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HomeMy WebLinkAbout08-5744 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 C RA M. ARKEMA, ESQUIRE - ID #203437 OUIS A. SIMONI, ESQUIRE - ID #200869 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 961 Weigel Drive :CIVIL DIVISION Elmhurst, Il 60126 Plaintiff ::Cumberland County v. Donna Crockett 111 South High Street NO. Sl qq Mechanicsburg, PA 17055 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 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 demands 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 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: 11 South High Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 11/20/06 DATE RECORDED: 2/4/06 BOOK: 1975 PAGE: 386 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: i i (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 9/13/08: Principal of debt due $125,783.77 Unpaid Interest at 9.5% from 5/1/08 to 9/13/08 (the per diem interest accruing on this debt is $32.74 and that sum should be added each day after 9/13/08 4,452.64 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy late charge of $53.81 should be added in accordance with the terms of the note each month after 9/13/08 161.43 Attorne s Fees (anticipated and actual to 5% of principal)' 6.289.19 TOTAL $137,292.03 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 faded 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 $137,292.03 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN 'L6 , 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 -a I ALL THAT CERTAIN Lot of Ground situate on the Eat sick of South Nigh Savet, in the Borough of Meahsaicsb & in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit; IR V WG T NG at a point on ilia building lime of said South High Stet and at *e nortbem line of Stouffer Alley , thence in a Northwardly direction along the building line of sand South High Street fourteen and ono-tenth (14.1) feet to an iron pia at corner of other lot of the Grantor hwein, of which this is a parr; thence in an Eastarardly direction along said lot of the Grantor herein and through to per line of a double F 1 , dwelling house erected on the lot of W=nd lurch ? coatvayed and on the lot of ground 4& ant &uvAa an, ft North, sad buyaarl, aed airs (13.6) font to on iron pin on floc Hue of Charies E. Diener and Virginia M. Dia=,*his wife; thme in a Southwatdiy direction along the lino of lot of add Charles E. Diener and Virginia M. Diener. his wife, ftutcan and two-tenths (14.2) feet to an iron pan on the northern line of Stouffer Alley aforesaid; thence in a Wes twaadly dizaction along the mart m line of said Stouffer Alley My-two (52) fret to a point an the building line of said South High Street and at tie place of BEGINNING. HAVING erected thereon the Southem buff of a double frame dwelling house, known as No. I 1 South High Street, Mee nib&,Pennsylvania. BRING the some Premises conveyed by Diane L. Trimmer, Russell C, Trimmer, Robin E. Kohila=, Kimberly M. Barnes, and Heidi C. S Ahmecr, by Dped dated July 1, 1998, and reaotted July 13, 1998, in the Office of the Recordear of Doods in and for Cumberland County in Record Book 181, Page 228, to Ricbard T. Beam, Grantor herein. Minbeth Beam join`s in this conveyance to adWgd& any ittterest he may bave in the subject pcopetty as spouse of Richard T. Beam, Grantors bewim UNDER AND SUBJECT, NRVERTHELESS, to tia one-fourth part of all . necessary charges and extpaa ses which shell front time to me a=m m monsaimna upk eeping, amending. repairing and cleaning fbe said sower, sinkwell, carpool, or drain. UNDER AND SUBJECT to any existing covenants, casements, euct?oachmeats, w,udltlom mstriedms, and agraemanix affcting flu; p opo y, vier'ble or of tveord. 07/31/08MSCH06170010016050451PA Cert breach act 6 and 91 ma 07/31/08 DONNA CROCKETT 11 S HIGH STREET MECHANICSBURG PA 17055-6347 COMBINED ACT 91/ACT 6 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that default. and the lender intends information about the nature of attached pages. the mortgage an your home is in to foreclose. Specific the default is provided in the 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 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 MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A 07/31/OBMSCH06170010016060451PA Cert breach act 6 and 91 ma r HOMEOWNERS NAME(S) : DONNA CROCKETT PROPERTY ADDRESS: 11 S HIGH STREET MECHANICSBURG PA 17055-6347 ACCOUNT NUMBER: 0016060451 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 Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county 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. 