HomeMy WebLinkAbout08-7178RICHARD F. STERN, ESQUIRE (03315)
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DIsKIN, ESQUIRE (86727)
STERN AND EISENBERG, LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKIN owN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSnvnE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OP COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
v.
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
Defendant(s)
Civil Action Number:
erg- ??70 ?1OLL`T -,
COMPLAINT IN
MORTGAGE FORECLOSURE
CIVIL ACTION MORTGAGE FORECLOSURE
NOTICE
This is an attempt to collect
a debt and any information obtained
will be used for that purpose.
You have been sued in Court. If you wish to defend the claims set forth in the following pages, you
must take action within twenty (20) days after this Civil Action and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the Court your defense or
objections to the claims set forth agains you.
You are warned that if you fail to do the case may proceed without you and a judgment may be
entered against you by the Court witho t further notice for any money claimed in the Civil Action or
for any other claim or relief requested b the plaintiff. You may lose money or property of other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, OR CANNOT AFFORD NE, GO TO OR TELEPHONE THE OFFICE SET FORTH
J:\Supriya\Complaints\Cumberland\Ocwen.Reiley.Lorraine.12.08. doc
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\Supriya\CompWnts\Cumberland\Ocwen.Reiley.Lorraine. %2.08.doc
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE
NOTICE
PURSUANT TO THE FAIR DEBT C LLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ.,
YOU MAY DISPUTE THE VALIDIT OF THE DEBT OR ANY PORTION THEREOF. IF YOU
DO SO IN WRITING WITHIN T IRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN
VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL
CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT
WILL BE ASSUMED TO BE VALID IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN
ADMISSION OF LIABILITY BY YOU
IF YOU NOTIFY US IN WRITING THIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE
COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE
OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE
MAILED YOU THE REQUIRED IN ORMATION, WE WILL CONTINUE THE COLLECTION
OF THIS DEBT.
THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT
TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
i
I
J:\Supriya\Complaints\Cumberland\Ocwen. Reiley.Lorraine.12.08.doc
RICHARD F. STERN, ESQUIRE (03315)
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
STERN AND EISENBERG, LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
v.
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
Defendant(s)
Civil Action Number: 0?- '7178 (!?,4
COMPLAINT IN
MORTGAGE FORECLOSURE
COMPLAINT
CIVIL ACTION MORTGAGE FORECLOSURE
1. Plaintiff is HSBC Bank US N.A., as Indenture Trustee for the registered Noteholders of
Renaissance Home Equity Loan Trust 2007-2, by its attorney in fact, Ocwen Laon
Servicing, LLC (hereinafter referred to as "HSBC Bank USA, N.A.") with offices located
at 1661 Worthington Road, §uite 100, West Palm Beach, FL 33409.
2. Defendant is Lorraine R. Rei ey, adult individuals with a last-known address of 505 Geary
Avenue, New Cumberland, A 17070.
3. Under date of 03/31/2007, d fendants executed and delivered to MERS, Inc., as Nominee
for Fidelity Mortgage a mortgage upon the premises 505 Geary Avenue, New
Cumberland, PA (the "Property") to secure the payment of the sum of $72,000.00. The
said mortgage is recorded in he Office for the Recording of Deeds in and for Cumberland
J:\Supriya\Complaints\Cumberland\Ocwen.Reiley.Lorraine.12.08. doc
County on 04/11/2007 in Book 1988 at Page 1513 and is incorporated herein by reference
4.
5.
6.
7
8.
9
as though set forth at length herein. A copy of the legal description of the premises is
attached hereto and made a part hereof as Exhibit "A".
The said mortgage was assig
Assignment which has been
Ocwen Loan Servicing LLC,
authorized to act for Plaintiff
Said Defendant is the real ov
17070.
In accordance with Act 91 of
information required by §40=
to HSBC Bank USA, N.A., the within Plaintiff, by
recorded or is in the process of being recorded.
to Ocwen Federal Bank FSB is the attorney in fact
of premises 505 Geary Avenue, New Cumberland, PA
1983, as amended, a combined notice providing the
of Act No. 6 of 1974, and Act 91, aforesaid, was sent to the
defendant and no response was made in the appropriate period of time. A true and correct
copy of the aforesaid notice i I? attached hereto and made a part hereof as Exhibit "B".
The said loan is in default as a result of the failure to pay the monthly installments of
$888.57 due on August 1,
The following is due on the
PRINCIPAL BALANCE
INTEREST accrued thru
Interest after 12/05/2008
rate of $20.02.)
LATE CHARGES accrue
Late charges after 12/05/:
rate of $30.68.)
ESCROW ADVANCES.
FEES BILLED ................
COSTS ............................
ATTORNEY'S FEE .......
TOTAL ...........................
The attorney fees set
Pennsylvania law, and will be
mortgage is reinstated prior to Sale,
performed.
for foreclosure of the mortgaged
plus $20.02 per day from 12/05/2008
charges of $30.68 per month from 1
WHEREFORE,
and on the same day of each month thereafter.
..................................................... $71,833.63
2/05/2008 of ............................... $3,084.04
hall accrue at the per diem
thru 12/05/2008 of ..................... $255.86
38 shall accrue at the monthly
...................................................... $829.38
...................................................... $259.68
...................................................... 300.00
...................................................... $3,600.00
...................................................... $80,162.59
above are in conformity with the mortgage documents and
in the event of a third party purchaser at Sheriffs Sale. If the
attorney fees will be charged based on work actually
iff,? HSBC Bank USA, N.A. requests this Court to enter judgment
for the sum of $71,833.63 plus interest thereon of $3,084.04
judgment is paid in full, late charges of $255.86, plus late
until judgment is paid in full, escrow advances of
J:\Supriya\Complaints\Cumberland\Ocwen.Reiley.Lorraine.
$829.38, fees billed of $259.68, costs of'$300.00, attorney's fees of $3,600.00 and all other amounts set
forth above, less any suspense as set foif th above, together with record costs and any other amounts to
which Plaintiff is entitled to recover.
STERN AND EISENBERG LLP
BY:
I F.-`StERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
Attorney for Plaintiff
Date: December 5, 2008
J:\Supriya\Complaints\Cumberland\Ocwen.Reiley.Lorraine.12.08.doc
VERIFICATION
Jessica Dybas is the Default Liaison of OCWEN LOAN SERVICING LLC
successor to Ocwen Federal Banl' and is authorized to sign this Verification on behalf of
same, and states that she verifies the foregoing Civil Action-Mortgage Foreclosure
against Lorraine R. Reile and avers the statements of fact
therein contained are made subject to the penalties of 18 PA C.S. Section 4904 relating to
the unsworn falsification to auth(rities, and that same are true upon the signer's personal
knowledge or information and be ief.
'A ?a - lnw
Jesdt Dybas
De Liais 3
%8X8>?Sx
Date:
December 5, 2008
0 0
COMMITMENTFOR TITLE INSURANCE
SCHEDULE C
Commitment No: WPAFMP0713821 Effective Date: February 23, 2007
ALL THAT CERTAIN piece or parcel of 1 'nd, situate in the Borough of New Cumberland, Cumberland
County, Pennsylvania, bounded and described in accordance with a survey by D.P. Raffensperger
Associates, dated June 4,1971, as follows, wit:
BEGINNING on the Northeast corner of S ith Avenue and Geary Avenue thence along the Eastern side of
Geary Avenue North 45 degrees 45 minute West 70 feet to a point at the division line between Lots Nos. 28
and 29 on the hereinafter mentioned Plan Lots; thence along said last mentioned division line North 44
degrees 15 minutes East 115.5 feet (Plan stews 116.5 feet) to a point at the division line between Lots Nos.
28 and 36 on said Plan; thence along said I st mentioned line and along the division line between Lots Nos.
28 and 37, South 58 degrees 15 minutes (Pion shows 14 minutes) East 71.69 feet to a point on the Northern
side of Smith Avenue; thence along the No thern side of Smith Avenue South 44 degrees 15 minutes West
131 feet to a point, the place of BEGINNING.
BEING Lot No. 28 on Plan of Lots of Hills de Manor, which Plan is recorded in the Office of the Recorder
of Deeds for Cumberland County in Plan Book 11, page 21.
Parcel No. 25-24-0811-133
For informational Purposes:
The property address is: 505 Geary Avenue, New Cumberland, PA 17070
Deed book volume: 34-5 page: 1055
01 OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
O C.W . N Orlando, Florida 32826
WWW.OCWEN.COM
September 30, 2008
VIA First Class Mail
VIA Certified Mail (return receipt requested)
Certified Number: 71069017515123166533
Reference Code: 0809
Lorraine R. Reiley
505 Geary Ave
New Cumberland, PA 10707-1857
Loan Number: 103365482
Property Address: 505 Geary Avenue, New Cumberland, PA 17070-0000
PLEASE SEETHE ENCLOSED.
rs
DACT91.11
This communication i? from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
a OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
?o
0 o w e N Orlando, Florida 32826
APPENDIX A
September 30, 2008
ACT 91 NOTICE
TAI?E ACTION TO SAVE
Y UR HOME FROM
?MRECLOSURE
This Notice explains how the orwram works.,
LA NOTIFICACION EN ADJUNTO I
CONTINUAR VIVIENDO EN SU
NOTIFICACION, OBTENGA UNA
AGENCIA (PENNSYLVANIA HOi
MENCIONADO ARRIBA. USTED
PROGRAMA LLAMADO "HOMEO`
EL CUAL PUEDE SALVAR SU CASA
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CORPORATION
CURRENT LENDER/SERVICER:
WWW.OCWEN.COM
DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
1SA. SI NO COMPRENDE EL CONTENIDO DE ESTA
RADUCCION INMEDIATAMENTE LLAMANDO A ESTA
NG FINANCE AGENCY) SIN CARGOS AL NUMERO
iEDE SER ELEGIBLE PARA UN PRESTAMO POR EL
ER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"
LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
Loraine R. Reiley
505 Geary Avenue
Ne* Cumberland, PA 17070-0000
10 65482
F ELITY MORTGAGE A DIVISION OF DELTA FUNDING
OC?WEN
I?
