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Home My WebLink About09-1375UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE --ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the Renaissance Home Equity Loan ":Cumberland County Asset-Backed Certificates, Series 2005-1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. Jeffrey Gaver 137 G Shirley Gaver NO. (? 9 109 Locust Street Shippensburg, PA 17257 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT NAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE LSTA DENANDA A UN ABOGADO INNEDIATAMWT ', SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCZTENTRA ESCRITA ABAJO PARA AVERIGVAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: HSBC Bank USA, N.A., as Indenture Trustee for the registered holders of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-1 Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 109 Locust Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Shippensburg COUNTY: Cumberland DATE EXECUTED: 1/12/05 DATE RECORDED: 2/18/05 BOOK: 1897 PAGE: 3024 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said mortgage as of 12/16/09: Principal of debt due $48,600.23 Unpaid Interest at 8.79% from 7/1/08 to 12/16/08 (the per diem interest accruing on this debt is $11.81 and that sum should be added each day after 12/16/08) 1,966.23 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthly late charge of $6.47 should be added in accordance with the terms of the note each month after 12/16/08) 19.74 Property Inspection 10.50 BPO 111.00 Attorneys Fees (anticipated and actual to 5% of principal) 2,430.01 TOTAL $53,742.71 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant (s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $53,742.71 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. U Ws , P.C. BAintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE oOLOUIS A. SIMONI, ESQUIRE ALL MT CERTAW lot of ground with the two and one half story frame dwelling boune and other necessary outbuildings thereon es'eteed, knovan as 109 Locust Street, situate is the Borough of FPsnsbu To Comty of Orland and Commonweiath of , Pe"msylvaai.a, boundid and described as foilowe SW At a Point Of the But side of Locust street at llr*r of lot now ar formerly of Frank Robgasons aheAce BODY alOng Locust-Street twenty nine (29) feet t0 s paint; tMa a Bastaardly along land now or formerly of Wolf and E, Wolf, ninerY two (02) feet ten (10) inches Ord an to a peca ; thes?ct along lot mw or fosfer2Y of Rex B. Gilbert, now Or farmerl.y =marked by a fence line, Southwardly tweet - feet: thencs a1mg said lot now or farmarly of Frank Robinson, awnumn. Y ninety two (82) feet ten (lo) inches to the place of 01116 TM SAME PR$MXU8 which M & M PAMZ&ls,. a general partner8hip, haviag as partners Benjamin R. trtuueser, Sr., and R. Mueser. Jr.., by Deed dazed and recorded February zs, 1986 in the CffiGt Ct the Recarder of needs in and foz Cumberland City, Pennsylvania, in Deed Sock 135, Page 109, granted be cOrmc ed UntO Richard Nalcolm Morria?, Jr. and OCKWENLoan Servicing, LLC 12650 Ingenuity Drive Orlando, Florida 32826 OCWEN WWW.OCWEN.COM November 13, 2008 Shirley Gaver 109 Locust Street Shippensburg, PA 17257 Loan Number: Property Address: 102074028 109 Locust Street, Shippensburg, PA 17257-0000 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515123711801 Reference Code: 0811 PLEASE SEE THE ENCLOSED DOCUMENT LXHisIT A DACr91.12 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. OCWENLoan Servicing, LLC yo3 r 12650 Ingenuity Drive C C W E N Orlando, Florida 32826 November 13, 2008 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE WWW.OCWEN.COM This is an official notice that he mortgage on YM home is in dnfsnl} and he lender intnnrl to foreclose, Sp? 1nfnoldon about the nature of the default is provided in the attached page. The HOMEOWNER'S MORTGAGE ASSTS NCE PROGRAM Notice explains how the program works may be able to help to save your home This The name, address and Rhone number of Consumer Credit ounse ing ABenci serving your County are fisted at the end of this Notice. If you h_ ave?nv a lestmns you may call the Peanaylvania Housing F;nancP Agency tob free at 1.800-342.2397 (Persons with Impaired hearing can call (717) 780-1862)v LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION PZKEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDPM R SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Shirley Gaver 109 Locust Street Shippensburg, PA 17257-0000 102074028 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. OCWEN DACT91.12 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. io OCWENLoan Servicing, LLC i 12650 Ingenuity Drive o O C W E N Orlando, Florida 32826 WWW.OCWEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE. ELIGIBLE FOR FINANCIAi ASSiSTANCF WHICH N A YOUR HO FORECLOSURE A HELP YOU MAKE FUTURE MO>aTCAGE pA)M •M IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TED[PORARY STAY OF FOR EC O RF -Under the A cL you are enfid .i to a jim . a Oy of foreciosu an morft-we for thirty !3111 Aove f. - +6e A-- ..t a1.... AT. L.