Loading...
HomeMy WebLinkAbout09-2547 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 CAANDRA 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 pleadinge@udron.com Beneficial Consumer Discount : COURT OF COMMON PLEAS Company d/b/a Beneficial Mortgage :CIVIL DIVISION Co of Pennsylvania 961 Weigel Drive Cumberland County Elmhurst, IL 60126 Plaintiff V. James P. McCrea Dawn McCrea 125 North 18th Street Harrisburg, PA 17103 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 F 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 V 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: N/A Assignments of Record to: N/A Recording Date: N/A 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: 83 West Main Street MUNICIPALITY/TOWNSHIP/BOROUGH: West Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 11/10/04 DATE RECORDED: 11/15/04 BOOK: 1887 PAGE: 4817 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 4/14/09: Principal of debt due $109,274.70 Unpaid Interest at 8.53% from 5/16/08 to 4/14/09 (the per diem interest accruing on this debt is $25.54 and that sum should be added each day after 4/14/09) 10,494.56 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthlyy late charge of $47.23 should be added in accordance with the terms of the note each month after 4/14/09) 0 Property Preservation 112.50 Attorneys Fees (anticipated and actual to 5W of principal) 5,463.74 TOTAL $125,950.50 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 1W 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 $125,950.50 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDRX9- LA-3300 F32?ES , P. C. BY: C ? 1?"?. Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE -ZOUIS A. SIMONI, ESQUIRE ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN THE CENTERLINE OF ROUTE 641, AT THE CORNER OF LAND OF SWARNER BROS. BODY SHOP; THENCE ALONG THE LATTER, NORTH 00 DEGREES 10 MINUTES 55 SECONDS EAST 276.78 FEET TO A POINT; THENCE ALONG THE SAME, SOUTH 89 DEGREES 49 MINUTES 05 SECONDS EAST 52.37 FEET TO A POINT AT LINE OF LANDS NOW OR FORMERLY OF BROWN; THENCE ALONG THE LATTER, SOUTH 09 DEGREES 21 MINUTES 23 SECONDS EAST 234.10 FEET TO A POINT; THENCE STILL ALONG THE SAME, SOUTH 00 DEGREES 00 MINUTES 05 SECONDS WEST 55.27 FEET TO A POINT IN THE CENTERLINE OF ROUTE 641; THENCE ALONG THE LATTER, NORTH 83 DEGREES 59 MINUTES 55 SECONDS WEST 91.90 FEET TO A POINT, THE PLACE OF BEGINNING. UNDER AND SUBJECT, NEVERTHELESS, TO ALL EASEMENTS, RESTRICTIONS, ENCUMBRANCES AND OTHER MATTERS OF RECORD OR THAT A PHYSICAL INSPECTION OR SURVEY OF THE PREMISES WOULD REVEAL. December 12, 2008 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO GHOMEOWNERIIS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 1. Page t of t B ,"IBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: James P. McCrea Dawn HeCrea 83W Main Street PahnfieK PA 17087 71171510558277 Beaefisiot QQn umer Dis?oy om an HFC or BFC Entity on Mortgage ROMEOWNERQS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY RF, F.I.IGIRI.F. FOR FINANCIAL, ASSISTANCE. WHWH CAN SAVE. YOUR 14jMF, FROM F0RR.CI,OSITRF. ANTI HELP VOU MAKE FIITTIRF MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERdS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE 9ACT13), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Oface-to-faced meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCTTR WITHIN THE NEXT (30) DAYS, IF YOU DO NOT APPT.Y FOR EMF.RGF,NC'Y MORTGAGE, ASSTSTANC'.F, YOIT MT1ST RRINCi VOTTR MORTGAGE iTP 10MATR THE. PART OF THIS NOTT E C`.A111-1) OHOW TO C'TTRE YOUR MORTGAGE DRFATIT.10, -XPT.ATNQ, HOW TO RRTNG YOTIR MORTGACYP TTP TO DATR CONSITMF.R CREDIT COTINSFILING AC RNCTF.S -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telenhnn . n umber- of designated on. umer credit -nuns _ling agencie- fnr the cmnf? in which the yrapcrhT?ic Incated are s .t oath at the and of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatell of your intentions. APPLICATION FOR MORTGAGE, ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner'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 Page 2 of 2 Lace- to-face meeting. YOU MILS 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. AGVNCY AMON - 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.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 83 W. Main Street Palinfield, PA 17081 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $944.65 for June 16.2008 #?-ough November 16. 2008 = $SC67.90 _ NQn_ft Late Ch AMek of $47.23 for June 19 2008 th% . Novem16_200$ Other charges (explain/itemize): Other Late Charge 16.72 TOTAL AMOUNT PAST DUES B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not plicahle): Na HOW TO CITRF. TAE DEFAIJI'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 S-968,00 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PPavmerm must he made either by cash, mshier'c nhey k, certified check or maneyr ardar mraAP?t?Ah_le and sent tn: You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not lice if not Wlicahle ): Na Page 3 of 3 r iF YOU DO N03: CITRR THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exer is its right& to sergierate the mMlpgp. 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 forednse npw y it martgaged property- IF THE MORTGAGE IS FOREC T .C1SED TlPIIN - 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 Nan more the def9nlt within the TRMTV (30) DAV^pi-rind. ym w,;ll not hp Muired to pa attorney's fees. OTHER ENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in banla uptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO MME THE DEFAULT PRIOR TO SHFRiFF'S SATE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to paymg ine rorai amounr men Pact nue, ltn gc any late., nr nthrr cha roq then chiey reasonable attnrnc y't fees and ends cnnn evd with the forerlncrrre cal and any ether cnets cnnn ed with the Sheriff c Sa)P„is ^ifie in writing by the lender and by Vafoming an nt w uirernents 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. EARi IERT POSSiRI,E SHERIFF'S SALF. DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 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 lender. Name of Lender/Servicer: HSBC Consumer Address: 961 Weigel Drive Elmhurst 