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HomeMy WebLinkAbout08-2137r 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 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. Richard T. Huntsberry n _ P.O. Box 152 NO. Rockland, ID 83271 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 717-249-3166 800-990-9108 MAY 22M q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION HSBC Mortgage Services, Inc. '-COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Richard T. Huntsberry Defendant(s) ":NO. 08-2137 Civil Term O R D E R AND NOW, this 2 3':? day of rr"01 2008, upon r D consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Richard T. Huntsberry, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Richard T. Huntsberry at P.O. Box 152, Rockland, ID 83271, and also at 136 Idaho Street, American Falls, ID 83211 and by posting the mortgaged premises located at 619 Market Street, New Cumberland, PA 17070. BY THE COURT: t 1 o - ?1,.L n r, fln 1 :01W cZA w8 Q1 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 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 I , 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: 619 Market Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of New Cumberland COUNTY: Cumberland DATE EXECUTED: 10/14/05 DATE RECORDED: 10/18/05 BOOK: 1927 PAGE: 1028 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 3/18/08: Principal of debt due $123,208.33 Unpaid Interest at 7.519. from 10/1/07 to 3/18/08 (the per diem interest accruing on this debt is $25.35 and that sum should be added each day after 3/18/08) 4,309.50 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $ 161.46 and that sum should be added on the first of each month after 3/18/08) (202.20) Late Charges (monthly late charge of $43.91 should be added in accordance with the terms of the note each month after 3/18/08) 271.67 Attorneys Fees (anticipated and actual to 50 of principal) 6,160.42 TOTAL $134,352.72 * This interest rate is subject to adjustment as more fully set forth in the Note and Mortgage. 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania I 1 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 $134,352.72 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 or 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 CERTADV lot of land situtate in the Soroutgh of New Cumberland Cumberland County, Pennsylvania. bounded and described as follows: BEGAMING at a point in the inteu=don of the southerly time of seventh Sheet with easterly lim of Marker Street; thence eastww4ly along the southerly line of Severuh Street .one Awdred rmt Vhl (128) fwt to the iitoa of a 30 fut w4s allay; thattra mulhw& JIX akag AC, »iwiw ly line of said alley MOW-t" MOM to a PW on the tine of lands now or late of John M. ZtAtn'aernfQn; thence westwardly dQid.tanda on hundred tweytry-eight (128) feet to the easterly litre of Markat Street: thence northward* along the eaarsrly kne of Amriwt Street thiffy ri o (32) feet to a point, the place ofBEGA HAVM 27r"©N ERECTED a two and one hal(stary brick dwelling known as u319114arket Streer, New Ctentbertand, Fennsyl?rtia. BEING the mum pwaises which John 3. Rant, Ill, $ftle elan, by deed dated January 24, 1997, and recanted January 28,1997 in d+a O ce o}'the Reooroder of Dee& in and for pmberlaW Goan Y. Pmwybwdo in Deed Bach 1S2, Page 70S, granted and maweyedCanto hWrry C Pfef er, JU,, mu l Patric to 4. Koffinger, now by marriage Patricia A. Pfef gr, Granrors herein. S r HSBC Ql 636 Grand Ragency Blvd Brandon, R 33510 1111111111111111111 71067112169003897859 * 0167944 000003024 01dnS3 0060110 617 Richard T Huntsberry 619 Market St New Cumberland PA j17070 -1945[ 1 )1111)III/I)IIIEItItII)IIIIIIIIIEI11tIliIElfliflillllllltl)III 01102/2008 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. i To see if HEMAP can help, you must MEET WITH ACONSUMER 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 ACONTINUAR VIVIENDO ENSU 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 t t HOMEOWNER' S NAME(S): PROPERTY ADDRESS: ACCOUNT NUMBER CURRENT LENDER/SERVICER RICHARD T HUNTSBERRY 619 MARKET STREET NEW CUMBERLAND PA 1 7070-1 945 0012237970 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 IFYOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BYTHE 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' sEmergency 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 at the 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. + 0167944 000003024 01N0S3 0060110 617 •_ f , 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) NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: ' 619 MARKET STREET NEW CUMBERLAND PA 17070-1945 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS. You are due and owing approximately $878.37 a month. You are past due since 11/01/2007. Other fees may have also accrued on your account. a TOTAL AMOUNT PAST DUE: $3747.06 