-_ '?__--- your YOUR MORTGAGE DEFALII T" EXPi AiNS HOW TO RM YOM MORTGAGE UP TO D=. CONSITM E F TT O 1NSFL ING A N IFS -If you -meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days alter the date of this meeting. Tg names. addres - and telenhone numbers of designated consumer credit counseling agencies for the county in which the l y is located are set forth at the end of this Nnti;i It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORT A ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). DACT91.12 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. OCWENLoan Servicing, LLC i 12650 Ingenuity Drive O C W E N Orlando, Florida 32826 WWW.OCWEN.COM HOW TO CUTRF. YOirR MORTr_AGF n??.rTr T (Bring ft up to date)* NATUR OF DEFA Ti T -The MORTGAGE debt held by the above lender on your property located at: 109 Locust Street, Shippensburg, PA 17257-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 4 payments in the amount of $ 517.82 from August 01, 2008 through November 13, 2008 DETAIL SUMMARY Principal and Interest ................................. $ 1,579.12 Interest Anmrage ..................................... $ 0.00 Escrow .......................................... : $ 472 29 .... ... Late Charges ........................................... . $ 0.00 Insufficient Funds Charges ........................... $ 0.00 Fees / Expenses ........................................ $ 290.21 Suspense Balance (CREDIT ........................ $ 0.00 Interest Reserve Balance (CREDIT ................ $ 0.00 TOTAL DUE.......................................... $ 2,341.62 HOW TO TRF. TuF. nFFArn T _ You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,341.62, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa, ents most be made either by Monev m bier' heck, Cfled r h k or Money Order made payalb]e and sent to OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197.6440 IF YOU DO NOT Q= THE D XA1T1 T _ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exemse is right to accelerate he morlg$ge debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mo and i? ! fly. IF THE MORT A I FO ECLOS D UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY 0 DAY period, you will not be squired to pay attorney's fees. OTHER LENDER EA=IES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CiTRF TNF nFFAiTi T PRiOR T jai RiEE'S SAi F _ If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have he right to U n the default and prevent the sale at annv time un to nne hnnr hafnrn tha Ck.Af Pa e..i,. v___ other costs connected with the Sheriff. as spec fled in writing by the lender 9nd by Red mmg my other requirements ceder the mom OV, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE S F i MS SAi DAT _ It is estimated that the earliest date that such a Sheriff's 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. DACT91.12 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. OCWENLoan Servicing, LLC t 12650 Ingenuity Drive a c w e N Orlando, Florida 32826 Name of Servicer: OCWEN HOW TO CONTACT THE SERVICER: Address: P.O. BOX 24737 WEST PALM BEACH, FL 33416-4737 Phone Number: 877-596,8580 Fax Number: 407-737-5693 Contact: LRC TMA TeamA WWW.OCWEN.COM 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 continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASS121 TION OF MORTGAGE _ you may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO H A THE RI AT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSLUR CRFDIT COUNSELING A FN 4 4F---- yO TR ['(IiTNTY DACr91.12 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 12650 Ingenuity Drive O C W E N Lando, Florida 32826 November 13, 2008 Jeffrey Gaver 109 Locust Street Shippensburg, PA 17257-0000 Loan Number: 102074028 Property Address: 109 Locust Street, Shippensburg, PA 17257-0000 WWW.OCWEN.COM VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515123711771 Reference Code: 0811 PLEASE SEE THE ENCLOSED DOCUMENT DACT91.12 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. i OCWENLoan Servicing, LLC 12650 Ingenuity Drive O C W E N Orlando, Florida 32826 November 13, 2008 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE WWW.OCWEN.COM The HOMEOwntFR'S MORT A I T NCF PRO RARi (IlE1?