road, a distance of 28.34 feet to the point and place of beginning. BEING ALL OF LOT NO. 9 AS SHOWN ON THE A13OVE-REFER- ENCED MAP. SUBJECT to recorded protective covenants for KinPburg Manor re- corded in Misc. Book 236, Page 318, in the office of the Recorder of Deeds for Cumberland County. SUBJECT nevertheless, to a 20 foot wide sewer easement as shown on said above described plan. HAVING thereon erected a two (2) story single family dwelling num- bered as 4 Briargate Road, Mechan- icsburg. BEING KNOWN AS: 4 Briargate Road Mechanicsburg, PA 17050. PROPERTY ID NO.: 38-23-0571- 037. TITLE TO SAID PREMISES IS VESTED IN Joseph P. Beil, as sole tenant (deceased) by deed from Jo- seph P. Beil and Leanne E. Beil, his wife dated 05/25/2001 recorded 06 /07 /2001 in Deed Book 264 Paee