60126 Phone Number: Fax Number: 630-6174891 Contact Person: _ MtM to Woodwort EFFECT [)F SHF.RTFF'S SALE - You. should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSIRKMON JIF MORTGAltF, - You may not 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. Page 4 of 4 40 . , 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 Page 5 of5 4- • 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 'T'IMES 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 ACTTON BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL, BANKRUPTCY LAW. CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 541-4670 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Deny Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of 6 w milled Mail PlevidBS: making reoW unique ' ier for your manpiece record of livery kept by the Postal Service for two 11110-t Remdbww. Yeats ertified Mail may ONLY be combined ertkied Mail is not available for an with First-Class Mang Priority Mali® iY class of Mtemationat mai1. l C tNSURA'CE COVERAGE IS PROVIDED with Certified Mail. For luabies, a consider insured or .ran additto a1 fee, a Return Rai" Registered Mail. -ev lively. Too n Rehm Receipt se m cote top rovide a Return EPeF 3811) t0 the article and add applicable and attach luplice te 0 m IpR a m R Requested1. To rvpostage fee watvea r for iw?ed. Postmark on your Certified Mail is is an addilaWrcledt'livery- el fee, delivery may be restricted to the addressee or iressee's aor"d at. Advise the clerk or mark the mailpiece with the iorsement , Postmark Certified Mail receipt is desired please present the arti- at the r?stmaAcing. It a postmark on the Cerified Mail _ipt is not n eded, detach and affix label with Postage and malt. RTANT; Sate this receipt and present it when making an Inquiry. M 380Q AU9- 2006 (Reverse) PSN 7530-02-000-9047 v ?? ©? ? . V T 0 q o t] ti CM? .4 tt M t3 D & = ? ¢ Q d ?( m .d di a C3 ¢ I3 0 iv E C3 1'? ?? C3 qS3 E 4P rs Uo- ¦ ¦ ¦ to CV 4 cC fV t" La?ryy( o . E c) ID y yy ?y Q T• C ?M ' ? yf ? y a ?f p? ;c cf Aa ? O ?a?aaa?a W O C1 Q r3 ---- C3 - C3 w r-u fl ild O Z M O ¢ V C) cc ^, r ?i a .. '7113 1 C d. dified mail Pt vides:• maitlng t unique We or for your mailplece record of ivefy kept by the Postal Service for two years rortant Hem[ ;srttfied Mail ay ONLY be combined with First-Class Mails or Priority Maile. :ertiiled Mail not available for any class of international mail. 40 INSUAA CE COVERAGE IS PROVIDED with Certified Mail. For aluabies, p e consider Insured or Registered max. .or an addd' ai fee, a Retum R rm be requested to provide proof of elivery. To n Return Receipt ?, p complete ar?d sttach a Return iaceipt (PS F 3611] to the article and add applicable postage to cover the te. Endorse 'ace Return Receipt Requestsd"• To receive a fee waiver for du red. te rn receipt, a USPSe postmark on your Certified Mail recelpt is rq or an a at fee, delivery may be restricted to the addressee or ddresaee's au rized aggeent Advise the clerk or mark the maitpiece with the ndorsement " eaftledD®Ilvery` a postmark o the Certified Mail receipt is desired, please present the arch le at the post office for postmarking. If a postmark on the Certified Mail :ceipt is not n eded, detach and affix label with postage and mail. VRTANT. Sue this receipt and present It when making an inquiry. orrn 36D0, Aupu 2006 (Reugrae) PSN 7530-2-OOD-9097 0 M r? M eD >ti d O O C3 C3 O ru Q m I% C3 I3 fti e i L 2 M, ni a j u Cn to - ? u Q O O -i w ni E7 C7 C3 ?.? O w U L-i w C ) . Q t'7 h??Q 4E EE LU w T_ - M f r ri Y..r r ti ?vI ?rtified M'11 Provide*. Amailing t p A unique i r for your mailpiece A record of slivery kept by the Postal Service fort,, years Potent R riders: Certified Mai May ONLY be combined ,ith First Class Malls or priority Mail, Certified Mai is not avalabie for any class of Irttemational mail. NO INSU NCE COVERAGE IS PROVIDED with Certified Mail For iatuables, pi 6 consider Insured or Registered Mail -or an addki fee, a Retain Receipt may be re q complete Too n Refum rv?e ICI q to rovide proof of ceipt (PS Form 3ait to the a article and ease l . attach a Return ee. Endorse 'Ipiem RReturn add applicable postage to cover the duplicate re um receipt, a USPV Requested`. To receive a fee waiver for equued, Ss postmark on your Cerdfiad Mail receipt is .Of an add' anal fee, delivery may be restricted to the addressee or ddressee's a thorized agent. Advise the clerk or mark the mailpiece with the ndorsement Restricted Delivery". a postmark the Certified Mail receipt is desired, lease present the arti- le at the p t office for Postmarking. if a p rceipt is not ceded, detach and affix label with pesos age and alrtfied mail 'ORTANT: S¢tra Ibis receipt and present It when making an inquiry. onn 3800. A sr 2005 (Reverse} PSN 7530-,2.000-9047 .A C3 ..,f7 N M cc C3 C3 O C3 C3 C3 ILL O M N 0 Q Iti t~ I! ?I o W Z W C d c,V t i r? D cc: to r X65 1 C3 M nj N ? C3 o 0 `?- a -?- o w ---- -j ---?-- Ir ? N U t? LU m T-0Lz ?ooi o rr WW uj . c r 0 T c C CQ 1. 1 1 • i 60 ed Mail Provides: fling receipt que identifier for your mallpiece :md of dei'nrej kept by the Postal Service for two years rnt Remi fled Mail may .NLY be combined with First-Class Mails or Priority Mails. fled Mail is no available for any class of international mail. INSURANCE OVERAGE 1S PROVIDED with Certified Mail. For ibles, please nsider Insured or Registered Mail. in additional t a Rerum Receipt may be requested to provide proof of :ry. To obtain turn Receipt service, please complete and attach a Return dpt (PS Form 11) to the article and add applicable postage to cover the endorse mallpl oe "Remm Receipt Requested". To receive a fee waiver for Aficate return ipt, a USPSe postmark on your Certified Mail receipt is red. an additional fee, delivery may be restricted to the addressee or asses's authorl zed agent. Advise the clerk or mark the maiipieoe with the irsement 'RB D&#vBry . iostmark on t Certified Mail receipt is desired, please present the arti- st the post offi for postmarking. If a postmark on the Certified Mail ipt is not need d, detach and affix label with postage and mail. ITANT. Save t is receipt and present it when making an inquiry, 13800, August (Raverm) PSN 75SD-02-=-9G47 s U I i W r" QD s m i ? i o W R ®s • r. i w r. i•.? ??pa1,a3 o C?