`AP) Notice explains how the program works, ----?y?e able bo heln to save your home '? h•c LA NOTIFICACION EN ADJUNTO ES DE SUMA PAPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Jeffrey Gaver 109 Locust Street Shippensburg, PA 17257-0000 102074028 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. OCWEN DACT91.12 This communication is from a debt collector attempting to collect a debt, any information obtained will be used for that purpose. OCWENLoan Servicing LLC f 12650 Ingenuity Drive o c w e N lando, Florida 32826 WWW.OCWEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBL FOR EEAKTAi ASSISTANCE 111IIICA CAN SAVE YOUR -HOME FROM FORECLOSLII2F ADUD LP YOU MAKE FiTTITRF. MnurnAr_E uAVwmw,.na IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. U MUST BRING YOUR MORT AGE LIP TO DATF TIIF PART OF *i I`'OTTCF CAi.i,Fi?"HOW TO C TRF YOUR MORTGAGE DEFAULT FXPi.AiNC HOl TO BRIM YOUR MORTGAGE Up To D A Tr, COQ R CREDTT CO TNSFI INC Ar,E----- - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. Tjg names. addresses and telephone numbers of designated consumer cre?it coun4e ieg agencies for the county 1n which v is located are set forth at he end n thi Nohcp. It is only neces ? the your lender imm iately of your intentions. y to schedule one face-to-face meeting. Advise APPLICATION FOR MORTGAGE ASSIRTANIr- - your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). DACT91.12 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. a OCWENLoan Servicing, LLC j 12650 Ingenuity Drive a,1 O O W E N ando, Florida 32826 WWW OCWEN.COM HOW TO CIiRF. TGA!GE A DER A iI T Bring it uuun to datel NATURE OF THE D FA n T -The MORTGAGE debt held by the above lender on your property located at: 109 Locust Street, Shippensburg, PA 17257-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 4 payments in the amount of $ 517.82 from August 01, 2008 through November 13 20118 DETAIL. SUMARy Principal and Interest ................................. $ 1 579.12 Interest Arrearage ..................................... Escrow , $ 0.00 .................................................. Late Charges ......... $ 472.29 .................................. Insufficient Funds Charges ........................... $ 0.00 $ 0 00 Fees / Expenses ........................................ S B l . $ 290.21 uspense a ance (CREDIT) ........................ $ 0 00 Interest Reserve Balance (CREDIT) ................ . $ 0 00 TOTAL DUE .......................................... . $ 2,341.62 HOW TO C-1 1RF TuE. nE>+Arrr T - you may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER , WHICH IS PA YMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE $2,341.62, PLUS ANY MORTGAGE THIRTY (30) DAY PERIOD. Pa ents must be Made either by Moncy Gram. cashi. r ed Check or Mon OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-0440 IF YOU DO NOT CURE THE D U T _ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender Intends to a ndo _u lights to Accelerate ¦• ____ .- the ¦¦rtgage debt, This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to fuse anon your mo gggI pmt IF THE AMT A r_F IS FORECLOSED 1PnN - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal Proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY p :io3• you will not be aguired to pLy attorney's fees. OTHER L.. R RENEUiFS - The lender may also sue you personally for the un aid sums due under the mortgage. P Principal balance and all other RIGHT TO CLmF THE DEFAULT PDr..R TO SHERIFF'S SAIS, - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, y_ou still have the right to cusp the ?el'ault and prevent at any time iM to one hour befon-dw-ShUM 2V 11,111, 11 1111113i 1110 so by RmAng the 1QW p lus my Inte or other ch r then due reasonable attorna's fees a a? coring ? with the fwe do a k a W gaff-SOUL i the Sheriff's ale As specified in writing by the lender a d by perform . - -other nquieements under the mortgage Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. FART JEST POSSIBi F ? 'S i DA - It is estimated that the earliest date that such a Sheriff's 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. DACT91.12 This communication is from a debt collector attempting to collect a debt, any information obtained will be used for that purpose. I OCWEIV Loan Servicing, LLC i 12650 Ingenuity Drive 0 o w E N Orlando, Florida 32826 Name of Servicer: OCWEN HOW TO CONTACT THE SERVICER: Address: P.O. BOX 24737 WEST PALM BEACH, FL 33416.4737 Phone Number: 877-5965580 Fax Number: 407-737-503 Contact: LRC TMA TeamA WWW.OCWEN.COM EFFECT OF SHERIFF'S SAL F _ You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGA[`F _ You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RrGH . TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING A FN('TFS SERVING YOUR COUNTY DACT91.12 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. V E R I F I .C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the' 'source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. U EN FJFIC P . C . BY: ' Attorn aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE "LOUIS A. SIMONI, ESQUIRE f- Q4Sy rl" rW c ti p P ca' ? 