DACT91.11
This communication is from a debt collector attempting to collect a debt;
any informat on obtained will be used for that purpose.
when you meet with the Counseling Aaency. ,',
a OCWEN Loan Servicing, LLC
12650 Ingenuity Drive
?
o c w O e N Orlando, Florida 32826
WWW.OCWEN.COM
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
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 ELIGIBILI
THE PENNSYLVANIA HOUSING F
TEMPORARY STAY OF FORECLOSURE
Y REQUIREMENTS ESTABLISHED BY
INANCE AGENCY.
Under the Act you are entitled to a temporary stay of foreclosure on
our morta e for thirty 30 days from the to of this Notice. Durin that time you must arran a and attend a "face-
to-face" meetin with one of the consumer c dit counselin a encies listed at the end of this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT 30 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE
ASSISTANCE YOU MUST BRING YO MORTGAGE UP TO DATE. THE PART OF THIS NOTICE
CALLED"HOW TO CURE YOUR MORT GE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE
ur 1V LAlr,.
listed at the end of this notice, the lender
meeting. The names, addresses and teleohc
meeting. Advise your lender immediately of yO
Notice (see following pages for specific infor
to resolve this problem with the lender, yo
Emergency Mortgage Assistance Program.
Emergency Assistance Program Application
end of this Notice. Only consumer credit con
in submitting a complete application to the I
postmarked within thirty (30) days of your fs
YOU MUST FILE YOUR APPLICATION
THE OTHER TIME PERIODS SET FO:
YOUR HOME IMMEDIATELY AND YOi
AGENCY ACTION -- Available funds for
the Agency under the eligibility criteria esti
days to make a decision after it receives yo
against you if you have met the time requ
Housing Finance Agency of its decision on i
NOTE: IF YOU ARE CURRENTLY PR(
FOLLOWING PART OF THIS NOTICE
CONSIDERED AS AN ATTEMPT TO CO:
(If you have filed ban
CIES -- If you meet with one of the consumer credit counseling agency
NOT take action against you for thirty (30) days after the date of this
intentions.
It is only necessary to schedule one face-to-face
,NCE -- Your mortgage is in default for the reasons set forth later in this
ation about the nature of your default.) If you have tried and are unable
have the right to apply for financial assistance from the Homeowner's
Po do so, you must fill out, sign and file a completed Homeowner's
ith one of the designated consumer credit counseling agencies listed at the
oeling agencies have applications for the program and they will assist you
ansylvania Housing Finance Agency. Your application MUST be filed or
y-to-face meeting.
OMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW
H IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
ergency mortgage assistance are very limited. They will be disbursed by
shed by the Act. The Pennsylvania Housing Finance Agency has sixty (60)
application. During that time, no foreclosure proceedings will be pursued
Iments set forth above. You will be notified directly by the Pennsylvania
jr application.
CTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE
CT THE DEBT.
you can still apply for Emergency Mortgage Assistance).
DACT91.11
This communication is from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
OCWENLoan Servicing, LLC
12650 Ingenuity Drive
O
O C WEN Orlando, Florida 32826
NATURE OF THE DEFAULT --The MOP
Geary Avenue, New Cumberland, PA 170
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY M(
are now past due:
2 payments in the amount of $ 888.57 from
Principal and Interest...
Interest Arrearage.......
Escrow ....................
Late Charges .............
Insufficient Funds Char;
Fees / Expenses..........
Suspense Balance (CRI:
Interest Reserve Balanc
TOTAL DUE...........
HOW TO CURE THE DEFAULT -- You
PAYING THE TOTAL AMOUNT PAST
PAYMENTS AND LATE CHARGES WE
W W W.OC WEN.COM
E debt held by the above lender on your property located at: 505
PAYMENTS for the following months and the following amounts
01, 2008 through September 30, 2008
............................. $ 1,227.30
............................. $ 0.00
............................. $ 652.06
............................. $ 225.18
es ........................... $ 0.00
............................. $ 122.22
3IT) ........................ $ 0.00
(CREDIT) ................ $ 0.00
.............................. $ 2,226.76
cure the default within THIRTY (30) DAYS of the date of this notice BY
TO THE LENDER, WHICH IS $2,226.76, PLUS ANY MORTGAGE
BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments
OCWEN
P.O. BOX 6440
CAROL STREAM, 11, 60197-6440
IF YOU DO NOT CURE THE DEFAULT 71I If you do not cure the default within THIRTY (30) DAYS of the date of
this Notice, the lender intends to exercise is rights to accelerate the mort a e debt. This means that the entire
outstanding balance of this debt will be consi ered due immediately and you may lose the chance to pay the mortgage in
monthly installments. If full payment of the tal amount past due is not made within THIRTY (30) DAYS, the lender
also intends to instruct its attorneys to start le al action to foreclose upon your mortgaged property.
mortgage debt. If the lender refers your case
proceedings against you, you will still be regi
$50.00. However, if legal proceedings are sta
incurred by the lender even if they exceed I
which may also include other reasonable cost
be required to pay attorney's fees.
OTHER LENDER REMEDIES -- The
other sums due under the mortgage.
THIRTY (30) DAY period and foreclosure
other requirements under the mortgage. (
mortgage to the same position as if you had
ON -- The mortgaged property will be sold by the Sheriff to pay off the
its attorneys, but you cure the delinquency before the lender begins legal
•ed to pay the reasonable attorney's fees that were actually incurred up to
A against you, you will have to pay all reasonable attorney's fees actually
,00. Any attorney's fees will be added to the amount you owe the lender,
If you cure the default within the THIRTY (30) DAY period, you will not
may also sue you personally for the unpaid principal balance and all
[FF'S SALE -- If you have not cured the default within the
have begun, you still have the right to cure the default and
your default in the manner set forth in this notice will restore your
defaulted.
DACT91.11
This communication is from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
OCWEN Loan Servicing, LLC
012650 Ingenuity Drive
: c WE N Orlando, Florida 32826 WWW.OCWEN.COM
EARLIEST POSSIBLE SHERIFF'S SALE D..TE - It is estimated that the earliest date that such a Sheriffs Sale of the
mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the servicer.
HOW TO CONTACT THE SERVICER:
Name of Servicer: OCWEN
Address: P.O. BOX 24737
WEST PALM BEACH, FL 33416-4737
Phone Number: 800-310-9229
Fax Number: 407-737-6300
Contact: Performing Collections Dept.
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged
property and your right to occupy it. If you c ntinue to live in the property after the Sheriffs Sale, a lawsuit to remove
you and your furnishings and other belongin could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -- You m y or X may not (CHECK ONE) sell or transfer your home to a buyer or
transferee who will assume the mortgage de provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and t at the other requirements of the mortgage are satisfied.
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 O THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF
YOU CURE THE DEFAULT. (HOWEVER, OU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT
MORE THAN THREE (3) TIMES IN ANY LENDAR 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.
DACT91.11
This communication is from a debt collector attempting to collect a debt;
any information obtained will be used for that purpose.
p
-? APPENDIX C
PENNSYLVANIA HOUSING FINANCE AGENCY
HDM)90WNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
(Rev. fi")
ovine Bed Co Hsover (]molar
? cadisit Sweet
aovv PA 17331
7)637.3761
X (717)637.3294
mcid commdmg Sammus ofFne".
wtsn 3r sued
kyseabom PA 17266
> orWemmern PA
L*;Immws Road
*wg PA 17102
541-1757
(717)3344670
m Carry Hoasinl AU&W1ty
43 halide st
dmq PA 17325
334-1511
(717)3344326
Mva4 Housig I -vueee Agency
is Hem)
Swallow HM Boa4 Bldg 203
urgh PA 15120
m Hmmlo; loc.
6' Ave, Suit. 950
btugh PA 15219
X91.1956 or (412)261-2102 or (103)792-2740)
(4I2))914512
S of Waptan PmmrAvanis, inc.
SENWAM Sweet
burdt PA IS=
an L gw of PitrsMrgh
p For SWW Oppmamity
SniW6dd St.
Ibw&PA 15222-2222
1)227
C(412)261-5207
ft Cateadom of PA
wood Stmel, Saic. 906
tw5bPA 15222
!)731-9954 orMM737.2933
C (412)8384963
west Hilt suer
tyaesbm8 PA 15370
)952.2893
U45'1RONG COUNTY
XS of Wmms Pvroay)vasdR Inc
7 E. Plank Road
Imaa PA 16M
14)94445700 a (614)944-5747
odd Cmgmd cs of PA
I Wood Su W, Sam 906
mburgh PA 15222
.2)331-9934 or (80D)737-2933
X (412)731-9963
lien. Co. Conammiy Aaim Proctor
7 water sta.t, Box 167
Manx PA 15701
!4)465-2657
X (724)465-5116
AVER COl7M'Y '
dm Heudng, inn
5 6' Avq, Suite 950
bantlk PA 15219
sing Opportunities of Beaver Canty, le.
Corpaalim St. Soilc 207
ver, PA 15009
1)726-7511
sing Opportunitia, Inc.
Scvmlh Stan
Be. 9
Kresoat PA 15134
Volley lkaemployed (:a?Mee
9' Amore
end PA 1512D
lt Caamdna of PA
Wood Soma, State 906
bmdkPA 15227
)338-9954 or (!03)737-2933
Hor 4wm Howasg Sw km
et! L'medn Nighwry
am PA 15537
4)6234129
X (1147673-7117
?mane Famomic DevdopwAa corp-od
4 Mmy Once Lan.
arrow PA 15901
4MS4536
X (114)539-1611
aWailaBm (Mace
MiBL Sweet
06"Oes, PA 16652 -
4)643, 2
CS orw- Ptmnsylvaoia, Inc
E Pkmk Read I
-PA 16602
4)944-6700
K (114)944-5747
and S-vices, Ina
Bid Main, Sued
o m PA 15501
4) 4454621 v (303)452-0146
X(814)443-3690
R= COUNTY ,
but counseling: Csmv
Wm6 FIN Baer
d'eg PA 19601
3)175-'7866
X (610) 375.7830
aomie Omottmily 6lisrt a county
N. Cesare street
rAh PA 17901
IJ622-1995
X (717)822-0429
i
CS OfLAisk Valley
I Coleco cart Bar
A" PA IM2
W14011 or (800)723.2744 (814) only
x (610)821-8932
Homily Housing Cotmaelor, Ins.