• rF,r) aCS , ' r.•i. u'? i? w ^VV i?v E ?t3 XL EL ?? F a wk R T v F o r. O ,.i...? 0 M O w -? r to ..n V a ? gr pdj a- RY! ?er cc00-U 8 ir ej L v V r\ . r V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the 'penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN , P. C. BY: Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ,LOUIS A. SIMONI, ESQUIRE 01 2D99 AN 23 AN 10: 0 7 fil; r, "r : Sheriffs Office of Cumberland County R Thomas Kline 0 lulu irrf? 6 Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy oFr ` --E - FF Civil Process Sergeant Beneficial Consumer Discount Company C se Number vs. 009-2547 James P. McCrea SHERIFF'S RETURN OF SERVICE 04/23/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a dilig nt search and inquiry for the within named defendant, to wit: James P. McCrea, but was unable to locate im in his bailiwick. He therefore deputized the Sheriff of Franklin County, PA to serve the within Co plaint In Mortgage Foreclosure according to law. 04/23/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a dilig nt search and inquiry for the within named defendant, to wit: James P. McCrea, but was unable to locate im in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 04/23/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Dawn McCrea, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 04/23/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Dawn McCrea, but was unable to locate he in his bailiwick. He therefore deputized the Sheriff of Franklin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 05/04/2009 Dauphin County Return: And now, May 4, 2009 I, Jack Lotwick, Sheriff of Dauphin Count Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Dawn McCrea the efendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in he County of Dauphin and therefore return same NOT FOUND. Per James McCrea, Dawn McCrea is li ing at 3611 Valley View Drive, Franklin County, Chambersburg, Pennsylvania 17201. 05/04/2009 10:09 AM - Dauphin County Return: And now May 4, 2009 I, Jack Lotwick, Sheriff of Dau hin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint n Mortgage Foreclosure, upon the within named defendant, to wit: James P. McCrea by making know unto himself personally, defendant served at Daupin County Courthouse Front and Market Streets Harrisburg, Pennsylvania 17101 its contents and at the same time handing to him personally the said rue and correct copy of the same. 05/15/2009 02:55 PM - Franklin County Return: And now May 15, 2009 I, Dane Anthony, Sheriff of Fr nklin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: James P. McCrea by making know unto Dawn McCrea, wife of defendant at 3611 Valley View Drive Chambersburg, PA 17201 its conten s and at the same time handing to her personally the said true and correct copy of the same. 05/15/2009 02:55 PM - Franklin County Return: And now May 15, 2009 I, Dane Anthony, Sheriff of F nklin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dawn McCrea by making known unto herself personally, defendant at 3611 Valley View Drive Chambersburg, PA 17201 its contents a rd at the same time handing to her personally the said true and correct copy of the same. 05/16/2009 Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on pril 29, 2009 at 1539 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upo the within named defendant, to wit: James P. McCrea, by making known unto Whitney McCrea, daughter of defendant, at 83 West Main Street, Plainfield, Cumberland County, Pennsylvania, 17081, is contents and at the same time handing to her personally the said true and correct copy of the same. Page 1 of 2 D5/16/200q! 03:39 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, stat s that on April 29, 2009 at 1539 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dawn McCrea, by making known unto Whitney McCrea, daughter of defendant, at 83 West Main Street, Plainfield, Cumberland County, Pennsylvania, 17081, i contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $95.50 June 24, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF y 5ner Page 2 of 2 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU ATTORNEY FOR PLAINTIFF - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 vleadinas@udren.com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania Plaintiff V. James P. McCrea Dawn McCrea Defendant (s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: June 16, 2009 REi4'JLAW OFFICES, P . C . Y: Att s for P ntiff MARK J. UD , ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE r V E R I F I C T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of, the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 6-A a v JaW(:1 James P. McCrea Dawn McCrea Loan #71171500558277 MJU #08120257-2 ?,, 0-4 Name : DAL c7.,n r Title: i?resiAler\" Company: HSBC Consumer Lending as servicer on behalf of Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania FLED-OiRCE OF T E PROTHONOTARY 2899 JUN 29 PM t: 02 F?R'rt?SYE.VAt+?A UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County 961 Weigel Drive Elmhurst, IL 60126 :MORTGAGE FORECLOSURE Plaintiff V. James P. McCrea :NO. 09-2547 Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 and P.O. Box 223 Plainfield, PA 17081 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) James P. McCrea and Dawn McCrea 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 Interest Per Complaint From 4/15/09 to 6/16/09 Late charges per Complaint From 4/15/09 to 6/16/09 $125,950.50 1,609.02 141.69 against the to file an thereof and and assess TOTAL $127,701.21 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. DAMAGES ARE HEREBY ASSESSED AS DATE : ?- d 66 cl UEN SAW OFFICE P.C. BY: At-torneys__.f.or Plaintiff MARK J. UDREN; ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE INDIC TED P 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. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 lei nas%Qudren Com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania Plaintiff V. James P. McCrea Dawn McCrea Defendant(s) TO: James P. McCrea 83 West Main Street Plainfield, PA 17081 Date of Notice: June 5, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 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, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND Y ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE U F HAT URPOSE. Mark ;squire Stuart Winneg, Esquire 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. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 nlPadi nanoudren nnm Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania Plaintiff V. James P. McCrea Dawn McCrea Defendant(s) TO: James P. McCrea P.O. Box 223 Plainfield, PA 17081 Date of Notice: June 5, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO 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 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE THA PURPOSE. ar squire Stuart Winneg, Esquire 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. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 n1 Pads neap++ArEn com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Cc of Pennsylvania Plaintiff V. James P. McCrea Dawn McCrea Defendant(s) TO: James P. McCrea 125 North 18th Street Harrisburg, PA 17103 Date of Notice: June 5, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND S?,N ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE ED F THAT" PURPOSE. Marx-t- vare=, Esquire Stuart Winneg, Esquire Lorraine Doyle, Esquire Alan M. Minato, Esquire Chandra M. Arkema, Esquire houis 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. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 nl?i ngsC?ud+' n com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Cc of Pennsylvania Plaintiff V. James P. McCrea Dawn McCrea Defendant(s) TO: James P. McCrea 3611 Valley View Drive Chambersburg, PA 17202 Date of Notice: June 5, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMDATIOBEOA DEBT DCWILLCBER ED FO THAT URPOgMEPT TO COLLECT A DEBT. ANY INFORM Marx J. uaren, ;squire Stuart Winneg, Esquire 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 004302 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 856-669-5400 nladingsCdtLdren _ com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Cc of Pennsylvania Plaintiff V. James P. McCrea Dawn McCrea Defendant(s) TO: Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 Date of Notice: June 5, 2009 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 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, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES DEEMED TO BE A DEBT COLLECTOR AN ATTEMPT TO US '-W- JO D TH PURPOSE. INFORMATION OBTAINED WILL BE Mark ren, squire Stuart Winneg, Esquire 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 ACT, THIS LAW FIRM IS COLLECT A DEBT. ANY UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - STUART WINNEG, ESQUIRE - LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUI: LOUIS A. SIMONI, ESQUIRE ID #04302 ID #45362 - ID #34576 - ID #75860 RE - ID #203437 - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-6900 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania 961 Weigel Drive Elmhurst, IL 60126 Plaintiff v James P. McCrea Dawn McCrea 125 North 18th Harrisburg, PA and P.O. Box 223 Plainfield, PA Street 17103 17081 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. ( o -+ AFFIDAVIT OF NON-MILITARY SERVICE STATE OF :L1 \ Vl ?_\O 5 COUNTY OF 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 Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last. known residence and employment of each Defendant are as follows: Defendant: Age Residence: Employment: Defendant: Age Residence: Employment: James P. McCrea Over 18 As captioned above Unknown Dawn McCrea Over 18 As captioned Unknown Sworn to and subscribed before me this day of 20cA. r _ic above a . ame : , L c1 Title: Company: HSBC Consumer Lending as servicer on behalf of Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania OFFICIAL SEAL 11 K \N ' ' N017ARY PJD1-iC FlT:'. 0 = 1LL1;,4-2!S VDREN 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 Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial Mortgage =CIVIL DIVISION Co of Pennsylvania 961 Weigel Drive :Cumberland County Elmhurst, IL 60126 Plaintiff V. James P. McCrea Dawn McCrea 125 North 18th Street Harrisburg, PA 17103 Defendant(s) NO . 11 - A-117 COMPLAINT IN MORTGAGE FORECLOSURE ti._y L1.'.? 1 ." 7 ? • ? AJ3 & ' -/ Xm YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 OF THE P-POT" A RY 2009 JUN 29 PM f : 03 ,NTY j33031 2 jn? -,N, 7335 N,.?; c c S ?'?- ? j' e f J"' 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 Beneficial Consumer Discount =COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea :NO. 09-2547 Dawn McCrea Defendant(s) TO: James P. McCrea 83 West Main Street Plainfield, PA 17081 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania ou are hereby notified that a Judgment has been entere ga' o in the above proceeding as indicated below. of ry 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 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania 961 Weigel Drive Elmhurst, IL 60126 Plaintiff V. James P. McCrea Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 and P.O. Box 223 Plainfield, PA 17081 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-2547 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) James P. McCrea and Dawn McCrea 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 $125,950.50 Interest Per Complaint 1,609.02 From 4/15/09 to 6/16/09 Late charges per Complaint 141.69 From 4/15/09 to 6/16/09 against the to file an thereof and and assess TOTAL ,$127,701.21 I /• N. 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 Z,AW OFFICE P . C . _ BY: C_ Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS DATE : INDI TED P PROT 1 v UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea :NO. 09-2547 Dawn McCrea Defendant(s) TO: James P. McCrea 3611 Valley View Drive Chambersburg, PA 17202 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, ou are hereby notified that a Judgment has been entere ga' o in the above proceeding as indicated below. 