9 <'= f i C A ?^ V C:? n Sheriffs Office of Cumberland County R Thomas Kline sv'p rf Cumbtr Edward L Schorpp Sheri 44# Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE of THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/12/2009 06:35 PM - William Cline, Deputy Sheriff, who being duly swom according to law, states that on March 12 2009 at 1835 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey Gaver by making known unto Jeffrey Gaver personally, at 214 E. Orange Street, Apt. A, Shippenburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/12/2009 06:35 PM - William Cline, Deputy Sheriff, who being duly swom according to law, states that on March 12 2009 at 1835 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Shirley Gaver by making known unto Jeffrey Gaver, husband of defendant, at 214 E. Orange Street, Apt. A, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $62.00 (PAID) March 17, 2009 S , R THOMAS KLINE, SHERIFF Deputy Sheriff Docket No. 2009-1375 HSBC Bank (U.S.A.) N.A. v Jeffrey Gaver & Shirley Gaver Fn ... , JJC3 ?i 23 C GA) 24 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingeoudren. com ATTORNEY FOR PLAINTIFF HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the 'Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. Jeffrey Gaver :NO. 09-1375 Shirley Gaver 109 Locust Street Shippensburg, PA 17257 214 E. Orange Street Apartment A Shippenburg, PA 17257 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and Defendant(s) Jeffrey Gaver and Shirley Gaver for failure Answer to Plaintiff's Complaint within 20 days from service for foreclosure and sale of the mortgaged premises, Plaintiff's damages as follows: As set forth in Complaint $53,742.71 Interest Per Complaint 1,405.39 From 12/17/08 to 4/14/09 Late charges per Complaint 19.41 From 12/17/08 to 4/14/09 against the to file an thereof and and assess TOTAL $55,167.51 Aft r I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY: Attorneys for P1 Ciff MARK J. UDREN, SQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE : A ?, ? ly _ ZG??R PRO PROTHY UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE,. ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKSKA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Dleadinaseudren.com 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, FL 32826 Plaintiff V. Jeffrey Gaver Shirley Gaver 109 Locust Street Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION C3 Cumberland County E r= tT7 ra i ?., 556 r c Cn 5 E5 rn NO. O - 3 l COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 al;Z05?6-- (I anerirrs vin-ce ort,umoeriana uoumy R Thomas Kline 4'?Ov of cau Edward L Schorpp Sheri Solicitor h. ? g-n'. Ronny R Anderson Jody S Smith Chief Deputy Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/12/2009 06:35 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 12 2009 at 1835 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey Gaver by making known unto Jeffrey Gaver personally, at 214 E. Orange Street, Apt. A, Shippenburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/1212009 06:35 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 12 2009 at 1835 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Shirley Gaver by making known unto Jeffrey Gaver, husband of defendant, at 214 E. Orange Street, Apt. A, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $62.00 (PAID) March 17, 2009 ;V00 two I R THOMAS KLINE, SHERIFF Deputy Sheriff Docket No. 2009-1375 HSHC Bank (U.S.A.) N.A. V Jeffrey Gaver & Shirley Gaver UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE ID #45362, LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKJ MA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCRBST CORPORATE CENTER 111 NOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003 856-669-5400 0 1 w„d nQgf++dren _ -nm HSBC Bank USA N.A. as Indenture Trustee for the registered Molders of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-1 Plaintiff V. Jeffrey Gaver Shirley Gaver Defendant(s) TO: Shirley Gaver 214 E. Orange Street Apartment A Shippenburg, PA 17257 Date of Notice: April 2, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-1375 