Bea 244
muSgaare PA 19348
1)414-3662
X (610)/44-6243
40t COUNTY
fosd-Fdtm Housing savio.s
81. Ban 194
ten PA 15537
4)6234129
C (814)623-7167
S of Weslaco Pen-Avania. Una
E Plank Road
ena PA 16602
9,14-6100 or (814)944-5747
pone Ferman Development
4 Mary Gram lane
Woven PA 15901
1)535.6556
((814)539-1688
0-iaeon Office
Mimi. Seas
ehngdmn PA 16652
So.W 7' Seim
87 0 or (BOD)M-PS37
AX (S70)2DmI
1 wMmkatst
flDtrs-Bmre PA 19M
570)82)4037 or (803)822-9537
AX (S70)Q)-1715
631 S AOepm St, subc IDD
mm C.BWPA 16601
614)731.3661
AX (1)4)231-3669
Pvl ieAy
mars PA 1111111
MS-3336 or (BOD)962-4M
Dmsa &
m211
PA 16947
Swam, PG Bea 319
PA 11614
wamaa guar
eBmaro PA 16901
?0)7245252
X (570)7243763
3 Wman Sbem, PO Box 709
.M ...A PA 11657
X (57d)36E132
1 Mom Suer
mdala PA 19431
OP53i941
X (57DAP-4117
Non6 Brad Street
at *Wa PA 19130
)765-1221
((215)765-1427
em Can4' Hennaing Guano. ba
Far Ricbmdem Avenue
Ohms PA 19047
.y AV.. Y FL
PA 19140
Cap of Fm*lbrd
dolphin PA 19124
7442990
(215)744.2012
nrvt cascading Swine
Nash Band sweet
dolphi. PA 19141
32,47500
(215)3244753
4 of DcLaam Vdlcy
Market Sweet, Soil. 1325
1ck PA 19107
563-5665
(215)SW-2M6
1 of Ddawa. Valley
nc Cwpmtc Cmtcr
Strew Road
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i of lcbig4 V.Il.y
Cmmt count ran
0" PA 16052
6214011 -(600)220-2733
(6)0)1121-6932
main. Credit Commei' oflfbigb Volley ' Hou®g Cog, lac
71 Crosson Court Pant Bur 244
SS Yak Rd, Sai¢ 107 virisclull PA Is= Square PA 19341
arvwee erPA 18974 61D)9214011 o(80D)22D-2733 61D)444-3682
15)444-9429 AX (610)921-8932 AX (610)144$243
AX (215)1566344
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44 13. D.Wb Pit. OD Node IT Street. Suite 60D _
S orPnaais PA 19406 400 Abutpm Esecubw Park, Suite I ' PA 19103
610)9'/1-221D aaft SummgPA 18411 153567-7274
AX (610)2654114 570)95'1.9163 or (100)922-9537 AX (215)963-9941
-9X(570)587.913419135
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KrMER CCDUN7Y - 9 Som9 T Sum Mmimy
PA 11360 Grimm Select
kclicre Horabg, Inc. 57D)420-Mw(XDD)9=-M7 PA 19124
25 6' Ave, Saito 950 AX (57D)42"Nl 15)744,2990
' PA 15219 ' AX (215)7442012
412)391-1956 or (412)25)-2102 It W )iarket In
AX (412)1914512 dkes-Bmrc PA 15702 of Dea"Mra Valley
570)92140137 or (80D)M-PS37 Acacia Rwft
utamg Oppormidec, Ion. AX (S1M)921-1715 E Market 2% Suite 215
Cnpame SC Suite 2D7 Wes C6W PA 19312
tssp rt PA IS132 631 S Adanm St, Sohn IDD 150615665
412)664-1590 Into CAW PA 16101
AX (412)664--MM 14)239-3661
AX (5)4)238-3669
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Buz 9 63 Amber Lee 741
PA 15134 r PA 197M
412)6641906 570)116.0510 or (BOD)822-0359 Sane iO3
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570)455.4944 HAZELTON 29
of Wearer. PA
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39 Nab Wadbtpon S1rW M L Dcki b Pike
k.dar PA 16001 ofPrttmia PA 19406
4)282-7812 MWMCDLWTY - 610)971-2210
AX (610)265.46!4
Vslky Unemployed Conodmse ofWearaa Ymmy4va.ia, Inc.
ZD 1- 9a Avenoe 17 E Plank Road
mrestod PA 15120 kkoaces PA 16602 XAlM COUNTY
,412)462-9962 814)944-1100
FAX (412)462-9964 AX (BI/pM-5747
XCS of Wenaa PA
Credit CDkwwJ.ra of PA
ymrmg-0MlM Co coaao For Co -.m y Adim (S'[PY) CA Bollefing
39 Nab Waslcupoo Sheet
101 Wood Strew, Suite 906 131 Lincoln Shod Wder PA 160DI
?itrsburgk PA 15222 Boer 1328 412)M2-7112
412)3394954 -(WD)737-2933 Ramrprak PA 17M
FAX (412)338-9963 - 570)3260587
AX (570)322-2197 '..
.. XEARPMLJ) 0OUN Y
;AMBRIA OOUI47'Y Xv: ofNabeema P®ay4vada I
.. Em.tmde Derdopest Cerpan-
631 S Abarm St, Suhe 100 954 May Ghaoe bane
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iD NI, Bas 324 814)39-3661 I,,, 14)5356556
3vetett PA 15537 AX (814MI-3669 AX (814)539-1628
'114)673-9129
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I Basin Strut 17 E. PLmk Recut
adtma Cc. Community Audw ?raw= NlIllsomport PA 17703 PA 16602
127 Water Shenk Bon 117 SM)3264)587 814)960.2100
ndima PA IS701 AX (578)122-2197, AX (814)044-5747
724x165-2657
rAX (724)"S-5118 of Wcmcm PA
3JESTER 19-A CoOge Park Fluor
XXS of Weeao PA PA ISM
39-A Cdkgc Pack Phu "urot Houciag Copondm 814)5394335
olndc. PA 15904 Nob Broad Shed
814)S394445 -WWcbMa PA 19130 Cd. Cammmily Aetlah PMUM
21S)76S-1221 Water Snack Ban 197
X= of WM- Pemmylvanis, Inc. AX (2IS) 76S-1427 donna PA IS701
'.17 E Ptmk Road )"s-2657
noncom, PA 16602 udgcl Caamdi s Carrier AX (724)465-5118
114)944-8100 47 Nab Fifth Sued
AX(814p44-5747 PA 19601 ofNMbeworm Pewytmia
610)375.7866 631 S Arhmtou St. Suite 100
.eyr.ne Frnoomic Dcvelop.sm Corpora im AX (610)375-7830 I.I. C.Dep PA 16801 ,
9S4 May Grace Lane 514)739-3668
obmto.a PA 159D1 CE AX(814)39-3669
114)53S.6556 67 Alleshm Ave, 2° FL
AX (214)539-1688 bb.&lp6)a PA 19140
15)426.8025 :LDfIDN COUNTY
lbkland Services, Inc. AX (215H269122
35 East main Shea ymodngilidm Coomies
-vt PA 15501 eds Fdloonhip Hone >aornission For Cmror.ariy Action (MV.P)
114) 445-9628 or (100)452-0148 02 S J..k- St 138 IJmoln Strew
AX(914)443-369D cdis PA 19063 O i7oa 1328
610)565-0846 illmtwpoet PA 17703
-9X(610)565-8567 570)326-0587
'.AMERON000NTY -9X(570)322.2197
A. Commr.iy Services Inc
iord6 Tice- Community Action Corp 39 E King Shea of Naabusrcrn PA
D bon 389 Pa 17602 01 Burin Sued
35 Wrst 4' Street 717)397-5182 or (800)788-5062 (H.O. ody) Millientspart PA 17703
mporium PA 15834 AX (71'!)3994127 5 70)3234627
114)496-1161 ?i AX (SM)3234626
AX (814)486-0825 mmiua Red (Tors of Cheer
729 Edgernonr Ave i' D IMS of Noe6ueean Peruraylvania
CCS of W.1- Pen-Ann(.. Inc er PA 19013 631 S Ad."- St. Sure 100
17 E. Plank Road 610)974-1414 t l.Callege PA 16901
1m PA 16602 8 14)239-3668 ,
34)944-9100 -n Counseling Savi- - AX(S14)233-3669
AX(914)944-5747 111 Broad Sued
O..PNa PA 19141
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2 1S)324-7500
ARSON COIIPIiY -9X(215)3248753
?
I W Markrl St
• O Box 1127
i0c6-Bone PA 16702
57D)S21-0837 or (800)922.9537
AX (570)821-1785
4DO Abington Ex=.b- Pack, SWU I
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570)597.9163 or (300)922-9537
AX (5701597-9L34N135
'moon on Eoonoaia OPP?trY of Irmxc Curly
63 Amber Lone
illrt-Barre PA 19702
570)8264510 or (M)MOSS9
AX (S10j629-1665?AI1 BEPORE FAXM
570)45549N WZELTON
AX (570)455.563 I-Car r BEFORE FAXING
57D)8364090 71.MKRANNOCX
okff T. Washington Co mar
2D F1o0and Strad
it PA 16503
14)453-9744
X (614)453-5749
.m F. Konody Cersac lot
21 Ead 20a Sect
.FA 16510
4)998.0400
,X(614)898-1243
mw Erin Cadamanky Anion Canadian:
West 9t. Suns
e PA 16501
4)4594581
X (614)456-0)61
mango Va0ey Urban League, Inc
Indiana Avtmn
rdl PA 16121
S dDds- Valley
S Market Street, Suite 1375
md.hka PA 191D7
)563-5665 .