07/31/OSMSCH06170010016060451PA Cert breach act 6 and 91 ma 1.. 0 APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pa es for specific information about the nature of your default . If you have tried and are unable to resolve this problem with the lender. you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so. you must fill out. sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have the applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR 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 mortggage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time. no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. * NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A * PETITION IN BANKRUPTCY. THE FOLLOWING PART OF THIS NOTICE * IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED* * AS AN ATTEMPT TO COLLECT THE DEBT. * (If you have filed bankruptcy you can still apply for * Emergency Mortgage Assistance.) **************************************************************** 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: 11 S HIGH STREET MECHANICSBURG PA 17055-6347 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS. You are due and owing approximately 1076.30 a month. You are past due since 06/01/08. Other fees may have also accrued on your account. TOTAL AMOUNT PAST DUE:$ 2314.03 07/31/O8MSCHO6170010016060451PA Cert breach act 6 and 91 ma ? 4 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 $ 2314.03. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: HSBC Mortgage Services P. 0. 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 mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys. but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However. if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender, even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not cured the default within the THIRTY (30 DAY period and foreclosure proceedings have begun, you sti 1 have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the the foreclosure sale and any other costs connected with the the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately five months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. 07/31/08MSCH06170010016060451PA Cert breach act 6 and 91 ma l-. 4 . 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: 800-365-6730 Fax Number: 813-571-8680 Contact Information: Loss Mitigation Department EFFECT OF SHERIFF'S SALE You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale. a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. provided that all the outstanding payments. charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: - TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. - TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. - TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. - TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. - TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. 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. 07/31/OSMSCH06170010016060451PA Cert breach act 6 and 91 ma A 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 judgment and mail you a copy of such judgment or verification. You are also advised that any 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 THIS PURPOSE. Enclosure: Validation of Debt Notice 6.17 07/31/08MSCH06170010016060451PA Cert breach act 6 and 91 ma 1 _ . 1 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 Judgment against the consumer and copy of such verification or Judgment will be mailed to the consumer by the debt collector; and (3) upon the consumer's written 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 you c have B any Mortgage questions Services or c concerns. notice free should contact of this Date: 07/31/08 HSBC Mortgage Services 636 Grand Regency Blvd. Brandon, FL 33510 (800) 365-6730 www.hsbcmortgageservices.com V E R I F I C A T 1 ,0 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 unaers3.giieu 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 P.C. 01 BY: Attorneys for aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE '-IOUIS A. SIMONI, ESQUIRE gJ G N-A n r-- C=) -n CX7 cn r? fTl rn N ' SHERIFF'S RETURN - REGULAR CASE NO: 2008-05744 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS CROCKETT DONNA GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon I t" nnovvrrrr r?nr.rnTn the DEFENDANT , at 0013:28 HOURS, on the 3 at 11 SOUTH HIGH STREET MECHANICSBURG, PA 17055 by day of October , 2008 nding to OF DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 r' Service 10.00 Affidavit 00 Surcharge 10.00 R. Thomas line ?v? u4?oY .00 38.00 10/07/2008 UDREN LAW OFF ICES Sworn and Subscibed to By: ?Z- -242&J-X 14 before me this day Deputy Sh ff of A.D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. WREN, 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 961 Weigel Drive :CIVIL DIVISION Elmhurst, I1 60126 ::Cumberland County Plaintiff V. :NO. 08-5744 Civil Term Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Defendant(s) SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Donna Crockett has filed Chapter 7 Bankruptcy in the Middle District of Pennsylvania on October 24th 2008, Bankruptcy Case No. 08-03920. UDREN LAW OFFICES,, P.C. BY: Atto-rrey-s-for `iL?a ntiff MARK J. UDREN, -ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE b-2 OG ??? ?..:, CS') ?? ?',?a 5 i?3 4 ? E.f.Y f '? ??; .[-1 .^C. j IjDREN 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 pleadings@udren.com HSBC M ATTORNEY FOR PLAINTIFF ortgage Services, Inc. :COURT OF COMMON PLEAS 961 Weigel Drive :CIVIL DIVISION Elmhurst, Il 60126 :Cumberland County Plaintiff ;MORTGAGE FORECLOSURE V. Donna Crockett NO. 08-5744 Civil Term 11 South High Street Mechanicsburg, PA 17055 De f endant (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) Donna Crockett 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 Plaintiffs damages as follows: As set forth in Complaint $137,292.03 Interest 9,036.24 From P 9/14/08 Complaint to n 6/16/09 Late charges per Complaint 538.10 From 9/14/08 to 6/16/09 TOTAL $146.866.37 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: 1,;?'-a Attorneys?or 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 : (o?/C9?09 PRO P OTHY i! UDR:EN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LOP-MINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHA.MRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 corn HS BC Mortgage Services Inc. Plaintiff V. Donna Crockett Defendant(s) TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Date of Notice: June 3, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 08-5744 Civil Term YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 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 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT LECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR TH SAN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE U ED IFO THAT PURPOSE. MaLr, a uaren, Esquire Stuart Winneg, Esquire Lorraine Doyle, Esquire Alan M. Minato, Esquire Chandra M. Arkema, Esquire Louis A. Simoni, Esquire Woodcrest Corporate Center Woodcrest Cherry Hill, New J ers?ey Suite 08003-03620 ? t 11 South High Street NO. Civl I Mechanicsburg, PA 17055 /'?1 Defendant(s) ATTORNEY FOR PLAINTIFF ge ervi.ces, Inc. ;COURT OF COMMON PLEAS 961 Weige Drive :CIVIL DIVISION Elmhurst, Il 60126 Cumberland County Plaintiff ?MORTGAGE FORECLOSURE V. Donna Crockett 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 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 882-6900 HSBC Mort a S FFIDAVIT OF NON-MILITARY SERVICE STATE OF -Ao q COUNTY OF ?? ?`?Sbv?DvoJ? SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the 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: Donna Crockett Over 18 As captioned above Unknown Sworn to and subscribed ? `L? this d, Zr. offo ?e 20p? me: 1tle: __L? Comp any: HSBC Mortgage Servic s, Inc. ti'YY Pw Notary Public State of Florida ry u 1 C ? `'e Maria D Vadney < My Commission DD651402 OF f,, Expires 03/15/2011 .b OF18 (Official Form 18)(12/07) UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA In re: Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden, and trade): Donna M. Crockett 11 S. High St. Mechanicsburg, PA 17055 Chapter 7 Case No. 1:08-bk-03920-MDF Last four digits of Social-Security, Individual Taxpayer-Identification, Employer Tax-Identification No(s)(if any): xxx-xx-7183 DISCHARGE OF DEBTOR It appearing that the debtor is