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A'HEARING AND YOU MAY LOSE Y66R PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENHES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-940-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE NECESIIDDIAND DEECOMPARARECERI STED ENTCORTEI0 SCUCKAREPRERUBA AALLGGUNAD DfCTAR SENTENCIA EN SU CONTRA USTED PUEDE PERDER BIENES Y OTROS DERECHOb, IMPORTANTES. DEBE LLE?AR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAMk POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PfTEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-940-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FO PURPOSE. Lorraine Doyie, zsqulre -Alan M. Minato, Esqquuire Chandra M. Arkema, Esquire Louis A. Simoni, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UD30M LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STVART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CKANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 NOODCREST ROAD, SUITE 200 CKXRRY BILL, NJ 08003 856-669-5400 HSBC Bank USA N.A. as Indenture Trustee for the registered Molders of the Renaissance Home Equityy Loan Asset-Backed Certificates, Series 2005-1 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Jeffrey Gaver Shirley Gaver Defendant(s) TO : Jeffrey Gaver 214 E. Orange Street Apartment A Shippenburg, PA 17257 NO. 09-1375 Date of Notice: April 2, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENHES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-930-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE TERMIN FICA NECES IDADODEDECOMPARDIEZ ENTCORTEI0 ESCUOCNKhREPREUBA AAUNAL LGUNAD DfCTAR SENTENCIA EN SU CONTRA USTED PUEDE PERDER BIENES Y OTROS DERECHOA, IMPORTANTES. DEBE LLE?AR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO O SI NO TIME DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE P?7EDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-930-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION. OBTAINED WILL BE USED FOB R TMLT_p-URPOSE. Stuart winneg ire Lorraine Doyle,, Esquire -Alan M. Minato, Esquire Chandra M. Arkema, Esquire Louis A. Simoni, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKENA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 7 ^AdinQedhidran rnm - - - HSBC Bank USA, N.A. as Indenture Trustee for the registered holders of the Renaissance Home Equityy Loan Asset-Backed E Certificates, Series 2005-1 Plaintiff V. Jeffrey Gaver Shirley Gaver Defendant(s) TO: Shirley Gaver 109 Locust Street Shippensburg, PA 17257 Date of Notice: April 2, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-1375 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST.YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YO{JR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-930-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION EL TRIBUNAL PODRA SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA DfCTAR SENTENCIA EN SU CONTRA USTED PUEDE PERDER BIENES Y OTROS DERECHOA, IMPORTANTES. DEBE LLkW ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO 0 SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAMt POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PfTEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-930-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE U OSE. Stuart Winneg, Esquire Lorraine Doyle, Esquire .-Alan M. Minato, Esquire Chandra M. Arkema, Esquire Louis A. Simoni, Esquire Woodcrest Corporate Center 111 Woodcrest Load, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CRANDRA M. ARREMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 r1 wnd? negdren eom HSBC Bank USA N.A. as Indenture Trustee e for the registered Molders of the Renaissance Home Equityy Loan Asset-Backed Certificates, Series 2D05-1 Plaintiff V. Jeffrey Gaver Shirley Gaver Defendant(s) TO: Jeffrey Gaver 109 Locust Street Shippensburg, PA 17257 Date of Notice: April 2, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-1375 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YF)bR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENHES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-9b0-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE INO DE ES FICACION NECESIDAD DEDECOMPARDIEZ ENTCORTEI0 SCUCHAREPRERUBA ALGUNAD DfCTAR SENTENCIA EN SU CONTRA USTED PUEDE PERDER BIENES Y OTROS DERECHOh, IMPORTANTES. DEBE LLE'VAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAMk POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 800-940-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. -Alan M. Minato, Esquire Chandra M. Arkema, Esquire Louis