((215)563.7020
I•u Fellowship Home
S Jaetrm Sues
6t. PA 19D63
))565.0546
( (610)565-6567
ddpha c-il for Commdty Adv
Nods 17' Soren, Snit. 600
ddpb)u PA 19103
sm Red Croat of r,%-
Edgomu Avc
aPA 19013
6741494
meal Cormsdhq Service;
N Broad SUOK
leA, PA 19141
Alleghmay Ave, 2" FL
laddphia PA 19140
5)426-6025
K (215)426-9172
mudry Naming Coumdor, Inc.
0- 244
watt Swot PA 19348
anssity Dwdopmw Crop of Fra is mil
w MAP
D Griaemu Sued
mdclpha PA 19124
)7442990
X (215)7442D12
3 of Ddmwoe Valky
Noah Pmvideme Road
is PA 19063
CCS of western Pdauylvma, Inc. 63-5665
DDD Unglwowa Road
drWAn PA 17102
17)541-17$7 Ave, Snit. 1
7SS-aMW
AX (717)5414670 f
PA 19087
71-2210
than Ieagc of Mat opolitua Hatrisburg
-7960
)097
07 N 6t. Sorest
auisbusg PA 17101
17)2345925 44 E Ddab P.M.
AX (717)2349459 of Prussia PA 19406
610)971.22)0
moI.[ Counseling S-ri s of Franklin
Wed 3' Sacd
lyruvd o PA 17261 COUNTY
17)762-3265
Old F. Kennedy Cantor. ha&
WCA of Carlisle 21 Bad 20m Street
I G Strad PA 16510
Male PA 17013 504)996.0400
17)243-3918 AX (614)498-1243
athcn Tit. Cormumity Action Corp
rmnity Actin Comsdsdon of iba Capital Regirm O Box 319
Dory Snore 35 Wed 4` Strut
cbmg PA 17104 imporim PA 15934
232-9757 914)486-1161
(717)2342227 AX (914)496-0[25
s County Hoisting A.0-ity
43 Cadide St. OUNTY
.bury PA 17325
334(518 T. Washington Ceuta
F
(717)334-9326 olland Suet
7
16503
c
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)DO Lingt down Road
uritbusg PA 17102
17)541-1757
1X (717)5414670
...unity Action C... as(on of the Capisi Region
14 Dory Stmt
arisburg PA 17104
17)232-9757
1X(717)2344227
ban Isague or Mc rapoliun Harrisburg
07 N 6' Shoes
nisborg PA 17) 01
17)234-5925
,((717)2349459
Iu F. Ksnady Center, Inc.
121 Fad 20v Stec[
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14)898-0400
U( (814)499-1243
,asw Eric Community Action Comminc
Wed 9t. Sheet
is PA 16501
14)4594581
IX (814)4560161
on Housing, Inc
r AM Suite 950
burgh PA 15219
)391-1956 or (412)281-2102
:(412)3914512
Wdsd ScM- lot
North Coma Awast e
roars PA ISSDI
1)445-9621
C(6)4)443-1690
m u ity Ae im smainvtst
9nan High Sues
mnbdg PA 15370
I)652-2993
me Candy Coommky Action Agency Ism.
Nab Bcana Aveuc
=MR PA 15401
!)437-0050 or (9DD)4274WPO
,(412)4374419
S ofweAaa PA
Tdamo Soren
msowa PA 15401
.)439-6939
1 Valley Usmpioyed Come
E. 9t. Avrme
--.A PA 15120
Lksaty good
Bon 547
ma PA 16365
torrid SWAM U.U k d
west 3' Suet
tynafimn PA 17269
.7)762-3265
3 ofwatas Pamaylvoum, Inc.
1 Sato Geogn Sara!
tt PA 17403
!miry Action Coromssion of the Capita Bared
Derry Sandi
along PA 17104
232.9757
(717)234-2227
mfwolmm PcrAwvnk Tom.
largkrown Rand
tang PA 17102
CA of Adak
a Strw
ide PA 17013
P13-3616
'(717)731-"89
mien Red Cora-Hanover (baps;
Mink Saw
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)234.3925
:(717)637-3294
w Lague of Matmpolimn Hsrisbrsg
'NeStred
Ww9 PA 17101
)2345925
:(717P34-9459
m Cowry Hosing Authority
143 Cali;k St.
mbug PA 17325
0341515
(717)3344326
hdford-Fulton Housing Serv(s
lD 1. Box 394
iverell PA 15537
614)423-9129
AX(934)623-7197
wocial Counseling Saviors of Franklin
1 Want 3# Sand
Vaynesboro PA 17269
)47)762.3295
'CCS of wedem Pennsylvania. Inc
12 South Georg Shed
ark PA 17403 -
1171946-4176
estheriation Office
17 Mimi. sew
untinadon PA 16652
I?.ctio; Kouzing. Int.
?25 !1 Ave, Sum 950
?. r,-=1Duryh PA 15219
412)391-1956 .1(412)261-2102
/.X (412)391-4512
mmuniry Aeum Southwest
12 We Kigh Soea
aynesburg PA 15370
724)852-2693
R.Y. (412)627-7113
,ADZ V diey Unemployed C annibee
20 E, 9` A-
oncslrad PA 15120
412)462-9962
AX (412)462-9964
of Wensm P-y)v®4, lac
North G&W Squam
Garden Camm Drive
reeaaburc PA 15601
dford-Fdtm Booing Services
) 1, Boa 394
-00 PA 15537
4)623.9129
X (814)623-7167
7 Mifflin Strad
ntingdoa PA 16652
4)643.2343
CS of Weskn Pmnsyivania, inc.
F 2 Plank Road
Dora PA 166M
4)944-B1D0
X (814)944-5747
COS of western Peansylvan)a, bre
Nodh Gale Square
i Garda Conner Drive
ransbure PA 13601
W.- F ie Developaa d Cnporadm
4 Mary Grant I-
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1)5356556
((614)539-1688
uu CO. Coomnity Arbon Program
Water So W, Boa 167
w PA 15701
)465-2657
(724KS-5118
S of w..tw PA
A College Park Mm
slows PA 15904
a F. Xcnwdy Coley, Inc
1 East 204 Stre4
PA 16510
1)995-040D
((814)898-1243
aoa Co. CDmmaity Action P.Z-
Wates Surd, Box 187
w PA 15701
1){65.2657
t(724)465-5118
S of Wenen PA
CA Building
North Washington Shw
er PA 16001
)262-7812
S of w.1- Pennsylmia, Ia.
E. Plank Road
ona PA 16602
Mifflin St-A
linedon PA 16652
DfNorthuslcm Pcnrvyl-i.
S 0f No lhmom. Pcnn5)4varoa omit OpporturyCabin G of Seho)ikill County
Abingum Pxa b- Park Sim 1 N-6 Cavc Sued
s Summio PA 18411 as M. PA 17901
567-9163 or(800)922-9537 570)622-1995
(570)587-9134/9135 AX(570)622-04Z9
"CASTERCOLWTY LYCOM)NG COUNTY
rmarniry Housing Counselor, I= Of Northeastern vanh
Rm 244
loan Sgesn PA 19346 1 W Masket &
3)414-3662 Box 1127
K (610)444-6243 ffflk?Bnvrc PA 16702
57D)S21-0837 er(BW)922-9537
S of w w= PenO Annis- Inc. AX (570)921-1785
Soulb Gorge Strm
k PA 17403 40D Abingloo Exeadive Park, Stdte 1
7)646.4176 Sworal5 PA 15411
570)587-9163 a (BDD)922.9537
S of Lehigh Valley AX (570)587-913V9135
1 C-ead Coon Eee
tekall PA I RDS2 1 Bodo Strew
1)9214011 or (800)220.2733 WffmspDn PA 37703
) & (814) ONLY 570)3216627
K (215)921-8932 - AX (570)923-9626
or Cwraamky Services foes
E King Strct cancausaw For Commonly Acbm (STEP)
aner Pa 17602 138 Lionolo Saes
'}397-5182 or(800)788-5062 10 Boa 1326
(717)3994127 Lualpot PA 17703
7
570)326-0567
ofweoem COUNTY
11 Federal Pha-Slik 406 rho F. Kennedy Ceder, Ism
Mill Shan 1 Fast 20* Sweat
ew C..dc PA 16101 :rkPA 16510
4)952-8074 614)996-0400
AX (814)9994I43
12 Chesus t Shed, Stone 227
adviik PA 16335 Tim Cwoamfty Action Carp
814)333-6570 - Box 369
" 35 west 41 Strat
So Valley Urban I cape, Inc. PA 15634
111th-, Avenue 814)486-1161
arreB PA 16121 AX(814)4VA=S
724961-5310
mole{ OppotOmBia ofliow Cmoy wffiRCER COUNTY
Carpodran 94 Sulk 207
PA ISW9 M-W VAI y Urbae Logue, lane
4)726-7202
1 I I.&- A-
AX (41Z)728.7202
1 MUD PA 16121
724)991-5310
sf wawa Pnresylvda, foe
? 1311130[
Opportunity Cabled of sdayOdll -W 39 Nosh wad"XI o Sand
Nora Centre Such 00e PA 16001
gknik PA 17901 4)282-7812
570)922-1995
AX (570)922-0429
AWFUN C
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39 E rmS Saw of wcLlm Pameylvaeia. foe
Pa 17602 17 E. Plank Rood
717)997-5182 or (&DD)78S-5062 Uncoon PA 16602
AX (717)3994127 149(4-6100
AX (814)9445747
IGH COUNTY DCCS OF NorOxadmo PA
631 S AOterton Sk Sulk 100
of Lehigh Valley College PA 16601
671 Crvoat Coun East 914)931-3668
II PA I ZDS2 AX (614) 23&3669 ,
610)9214011 or (600)220.2733
70)&(114)ONLY eadmiealiea Olfia
AX (610)921.6932 17 Mi(BinSaar
atingdm PA 16652
nnk OppoAunily Cabind of Schuylkill ny 614)943-2343
25 North Cewc Saw
otaviOc PA 179DI
5 70)622-1995 h ONROE COUNTY
AX (570)622-0429
ofNonhonem Pa Wania
ZERNE COUNTY 1 W Marlin SC
Boa 1127
of Nonhadern Pea vane ills -Bane PA 15702
5 70)921-0837 or (800)922-9537
1 W Mwkci SI AX (570)921-1715
Box 1127
ilka-Bore PA 18702 Soul T Sftd
5 70)921-0837 or (800)2.9537 ao W W.X PA 18360
AX (570)821-1765 5 70) 420.5960 or (600)922-9537
AX (570)420-8961
4 00 Abingdon Exenulivc Ark Suite I
arks Summin PA 19411 4 00 Abington FxecWw Park Suile 1
5 70)S87-9163 m (600922-9537 'l arkagwarun1UPA 18411 ,
AX (57D)587-91349135 3 70)587-9163 or (6 0 0)922-95 3 7
AX (570)517-91349135
mmiasion on Ecoromin Oppomniry of Lan County
6 3 Amber Lane mminim on Fionomies Opporlmiy of Larose Canny
ilkes-Bare PA 18702 6 3 Amber Lane
5 70)926-0510 or (800)622-0359 flees-Have PA 19702
m Housing Corooo000
)Jmth Broad Sam
addphU PA 19130
0765-1221
:(215)765-)427
:S fDairarare Valley
i.u m Bus n- Center
W Gemuntovm Putt, Suite 140
isuetvn PA 19401
)563-5665
b-a Counseling Sirs
N Broad Sv=
,delpho PA 19;41
)324-7500
.(215)324-8753
remrity Action Developrtnx Consni aim
Yblh Sued
ismwu PA 19401
{277-6363
(610)277-2173
W Market St
Box 1127
Oars-Banc PA 16702
0)821-0537 m(500)922-9537
X (570)61--1785
0 Abington Eseeudw Park, Suite 1
rks Smnmib PA 15411
0)587.9163 or (500)922-9537
K (570)557-9134/9135
Basic So.%
I'mnspert PA 17703
))323-6627
( (S70)323-6626
nomie Oppoooity cabinet of scetwkill county
North Centre Street
wille PA 17901
1)622-)995
(570)622-0429
m of Western Pemsy{vame, 1.