0 o y X Judgment by Default Money Ju Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict 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 II UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Cc of Pennsylvania 961 Weigel Drive Elmhurst, IL 60126 Plaintiff V. James P. McCrea Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 and P.O. Box 223 Plainfield, PA 17081 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-2547 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) James P. McCrea and Dawn McCrea 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 Interest Per Complaint From 4/15/09 to 6/16/09 Late charges per Complaint From 4/15/09 to 6/16/09 $125,950.50 1,609.02 141.69 against the to file an thereof and and assess TOTAL $127,701.21 i 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. ---- ---------- UD.REIIVIL W OFFICES P. C. BY: Attorneys for Plaintiff MARK J. UDREN; ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS DATE : o? INDI TED O PROT 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 Beneficial Consumer Discount `:COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. 'MORTGAGE FORECLOSURE James P. McCrea Dawn McCrea :NO. 09-2547 Defendant(s) TO: James P. McCrea 125 North 18th Street Harrisburg, PA 17103 NOTICE Pursuant to Rule 236 of the Supreme Court of Pen ylvani you are hereby notified that a Judgment has been entere ga' u in the above proceeding as indicated below. o hon x Judgment by Default Money Jug Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict 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. 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 Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania =Cumberland County 961 Weigel Drive Elmhurst, IL 60126 :MORTGAGE FORECLOSURE Plaintiff V. James P. McCrea :NO. 09-2547 Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 and P.O. Box 223 Plainfield, PA 17081 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 against the Defendant(s) James P. McCrea and Dawn McCrea for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $125,950.50 Interest Per Complaint 1,609.02 From 4/15/09 to 6/16/09 Late charges per Complaint 141.69 From 4/15/09 to 6/16/09 TOTAL $127,701.21 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. DAMAGES ARE HEREBY ASSESSED AS DATE : cy G/ 0??9 UDFkRN'ZAW OFFICE P. C. BY: C Attorneys._for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE D INDIAPROTHY PR 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 Beneficial Consumer Discount ':COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea , Dawn McCrea ::NO. 09-2547 Defendant(s) TO: James P. McCrea P.O. Box 223 Plainfield, PA 17081 NOTICE Pursuant to Rule 236 of the Supreme Court of Pe ylv nia, you are hereby notified that a Judgment has been entere a' in the above proceeding as indicated below. rot ho X Judgment by Default Money Ju Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict 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 STUART WINNEG, ESQUIRE - ID LORRAINE DOYLE, ESQUIRE - ID ALAN M. MINATO, ESQUIRE - ID CHANDRA M. ARKEMA, ESQUIRE - WOODCREST CORPORATE CENTER #04302 #45362 #34576 #75860 ID #203437 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania 961 Weigel Drive Elmhurst, IL 60126 Plaintiff V. James P. McCrea Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 and P.O. Box 223 Plainfield, PA 17081 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-2547 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) James P. McCrea and Dawn McCrea 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 $125,950.50 Interest Per Complaint 1,609.02 From 4/15/09 to 6/16/09 Late charges per Complaint 141.69 From 4/15/09 to 6/16/09 against the to file an thereof and and assess TOTAL $127,701.21 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. DAMAGES ARE HEREBY ASSESSED AS DATE : UDREi?fi" I?AW OFFICE P. C. BY: C Attorneys_ for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE INDI ED P PROTH X-? / 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 Beneficial Consumer Discount ?COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea -:NO. 09-2547 Dawn McCrea Defendant(s) TO: Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 NOTICE Pursuant to Rule 236 of the Supreme Court of Ar ylvania, ou are hereby notified that a Judgment has been enteg ' s in the above proceeding as indicated below. onotry 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 pleadings@udren.com ATTORNEY FOR PLAINTIFF Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County 961 Weigel Drive Elmhurst, IL 60126 :MORTGAGE FORECLOSURE Plaintiff V. James P. McCrea :NO. 09-2547 Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 and P.O. Box 223 Plainfield, PA 17081 De f endant (s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and Defendant(s) James P. McCrea and Dawn McCrea 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 Interest Per Complaint From 4/15/09 to 6/16/09 Late charges per Complaint From 4/15/09 to 6/16/09 $125,950.50 1,609.02 141.69 against the to file an thereof and and assess TOTAL $127,701.21 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. DAMAGES ARE HEREBY ASSESSED AS DATE : ( oZ-y CCU UDREiVZAW OFFICES P. C. BY: C Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE IND TED P O PROT UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU ATTORNEY FOR PLAINTIFF - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania Plaintiff V. James P. McCrea Dawn McCrea Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 09-2547 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due Interest From 6/17/09 to Date of Sale December 9, 2009 Ongoing Per Diem of 25.54 to actual date of sale including if sale is held at a later date (Costs to be added) $ $127,701.21 4,495.04 UDRE P. C. BY: Mo neys fmblaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE Ail" a y, ?0 9 at / ` o y'P„A., 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 Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial '-CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea :NO. 09-2547 Dawn McCrea Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: :UDREN LAW C. : At'torney-s-- f (Dr Pint i f f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE vLi? , a-i"-j YPA?