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 $3747.06, 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 . + 0167144 000003024 01441iS3 0060110 617 A- 1 , 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 attorney s fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney' 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 Sherif sSale. You may do so by paying the total amount past due, plus any late or other charges due, reasonable attorney' 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: 813-571.8680 Contact Information: Loss Mitigation Department EFFECT OF SHERIFF' SSALE -You should realize that a Sheriff sSale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff 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. . 9167944 00UUUH024 01H"S3 0060110 617 L f1 0 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. f? FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE tl 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 f? debt is valid. If you notify this office in writing within thirty (30) days from receiving this imp 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 IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ENCLOSURE: Validation of Debt Notice ? 0567944 000003024 DIMM13 0060310 617 6 . • 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 notifies 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 ADEBT 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: 01/02/2008 HSBC Mortgage Services 636 Grand Regency Blvd. Brandon, FL 33510 (800) 365-6730 www.hsbanortgageservioes.com 4 0367944 000003024 09NOS3 0060310 617 1. • V E R I F 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. UDREN OFFI S, P.C. BY: 1 Attorn s fo Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -%--LOUIS A. SIMONI, ESQUIRE 00 O ! 1 6 SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02137 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS HUNTSBERRY RICHARD T 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 HUNTSBERRY RICHARD T but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT 619 MARKET STREET NOT FOUND , as to HUNTSBERRY RICHARD T NEW CUMBERLAND, PA 17070 PROPERTY APPEARS TO BE VACANT. PER POST OFFICE, ADDRESS IS 136 IDAHO ST AMERICAN FLS, ID 83211-1234. Sheriff's Costs: Docketing 18.00 Service 18.00 Not Found 5.00 Surcharge 10.00 .00 5 So answe R. Thomas-Kline Sheriff of Cumberland County UDREN LAW OFFICES 04/16/2008 Sworn and Subscribed to before me this day 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, pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Richard T. Huntsberry Defendant(s) :NO. 08-2137 Civil Term MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, moves this Honorable Court for an order directing service of the Complaint in Mortgage Foreclosure upon Defendant(s), Richard T. Huntsberry by regular mail and certified mail and by posting the mortgaged premises and in support thereof avers the following: 1. The last known address of Defendant(s) is P.O. Box 152, Rockland, ID 83271. 2. Process was unable to be served at P.O. Box 152, Rockland, ID 83271, because service could not be made at such an address. 3. Process was also unable to be served at 619 Market Street, New Cumberland, PA 17070, which is the mortgaged premises. A copy of the Return of Service is attached hereto as Exhibit A. 4. The Sheriff's Department provided the Plaintiff with an alternate address. Process was also then unable to be served at 136 Idaho Street, American Falls, ID 83211. A copy of the Return of Service is attached hereto as Exhibit B. 5. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit C. 6. Said investigation was unable to determine an alternate address for said Defendant(s). WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage Foreclosure upon said Defendant(s), Richard T. Huntsberry by regular mail and certified mail and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. 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. 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 .Cumberland County V. Richard T. Huntsberry Defendant(s) :NO. 08-2137 Civil Term MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE : A sheriff ' s return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit A and B, the Sheriff and/or Process Server has been unable to serve the Complaint in Mortgage Foreclosure at the Defendant's last known address. Although Plaintiff is still unable to determine the Defendant's whereabouts, a good faith effort to discover the whereabouts of the Defendant(s)has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit C. WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint in Mortgage Foreclosure upon Defendant(s) by regular mail and certified mail and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-02137 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS HUNTSBERRY RICHARD T 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 HUNTSBERRY RICHARD T but was unable to locate Him in, his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 619 MARKET STREET NOT FOUND , as to HUNTSBERRY RIC4ARn T NEW CUMBERLAND, PA 17070 PROPERTY APPEARS TO BE VACANT. PER POST OFFICE, ADDRESS IS 136 IDAHO ST AMERICAN FLS, ID 83211-1234. Sheriff's Costs: So answt;:s-:_,_ --+ Docketing 18.00 Service 18.00 --?"` Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 51.00 UDREN LAW OFFICES 04/16/2008 Sworn and Subscribed to before me this day of A.D. F t L .: U ' a,1 I ryr i n n .1 f, P I',, i 11 1 berth k TH0149X5 KLINE &+iff ti RON,NY R ANDERSON EDWARD L- SCHORPP Chief Deputy Soi3Cltor JODY S, SMITH OFFICE OF THE SHERIFF Real Estate Sergeant One Courthouse Square Cartisla, Permsylvania 1701 a Tor Fo »ter ? A gerrcy Coutcol b.< Datc: Address Informatiozt Roque -s Please furnish this agency '%ith the new address, if available, for the following individuai or verify the address given below is one at which mail for this individual is currently being delivered, If C `vhetbtz following address is a post office box, please iurmish the strtet address as ecarded on the box holder's aPplication farm Name: 1('yt. ice{ 77 ry rt Last Kswwn Address: / A/a I certify the address information for this individual is required for the Performance of this agency's official (Signature of Agency Off=c:al) Or) () Mail is delivered to address given. (} Not Known at Address Given () Moved, ,eft No Forwarding Address ( ) No Such Address For Post Office .Use Only New Address ? FL S l 3 2 / / -12 () Other (specify) Box holds: s' Street address. Agen? c :,; Address PastmarkD to sujq> Please fax results to tl:e Cumberland Count Address Inforrriation R y Sheriff's OFficc, i\'urnbe r (717)2 qQ_ equest (Required format) - 6392 Exhibit 352.44b `,i-nga=ec Servico. Inc. M af.. Plaintifffy I2icAN T Ilunhbergz out al. I'lefendanttsl 11 DREN LAW CWFKTS Ms.'ykki Phan 111 !l -0 St Ind. Ste 201) C h rr\ Hill, \ i 1161103-30211 Sern ice -of Process by APS Internat c al, IA(L 1 -1300-32 8-7171 PS lFaternationaal Plaza 7MM Glenrnp Rmd "tli tnewopolis, MN 554392122 .?ePS rile 0: 089"10 ?M] AFFIDAVIT OF DU-H, AND EHUGENTATTEDAPT Sers ive of Process on: --Richard T. F1FPFat0wrry (Vurt Me W OW 2 L37 (I st ss. _ cciunt? of-, CV,ame of Scrvrr: - tttrderslun€ d_ being dale sw5zrra d. ? ;_> that at all wis _;ttit wd taertr w s le taus of le-gal age and tats not a pan; 1A WWI; Moments Served: the and E. A arm17wd t4 wrvc M Murnetrts d uv rihed as: Complaint in Niortgage Foreclosure wer, ice of Process on: The undersigmed stteillpter to sere the docunwms on Richard T. Hutttshvrrc am . tur due an.. .. _?r' tmab _ _ AlteiMPIS: Th, IN IM, ltiz- a A A i n dit[ [`I . 713du Lo 4 0A A orrice: dace, s.? .c AFre,ra rF cl_ IN Id ah" Street. _ rneHmn ra:IV. M 4 = 141234 r a t< ? 2 n, u on" Mum n& r ? ? , F K,,, Q nr N,it!-" tlate?'t'ica,i,:lclttress ,t [Ft aP,i;Feat: Reasin; for N(m) ser, ice: Based upon the above stated facts WN-il h lieges the defendant is avoiding service. Signature crf_tierver: ?'-tlc`larsr<?11t ! ._-' l^}r_S tltade" p:ftalt? that A lorcpcir, , is irue mul eUr=L r , 5 /r Al's International, Lt(I. ')ub,ribed an,2 tia? ilti day .20 e'a"t Public -? 6r-01-08 02:16pm Fros-Player's Association 636 230 0558 T-469 P.005/029 F-214 PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 08030339-1 Attorney Firm: MARK J UDREN & ASSOCIATES Case Number: Subject: Richard Huntsberry A.K.A.: Richard T Huntsberry Property Address: 619 Market Street New Cumberland, PA 17070 Last Known Address: PO Box 162 Rockland, ID 83271 Last Known Number: ( ) - Melissa Brower, being duty sworn according to law, deposes and says: 1. 1 am employed in the capacity of location Specialist for Players National Locator. 2. On 04101/2008, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NU48ER(S):216-62.9693 B. EMPLOYMENT SEARCFf We were unable to verify current employment for Richard Huntsbeny. 0. INQUIRY OF CREDITORS: Creditors Indicated the last reported address for Richard Huntsbar y is PO Box 152, Rockland, ID 83271 with no valid home number. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: Directory assistance does not have a listing for Richard Huntsberry. We spoke with a relative at 541:772-8863 who stated Richard is living Is Idaho, but did not have a forwarding address. INQUIRY OF NEIGHBORS - We were unable to contact any neighbors who could verify any information for Richard Huntsberry. INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of March 28,1008 tie National Change of Add" (NCOA) has no change for Richard Huntsberry from 619 Market Streets 969; Cumberie_ d, PA 17070. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: We were unable to verify current drivers license Information for Richard Huntsberry. OTHER INQUIRIES - A. DEATH RECORDS: As of March 28, 2008 the Social Security Administration has no death record on file for Richard Huntsberry and/or A.K.A's under the social security number provided. EXHIBIT C Apr-01-08 02:16pm From-Player's Association 636 230 0558 T-469 P.006/029 F-214 B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None Found. C. COUNTY VOTER REGISTRATION: We were unable to confirm a listing with the County Voters Registration Office. ADDITIONAL INFORMATION ON SUBJECT - A. DATE OF BIRTH: April 1958 AFFIANT Melissa Subscri t d d SW KrLc ine M. Scott, Notary Public St Louis County, State of Missouri My Commm"n Expires 91212010 P B ( Cornmfasion Number 06428865 Players National Locator 174 Clafton Road, Ste 225 ElWN&, MO 63011 (536)230-9922 (636)230-0558 r VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to take this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. Date: May 20, 2008 UDREN LAW OFFICES, P.C. BY : Zja?2?4/ *lL ? i/7 i 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. 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 :Cumberland County V. Richard T. Huntsberry Defendant(s) NO. 08-2137 Civil Term CERTIFICATE OF SERVICE I, hereby certify that I have served true and correct copies of the attached Motion For Special Service upon the following person(s) named herein at their last known address or their attorney of record by: X Regular First Class Mail Certified Mail Other Date Served: May 20, 2008 TO: Richard T. Huntsberry P.O. Box 152, Rockland, ID 83271 and 136 Idaho Street, American Falls, ID 83211 and 619 Market Street, New Cumberland, PA 17070 UDRENNLAW OFFICES, P.C. BY: 1 Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE w 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 Plaintiff :CIVIL DIVISION .Cumberland County V. Richard T. Huntsberry ::NO. 08-2137 Civil Term Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: June 2, 2008 UDRENAW'4&4? LAW OFFICES, P.C. BY: ?' Att6rneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION HSBC Mortgage Services, Inc. COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Richard T. Huntsberry Defendant(s) :NO. 08-2137 Civil Term O R D E R AND NOW, this .13'1 day of IF 2008, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure and all subsequent pleadings on Defendant(s), Richard T. Huntsberry, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure and all subsequent pleadings by certified mail and regular mail to the last known address of Defendant(s), Richard T. Huntsberry at P.O. Box 152, Rockland, ID 83271, and also at 136 Idaho Street, American Falls, ID 83211 and by posting the mortgaged premises located at 619 Market Street, New Cumberland, PA 17070. BY THE COURT: J. TRUE COPY FROM RECORiwi 11 Testimony whemot, I here unto at my heir: )d the eeu of sold Court at CArINMr, Pit. Rr?flIOIII1Mrl1 C 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 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 r. "'-, Plaintiff Cumberland County ?z V. "?F a1 Richard T. Huntsberry P.O. Box 152 NO. 03 L?lvl?'- Rockland, ID 83271 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 717-249-3166 'J 800-990-9108 0'fo 303-??-'/ ?j G ? m ?? ' c.... ? Q , ,??"?'„ ' acs .r '' ?c_. ?"' ? ?; ? ? L ? ? ? { ? ? + CASE NO: 2008-02137 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS HUNTSBERRY RICHARD T KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HUNTSBERRY RICHARD T the DEFENDANT , at 1814:00 HOURS, on the 9th day of June 2008 at 619 MARKET STREET NEW CUMBERLAND, PA 17070 by handing to POSTED PROPERTY AT 619 MARKET STREET NEW CUMBERLAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Posting Surcharge &/Jvor 4- 18.00 17.00 6.00 10.00 00 51.00 So Answers: R. Thomas Kline 06/09/2008 UDREN LAW OFFICES Sworn and Subscibed to By: before me this day of A.D. .,0 .'V' 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 :Cumberland County V. Richard T. Huntsberry Defendant(s) NO. 08-2137 Civil Term VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter he mailed a true and correct copy of the Complaint in Mortgage Foreclosure to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant (s) as follows: DATE MAILED: Richard T. Huntsberry P.O. Box 152, Rockland, ID 83271 and 136 Idaho Street, American Falls, ID 83211 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. Dated: ?.X ll I t UDREN LAW OFFICES P.C. BY: 0al dly? ? Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE u y a C7• 00 s jp O O ?a C7 -'M mm *CO Z ?°OC =vp? z 0M `9:-Pipm Dm C7 m-0 O ?? ru . . r-9' i -- -0 -0 c A tv ? ? - 43 ! CO Postage $ o ; o CerdW Fee C3' O p p Retum Recelpt Fee r 3l (Endorsement Required) C3r-3 Restricted Delivery Fee (Endorsement Required) Di C3 ru ! ru O O Tote) & Fees Postage $ m m Sent O O ?.? a o - Ufreet,. .. or P° awr No. - ----------- ' t a L ,A ? r)M m Ow6 ?l r ? rv ? 17w . ? m O V? n C? m M e? rrr 0 Poshnark Here ?/{' n fV X J. i t .. LIJ C] • I ID Y0UB-000•.Z0ESL• NSd (ef+e^ )9002 i6'00?£ lwo? 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