HomeMy WebLinkAbout09-0550SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1 ;
PLAINTIFF
VS. ;
Melody L. Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
?"?o C F V , rih
NO.. 6 9 _ - l --t
CIVIL ACTION - EJECTMENT 21000
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN
TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY
ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO
SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY
CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED
BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS
IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
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.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED
QUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS
SIGUIENTES,USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA
DE LADEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA
APARIENCIAESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA
CORTE ENFORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS
ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE,LA
CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED
SINPREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE
ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO OSUS
PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO
TIENEABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDECONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
05-24646
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee COURT OF COMMON PLEAS
for the registered holders of the Renaissance CUMBERLAND COUNTY
Home Equity Loan Asset-Backed
Certificates, Series 2005-1 NO.:
PLAINTIFF
VS.
Melody L. Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS ;
CIVIL ACTION - EJECTMENT
Plaintiff hereby complains against Defendants as follows:
1. Plaintiff, HSBC Bank USA, N.A., as Indenture Trustee for the registered holders
of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-1 ("Plaintiff'), a
corporation, has an office located at 1665 Palm Beach Lakes, Suite 105, West Palm Beach, FL
33401, and is properly conducting business in the Commonwealth of Pennsylvania.
2. Defendants are Melody L. Pottorff and Occupants ("Defendants") and they reside
at 1012 Mill Road, Mechanicsburg, PA 17050 (the "Premises").
3. The Premises, which is where the ejectment is to take place, is located at 1012
Mill Road, Mechanicsburg, PA 17050. A true and correct copy of the legal description of the
Premises, is attached hereto, incorporated herein by reference, and marked as Exhibit "A."
4. The Premises were sold at Sheriffs sale by the Sheriff of CUMBERLAND
County, Pennsylvania, after due advertisement and according to law, under and by virtue of a
Writ of Execution issued to satisfy a Judgment in Mortgage Foreclosure entered in the Court of
Common Pleas of Cumberland County, Pennsylvania, at the suit of. HSBC Bank USA, N.A., as
Indenture Trustee for the registered holders of the Renaissance Home Equity Loan Asset-Backed
Certificates, Series 2005-1 v. Melody Potorff.
The case number of said Judgment is: 05-5074.
6. The Sheriffs sale was held on: December 10, 2008
7. Melody L. Pottorff and Carmi M. Wire were the previous owners of the
Premises by virtue of a Deed dated January 7, 2005, and recorded in the Office of the Recorder
of Deeds for CUMBERLAND County, Pennsylvania on January 18, 2005, in Deed Book 267,
Page 876, CUMBERLAND County, Pennsylvania and the said Carmi M. Wire departed this life
on or about August 6, 2007 thereby vesting title in Melody L. Pottorff.
8. Plaintiff purchased the Premises at the Sheriffs sale.
9. Plaintiff acquired valid title to the Premises on the date of and by virtue of
said Sheriffs sale.
10. Plaintiff is still the real owner of said Premises and is entitled to immediate
possession of the Premises.
11. The Deed in favor HSBC Bank USA, N.A., as Indenture Trustee for the
registered holders of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-
1 was recorded with the CUMBERLAND County Department of Records as Instrument No.
200840571, on December 29, 2008.
12. Said Deed is a matter of public record and therefore, is hereby incorporated
by reference herein as though fully set forth at length. A true and correct copy of the Sheriff s
Deed, is attached hereto, incorporated herein by reference, and marked as Exhibit "B."
13. The persons in possession of the Premises are believed to be the Defendants
in this action who are occupying the Premises without right and without claim to title.
14. Plaintiff is entitled to immediate possession of the Premises.
WHEREFORE, Plaintiff demands judgment, in ejectment, for immediate possession of
the Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in
this action.
Respectfully submitted,
SHAPIRO & DENARDO, LLC
Date: n7 BY:
Leg ie J. Rase, Esquire
Attorney for Plaintiff
File # 05-24646
ALL THAT CERTAIN lot or tract of land situate in Hampden Township, Cumberland County,
Pennsylvania, more particularly bounded and described as follwsa, to wit:
BEGINNING at a point on the center line of a public road at the southeast corner of lands now or
formerly of Adam Snyder; thence North 40 degrees 13 minutes East by lands now or formerly of
Adam Snyder for a a distance of 165.71 feet to a stake; thence South 49 degrees 30 minutes East
for a distance of 72 feet to a stake; thence North 89 degrees 14 minutes East for a distance of
51.38 feet to a stake; thence South 38 degrees 35 minutes East by lands now or formerly of
Grantor leased to Lloyd Ehy for a distance of 25 feet to a stake; thence South 38 degrees 56
minutes West by lands now or late of Herbert Abel for a distance of 202.65feet to a point on the
center line of said public road; thence North 45 degrees 28 minutes West by said center line for a
distance of 140.28 feet to to point and place of BEGINNING.