entitled to a discharge, IT IS ORDERED:The debtor is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code). BY THE COURT Dated: baly 1 009 Mary D. France United States Bankruptcy Judge SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION. This document is electronically signed and filed on the same date. Case 1:08-bk-03920-MDF Doc 12 Filed 02/12/09 Entered 02/12/09 01:01:39 Desc Discharge Ch 7 Pre/Post Act Page 1 of 2 OF 18 continued (12/07) EXPLANATION OF BANKRUPTCY DISCHARGE IN A CHAPTER 7 CASE This court order grants a discharge to the person named as the debtor. It is not a dismissal of the case and it does not determine how much money, if any, the trustee will pay to creditors. Collection of Di charged Debts Prohibited The discharge prohibits any attempt to collect from the debtor a debt that has been discharged. For example, a creditor is not permitted to contact a debtor by mail, phone, or otherwise, to file or continue a lawsuit, to attach wages or other property, or to take any other action to collect a discharged debt from the debtor. [In a case involving community property. J [There are also special rules that protect certain community property owned by the debtor's spouse, even if that spouse did not file a bankruptcy case.] A creditor who violates this order can be required to pay damages and attorney's fees to the debtor. However, a creditor may have the right to enforce a valid lien, such as a mortgage or security interest, against the debtor's property after the bankruptcy, if that lien was not avoided or eliminated in the bankruptcy case. Also, a debtor may voluntarily pay any debt that has been discharged. Debts That are Di char i The chapter 7 discharge order eliminates a debtor's legal obligation to pay a debt that is discharged. Most, but not all, types of debts are discharged if the debt existed on the date the bankruptcy case was filed. (If this case was begun under a different chapter of the Bankruptcy Code and converted to chapter 7, the discharge applies to debts owed when the bankruptcy case was converted.) Some of the common types of debts which are = discharged in a chapter 7 bankruptcy case are: a. Debts for most taxes; b. Debts incurred to pay nondischargeable taxes; c. Debts that are domestic support obligations; d. Debts for most student loans; e. Debts for most fines, penalties, forfeitures, or criminal restitution obligations; f. Debts for personal injuries or death caused by the debtor's operation of a motor vehicle, vessel or aircraft while intoxicated; g. Some debts which were not properly listed by the debtor; h. Debts that the bankruptcy court specifically has decided or will decide in this bankruptcy case are not discharged; i. Debts for which the debtor has given up the discharge protections by signing a reaffirmation agreement in compliance with the Bankruptcy Code requirements for reaffirmation of debts; and j. Debts owed to certain pension, profit sharing, stock bonus, other retirement plans, or to the Thrift Savings Plan for federal employees for certain types of loans from these plans. This information is only a general summary of the bankruptcy discharge. There are exceptions to these general rules. Because the law is complicated, you may want to consult an attorney to determine the exact effect of the discharge in this case. Case 1:08-bk-03920-MDF Doc 12 Filed 02/12/09 Entered 02/12/09 01:01:39 Desc Discharge Ch 7 Pre/Post Act Page 2 of 2 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 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsou.dren.com HSBC Mortgage Services, Inc. 961 Weigel Drive Elmhurst, I1 60126 Plaintiff V. Donna Crockett ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION -r3 `. ry! -n r`n ?r.._ ? t=?fff PLEAS-, ^ Cumberland county 11 South High Street = NO. Mechanicsburg, PA 17055 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, within twent you must take action y (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 ud entered against you by the Court without further not icet fomay be r 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 TARE 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 6&! U c W3-j' .1. ( MA SHERIFF'S RETURN - REGULAR CASE NO: 2008-05744 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HSBC MORTGAGE SERVICES INC VS CROCKETT DONNA GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CROCKETT DONNA the DEFENDANT at 0013:28 HOURS, on the 3rd day of October 2008 at 11 SOUTH HIGH STREET MECHANICSBURG. PA 17055 by handing to HOLLY CROCKETT ADULT DAUGHTER OF DEFENDANT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 , Service 10.00 Affidavit . 