2000 Ungkdw Road
iarriaGsg PA 17102
717)541-1757
AX (717)5414670
4/o I.rague of Mdmptalilan Hamebtcg
107 N 61 Street
.&burg PA 17101
7)7)234-5925
'AX (717)234-9459
'WCA of Carlisk
01 G Street
:arihle PA 17013
717)243-3619
AX (717)731-9569
6anda) Comsdiog Swices of F-kr.
1 West 31S0ed
hyuesbmo PA 17265
717)762-3295
1.9we i-tion O6tm
17 Mitttin Sped
uodngdote PA 16652
14)643-2343
otonurniy Action Cwrmoesion of the Capita Region
S14 Deny Street
snisburg PA 17104
17)232-9757
AX (717)2342227
tram Housing Corporation
46 Norm Broad Shed
'hiladdphia PA 19130
215)765-1221
AX (2I5) 765-1427
lort)-st Counseling Service
DDI N Broad Street
hiladdphia PA 19141
1-15)3247500
AX (215)324-9753
:CCS of Ddavnre Valley
515 Market Shed, Suite 132.5
hiladelphia PA 19107
215)363-5665
AX(215)563-7020
eda Fen-&ip Horse
2 S hcksoe So=
Ai. PA 19D63
10)565-0k46
X(610)565-8567
:CA
D North 17' Strcl, Suit. 600
a.Mphia PA 19103
:5)567-7803
X(215)963-9941
= ofDchvntte Valley
c Cherry Hill, Suite 215
eny Hill w 09082
SA63-5665
using Am istioo of Dehwaee Valley
)D Wahm Street, Sufic 601
iladelphia PA 19102 I'..
5)545-6D10 ?i-
X (215)790-9132
ad., Aaxiation ofDdawan: Vntlry
I Nam Wakes sued
hdclpbis PA 19123 1
5)978-0224
X(215)765-7614
rmmiy Devdopmrm Cory ef`F.ldasd?
up Mmiwy
0 Oriscona Street
Wdphis PA 19124
5)744.2990
K (215)744.2012
,reap C "&d fS...wlim bsdhde
C.". SI
beavllk PA 19320
1)212.6741
E Dekalb Pike
tofPm,aia PA 1%06
0971.2210
Yok Rd, Suite 103
minder PA 18974
: (215)956.63"
1 W Market St
0 Box 1127
fi0res-Bone PA IBM
)4)121-0537 -(500)122-9537
AX (570)821-1755
Storm 71 shed
hondsbtrg PA 15360
70) 420-IM or (500)922-9537
AX (570N2048981
100 Abington E..ugve Pads, Sr0e 1
lads SemmiltPA 18411
70)587-9163 or (800)922-9537
lX (570)557-91349135
'hem Tier Conaranliy Aedm Corp
Wed 41 Sued
uro PA 15534
)456.1161
(914)456-0825
dgd CDunWig Censor
7 Nom Fifth Strcct
n8ng PA 19601
0)375-7566
X(610)375-3380
mrniaion m Economics Oppomniy of!
I Artier Lane
Iker-Bore PA 18702
0)126-0510. (soo)sn-0359
X (570)529-1665--LL BEFORE FA)
0)4554994 HAZELTON
X (570)455-5631- CALL BEFORE FA)
0)8364090 T13NXHANNOCK
norok Opportunity Cabind of Schuylkill
North Centre Street
urine PA 17901
0)622-1995
K 1370)6224429
lx of LAigh Valley
Be. A
hehall PA 18052
9)824-1011
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_ n?
3T
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-07178 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HSBC BANK USA NA
VS
REILEY LORRAINE R
MARK CONKLIN
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
REILEY LORRAINE R
DEFENDANT
the
at 1935:00 HOURS, on the 12th day of December-, 2008
at 505 GEARY AVENUE
NEW CUMBERLAND, PA 17070
MARK REILEY
by handing to
SON
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 15.30
Postage .58
Surcharge 10.00
.00
43.88
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
12/15/2008
STERN & EISENBERG
By:
Deput Sheriff
of A. D.
RIjCI-IARD F. STERN, ESQUIRE
y/TEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
Defendant(s)
Civil Action Number: 08-7178 CIVIL
TERM
MORTGAGE FORECLOSURE
PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Enter judgment in favor of Plaintiff and against Defendant(s), Lorraine R. Reiley, for failure of said
Defendant(s) to file a responsive pleading to the Complaint within twenty (20) days of service thereof.
PRINCIPAL BALANCE .......................................................$71,833.63
INTEREST accrued thru 12/05/2008 of ............................... $3,084.04
Interest after 12/05/2008 shall accrue at the per diem
rate of $20.02.)
LATE CHARGES accrued thru 12/05/2008 of ..................... $255.86
Late charges after 12/05/2008 shall accrue at the monthly
rate of $30.68.)
ESCROW ADVANCES.
.................................................. $829.38
J:\Supriya\Sales\Cumberland\Ocwen. Reiley.08.09. doe
FEES BILLED .......................................................................$259.68
COSTS ...................................................................................300.00 *54* 6"'J&
ATTORNEY'S FEE .............................................................. $3,600.00
Sub-Total Through Date of Complaint ............................$80,162.59
ACCRUED INTEREST after 12/05/2008 shall accrue
at the per diem
rate of $20.02 to August 14, 2009 .........................................$5,045.04
ACCRUED LATE CHARGES Late charges
after 12/05/2008 accruing at the monthly rate of
$30.68 through August 14, 2009 ...........................................$245.44
TOTAL DUE THROUGH DATE OF REQUEST
FOR JUDGMENT ................................................................. $85,453.07
STERN AND EISENBERG LLP
BY:
,?VIN MRD F. STERN, ESQUIRE
VEN K. EISENBERG, ESQUIRE
P. DISKIN, ESQUIRE
Date: August 14, 2009 Attorney for Plaintiff
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09.doc
U?"q
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DIsxIN, EsQuIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
Civil Action: 08-7178 CIVIL TERM
MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF MONTGOMERY
I, the undersigned, being duly sworn according to law, deposes and says, to the best of his
knowledge, information and belief, Defendants':
Last-known address is
505 Geary Avenue, New Cumberland, PA 17070
2. Is over the age of twenty-one.
3. Is not now nor has been within the last six (6) months in the Armed Services of the
United States as defined in the Soldiers' Civil Relief Act of 1940, as amended.
STERN AND EISENBERG LLP
0OMMO"MkL-TM? sr VANA
NOTARIAL SEAL
HELEN CAPASSO, Notary Public
Jenkintown Som., Montgomery County
Commission Expires October 21, 2012
Sworn to and subscrib d before me
this Day of 92009.
4.10 4-4-a&2
Notary Public
BY:
EN K. EISENB RG
CHARD F. STERN
KEVIN P. DISKIN
Attorney for Plaintiff
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09. doc
?' ? "i.
....
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
Defendant(s)
JTJW
,XN
rVI AR D F. STERN
Attorney for Plaintiff
CERTIFICATION UNDER RULE 237.1
I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day
notice of intention to enter judgment by default was sent to Defendants in accordance with Pa. R.C.P.
No. 237.1., a true and correct copy of which is attached hereto.
Civil Action: 08-7178 CIVIL TERM
MORTGAGE FORECLOSURE
STERN AND EISENBERG LLP
BY:
S K. EISENBERG
N P. DISKIN
N
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09. doe
! .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
HSBC Bank USA National Association,
As Trustee, By its attorney in fact,
Ocwen Loan Servicing, LLC, successor
vs.
LORRAINE R. REILEY
To: Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
Date of Notice: July 30, 2009
NO. OB-7178 Civil Term
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEYAND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) 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 NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:]
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.