A. Simoni, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA X. ARKENA, ESQUIRE - ID #203437 MOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, N.A., as ":COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the :Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, €MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver Shirley Gaver NO. 09-1375 Defendant(s) TO: Shirley Gaver 214 E. Orange Street Apartment A Shippenburg, PA 17257 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren , Esquire At this telephone number: 856-669-5400 MREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF NhRK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. KINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 nleadingsoudren.com HSBC Bank USA, N.A., as =COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the :Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, .MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver : NO. 09-1375 Shirley Gaver Defendant(s) TO: Jeffrey Gaver 214 E. Orange Street Apartment A Shippenburg, PA 17257 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren , Esauire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. NARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 HSBC Bank USA, N.A., as Indenture Trustee for the registered holders of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-1 Plaintiff V. Jeffrey Gaver Shirley Gaver Defendant(s) TO: Jeffrey Gaver 109 Locust Street Shippensburg, PA 17257 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE =NO. 09-1375 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren , Esquire At this telephone number: 856-669-5400 -"I LA ODREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 com 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 V. Jeffrey Gaver Shirley Gaver Defendant(s) TO: Shirley Gaver 109 Locust Street Shippensburg, PA 17257 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-1375 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court.Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren , Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsoudren.com ATTORNEY FOR PLAINTIFF HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the ::Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 Plaintiff v. ":NO. 09-1375 Jeffrey Gaver Shirley Gaver Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS 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 Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Jeffrey Gaver Over 18 As captioned above Unknown Shirley Gaver Over 18 As captioned Unknown Sworn to and subscribed before me this 14th day CK April' * 0"9 above _s c Name : .v ?9G 2 i+- o? G Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. Notary :NW_-- Comtirds W6q*Mj0A5W3 I`' K-, In UNCTARY M99 APR 14 Pt-I !: 40 141. 00 ?? ?'q!? CK--?d 13609y 2? a? 3?4y 1Vo-?-? cam.. •n? ? C?c-?. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsoudren.com ATTORNEY FOR PLAINTIFF HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the :Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver :NO. 09-1375 Shirley Gaver Defendant (s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $55,167.51 Interest From 4/15/09 1,665.21 to Date of Sale September 2, 2009 ongoing Per Diem of 11.81 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P . C BY: ';;?_ Attorneys fo aintiff MARK J. UDR EN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE OF THE' Pi,:4- 71`,01NOTARY 2099 APR 14 Pil 1: 40 42q.ob ?cL- ?4?- •?' 2a.rv - er , !'?l . lsc? - it r r /61 - 00 x v 4J, ?. a 3 --tt r e ?.? es: ?,C?? Tssu.sd UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHBRRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, N.A., as `COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the :Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver € NO. 09-1375 Shirley Gaver Defendant(s) C E R T I F I C A T E I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorneys f P aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ?? VI , j. ,tin UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, N.A., as =.COURT OF COMMON PLEAS Indenture Trustee for the ;CIVIL DIVISION registered holders of the €:Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver :NO. 09-1375 Shirley Gaver Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 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 in the above action, by its attorney, Mark J. Udren , ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 109 Locust Street, Shippensburg, PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name Address Jeffrey Gaver 109 Locust Street Shippensburg, PA 17257 214 E. Orange Street Apartment A Shippenburg, PA 17257 