00 Surcharge 10.00 R.?Thomas Kline .00 38.00 10/07/2008 UDREN LAW OFFICES Sworn and Subscibed to ByL4 before me this day e Deputy Sh ?ff? of ?_ A. D. Ff LFIJ F; E ARY 19 2"'09 16 t qj 4 !q. oo Po ATTY 6406 136A 50 P.T% A,?(/ 740 ) ,,. eol I?•lor.:? r - UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 ATTORNEY FOR PLAINTIFF 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 pleadinas@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Donna Crockett Defendant(s) :NO. 08-5744 Civil Term TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default Prothonotary 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 Esau' re At this telephone number: 856-669-5400 (,/&-/oq 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 pleadings@udren.com ATTORNEY FOR PLAINTIFF HSBC Mortgage Services, Inc. =COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Donna Crockett :NO. 08-5744 Civil Term Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $146,866.37 Interest From 6/17/09 5,762.24 to Date of Sale December 9. 2009 Ongoing Per Diem of 32.74 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. BY: Attorneys f aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE d"J F1LEC--O? -Ill ,E w' Y 2009 JU' ? IJ.- 4A4.00 p° w 4 4 -djp CP r 7k-5-0 146F lq,do e6F a -s0 yd - X41 4 1 io.bb Pd. m 4a-od dw ?s ,#. S-0 disc ?,# m4iso RE Ojut ?ssu?ol 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 pleadinas@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Donna Crockett Defendant(s) 'NO. 08-5744 Civil Term PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: June 16, 2009 UDREN LAW OFFICES, P.C. BY: Attorneys fob laintiff 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, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent 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: O d ame: Title : /L l?.TGl/'?L ?/( Company: HSBC Mortgage Servi es, Inc. Donna Crockett Loan 40016061451 MJU #08090223-1 FILED--C)i= ICS OF THE : 2009 JUILI 15 A1111: a 3 CUB A 1 `t 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 Donna Crockett =NO. 08-5744 Civil Term Defendant (s) C E R T I F I C A T E I hereby state that as 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. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorneys f ?laintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE C. S. FILE0 ,,{ T r iARY F THE 'l 2009 JU1 16 Aix 11 04 CLNI 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 Donna Crockett :NO. 08-5744 Civil Term Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B• In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is th e mortgaged property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B• Tenants by Entireties C. Joint Tenants with right of survivorship D• A partnership E• Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B• C Not resident in the Commonwealth of Pennsylvania . If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE L.FG_u FI E I F" 2ugg UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 ATTORNEY FOR PLAINTIFF 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 Donna Crockett 'NO. 08-5744 Civil Term 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: 11 South High Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Donna Crockett 11 South High Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS ##1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address HSBC Mortgage Services, Inc. 961 Weigel Drive Elmhurst, I1 60126 ' 5t Name and address of the property: Name None Address 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. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 11 South High Street Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 16, 2009 UDREN LAW OFFICES, P.C. BY: Attorneys fo P aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE every other person who has any record lien on FILLD-CJ r E ! 4 U 2 c 0 9 J IA 16 U N!, i,r? ;'\• lt" r. is 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 Donna Crockett :NO. 08-5744 Civil Term Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Your house (real estate) at 11 South High Street Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $146,866.