BEING Tract No. 9 and 10 on a series of separate surveys made by D.P. Raffensperger,
Registered Surveyor, and dated April 9, 1956, and improved with a one story frame dwelling
with a basement garage.
BEING the same premises which Kurt Anthony Stelzer and Elizabeth L. Stelzer, husband and
wife, by Deed dated January 7, 2005 and recorded in the Cumberland County Recorder of Deeds
Office on January 18, 2005 in Deed Book 267, page 876, granted and conveyed unto Melody L.
Potorff and Carmi M. Wire.
EXHIBIT "A"
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200840571
Recorded On 12129/2008 At 9:32:21 AM * Total Pages - 5
* Instrument Type - DEED-SHERIFF'S
Invoice Number - 34392 User ID - MSW
* Grantor - POTTORFF, MELODY L
* Grantee - REGISTERED HOLDERS OF THE RENASISSANCE HOME EQUITY LOAN ASSET-BAC
* Customer - SHERIFF
* P'bE8
STATE IMIT TAX
STATE JCS/ACCESS TO
JUSTICE
RECORDING FEES -
RECORDER OF DEEDS
PARCEL CERTIFICATION
VMS
AFFORDABLE HOUSING
COU14TY ARCHIVES rSE
ROD ARCHIVES FEE
CWtBERLIIND VALLZY SCHOOL
DISTRICT
RANPDEN TOIINSHIP
TOTAL PAID
$0.50
$10.00
$12.50
$10.00
$11.50
$2.00
$3.00
$0.00
$0.00
$49.50
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
RECORDER O/D D$
• - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
EAh;b;V "8"
y . D`lle._
000u01
Tax Parcel No. 10-17-1033-026
Know all Men by these Presents
That I, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of
Pennsylvania, for and in consideration of the sum of $1.00, (One Dollar), to me in hand
paid, do hereby grant and convey to HSBC Bank USA, N.A., as Indenture Trustee for
the Registered Holders of the Renaissance Home Equity Loan Asset-Backed
Certificates, Series 2005-1
Real Estate Sale No. 43
Writ No. 2005-5074 Civil Term
HSBC Bank USA N.A., as Indenture Trustee for the registered holders of the
Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-1
VS
Melody L. Pottorif
Attomey Michael Clark
LEGAL DESCRIPTION
ALL THAT CERTAIN tot or tract of land situate in Hampden Township, Cumberland County,
Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on the center line of a public road at the southeast comer of lands now or formerly
of Adam Snyder, thence North 40 degrees 13 minutes East by lands now or formerly of Adam Snyder for a
distance of 165.71 feet to a stake; thence South 49 degrees 30 minutes East for a distance of72 feet to a
stake; thence North 89 degrees 14 minutes East for a distance of 51.38 feet to a stake; timmm South 38
degrees 35 minutes East by lands now or formerly of Grantor leased to Lloyd Eby for a distance of 25 feet
to a stake; thence South 38 degrees 56 minutes West by lands now or late of Herbert Abel for a distance of
202.65feet to a point on the center line of said public road; thence North 45 degrees 28 minutes West by
said center line for a distance of 140.28 feet to the point and place of BEGINNING.
BEING Tract No. 9 and 10 on a series of separate surveys made by D.P. Raffensperger, Registered
Surveyor, and dated April 9,1956, and improved with a one story frame dwelling with a basement garage.
BEING the same premises which Kurt Anthony Stelzer and Elisabeth L. Stelzer, husband and wife, by
Deed dated January 7, 2005 and recorded in the Cumberland County Recorder of Deeds Office on January
18, 2005 in Deed Book 267, page 876, granted and conveyed unto Melody L. Pottorff and Canni M. Wire.