COURT ADMINISTRATOR
4TH FL., CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
J:VWTEN DAY\CUMBERLANDIOCWEN.REILEY.LORRAINE.R.07.09.DOC
ST ?EISENBERG LLP
KEVIN . DISKIN
Attorney for Plaintiff
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I.D. #86727
k8r??,"rct
OF THE PROTHONOTARY
2009 AUG 17 PM 2= 16
€'ENNSYLifAaN A
414. cc> p a Awl
(x* I59'5.2
ex* aaaa-7a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
HSC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Egi.ity Loan Trust 2007-2, by its attorney in
fa(.t, Ocwen Loan Servicing, LLC
VS.
Lorraine R. Reiley
-O THE PROTHONOTARY OF THE SAID COURT:
( ) Confessed Judgment
( ) Other
File No. 08-7178 Civil Term
Amount Due $85,453.07
Interest from 8/15/09 at the per diem rate of
$20.02 until judgment is paid in full.
Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
.ccount based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
I pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County,
f )r debt, interest and costs, upon the following described property of the defendant(s)
Lorraine R. Reilev
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
(,state, supply six copies of the description; supply four'copies of lengthy personalty list)
<<nd all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date August 14, 2009 Signature:
Print Name
Address:
Attorney for:
Telephone
Kevin P. Diskin, Esquire
261 Old York Road
T h- Pavilion, Suite 4-10
Jenkintown, PA 19046
Plaintiff
(215)572-8111
Supreme Court ID No.: 86727
(over)
0
IWAF
2009 AUG 17 Phi 2: 16
GOUNTY
PENNSYLVANIA
.$a4.oo
g3.88
78.50
14. oo
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PO AT-ry
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Cv-*O 1,59W
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RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
Defendant(s)
Civil Action: 08-7178 CIVIL TERM
MORTGAGE FORECLOSURE
CERTIFICATE UNDER ACT 91 OF 1983
It is hereby certified that the Sheriffs Sale scheduled in the above-captioned matter is not
protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L. 1688,
No.. 621 because notice, as required, was sent to Defendants and no timely response was made.
STERN AND EISENBERG LLP
BY:
EVEN K. EISENBERG
;'/RICHARD F. STERN
KEVIN P. DISKIN
Attorney for Plaintiff
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09. doe
R r
OF THE PROTHIMTARY
2009 AUG 17 PM 2., 16
P'ENNS` LVAMA,
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Civil Action: 08-7178 CIVIL TERM
Lorraine R. Reiley
Defendant(s)
MORTGAGE FORECLOSURE
CERTIFICATION OF ADDRESS
It is hereby certified that the last known addresses of the parties are as follows:
HSBC Bank USA, N.A.
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
(Plaintiff)
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
(Defendant(s))
BY:
STERN AND EISENBERG LLP
S7VEN K. EISENBERG
CHARD F. STERN
KEVIN P. DISKIN
Attorney for Plaintiff
J:\S upriya\S ales\Cumberland\Ocwen. Reiley.08.09. doc
FIoF THE WTPCNOTARY
2009 AUG 17 PM 2; 16
PENNSYLVANtA.
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DIsKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
Civil Action: 08-7178 CIVIL TERM
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for
the Writ of Execution was filed, the following information concerning the real property located at 505
Geary Avenue, New Cumberland, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
2. Name and address of Defendant(s) in the judgment:
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
New Cumberland Boro
1120 Market Street
PO Box 220
New Cumberland, PA 17070
Greenpoint Mortgage Funding
2300 Brookstone Center Parkway
Columbus, OH 31904
7:\Supriya\Sales\Cumberland\Ocwen. Reiley.08.09. doc
4. Name and address of the last recorded holder of every mortgage of record:
N/A
5. Name and address of every other person who has any record lien on the property:
N/A
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:
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128
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:
Domestic Relations Tax Claim Bureau
Cumberland County Cumberland County Courthouse
13 North Hanover Street One Courthouse Street
Carlisle, PA 17013 Carlisle, PA 17013
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. Section 4904 relating to unsworn falsification to authorities.
Date: August 14, 2009
STERN AND EISENBERG LLP
SIT EN K. EISENBERG
BY:
CHARD F. STERN
VIN P. DISKIN
Attorney for Plaintiff
Sworn o and subsc ibed before me
this D y of t4q , 2009.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
HELEN CAPASSO, Notary Public
Jenkintown Boro., Montgomery County
My Commission Expires October 21, 2012
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09.doc
Zt}09 AUG ? ? PM 2' 16
CUM, t 4iJ ; j:)UNTY
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Civil Action: 08-7178 CIVIL TERM
Lorraine R. Reiley
Defendant(s)
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
Your real estate at 505 Geary Avenue, New Cumberland, PA is scheduled to be sold at Sheriffs Sale
on Wednesday, MARCH 3, 2010 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (location of sale) to enforce the court judgment of $85,453.07 obtained by HSBC
Bank USA, N.A. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and
Eisenberg LLP, telephone (215) 572-8111.
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09. doc
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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111.
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 Stern and Eisenberg LLP, telephone (215) 572-8111.
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 a 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 on a date specified by the
Sheriff no later than 30 days after the sale date. 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 the date of filing
of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine
the actual date of filing of said schedule.
7. You may also have other rights and defenses, or ways of getting your house 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09. doe
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
Civil Action: 08-7178 CIVIL TERM
MORTGAGE FORECLOSURE
RE: PREMISES: 505 Geary Avenue, New Cumberland, PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above Defendant.
As a result of a default, the above referenced premises, also described on the attached sheet, will be
sold by the Sheriff of Cumberland County on Wednesday, MARCH 3, 2010 at 10:00 A.M. at Sheriffs
Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $85,453.07 together with
interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of
Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have
discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so
that you can protect your interest, if any, in the lien you have on the premises. If you have any
questions regarding the type of lien or the effect of the Sheriff s Sale upon your lien, we urge you to
CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30
days after the sale date and the distribution will be made in accordance with the schedule unless
exceptions are filed thereto within ten (10) days thereafter.
August 14, 2009
STERN AND EISENBERG LLP
L
B
./STEVEN K. EISENBERG
Zl' RICHARD F. STERN
KEVIN P. DISKIN
Attorney for Plaintiff
J:\Supriya\Sales\Cumberland\Ocwen. Reiley.08.09. doc
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land, situate in the,Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey by D.P.
Raffensperger Associates, dated June 4, 1971, asfollows, to wit:
BEGINNING on the Northeast corner of Smith Avenue and Geary Avenue thence along the
Eastern side of Geary Avenue North 45 degrees 45 minutes West 70 feet to a point at the division
line between Lots Nos. 28 and 29 on the hereinafter mentioned Plan of Lots; thence along said
last mentioned division line North 44 degrees 15 minutes East 115.5 feet (Plan shows 116.5 feet)
to a point at the division line between Lots Nos. 28 and 36 on said Plan; thence along said last
mentioned line and along the division line between Lots Nos. 28 and 37, South 58 degrees 15
minutes (Plan shows 14 minutes) East 71.69 feet to a point on the Northern side of Smith Avenue;
thence along the Northern side of Smith Avenue South 44 degrees 15 minutes West 131 feet to a
point, the place of BEGINNING.
BEING Lot No. 28 on Plan of Lots of Hillside Manor, which Plan is recorded in the Office of the
Recorder of Deeds for Cumberland County in Plan Book 1.1, page 21.
Parcel No. 25-24-0811-133
HAVING thereon erected premises known and numbered as 505 Geary Avenue.
UNDER AND SUBJECT to all conditions, restrictions, reservations, and limitations of record against
this property.
TITLE IS VESTED IN: Lorraine R. Reiley, single person, by that Deed, dated August 13, 1990, and
recorded on August 24, 1990, in Book 534, at Page 1055, of the Cumberland County Records.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-7178 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HSBC BANK USA, N.A., as Indenture Trustee for the
registered Noteholders of RENAISSANCE HOME EQUITY LOAN TRUST 2007-2, by its attorney
in fact, OCWEN LOAN SERVICING, LLC, Plaintiff (s)
From LORRAINE R. REILEY
(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 $85,453.07
L.L. $.50
Interest from 8/15/09 at the per diem rate of $20.02 until judgment is paid in full -- to be determined
Atty's Comm %
Due Prothy $2.00
Atty Paid $162.88 Other Costs
Plaintiff Paid
Date: 8/17/09
urtis R. Long, P o ota
(Seal) By:
Deputy
REQUESTING PARTY:
Name: KEVIN P. DISKIN, ESQUIRE
Address: STERN AND EISENBERG, LLP
261 OLD YORK ROAD
THE PAVILION, SUITE 410
JENKINTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111
Supreme Court ID No. 86727
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION-LAW
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I.D. #86727
HSBC Bank USA, N.A., as Indenture Trustee for the
registered Noteholders of Renaissance Home Equity Loan
Trust 2007-2, by its attorney in fact, Ocwen Laon Servicing,
LLC
V. Civil Action Number: 08-7178 CIVIL TERM
Lorraine R. Reiley
Defendant(s)
CERTIFICATE OF SERVICE
I, KEVIN P. DISKIN, ESQ., attorney for the within Plaintiff, hereby certify
that notice of the Sheriff's Sale was mailed to the Defendants by certified mail,
return receipt requested on December 28, 2009, as evidenced by copy of
certified mail receipts attached.
I further certify that notice of the Sheriff's Sale was mailed to each
lienholder by regular, first-class, postage prepaid mail on December 28, 2009, as
evidenced by copy of certificates of mailing attached.