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES 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. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU; WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. Plaintiff V. Donna Crockett Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 08-5744 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Donna Crockett PROPERTY: 11 South High Street, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on December 9, 2009, at 10:00 A.M., at 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 that 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. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-5744 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 DONNA CROCKETT (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 att achment 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 $146,866.37 L.L. $.50 Interest FROM 6/17/09 TO DATE OF SALE 12/09/09 ON GOING PER DIEM OF $32.74 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT LATER DATE. - $5,762.24 Atty's Comm % Atty Paid $157.00 Plaintiff Paid Date: 06/16/2009 (Seal) REQUESTING PARTY: Name: LORRAINE DOYLE, ESQ Address: WOODCREST CORPORATE CENTER 111 WOODCREST RD., SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 Due Prothy $2.00 Other Costs TO BE ADDED Curtis R. Long, Prothonotary By: 4i Depu R Thomas Kline Sheriff Ronny R Anderson Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND 000N7YLFj,1-,1'y,- J OF S Smith Civil Process Sergeant Edward L Schorpp Solicitor i C ?SFF C6F i?c .?r?Rl?r= L HSBC Mortgage Services, Inc. vs. Donna Crockett SHERIFF'S RETURN OF SERVICE Case Number 2008-5744 09/25/2009 02:05 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 09-25-09 at 1403 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 Donna Crockett, located at, 11 South High Street, Cumberland County, Pennsylvania according to law. 10/02/2009 08:13 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 10-02-09 at 2013 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: Donna Crockett, by making known unto, Holly Crockett, adult in charge, at 11 South High Street, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 10/20/2009 Property sale cancelled on 10/20/2009 SHERIFF COST: $753.00 ? / jL1.'' 09 November 23, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF (._c1 (p) CountySuite Sheriff. f elecsoft_ fr,,. cle 73J 84 j, .7 .3 y,;? 0 ? UDRSN 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 CHANDR.A M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 .com HSBC Mortgage Services, Inc. Plaintiff V. Donna Crockett Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-5744 Civil Term 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: 11 South High Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Donna Crockett 11 South High Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name - - - - - -Addreas - - - - - 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. 961 Weigel Drive Elmhurst, I1 60126 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 11 South High Street Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 16, 2009 UDREN LAW OFFICES, P.C. BY: Attorneys fo P aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAVA OFFICES, P.C. -XARr?, 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 pleadingo@udren.com HSBC Mortgage Services, Inc. Plaintiff V. Donna Crockett Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 08-5744 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Your house (real estate) at 11 South High Street Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $146,866.37, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . YOU MAY STILL BS ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVM IF .THE SHERIFF'S SALE DOES TAKE PLACE. r 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN LOT OF GROUND SITUATE ON THE EAST SIDE OF SOUTH HIGH STREET, IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE BUILDING LINE OF SAID SOUTH HIGH STREET AND AT THE NORTHERN LINE OF STOUFFER ALLEY; THENCE IN A NORTHWARDLY DIRECTION ALONG THE BUILDING LINE OF SAID SOUTH HIGH STREET FOURTEEN AND ONE-TENTH (14.1) FEET TO AN IRON PIN AT CORNER OF OTHER LOT OF THE GRANTOR HEREIN, OF WHICH THIS IS A PART; THENCE IN AN EASTWARDLY DIRECTION ALONG SAID LOT OF THE GRANTOR HEREIN AND THROUGH THE CENTER LINE OF A DOUBLE FRAME DWELLING