- a od 9 'Ce i ! a y,,k G mil` oQ!' y 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 Beneficial Consumer Discount ::COURT OF COMMON PLEAS Company d/b/a Beneficial =CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea =NO. 09-2547 Dawn McCrea 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 , P. C. B'Y Attorneys for iff MARK J. UDREh, ESQU E STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE -ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ?,?1,?@ .,?- C.???.e; Cow /a ?? ? ??? ?? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF J 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 Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea :NO. 09-2547 Dawn McCrea Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania, 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: 1. Name and address of Owner(s) or reputed Owner(s): Name Address James P. McCrea 125 North 18th Street Harrisburg, PA 17103 P.O. Box 223 Plainfield, PA 17081 83 West Main Street Plainfield, PA 17081 3611 Valley View Drive Chambersburg, PA 17202 Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 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 t a record lien on the real property to be sold: Name Address Dagen Verna Mae PA State Employees Credit Union 4. Name and address of of record: Name Address Beneficial Consumer 961 Weigel Drive Discount Company d/b/a Elmhurst, IL 60126 Beneficial Mortgage Co of Pennsylvania 5. Name and address of every other person who has any record lien on the property: Name Address West Pennsboro Township Agent John Epley 2150 Newville Road Carlisle, PA 17015 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 1 Alliance Dr. Carlisle, PA 17013 Attn: Melissa Van Eck PO Box 6662 Apt/Ste B Harrisburg, PA 17112 the last recorded holder of every mortgage 83 West Main Street Plainfield, PA 17081 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: June 16, 2009 UDREN , BY: At laintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE "14 , BOO 9 a /.?'? ?.? 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. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea ::NO. 09-2547 Dawn McCrea Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James P. McCrea 83 West Main Street Plainfield, PA 17081 Your house (real estate) at 83 West Main Street (West Pennsboro Township) Plainfield, PA 17081 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $127,701.21, 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 oq UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF f 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 Beneficial Consumer Discount COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania =Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea :NO. 09-2547 Dawn McCrea Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James P. McCrea P.O. Box 223 Plainfield, PA 17081 Your house (real estate) at 83 West Main Street (West Pennsboro Township) Plainfield, PA 17081 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $127,701.21, 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. 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 Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial ;CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. 'MORTGAGE FORECLOSURE James P. McCrea ::NO. 09-2547 Dawn McCrea Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James P. McCrea 125 North 18th Street Harrisburg, PA 17103 Your house (real estate) at 83 West Main Street (West Pennsboro Township) Plainfield, PA 17081 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $127,701.21, 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ?y aQaq ? i? a?P,? 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 Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea ::NO. 09-2547 Dawn McCrea Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James P. McCrea 3611 Valley View Drive Chambersburg, PA 17202 Your house (real estate) at 83 West Main Street (West Pennsboro Township) Plainfield, PA 17081 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $127,701.21, 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 i THE SHERIFF'S SALE DOES TARE 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 A&j a4zf,&? a" ?- /,tppo? =? y , ""', ), C4 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 Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE James P. McCrea :NO. 09-2547 Dawn McCrea Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dawn McCrea 3611 Valley View Drive Chambersburg, PA 17202 Your house (real estate) at 83 West Main Street (West Pennsboro Township) Plainfield, PA 17081 is scheduled to be sold at the Sheriff's Sale on December 9, 2009, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $127,701.21, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICES 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.) 16 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 TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 d-"I ' c ? VU- ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT IN THE CENTERLINE OF ROUTE 641, AT THE CORNER OF LAND OF SWARNER BROS. BODY SHOP; THENCE ALONG THE LATTER, NORTH 00 DEGREES 10 MINUTES 55 SECONDS EAST 276.78 FEET TO A POINT; THENCE ALONG THE SAME, SOUTH 89 DEGREES 49 MINUTES 05 SECONDS EAST 52.37 FEET TO A POINT AT LINE OF LANDS NOW OR FORMERLY OF BROWN; THENCE ALONG THE LATTER, SOUTH 09 DEGREES 21 MINUTES 23 SECONDS EAST 234.10 FEET TO A POINT; THENCE STILL ALONG THE SAME, SOUTH 00 DEGREES 00 MINUTES 05 SECONDS WEST 55.27 FEET TO A POINT IN THE CENTERLINE OF ROUTE 641; THENCE ALONG THE LATTER, NORTH 83 DEGREES 59 MINUTES 55 SECONDS WEST 91.90 FEET TO A POINT, THE PLACE OF BEGINNING. UNDER AND SUBJECT, NEVERTHELESS, TO ALL EASEMENTS, RESTRICTIONS, ENCUMBRANCES AND OTHER MATTERS OF RECORD OR THAT A PHYSICAL INSPECTION OR SURVEY OF THE PREMISES WOULD REVEAL. BEING KNOWN AS: 83 West Main Street, Plainfield, PA 17081 PROPERTY ID NO.: 46-18-1394-011 TITLE TO SAID PREMISES IS VESTED IN JAMES P. MCCREA AND DAWN MCCREA, HUSBAND AND WIFE BY DEED FROM WILLIAM J. MANNA AND CHERYL L. MANNA, HUSBAND AND WIFE DATED 9/18//2000 RECORDED 9/22/2000 IN DEED BOOK 229 PAGE 544. FILED--O; T`r r CIF THE P =? 01" OiTRRY ?OrS JUN 29 PH 1: C .t /33J 3 7 9 7+1-7 33 ? 4 7V SO cusp ?? 9?-,so i? t 1 s ? s'o P d ? ?Y ?-iy . ?-o P°L 47 ?-?, O b ??e Cd. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-2547 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE CO OF PENNSYLVANIA Plaintiff (s) From JAMES P. MCCREA AND DAWN MCCREA (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$127,701.21 L.L.$.50 Interest FROM 6/17/09 TO DATE OF SALE DECEMBER 9, 2009 - ONGOING PER DIEM OF $25.54 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $4,495.04 Atty's Comm % Atty Paid $214.50 Plaintiff Paid Date: June 29, 2009 Due Prothy $2.00 Other Costs rtis R. Long, P a y (Seal) REQUESTING PARTY: By: Deputy Name ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, P.C., 111 WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200, CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 75860 -. 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. ARREMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. RAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Beneficial Consumer Discount ECOURT OF COMMON PLEAS Company d/b/a Beneficial :CIVIL DIVISION Mortgage Co of Pennsylvania €Cumberland County Plaintiff ENO. 09-2547 v. James P. McCrea Dawn McCrea Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: July 30, 2009 UDREN LAW OF ~P.C. ne s for tiff MARK J. UDREN,`ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ~~eneficist Co"dsumer Discount Company, et. al., Plaintiff(s) vs. James P. McCrea, et. al., Defendant(s) Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Ste 200 Cherry Hill, NJ 08003-3620 State of: APS. File #: 097761-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --James P. McCrea Court Case No. 09-2547 /7N i'~ 1 ss. County of: ~K~ 1~ Name of Server: Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: i I.1c+- - ~-lli `TF-, ,undersigned, being duly sworn, deposes and says that at the time of s~ ice, s/he was of legal age and was not a party to this action; that on the day of ~ ~~ , 20 ~, at ~ ~ $ o'clock ~M at 3611 Valley View Drive, #2 ~ In , Chambersbur¢, PA 17201 the undersigned served the documents described as: Notice of Sheriff s Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: James P. McCrea ^ By personally delivering them into the ,h/~ands of the pernso_n to be served. By delivering them into the hands of ~1,. )~ N ~C Vf`~-'~ ~, tN i•~~- , a person of suitable age, who verified, or who upon questioning stated, that.l~Ie~'she resides with James P. McCrea at the place of service, and whose relationship to the person. is: ~~ The person receiving docu eats is described as folio s: Sex „~; Skin Color ~~'~ ;Hair Color i ~~ ;Facial Hair ~l/n~~e- Approx. Age ;Approx. Height ~ ~G " ;Approx. Weight ~ S To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares and pena f perjury Subscribed and sworn to before me this th ~ egoing is ru d o ect. T~/~~day of ~~ 20 D 9 t ~ t a -/-tF-- gnature of Server Notary Public (Commission Expires) APS International, Ltd. ..~ NOTARIAL SEAL LIICILLE M. CARfl Nofory ~ubpc LETTERKENN1111N-, FRANKLIN COIINTtt MIr CornnNalon Exp1-~ra Nov 10. 4011 ~. ,iA9ffi JAIifATQN 1°YAA~ .H ~UI~U.i ollcltrq y~~foN IITtAU4J NIlkNASii 41NT YNN3~iAffiT!'J~ t t0~ .Qt vbil i9tilfixffi nolatlmmo~ yM ,~ ~ •~enefic~tl C~~mer Discount Company, et. al., Plaintiff(s) vs. James P. McCrea, et. al., Defendant(s) Service of Process by ,APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 097761-0001 UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Ste 200 Cherry Hill, NJ 08003-3620 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Dawn McCrea Court Case No. 09-2547 State of:~e1JN~~(JJaI/i ~ - - -) ss. - - - - - - - - - - - - - - - - - - County of: 77~~~~~~ r1 Name of Server: ~ucvJCi 1^` > ~M ,undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a party to this action; )ate/Time •f Service: thzt ~n the ~_day of ~ ~ , 20 ~, at f ~ o'clock ~M Place of Service: at 3611 Valley View Drive, #2 ~ 1n Chambersbur¢, PA 17201 Documents Served: the undersigned served the documents described as: Notice of Sheriff s Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Dawn McCrea Person Served, and Method of Service: ~., By personally delivering them into the hands of the person to be served. ^ By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Dawn McCrea at the place of service, and whose relationship to the person is: Description of Person The person receiving doc nt is described as follow Receiving Documents: 1 fSex ~ , Skin Color ~ ;Hair Color f •ztr~- ;Facial Hair_~d ~ e '~°• ~ Approx. Age 3 ~ ;Approx. Height ~5 ~ G `~ ;Approx. Weight C ~ 6 s '`~ To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares a er pen of perjury Subscribed and sworn to before me this th th o egoing ' t e nd orre t. -~~~day of , 20 ~ 9 t~ ~a ~! Signature of Server Notary Public (Commission Expires) APS International, Ltd. ~~~~ NOTARIAL tIEAt LUCILLE M. CARTY Notary I~ubNc LETTERKENNY TYVP. RRANKLIN COUNTY trty Cotnml~ulon Expl-~s Nov t 0, ZOt 1 .- r . ~ .,~.,,,~.yp ~i ' 5 ~' 3 {"1G. ~Q~9 ~UG,1.~'.: ~'~ 2~ 50 ~~ 3A3,* S,'iiAA'ft~1N ~~~~,:~ .~ ~a~t;~ut aHtiu9 ~~otrst~ t~t~uo-a ~~~~~s~~~ ;~ww; r~~t~~s~~rr~.r r rr~s .~+ ,.asp e~rscxa na=arlrrrr~a~ v~ w IIDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINB DOYLE, ESQIIIRE - ID #34576 ALAN M. MINATO, ESQIIIRE - ID #75860 CHANDRA M. ARKEMA, ESQIIIRE - ID #203437 LOIIIS A. SIMONI, ESQIIIRE - ID #200869 ADAM L. RAYES, ESQIIIRE - ID #86408 MARGUERITE L. THOMAS, ESQIIIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Beneficial Consumer Discount Company d/b/a :COURT OF COMMON PLEAS Beneficial Mortgage Co of Pennsylvania :CIVIL DIVISION :Cumberland County Plaintiff v. James P. McCrea Dawn McCrea ENO. 09-2547 Defendant(s) AFFIDAVIT OF SERVICE PIIRSIIANT TO Pa.R.C.P.RIILE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: July 30, 2009 UDREN C. _~ Attorneys--~~for Plaifi~i:ff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 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 #758fi0 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania Plaintiff v. James P. McCrea Dawn McCrea Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): James P. McCrea and Dawn McCrea PROPERTY: 83 West Main Street, (West Pennsboro Township) Plainfield, PA 17081 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on December 9. 