STERN AND EISENBERG LLP
BY:
KEVIN P. DISKIN
Attorney for Plaintiff
12/28/09
J:\ANN\CERTIFICATES\CUMBERLAND\OCWEN.REILEY.12.09.DOC
Posta) Service UN/TE?DSTGTES
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co Lorraine R. Reiley New Cumberland, PA 17070 -- ° m
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G7y. Sfale, Z17i4 New Cumberland, PA 17070 '° PS Form 3817, qpf? 2007 PSN 7530.02_ c
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Carlisle, PA 17013 Carlisle, PA 17013 --' <
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o m° o PS Form 3817, ° ° °
PS Form 3817, April 2007 PSN 7530-02-000-9065 April 2007 PSN 7530-02.000_gpfi5
UNITEDSTATES
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UNITEDSTdTES
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To: M Y
Greenpoint Mortgage Funding
- 2300 Brookstone Center Parkway - ° a-°
- Columbus, OH 31904 - ,p
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PS Form 3817, April 2007 PSN T530-02-000.9065
2 ?C 3 E F'
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
r'
F:
20i0 A ?? 23 F' 3 ?.3
Edward L Schorpp
Solicitor
z
HSBC Bank USA
vs. Case Number
.
Lorraine R Reiley 2008-7178
SHERIFF'S RETURN OF SERVICE
09/24/2009 07:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09-24-09
at 1950 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 Lorraine R. Reiley, located at 505 Geary Avenue, New
Cumberland, Cumberland County, Pennsylvania according to law.
09/24/2009 07:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 09-24-09
at 1950 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: Lorraine R. Reiley, by making known unto,
Michael Reiley, adult in charge, at 505 Geary Avenue, New Cumberland, Cumberland County,
Pennsylvania its contents and at the same time handing to him personally the said true and correct copy
of the same.
11/23/2009 Property sale postponed to 3/3/2010.
03/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice
had been given according to law, he exposed the within described premises at public venue or outcry at
the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 3, 2010 at 10:00 o'clock A.M. He
sold the same for the sum of $1.00 to Attorney Richard Stern, on behalf of , being the buyer in this
execution, paid to Sheriff Ronny R. Anderson, the sum of $ 933.20
SHERIFF COST: $933.20 SO ANSWERS,
(5?,, N . zzj??
April 23, 2010 RONW R ANDERSON, SHERIFF
-?ijl M_
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DIsKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINToWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
S
Civil Action: 08-7178 CIVIL TERM
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe for
the Writ of Execution was filed, the following information concerning the real property located at 505
Geary Avenue, New Cumberland, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
2. Name and address of Defendant(s) in the judgment:
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
New Cumberland Boro
1120 Market Street
PO Box 220
New Cumberland, PA 17070
Greenpoint Mortgage Funding
2300 Brookstone Center Parkway
Columbus, OH 31904
J:\Supriya\S ales\Cumberl and\Ocwen.Reiley.08.09. doc
4. Name and-address of the last recorded holder of every mortgage of record:
N/A
5. Name and address of every other person who has any record lien on the property:
N/A
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:
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128
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:
Domestic Relations Tax Claim Bureau
Cumberland County Cumberland County Courthouse
13 North Hanover Street One Courthouse Street
Carlisle, PA 17013 Carlisle, PA 17013
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. Section 4904 relating to unswom falsification to authorities.
Date: August 14, 2009
Sworn o and subsc ibed before me
this D y of , 2009.
Notary Public
STERN AND EISENBERG LLP
BY:
T EN K. EISENBERG
CHARD F. STERN
KEVIN P. DISKIN
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
HELEN CAPASSO, Notary Public
Jenkintown Boro., Montgomery County
My Commission Expires October 21, 2012
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09. doc
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Civil Action: 08-7178 CIVIL TERM
Lorraine R. Reiley
Defendant(s)
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
Your real estate at 505 Geary Avenue, New Cumberland, PA is scheduled to be sold at Sheriffs Sale
on Wednesday, MARCH 3, 2010 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (location of sale) to enforce the court judgment of $85,453.07 obtained by HSBC
Bank USA, N.A. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and
Eisenberg LLP, telephone (215) 572-8111.
J:\Supriya\Sales\Cumberl and\Ocwen.Reiley.08.09. doc
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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111.
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 Stern and Eisenberg LLP, telephone (215) 572-8111.
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 a 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 on a date specified by the
Sheriff no later than 30 days after the sale date. 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 the date of filing
of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine
the actual date of filing of said schedule.
7. You may also have other rights and defenses, or ways of getting your house 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\Supriya\Sales\Cumberland\Ocwen. Reiley.08.09. doc
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIN11LE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Lorraine R. Reiley
Civil Action: 08-7178 CIVIL TERM
MORTGAGE FORECLOSURE
RE: PREMISES: 505 Geary Avenue, New Cumberland, PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above Defendant.
As a result of a default, the above referenced premises, also described on the attached sheet, will be
sold by the Sheriff of Cumberland County on Wednesday, MARCH 3, 2010 at 10:00 A.M. at Sheriffs
Office, Cumberland County Courthouse, Carlisle, PA 17013 (subject to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $85,453.07 together with
interest, costs (and such other allowed amounts) thereon entered in the above matter in favor of
Plaintiff against the above-named Defendant(s) who is/are also the real owner of said premises. I have
discovered that you may have a lien and/or interest in the premises to be sold. This notice is given so
that you can protect your interest, if any, in the lien you have on the premises. If you have any
questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to
CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30
days after the sale date and the distribution will be made in accordance with the schedule unless
exceptions are filed thereto within ten (10) days thereafter.
August 14, 2009
STERN AND EISENBERG LLP
L
_e_? -
B
TEVEN K. EISENBERG
RICHARD F. STERN
KEVIN P. DISKIN
Attorney for Plaintiff
J:\Supriya\S ales\Cumberl and\Ocwen.Reiley.08.09. doc
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land, situate in the:Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey by D.P.
Raffensperger Associates, dated June 4, 1971, as-follows, to wit:
BEGINNING on the Northeast corner of Smith Avenue and Geary Avenue thence along the
Eastern side of Geary Avenue North 45 degrees 45 minutes West 70 feet to a point at the division
line between Lots Nos. 28 and 29 on the hereinafter mentioned Plan of Lots; thence along said
last mentioned division fine North 44 degrees 15 minutes East 115.5 feet (Plan shows 116.5 feet)
to a point at the division line between Lots Nos. 28 and 36 on said Plan; thence along said last
mentioned line and along the division line between Lots Nos. 28 and 37, South 58 degrees 15
minutes (Plan shows 14 minutes) East 71.69 feet to a point on the Northern side of Smith Avenue
thence along the Northern side of Smith Avenue South 44 degrees 15 minutes West 131 feet to a
point, the place of BEGINNING.
BEING Lot No. 28 on Plan of Lots of Hillside Manor, which Plan is recorded in the Office of the
Recorder of Deeds for Cumberland County in Plan Book 1.1, page 21.
Parcel No. 25-24-0811-133
HAVING thereon erected premises known and numbered as 505 Geary Avenue.
UNDER AND SUBJECT to all conditions, restrictions, reservations, and limitations of record against
this property.
TITLE IS VESTED IN: Lorraine R. Reiley, single person, by that Deed, dated August 13, 1990, and
recorded on August 24, 1990, in Book 534, at Page 1055, of the Cumberland County Records.
RICHARD F. STERN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG LLP
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKAITowr1, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSRvIILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney in fact,
Ocwen Laon Servicing, LLC
V.
Civil Action: 08-7178 CIVIL TERM
Lorraine R. Reiley
Defendant(s)
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
Your real estate at 505 Geary Avenue, New Cumberland, PA is scheduled to be sold at Sheriffs Sale
on Wednesday, MARCH 3, 2010 at 10:00 A.M., at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (location of sale) to enforce the court judgment of $85,453.07 obtained by HSBC
Bank USA, N.A. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern and Eisenberg, LLP the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call Stern and
Eisenberg LLP, telephone (215) 572-8111.
J:\Supriya\Sales\Cumberland\Ocwen.Reiley.08.09. doc
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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling Stern and Eisenberg LLP, telephone (215) 572-8111.
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 Stern and Eisenberg LLP, telephone (215) 572-8111.
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 a 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 on a date specified by the
Sheriff no later than 30 days after the sale date. 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 the date of filing
of said schedule. You should check with the Sheriffs Office by calling (717) 240-6390 to determine
the actual date of filing of said schedule.
7. You may also have other rights and defenses, or ways of getting your house 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\Supriya\S a1es\Cumber1and\0cwen.Rei1ey.08.09. doc
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land, situate in the:Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey by D.P.
Raffensperger Associates, dated June 4, 1971., as.follows, to wit:
BEGINNING on the Northeast corner of Smith Avenue and Geary Avenue thence along the
Eastern side of Geary Avenue North 45 degrees 45 minutes West 70 feet to a point at the division
line between Lots Nos. 28 and 29 on the hereinafter mentioned Plan of Lots; thence along said
last mentioned division line North 44 degrees 15 minutes East 115.5 feet (Plan shows 116.5 feet)
to a point at the division line between Lots Nos. 28 and 36 on said Plan; thence along said last
mentioned line and along the division line between Lots Nos. 28 and 37, South 58 degrees 15
minutes (Plan shows 14 minutes) East 71.69 feet to a point on the Northern side of Smith Avenue;
thence along the Northern side of Smith Avenue South 44 degrees 15 minutes West 131 feet to a
point, the place of BEGINNING.
BEING Lot No. 28 on Plan of Lots of Hillside Manor, which Plan is recorded in the Office of the
Recorder of Deeds for Cumberland County in Plan Book 1.1, page 21.
Parcel No. 25-24-0811-133
HAVING thereon erected premises known and numbered as 505 Geary Avenue.
UNDER AND SUBJECT to all conditions, restrictions, reservations, and limitations of record against
this property.
TITLE IS VESTED IN: Lorraine R. Reiley, single person, by that Deed, dated August 13, 1990, and
recorded on August 24, 1990, in Book 534, at Page 1055, of the Cumberland County Records.