HOUSE ERECTED ON THE LOT OF GROUND HEREBY CONVEYED AND ON THE LOT OF GROUND ADJACENT THERETO ON THE NORTH, AND BEYOND, FIFTY-THREE AND SIX-TENTHS (53.6) FOOT TO AN IRON PIN ON THE LINE OF CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE; THENCE IN A SOUTHWARDLY DIRECTION ALONG THE LINE OF LOT OF SAID CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE, FOURTEEN AND TWO-TENTHS (14.2) FEET TO AN IRON PIN ON THE NORTHERN LINE OF STOUFFER ALLEY AFORESAID; THENCE IN A WESTWARDLY DIRECTION ALONG THE NORTHERN LINE OF SAID STOUFFER ALLEY FIFTY-TWO (52) FEET TO A POINT ON THE BUILDING LINE OF SAID SOUTH HIGH STREET AND AT THE PLACE OF BEGINNING. HAVING ERECTED THEREON THE SOUTHERN HALF OF A DOUBLE FRAME DWELLING HOUSE, KNOWN AS NO. 1 I SOUTH HIGH STREET, MECHANICSBURG, PENNSYLVANIA. BEING THE SAME PREMISES CONVEYED BY DIANE L. TRIMMER, RUSSELL C. TRIMMER, ROBIN E. KOHLHAAS, KIMBERLY M. BARNES, AND HEIDI C. STUHLTRAGER, BY DEED DATED JULY 1, 1998, AND RECORDED JULY 13,1998, IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN RECORD BOOK 181, PAGE 228, TO RICHARD T. BEAM, GRANTOR HEREIN. ELIZABETH BEAM JOINS IN THIS CONVEYANCE TO EXTINGUISH ANY INTEREST HE MAY HAVE IN THE SUBJECT PROPERTY AS SPOUSE OF RICHARD T. BEAM, GRANTORS HEREIN. UNDER AND SUBJECT, NEVERTHELESS, TO THE ONE-FOURTH PART OF ALL NECESSARY CHARGES AND EXPENSES WHICH SHALL FROM THE TIME TO TIME ACCRUE IN MAINTAINING, UPKEEPING, AMENDING, REPAIRING AND CLEANING THE SAID SEWER, SINKWELL, CESSPOOL, OR DRAIN. UNDER AND SUBJECT TO ANY EXISTING COVENANTS, EASEMENTS, ENCROACHMENTS, CONDITIONS, RESTRICTIONS, AND AGREEMENTS AFFECTING THE PROPERTY, VISIBLE OR OF RECORD. BEING KNOWN AS: 11 SOUTH HIGH STREET, MECHANICSBURG, PA 17055 PROPERTY ID NO.: 16-23-0567-015 TITLE TO SAID PREMISES IS VESTED IN DONNA CROCKETT, SINGLE ADULT INDIVIDUAL BY DEED FROM RICHARD T. BEAM AND ELIZABETH BEAM, HUSBAND AND WIFE DATED 2/28/06 RECORDED 3/09/06 IN DEED BOOK 273 PAGE 2458. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-5744 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 DONNA CROCKETT (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 $146,866.37 L.L. $.50 Interest FROM 6/17/09 TO DATE OF SALE 12/09/09 ON GOING PER DIEM OF $32.74 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT LATER DATE. -- $5,762.24 Atty's Comm % Due Prothy $2.00 Atty Paid $157.00 Other Costs TO BE ADDED Plaintiff Paid Date: 06/16/2009 J Curtis R. Long, Prothonotary (Seal) By: Depu REQUESTING PARTY: Name: LORRAINE DOYLE, ESQ Address: WOODCREST CORPORATE CENTER 111 WOODCREST RD., SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 Real Estate Sale # On August 19, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Mechanicsburg, Cumberland County, PA Known and numbered as, 11 South High Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 19, 2009 By: 1 Real Estate Coordinator 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: October 23 and October 30, 2009 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. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 30 da October, 2009 r Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 waft M. 2940~ ft" HSBC Mortgage Services, Inc. VS. Donna Crockett Atty: Lorraine Doyle ALL THAT CERTAIN lot of ground situate on the east side of South High Street, in the Borough of Mechanics- burg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the building line of said South High Street and at the northern line of Stouffer Alley; Thence in a north- wardly direction along the build- ing line of said South High Street fourteen and one-tenth (14.1) feet to an iron pin at corner of other lot of the grantor herein, of which this is a part; Thence in an G direction along said lot of the grantor herein and through the cuter line of a dude frame dwelling house erected on the lot of ground hereby conveyed and on the lot of ground adjacent thereto on the north, and beyond, fifty-three and six-tenths (53.6) foot to an iron pin on the line of Charles E. Diener and Virginia M. Diener, his wife; Thence in a south wardly direction along the line of lot of said Charles E. Diener and Virginia M. Diener, his wife, fourteen and two-tenths (14.2) feet to an iron pin on the northern line of Stouffer Alley aforesaid; Thence in a westwardly direction along the northern line of said Stouffer Alley fifty-two (52) feet to a point on the building line of