The same having been sold by me to the said grantee on the 10th day of December Anno
Domini Two Thousand and Eight (2008) after due advertisement according to law,
under and by Virtue of a Writ of Execution issued on the 22nd day of August Anno
Domini 2008 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and Five (2005) Number 5074 at the suit of HSBC Bank
USA, N.A., as Indenture Trustee for the registered holders of the Renaissance Home
Equity Loan Asset-Backed Certificates, Series 2005-1 against Melody L. Pottorfl.
l7he same having been sold by me to the said grantee on the 10th day' of December Anna
Domini Two Thousand and Eight (2008) after due advertisement according, to law,
under and by Virtue ofa Writ of Execution issued on the 22nd day of August Anno
Domini 2008 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Term. Two Thousand and Five (2005) Dumber 5074 at the suit of HSBC Bank
USA, N.A., as Indenture Trustee for the registered holders' of the Renaissance Home
Equity Loan Asset-Backed Certificates, Series 2005-::1 against Melody L. J"ottorff
1 auau tagea uny urive
Orlando, .FL 32826
S icitor
VERIFICATION
The undersigned, an officer of the Corporation, which is the Plaintiff in the foregoing
Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being
authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth
in the foregoing Complaint are taken from records maintained by persons supervised by the
undersigned who maintain the business records of the Property held by Plaintiff in the ordinary
course of business and that those facts are true and correct to the best of the knowledge,
information and belief of the undersigned.
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: January 26, 2009
tTLE Jessica bas
Defaul Se icing Liaison
NY: O Loan Servicing, LLCs
File # 05-24646
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SHERIFF'S RETURN - REGULAR
CASE NO: 2009-00550 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HSBC BANK USA N A
VS
POTTORFF MELODY L ET AL
SHAWN HARRISON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within NOTICE was served upon
POTTORFF MELODY L the
DEFENDANT
, at 0016:22 HOURS, on the 5th day of February-, 2009
at 1012 MILL ROAD
MECHANICSBURG, PA 17050
MELODY POTTORFF
a true and attested copy of NOTICE
COMPLAINT IN EJECTMENT
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
of
So Answers:
18.00
10.80 J
.00 10.00 R. Thomas Kline
.00
38.80 02/06/2009
SHAPIRO & DEN
By:
day Deput Sheriff
A.D.
by handing to
C\j
- Y
SHERIFF'S RETURN - REGULAR
CASE NO: 2009-00550 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HSBC BANK USA N A
VS
POTTORFF MELODY L ET AL
SHAWN HARRISON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within NOTICE was served upon
OCCUPANT(S) the
DEFENDANT at 0016:22 HOURS, on the 5th day of February , 2009
at 1012 MILL ROAD
MECHANICSBURG, PA 17050
JEREMY HART (ADULT SON)
a true and attested copy of NOTICE
COMPLAINT EJECTMENT
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscibed to
before me this
of
So Answers:
6.00
r?? 'rc mt.C
.00
.00
10.00 R. Thomas Kline
.00
16.00 02/06/2009
SHAPIRO & DENAR
By:
day eputy Sheriff
, A. D.
by handing to
together with
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SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
VS.
Melody Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
PRAECIPE FOR JUDGMENT FOR POSSESSION
FOR FAILURE TO ANSWER
Enter Judgment for immediate possession of the Premises located at: 1012 Mill Road,
Mechanicsburg, PA 17050, in favor of Plaintiff and against the Defendants above captioned for
failure to file an answer to Plaintiffs Complaint within 20 days from service of the Complaint.
BY. G%
eslie J. Rase, Esquire
Attorney for Plaintiff
AND NOW, judgment for immediate possession of the Premises located at 1012 Mill
Road, Mechanicsburg, PA 17050 is entered in favor of th laintiff and ainst the Defendants.
o. Prothy.
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF
vs.
Melody Pottorff and Occupants
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Melody Pottorff
DATE OF NOTICE: February 26, 2009
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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,
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.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE
SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10)
DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNA PODRA, SIN NECESIDAD DE COMPARARECER
USTED IN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA. USTED PUEDE
PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN
ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCIA LEGAL:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Melody Pottorff
1012 Mill Road
Mechanicsburg, PA 17050
Occupants
1012 Mill Road
Mechanicsburg, PA 17050
Leslie J. Rase, Esquire
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF ;
Vs.
Melody Pottorff and, Occupants
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Occupants
DATE OF NOTICE: February26, 2009
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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,
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.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE
SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10)
DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNA PODRA, SIN NECESIDAD DE COMPARARECER
USTED IN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA. USTED PUEDE
PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN
ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCIA LEGAL:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Melody Pottorff
1012 Mill Road
Mechanicsburg, PA 17050
Occupants
1012 Mill Road
Mechanicsburg, PA 17050
Leslie J. Rase, Esquire
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610) 278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF
VS.
Melody L. Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 04 , _5',SU - Lo,'v ,
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF Florida
COUNTY OF Orange
s.s..
THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are
based upon investigations made and records maintained by us either as Plaintiff or as servicing
agent of the Plaintiff herein and that the above named Defendant(s) are not in the Military or
Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors
Civil Relief Act of 1940, as amended, and that the age and last known residence and employment
of each Defendant are as follows:
Defendant: Melody L. Pottorff
Age: Over 18
Residence: 1012 Mill Road, Mechanicsburg, PA 17-050
Employment: Unknown
Defendant: OCCUPANT
Age: Unknown
Residence: 1012 Mill Road, Mechanicsburg, PA 17050
Employment: Unknown
essica
Sworn to and subscribed
before me this 26th day
of January 2009.
Olul
Notary PublicIc/
icing Liaison
Loan Servicing, LLC
MYCO •,•,n,??w?q A Q LIftM
3 ON # 00801078
p`Y f4, 20f?
05-24646
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF
VS.
Melody Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
CERTIFICATE OF SERVICE
I, Leslie J. Rase, Esquire hereby certify that I have served true and correct copies of the
attached papers upon the following persons named herein at their last known address or their
attorney of record by regular mailing, postage pre-paid, as follows, on
Melody Pottorff
1012 Mill Road
Mechanicsburg, PA 17050
Current Occupant
1012 Mill Road
Mechanicsburg, PA 17050
BY:
d s J. Rase, Esquire
Attorney for Plaintiff
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Curtis R. Long, Prothonotary
TO: Melody Pottorff
1012 Mill Road
Mechanicsburg, PA 17050
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF
VS.
Melody Pottorff and Occupants ;
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, ou are hereby notified that a
Judgment has been entered against you in the ove e i gas indicated below.
urtis R. L g
Prothonotary
[XX] Judgment by Default
[XX] Judgment for Possession
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY LESLIE J. RASE, ESQUIRE BY CALLING (610) 278-6800
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Curtis R. Long, Prothonotary
TO: Occupant
1012 Mill Road
Mechanicsburg, PA 17050
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1 ;
PLAINTIFF
VS. ;
Melody Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, yoq are hereby notified that a
Judgment has been entered against you in the ve pr c in s indicated below.
Curtis R. ong
Prothonotary
[XX] Judgment by Default
[XX] Judgment for Possession
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY LESLIE J. RASE, ESQUIRE BY CALLING (610) 278-6800
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
VS.
Melody Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Kindly issue a Writ of Possession in the above matter for property located at 1012 Mill
Road, Mechanicsburg, PA 17050 as more fully described in the Complaint.
(Costs to be added) $
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WA IRO & DENARDO, LLC
LESLIE J. RASE, ESQUIRE
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SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
PLAINTIFF
VS.
Melody Pottorff and Occupants
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1
The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for
the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of
record, if any, after the default occurred and at least (10) days prior to the date of the filing of the
Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto,
February 26, 2009, to:
Melody Pottorff
1012 Mill Road
Mechanicsburg, PA 17050
Occupants
1012 Mill Road
Mechanicsburg, PA 17050
Laraine Colwell, Legal Assistant
SHAPIRO & DENARDO, LLC
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SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 05-24646
HSBC Bank USA, N.A., as Indenture Trustee
for the registered holders of the Renaissance
Home Equity Loan Asset-Backed
Certificates, Series 2005-1
1665 Palm Beach Lakes, Suite 105
West Palm Beach, FL 33401
PLAINTIFF
VS.
Melody Pottorff and Occupants
1012 Mill Road
Mechanicsburg, PA 17050
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-550-CIVIL
CERTIFICATION OF ADDRESS
I hereby certify that the correct addresses of the judgment creditor (Plaintiff) and that the
last known address of the judgment debtors (Defendants) are as above.
SHAPIRO & DENARDO, LLC
BY:
Leslie J. Rase, Esquire
Attorney for Plaintiff
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WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HSBC BANK USA, N.A, as
Indenture Trustee for the registered
holders of the RENAISSANCE HOME
EQUITY LOAN ASSET-BACKED
CERTIFICATES, SERIES 2005-1
12650 Ingenuity Drive
Orlando, Florida 32826
VS. No. 09-550 Civil Term_
MELODY POTTORFF and
OCCUPANTS
1012 Mill Road
Mechanicsburg, PA 17050
Costs
Attorney's $ 171.30
Plaintiff s $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
HSBC BANK USA, N.A, as Indenture Trustee for the registered holders of the RENAISSANCE
HOME EQUITY LOAN ASSET-BACKED CERTIFICATES, SERIES 2005-1,
being: (Premises as follows):
1012 MILL ROAD, MECHANICSBURG, PA 17050
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
(YA'"420
is R. Lo o ono ,
Common Pleas Court of timberland County, PA
Date 3/10/09
(Seal)
2of2
No 09-550 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
HSBC BANK USA, N.A, as
Indenture Trustee for the registered
holders of the RENAISSANCE HOME
EQUITY LOAN ASSET-BACKED
CERTIFICATES, SERIES 2005-1
VS.