2009, at 10:00 A.M., in the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXIHIBIT A ~ ' m N '0 n C7 Q D n (D v 0 ~_ N O N Cn v N c sy sZ ~'I O 3 w D1 V V fD 6 v m m~ O 3 c :;. n O 'a 7 d ~_ N 7 ui c Cn ? W N ~ O c0 OD v ~ Vt A W N r Z c. ~ ~ ~a~ ~ c c Q _ C ~ N NN7 (n y ~ ~ N o ~ N ~ 30 ~ a O N Ul ~ N N ~ O v ~ m c~ N m T ~~ ~ T T /~ ~ ~ n n Z i ~ D ~D ~ V ~ ~m V N l/ pmp ~o oc ~ i ~ ° ' ~ o'n Qm ' ~ ~D aom~ mm za~o ° c D c~pv m - fD , m X ~ v~ -'i x~ , ~ Om n ~,~ yN ~ r" ~ 3 -pZ Q-~p ~ z Ncp - i nC7 O~ D a m Z ~nZ ~ ` 0 0 ~ o D° b D N p N~ 2 ~ m m~ y A ~mD ~-1 ;o o i m ~~C~ wC~ cn~ cnc~ ~ ~ 2V1~ ~ ~`D mo ~~ m Nn i D ~0 (~ oo C O + t~Tl-ri r_~ rnO AO Dz ~' ~, r~ ~~~ f~° ~~ ~c ~ ~oD 01D2 y~ ~~ ~ C~ ~ ZO'r m ~o ~ ~ O~ m ~ 3 oNm , me ~'W ~ "~ ?~ v ~'~ oc i ~ ~~ o. 3 w to °' ° '`Z ~~°c m 'a W ~ _ nD <;,~ O hm ~ ° 05~ ~ w~• ~ ? m ~ n obi rn nOi ~ ~ ~ D m W D O ~ N ~ o n> ~ ~; ~ ~~ z - -vm ~O p o o m ~ ~ ~ ~ jD-~ = D~ a ~ ~ N Z p z D o n D ' ~ m m X w ~ ~ ~ W ~ o (~ j N O m m v y ^ ^ ^^ ~ ~ o ~m A _ ~ fD N a a m ~, ~ ~ ,D y n ~o m , ~ a , ~ 016f-{26519216 m o {~ ^ ^ ~ ^ i ~~ ~, ~ ~ ..~ CD ry ry N 7 'Y ~ Q7%13l2QOg ~ ~ o ~ m n ~ Mailed From 0$00.3 °-~ . fD 3 ~ m ~ , US POSTAGE g o o3nmc ~ - ~ <n c ~ n ~ 3 o m ~ w ~ m 2 y a- SN m~ m n~':~ o ~ m O ~> G tCN ' n < ~ y ~ y o N~ ~ ~ ~ _ ~ ~ fD ~ ~ O d _. O~ O j C O G~ ~ m 3 m p ~ w <D 07 A ~ m ~~~ O mm~m v~ ~~ Ot j d j ~ (NT O N ~~ d N O ~j n m Vj -_ C fD > Q 3°,$a~c c ~ o m. ~ o ~ m x m a ~ ~a_ N H ? ~ y n d m m m ~ ~ C C ai c m p$ m a m ~ fD ~ ~ m 3 m " n x.m ~~ m n-~m3on 3 ° n -O AN ~ ~~D ~ O ' ~ m ~ ir n~ f mc~§.3m3 ~= m ~~» 1 m 0~~ a o ~ ° ,Z ~ ~ C W l N~ 7 ~ ~ 3 0 v v „~ o c d ` 0 ~ ~ m n '~ ° ~ m ~. _~ ~» . ~ fDa+m ~~~0~'n ~~ ~ ~y m w v 2~ Tln m co n ~~w? NO D -may o 3 ~ m . ~y ~ 'c x ~ m3m3 ,+ ( ~_ ~(/~ wdo~m3 v ~vi~ y;1„, ,_~ m2 c3 m ° ~ 3 ..+.. tw o . .~ ~ O omgm~ v v > tBl A N '~ ~ , > y c S m m T N o m m~ o N ODREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #453.62 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. RAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ATTORNEY FOR PLAINTIFF 856-669-5400 Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania Plaintiff v. James P. McCrea Dawn McCrea Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-2547 PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: July 30, 2009 UDREN LAW OF P.C. ne s for tiff MARK J. UDREN, UIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE .ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ~eneticial Consumer Discount Company, et. al., Plaintiff(s) ~S. James P. McCrea, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Ste 200 Cherry Hill, NJ 08003-3620 ;Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 097761-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -James P. McCrea Court Case No. 09-2547 State of: ~'iJNsy !V ~'1.1 ~ ~ - -- -) ss. - - - _ - -- - - - - - - - - - - - County of: R'~~ ~~' i ~ Name of Server: Nis-- ~- ~ ,undersigned, being duly sworn, deposes and says that at the time of s ice, s/he was of legal age and was not a party to this action; Date/Time of Service: ~ that on the day of _ v ~ _, 20 ~, at - ~ $ o'clock ,~M Place of Service: at 3611 Va11e~View Drive, #2 , 1n Chambersburg, PA 17201 Documents Served: the undersigned served the documents described as: Notice of Sheriff s Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s) was served on: James P. McCrea Person Served, and Method of Service: ~ By personally delivering them into the hands of the per so n to be served. ,, n _ By delivering them into the hands of TJ~ N IBC ~X~~-~- ~, ~t! i.~~- , a person of suitable age, who verified, or who upon questioning stated; that~le/she resides with James P. McCrea at the place of service, and whose relationship to the person is: ~,~-'~ Description of Person Receiving Documents: The person. receiving docu a is is described as follo s: .~- Nt)VJ~- Sex ~ Skin Color ~ ~~ i ~ H i C l F i l H i „ ; ; r a o or ; ac a a r Approx. Age ;Approx. Height ~ ~G " ;Approx. Weight C) S To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares and pena f perjury Subscribed and sworn to before me this th ~ egoing is rll d o ect. ~~^~day of , 20 i. la%i gnature of Server Notary Public (Commission Expires) APS International, Ltd. ~~~....~ NOTARIAL tEAI LiJCILtE M. CART1- Notary rubNc LEtTERKENNY TWR FRANIC~IN COtlN1Y My ComrMplon Expire: Nov 10. Y01 i EXH~~17'8 .~ ~. Y ` Beneficial C~ amer Discount Company, et. al., Plaintiff(s) vs. .- James P. McCrea, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd, Ste 200 Cherry Hill, NJ 08003-3620 Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 097761-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: -Dawn McCrea Court Case No. 09-2547 State of: ~cu1,1~~(~J~Ni ~ ) ss. - - - - - - - - - - - - - - - - - - - - - - - - - - County of• 11 ~~~~ ~.1 Name of Server: wcv.,c~ ~~ t~. , ~t~ ,undersigned, being duly sworn, deposes and says that at the time of service, s/he~wa-s-of legal age and was not a party to this action; Date/Time of Service: that on the day of ~l y~~ , 20 ~., at f ~ o'clock °~M Place of Service: at 3611 Valley View Drive, #2 , in Chambersbur¢, PA 17201 Documents Served: the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property Service of Process on: A true and correct copy of the aforesaid document(s) was served on: Dawn McCrea Person Served, and Method of Service: ~, BY Personally delivering them into the hands of the person to be served. ^ By delivering them into the hands of , a person of suitable age, who verified, or who upon questioning stated, that he/she resides with Dawn McCrea at the place of service, and whose relationship to the person is: Description of Person The person receiving doc ~"nt is described as follow Receiving Documents: ex ~~ Skin Color n' ~~ Hair Color ~~7 n~ '~a~ ~ ~~ItS .G~~ ;Facial Hair Approx. Age ~ Jt"' ;Approx. Height ~5 ~ G ~ ;Approx. Weight 1 ~G ~ b s To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares u er pe of perjury Subscribed and sworn to before me this th th o egoing ' t e nd orre t. ~.. fyLday of , 20 ~ 9 --t- ir /~ ii Signature of Server Notary Public (Commission Expires) APS International, Ltd. NOTARIAL iE/1l LUCILLE N. CARTY Notory PubNc lETTERKENNY TWP, FRANKLMI COtIMY My CommiKlon Explr~ Nov 1 O, 2011 ~xNIB~T 8 ~~ j ifs rFt~~~'~iilYlf ?, At~G i ~ Pty 2~ 36