WRIT OF EXECUTION and/or ATTACHMENT
COMI\4-ON'WEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-7178 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HSBC BANK USA, N.A., as Indenture Trustee for the
registered Noteholders of RENAISSANCE HOME EQUITY LOAN TRUST 2007-2, by its attorney
in fact, OCWEN LOAN SERVICING, LLC, Plaintiff (s)
From LORRAINE R. REILEY
(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 $85,453.07
L.L. $.50
Interest from 8/15/09 at the per diem rate of $20.02 until judgment is paid in full -- to be determined
Atty's Comm %
Atty Paid $162.88
Plaintiff Paid
Date: 8/17/09
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs 4 Curtis R. Lon , o onota
By:
Deputy
Name: KEVIN P. DISKIN, ESQUIRE
Address: STERN AND EISENBERG, LLP
261 OLD YORK ROAD
THE PAVILION, SUITE 410
JENKINTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111
Supreme Court ID No. 86727
Real Estate Sale #
On September 15, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Borough of New Cumberland, Cumberland County, PA
Known and numbered as 505 Geary Avenue,
New Cumberland, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: September 15, 2009
By: ?
?
Real Estate oordinatofr
f;
?iir, .
LAW OFFICES
Stern and Eisenberg LLP
261 Old York Road. The Pavilion. Suite 410. Jenkintown, PA 19046-3722. Telephone: (215) 572.8111. Facsimile: (215) 572.5025
New Jersey Office: 22 North Main Street . Lambertville, NJ 08530 . Telephone: (609) 397.9200
August 14, 2009
RE: HSBC BANK USA, N.A.
VS. LORRAINE R. REILEY
C.C.P. CUMBERLAND CO. NO. 08-7178 Civil Term
Sheriff s Office
Cumberland Courthouse
One Courthouse Square
Carlisle, PA 17013
Dear Sir or Madam:
Please make service upon the Defendants at the following address:
Lorraine R. Reiley
505 Geary Avenue
New Cumberland, PA 17070
Please also return an affidavit of service when completed in the enclosed, self-addressed stamped
envelope. Thank you.
KPD/sp
Enclosures
Very truly yours,
KJ:\Supriya\Sales\Cumberland\Ocwen. Reiley.08.09.doc
Richard F. Stern/rstern@sterneisenberg.com . Steven K. Eisenberg*/seisenberg@sterneisenberg.com . Kevin P Diskin*/kdiskin@sterneisenberg.com
Margery J. Schneider*/mschneider@sterneisenberg.com *Admittted to practice in PA&NJ
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land, situate in the Borough of New Cumberland,
Cumberland County, Pennsylvania, bounded and described in accordance with a survey by D.P.
Raffensperger Associates, dated June 4, 1971, as-follows' to wit:
BEGINNING on the Northeast corner of Smith Avenue and Geary Avenue thence along the
Eastern side of Geary Avenue North 45 degrees 45 minutes West 70 feet to a point at the division
line between Lots Nos. 28 and 29 on the hereinafter mentioned Plan of Lots; thence along said
last mentioned division line North 44 degrees 15 minutes East 115.5 feet (Plan shows 116.5 feet)
to a point at the division line between Lots Nos. 28 and 36 on said Plan; thence along said last
mentioned line and along the division line between Lots Nos. 28 and 37, South 58 degrees 15
minutes (Plan shows 14 minutes) East 71.69 feet to a point on the Northern side of Smith Avenue
thence along the Northern side of Smith Avenue South 44 degrees 15 minutes West 131 feet to a
point, the place of BEGINNING.
BEING Lot No. 28 on Plan of Lots of Hillside Manor, which Plan is recorded in the Office of the
Recorder of Deeds for Cumberland County in Plan Book 1.1, page 21.
Parcel No. 25-24-0811-133
HAVING thereon erected premises known and numbered as 505 Geary Avenue.
UNDER AND SUBJECT to all conditions, restrictions, reservations, and limitations of record against
this property.
TITLE IS VESTED IN: Lorraine R. Reiley, single person, by that Deed, dated August 13, 1990, and
recorded on August 24, 1990, in Book 534, at Page 1055, of the Cumberland County Records.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 08-7178 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HSBC BANK USA, N.A., as Indenture Trustee for the
registered Noteholders of RENAISSANCE HOME EQUITY LOAN TRUST 2007-2, by its attorney
in fact, OCWEN LOAN SERVICING, LLC, Plaintiff (s)
From LORRAINE R. REILEY
(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 gamishee(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 $85,453.07
L.L. $.50
Interest from 8/15/09 at the per diem rate of $20.02 until judgment is paid in full - to be determined
Atty's Comm %
Atty Paid $162.88
Plaintiff Paid
Date: 8/17/09
(Seal)
REQUESTING PARTY:
Name: KEVIN P. DISKIN, ESQUIRE
Address: STERN AND EISENBERG, LLP
261 OLD YORK ROAD
THE PAVILION, SUITE 410
JENKINTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-81.11
Due Prothy $2.00
Other Costs
Curtis R. Lon ono ry
By:
Deputy
yt rt; t.:,::.
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Supreme Court ID No. 86727
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, October 30 and November 6, 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.
r-
Coyne,
SWOMS; TO AND SUBSCRIBED before me this
6 day of November, 2009
Notary
F OTARIAL SEAL
RAH A COLLINS
otary Public
O, CUMBERLAND COUNTY
ion Expires Apr 28, 2010
Writ No. 2008-7178 civil
HSBC Bank USA, N.A., as
indenture Trustee for the
registered Noteholders of
Renaissance Home Equity Loan
Trust 2007-2, by its attorney in
fact, Ocwen Loan Servicing, LLC
VS.
Lorraine R. Reiley
Atty: Kevin P. Diskin
ALL THAT CERTAIN piece or par-
cel of land, situate in theBorough
of New Cumberland, Cumberland
County, Pennsylvania, bounded
and described in accordance with
a survey by D.P. Raffensperger As-
sociates, dated June 4, 1971 as;.
follows, to wit:
BEGINNING on the Northeast
corner of Smith Avenue and Geary
Avenue thence along the Eastern side
of Geary Avenue North 45 degrees 45
minutes West 70 feet to a point at the
division line between Lots Nos. 28
and 29 on the hereinafter mentioned
Plan of Lots; thence along said last
mentioned division line North 44
degrees 15 minutes East 115.5 feet
(Plan shows 116.5 feet) to a point at
the division line between Lots Nos.
28 and 36 on said Plan; thence along
said last mentioned line and along
the division line between Lots Nos. 28
and 37, South 58 degrees 15 minutes
(Plan shows 14 minutes) East 71.69
feet to a point on the Northern side
of Smith Avenue; thence along the
Northern side of Smith Avenue South
44 degrees 15 minutes West 131 feet
to a point, the place of BEGINNING.
BEING Lot No. 28 on Plan of Lots
of Hillside Manor, which Plan is re-
corded in the Office of the Recorder
of Deeds for Cumberland County in
Plan Book 11, page 21.
Parcel No. 25-24-0811-133.
HAVING thereon erected premises
known and numbered as 505 Geary
Avenue.
UNDER AND SUBJECT to all
conditions, restrictions, reservations,
and limitations of record against this
property.
TITLE IS VESTED IN: Lorraine R.
Reiley, single person, by that Deed,
dated August 13, 1990, and recorded
on August 24, 1990, in Book 534,
at Page 1055, of the Cumberland
County Records.
The Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
the Patr1*ot*tXews
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587,' Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
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
10/30/09
11/06/09
Sworn to and ubscribed before me this 16 day of ovember, 2009 A.D.
-._- Notary Public '?`
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal i
Sherrie L. Kisner, (Votary Public
City Of Haririsburg, Dauphin County
My Commission Expire* Nov. 26, 2011
Member, Pennsylvania Asao.iation of Notaries
Writ. No. 2008-7178 Civil Term
HSBC Bank USA, N.A., as
indenture Trusts for the
registered Noteholders of
Renaissance Home Eilulty Loan
'trust 2007-2, by Its attorney In
fact, Oman Lo4in Servicing,
LLC
Vs
Lorraine R. Relloy
Atty: Kevin P. Makin
ALL THAT CERTAIN piece or parcel of land,
situate in theBorough of New Cumberland,
Cumberland County, Pemsyivania, bounded and
described in accordance with .a survey by D.P.
RaMnsperger Associates, dated June 4, 1971
as;;follows, to witi
BEGINNING on the Northeast comer of Smith
Avenue. and Geary Avenue 'thence along the
Eastern side of Geary Avenue North 45 degrees
45' minutes West 70 feet to a point at the division
fine between Lots Nos. 28 and 29 on the
hereinafter mentioned Plan of Lots; thence along
said last mentioned division line North 44
degrees 15 minutes East 1155 feet (Plan shows
116.5 feet) to a point atthe'division line between
Lots Nos. 28 and 36 on. said Plan; thence along
said last mentioned line and along the division
line between Lots Nos. 28 and 37, South 58
degrees 15 minutes (Plan shows 14 minutes)
East 71.69 feet to a point on the Northern side of
Smith Avenue; thence along the Nortpem side.of
Smith Avenue South 44 degrees 15 minutes
West, 131 feet to a point, the place of
BEGINNING.
BEING Lot No. 28 on Plan of Lots of Hillside
Manor, which Plan is recorded in the Office of
the Recorder of Deeds for Cumberland County
in Plan Book 11, page 21.
Parcel No. 25-24881.1-133
HAVING thereon erected premises known and
numbered as 505 Geary Avenue.
UNDER AND SUBJECT to all conditions,
restrictions, reservations, and limitations of
record against this property,
TrIU IS VESTED IN: Lorraine R. Reiley;
single person, by that Deed, dated August l3,
1990, and recorded on August 24,1990, in Book
534, at Page 1055, of the Cumberland County
Records.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which RENAISSANCE HOME EQUITY LOAN TRUST 2007-2 AIF/TR is the
grantee the same having been sold to said grantee on the 3RD day of MARCH A.D., 2010, under and by
virtue of a writ Execution issued on the 17TH day of AUG, A.D., 2009, out of the Court of Common
Pleas of said County as of Civil Term, 2008 Number 7178, at the suit of RENAISSANCE HOME
EQUITY LOAN TRUST 2007-2 AIF/TR against LORRAINE R REILEY is duly recorded as
Instrument Number 201010266.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this -? 6
A.D. a olo
day of
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