said South High Street and at the place of BEGINNING. HAVING ERECTED THEREON the southern half of a double frame dwelling house, known as No. 11 South H* shvet, Wig Penny vmia. , BEING the same premises con- veyed by Ilse L. C. Trimmer, Robin E. Kohlhaes, Kimberly M. Bames, and Heidi C. Stuhltrager, by deed dated July 1, 1998, and recorded July 13, 1998, in the Office of the Recorder of Deeds in and for Cumberland County in Re- cord Book 181, Page 228, to Richard T. Beam, grantor herein. Elizabeth Beam joins in this con- veyance to extinguish any interest he may have in the subject property as spouse of Richard T. Beam, grantors herein. UNDER AND SUBJECT, never- theless, to the one-fourth part of all necessary charges and expenses which shall from the time to time accrue in maintaining, upkeeping, amending, repairing and cleaning the said sewer, sinkwell, cesspool, or drain. UNDER AND SUBJECT to any existing covenants, emm rents, encroachments, owWibm e. rew ric- tio", and agreements meeting the property, visible or of record. B mG KNOWt4 AS: 11 SOUTH HIGH STREET, MECHANICSWJPG, PA 17055. PROPERTY ID NO.: 16-23-0567- 015. TITLE TO SAID PREMISES IS VESTED in Donna Crockett, single adult individual by deed from Rich- ard T. Beam and Elizabeth Beam, husband and wife dated 2/28/06 recorded 3/09/06 in Deed Book 273 Page 24358. "'"he Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patr1*otAvXtws,1 Now you know 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 Leslie Kramer, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 she 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 she 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: 10/23/09 10/30109 Fa r Sworn to and subscribed before me this 16 day of November, 2009 A, D. Notary Public pia,n kly F npp 26, 2011 Writ No. 2008-5744 Civil Term 'SBC Mortgage Services, Inc. Vs Donna Crockett Atty: Lorraine Doyle ALL THAT CERTAIN LOT OF GROUND SITUATE ON THE EAST SIDE OF SOUTH HIGH STREET, IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE. BUILDING LINE OF SAID SOUTH HIGH STREET AND AT THE NORTHERN LINE OF STOUFFER ALLEY; THENCE IN A NORTHWARDLY DIRECTION ALONG THE BUILDING LINE OF SAID SOUTH HIGH STREET FOURTEEN AND ONE-TENTH (14.1) FEET TO AN IRON PIN AT CORNER OF OTHER LOT OF THE GRANTOR HEREIN, OF WHICH THIS IS A PART; THENCE IN AN EASTWARDLY DIRECTION ALONG SAID LOT OF THE GRANTOR HEREIN AND THROUGH THE CENTER LINE OF A DOUBLE FRAME DWELLING HOUSE ERECTED ON THE LOT OF GROUND HEREBY CONVEYED AND ON THE LOT OF GROUND ADJACENT THERETO ON THE NORTH, AND BEYOND, FIFTY-THREE AND SIR-TENTHS (53.6) FOOT TO AN IRON PIN ON THE LINE OF CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE; THENCE IN A SOUTH WARDLY DIRECTION ALONG THE LINE OF LOT OF SAID CHARLES E. DIENER AND VIRGINIA .M. DIENER, HIS WIFE. FOURTEEN AND TWO-TENTHS (14.2) FEET TO AN IRON PIN ON THE NORTHERN LINE OF STOUFFER ALLEY AFORESAID THENCE IN A WESTWARDLY DIRECTION ALONG THE NORTHERN LINE OF SAIL STOUFFER ALLEY FIFTY-TWO (52) FEET TO A POINT ON THE BUILDING LINE 01 SAID SOUTH HIGH STREET AND AT THE PLACE OF BEGINNING. HAVING ERECTED THEREON THE SOUTHERN HALF OF A DOUBLE FRAME DWELLING HOUSE, KNOWN AS NO. I i SOUTH HIGH STREET. MECHANICSBURG, PENNSYLVANIA. utL U -, I' vli5t..?.e, F,1: BY DIANE 1. TRIMMER, RUSSELL I' TRIMMER. ROBIN E. KOHLHAAS, KIMBERLY M. BARNES, AND HEIDI C STUHLTRAGER, BY DEED DATED JULY 1998, AND RECORDED JULY 13, 1998, 1, THE OFFICE OF THE RECORDER 017 D«EDS IN AND FOR CUMBERLAN COUNTY IN RECORD BOOK 181. PATE 228, TO RICHARD T. BEAM, GRANTO;t HEREIN. ELIZABETH BEAM JOINS IN THIS CONVEYANCE TO EXTINGUISH ANY INTEREST HE MAY HAVE IN THE SUBJECT PROPERTY AS SPOUSE OF . RICHARD T. BEAM, GRANTORS HEREIN UNDER AND SUBJECT, NEVERTHELESS TO THE ONE-FOURTH PART OF AIs NECESSARY CHARGES AND EXPENSES WHICH SHALL FROM THE TIME TO TIME ACCRUE IN MAINTAINING, UPKEEPINC, AMENDWQ. REPAIRING AND CLEANING THE SABJ'VM SWKWELL, CESSPOOL, OR DRAIN. UNDER AND SURWT TO ANY EXISTING COVENANTS, FASJNTS ENCROACHMENTS. CONDITIONS. RESTRICTIONS, AND AGREEMENT.. AFFECTING THE PROPERTY, VISIBLE 01? OF RECORD. BEING KNOWN AS: 11 SOUTH HIC± STREET, MECHANICSBURG. PA 17055 PROPERTY ID NO.: 16-23-0567-015 TITLE TO SAID PREMISES IS VESTED IN DONNA CROCKETT. SINGLE ADULT INDIVIDUAL BY DEED FROM RICHARD BEAM AND ELIZABETH BEAM, HUSBAND AND WIFE DATED 2128/06 RECORDED a [19/06 IN DEED BOOK 273 PAGE 2458.