Shirley Gaver 109 Locust Street Shippensburg, PA 17257 214 E. Orange Street Apartment A Shippenburg, PA 17257 r 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last of record: Name HSBC Bank USA, N.A., as Indenture Trustee for the registered holders of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2005-1 recorded holder of every mortgage Address 12650 Ingenuity Drive Orlando, FL 32826 Beneficial Consumer Discount 636 Grand Regency Blvd. Company d/b/a Brandon, FL 33510 Beneficial Mortgage Co. of PA 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 109 Locust Street Shippensburg, PA 17257 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: April 14, 2009 UDREN LAW OFFICES, P.C. BY: Attorneys fojr:::?Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE Fit FD--Dl FICE {tilts OF THE P_7 " ? 2009 AFF 14 H, 1= 40 r U''-,T; i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the :Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver :NO. 09-1375 Shirley Gaver Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jeffrey Gaver 109 Locust Street Shippensburg, PA 17257 Your house (real estate) at 109 Locust Street Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 2, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $55,167.51, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 FlLEFD--O' r'i )T !? ; TA ?Y F THE PPi' X! 2009 APP 14 PH 1: 4 0 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID # 04302 STUART WINNEG, ESQUIRE - ID # 45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingseudren.com HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the `CIVIL DIVISION registered holders of the =Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver ::NO. 09-1375 Shirley Gaver Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Shirley Gaver 109 Locust Street Shippensburg, PA 17257 Your house (real estate) at 109 Locust Street Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 2, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $55,167.51, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. C+. 1 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 FILE QF THE 2009 APR 14 Ph 1: " t i.ia Uli'V UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings®udren.com HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the ::Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, :MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver :NO. 09-1375 Shirley Gaver Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jeffrey Gaver 214 E. Orange Street Apartment A Shippenburg, PA 17257 Your house (real estate) at 109 Locust Street Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 2, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $55,167.51, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the.Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 r;?????, -iCE- 2009 APR, 14 pi-,l I : 40 6 r? s v a Ups ?{i?-? M UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings®udren.com HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Indenture Trustee for the :CIVIL DIVISION registered holders of the :Cumberland County Renaissance Home Equity Loan Asset-Backed Certificates, '-MORTGAGE FORECLOSURE Series 2005-1 Plaintiff V. Jeffrey Gaver :NO. 09-1375 Shirley Gaver Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Shirley Gaver 214 E. Orange Street Apartment A Shippenburg, PA 17257 Your house (real estate) at 109 Locust Street Shippensburg, PA 17257 is scheduled to be sold at the Sheriff's Sale on September 2, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $55,167.51, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OMM'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. k 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 TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO. YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 F L?1, OF THE 2009 APR 14 Ph 1 ? 40 z ' 4 ,t ? t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1375 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 HOLDERS OF THE RENAISSANCE HOME EQUITY LOAN ASSET- BACKED CERTIFICATES, SERIES 2005-1, Plaintiff (s) From JEFFREY GAVER AND SHIRELY GAVER (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 gamishee(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 $55,167.51 L.L. $.50 Interest FROM 4/15/09 TO DATE OF SALE 9/2/09 - ONGOING PER DIEM OF $11.81 TO ACUTAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $1,665.21 Atty's Comm % Atty Paid $181.00 Plaintiff Paid Date: APRIL 14, 2009 (Seal) Due Prothy $2.00 Other Costs C s . Long, P no ry By: Deputy REQUESTING PARTY: Name LORRAINE DOYLE, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576