MELODY POTTORFF and
OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 171.30
Plff (s) $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
LESLIE J. RASE, ESQUIRE
SHAPIRO & DENARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
610-278-6800
ID# 58365
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the day of I caused the within
named , to have possession of the premises described with the
appurtenances, and
Sworn and subscribed to before me this
Day of ,
So Answers,
Sheriff
Sheriffs Office of Cumberland County
R Thomas Kline 4oOt r of f luffbrrf y? Edward L Schorpp
Sheriff Solicitor
Ronny R Anderson °. z .' Jody S Smith
Chief Deputy <)MCE F 7?< SPCRIFr Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
03/16/2009 07:37 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on March 16,
2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action,
upon the within named defendant, to wit: Melody Pottorff, by making known unto Joshua Pottorff, adult in
charge for Melody, at 1012 Mill Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and
at the same time handing to him personally the said true and correct copy of the same.
03/16/2009 07:37 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on March 16,
2009 at 1937 hours, he served a true copy of the within writ of possession, in the above entitled action,
upon the within named defendant, to wit: Occupant(s), by making known unto Joshua Pottorff, occupant,
at 1012 Mill Road, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time
handing to him personally the said true and correct copy of the same.
05/18/2009 By virtue of this writ, on the 14th day of May, 20091 caused the within named HSBC Bank USA, N.A., as
Indenture Trustee for the registered holders of the Renaissance Home Equity Loan Asset-Backed
Certificates, Series 2005-1, to have possession of the premises described as 1012 Mill Road,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
SHERIFF COST: ; $ 1 0 3. 6 3
May 18, 2009 ? 9,
09-3 -_0
SO ANSWERS,
R THOMAS KLINE, SHERIF
a_
By virtue of this writ, on the 14th day of May, 2009 _,I
caused the within named HSBC Bank USA, N.A., as Indenture Trustee for the re istered
holders of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-1, to have
possession of the premises described 1012 Mill Road, Mechanicsburg, Cumberland
Count Pennsylvania, 17050
Sworn and subscribed to before me this
Day of
Sheriff's Return
Docketing
Poundage
Prothonotary
Mileage
Possession
Surcharge
$ 18.00
2.03
2.00
21.60
30.00
30.00
$ 103.63
LS E d J i ?`a6? ?QQZ
Advance Costs
Sheriff s Costs
$ 250.00
103.63
$ 146.37
So Answers,
By
Prothonotary Deputy
W2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HSBC BANK USA, N.A, as
Indenture Trustee for the registered
holders of the RENAISSANCE HOME
EQUITY LOAN ASSET-BACKED
CERTIFICATES, SERIES 2005-1
12650 Ingenuity Drive
Orlando, Florida 32826
VS. No. 09-550 Civil Term_
MELODY POTTORFF and
OCCUPANTS
1012 Mill Road
Mechanicsburg, PA 17050
Costs
Attorney's $ 171.30
Plaintiff's $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
HSBC BANK USA, N.A, as Indenture Trustee for the registered holders of the RENAISSANCE
HOME EQUITY LOAN ASSET-BACKED CERTIFICATES, SERIES 2005-1,
being: (Premises as follows):
1012 MILL ROAD, MECHANICSBURG, PA 17050
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
Cuftis R. Lon onota ,
Common Pleas Court of Cumberland County, PA
Date 3/10/09
(Seal)
r
2of2
No 09-550 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
HSBC BANK USA, N.A, as
Indenture Trustee for the registered
holders of the RENAISSANCE HOME
EQUITY LOAN ASSET-BACKED
CERTIFICATES, SERIES 2005-1
VS.
MELODY POTTORFF and
OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 171.30
Plff (s) $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
LESLIE J. RASE, ESQUIRE
SHAPIRO & DENARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
610-278-6800
ID# 58365
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the
named
appurtenances, and
day of . I caused the within
_, to have possession of the premises described with the
Sworn and subscribed to before me this
Day of ,
So Answers,
Sheriff