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Home My WebLink About09-5601D 4 , Brandon, FL 33510 Plaintiff €Cumberland County V. Daniel G. Poth Jane M. Poth NO. Q 437 Shippensburg Road 7 J Newville, PA 17241 Defendant(s) ATTORNEY FOR PLAINTIFF HSBC Mortgage Services Inc. :COURT OF COMMON PLEAS 636 Grand Regency Blvd. `:CIVIL DIVISION 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 ?ADAM L. KAYES, 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 pleadings@udren.com 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 demanders 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 c notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 I. NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is -deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 I 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: HSBC Mortgage Services Inc. Recording Date: LODGED FOR RECORDING 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 437 Shippensburg Road MUNICIPALITY/TOWNSHIP/BOROUGH: North Newton Township COUNTY: Cumberland DATE EXECUTED: 11/12/05 DATE RECORDED: 11/22/05 BOOK: 1931 PAGE: 4170 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 8/10/09: Principal of debt due $115,279.35 Unpaid Interest at 8.99% from 6/1/08 to 8/10/09 (the per diem interest accruing on this debt is $28.39 and that sum should be added each day after 8/10/09) 17,329.39 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0 and that sum should be added on the first of each month after 8/10/09) 1,784.64 Late Charges (monthlyy late charge of $61.63 should be added in accordance with the terms of the note each month after 8/10/09) 862.82 Suspense Balance (533.57) Attorneys Fees (anticipated and actual to 5% of principal) 5,763.97 TOTAL $141,091.60 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $141,091.60 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: . Attorneys or aintiff MARK J. UDRE9-IZESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ? ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE fY ALL. IMO TWO TRACTS OIC PARMLS OF LAND AND PREMIUM. SITUATE, LYING AND BEING IN THE TOWNSIBP OF NORTH NEWTON IN THE COUNTY OF CUMBEICI.AND AND COMMONWEALTH OF PENNSYLVANIA MORE PARTICULARLY DESCRIBED AS FOLLOWS: TRACT wo. I : BEGINNING AT A POINT IN 7E3s CENTER OF PENNSYLVANIA STATE. ffiC9HWAY ROUTE: NO. 533, WHICH POINT IS TIM CORNER OF EAT NO.9 AS SHOWN ON THE HEREINAFTER wmgr ONED PLAN OI: LC)i5: THENCE SOUTH 43 DBaREES 8 MQ+1UT,trS EAST ALONG THE WESTERN LINE: OF SAID LOT NO.9 A DwrAAM OF 200 FF.Efi' TO A POINT; TMNCR SOUTH 44 DEGREES 35 KNtJT8S WEST. A XOTANCE OF 91 FEET TO A POINT ON THE EAMERN LINE OF A 2S FOOT FARM LANE: TEEENC$ WORTH 39 DEGREES 25 MINUTES WEST ALONG 'THE EASTERN LINES OF SAID FARM LaNB, A DISTANCE OF 20DA FEET TO A POINT IN TIM CENTER OF SAID PENNSYLVANIA STATE HIGHWAY ROUTE NO. 5331, THENCE ALONG THE CENTER LbM OF SAID PENNSYLVANLA SLATE HPWAY ROUTS N0.533, NORTH 44 DEGREES 35 MIAI =5 EAST. A DISTANCE OF 77.3 FEET TO A POINT, THE PLALIE OF 13BOINNING. TRACT' NO 2: BEGINNING AT A POINT IN THE CENTER OF PENNMVANIA STATSMORWAY ROUTE NO. 533. WMCH POINT IS THE NORTHEASTERN COMM OF LOT NO. IO ( MAC!' NO. I ABOVE DE9CBIBSD ? AS SnOWN ON THE HsmouYm mEsmobm PLAN OF EATS: THENCE SOUTH 43 DEGREES 8 MINM BS EAST, A DISTANCE OF 200 FEET TO A POINT; THENCE 44 DECREES 35 Mn&MES EAST. 43DEC&EEDISTANCE OF 10D I= TO A POINT, Tm SOUTKWEST CORNER D MNCTIES WEST ALONG THE WFSTSRRNLWE OF I,OTN0.8 AFDILOT NO. 8, STANC:E OF ?20D FEET TO A POINT IN THE CENTER-OF MID PENNSYLVANIA STATESMIGHWAY ROUTE POINT IN THE CENTER OF SAED PENNSYLVANIA STATE E uGMA.Y ROUTE NO, 53X THENCE ALONG THE CENTER LINE OF SAS STATE HIGHWAY, SOUTH 44 DEGREES 35 I?+IB+TIITES WEST. A DISTANCE OF 100 FEET TO A POENT.THE PLACE OF BEGEPf M0. PARC:PI P :iil494593-994 April 22, 2009 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The HOMROWNF,ROS MORTGAGE ASSISTANCE PROGRAM (H .MAPS may he Alp. to help to cave your home. This Notice exnlainc how the program warks. 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 FOR EL PROGRAMA LLAMADO OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDDGR SU HIPOTECA. Page Iof6 EXHIBIT A HOMEOWNER'S NAME(S): Daniel G. Poth JAne M. Poth PROPERTY ADDRESS: 437 Shippensburg Road Newville, PA 17241 _ LOAN ACCT. NO.: 0012275376 --- LENDER: Fidelity of Penn&xlvania Mort?g,..Inc,_- ORIGINAL CCIRRENT LENDER: _IiSSC Mortgage Services HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOTT MAY BF, FT.TGIR .F FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECT.OSTTRF. AND HF.T P YOU MAKE, FITTURF MORTGAGF, PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERQS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE BACTO), 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 FORF.C_LC)STTRE - 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 Dface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MF.FTING MUST OCCITR WITH NOTICE CAT T FT) DHOW TO CURE YOUR MORTGAGR T)F.FAT I .TU, FXPT .ATLAS HOW TO RRTNCT YOTTR MORTCTAGR UP TO DATE.- C_'ONSUMER CREDIT COTTNS .I.TNG AC:F.NC1F,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 an telenhnne numbers are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender imm_edi_ ateel 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 Page 2 of 6 ` program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AC.FNC'V ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania. Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 437 Shippensburg Road Newville PA 17241 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 $1428.98 for July 1, 2008 through December 1, 2008 = $8573.88 Monthly Payments of X1455_.56 for January 1, 2009 through April 1_,,,2009 = 22.24 MonWa_Late Charles of $61:63 for Jul. l? 20118 through Apxal 1.2909 = %_16,30 Other charges (explain/itemize): BPO = $100.00 Property Inspections = $12.50 TOTAL AMOUNT PAST B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do no zse if not ap In icahle): DA HOW TO CURE THE DEEAUL,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 515181.63_ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa r_nts must he made either by cash rashi is rherk? certified check or money order made payable and cent to: ITdren L.aw Offices, P.C. Wooderest Corporate C,piter 111 Wood rest Road, Suite 200 C'"herre Hull, N.T 08003-3620 Page 3 of 6 'You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (M not use if not =licahle_): WA IF VOU DO NOT CURE THF. DF.FATTLT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise .its rights to ac ..1 .ra he mi rage de ht_ This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose tllon your mortgaged pr=rty IF THF. MORTGAC.F, Ifi FORRCLOSF,D UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THTRTY (30) DAY period, you will not he required to pay attorney's fees- OTHER i .F.NDF,R RF.MF.DIF.S - 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 bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGTTT TO C"IFRT. THE 1)F.FAIJT,T PRTOR TO SHFRTFF'S SAT.F -If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour hefnre,the Sheriff's Sale- Y011maydosohy paying the tntal amount then past due,, plus any late or other charges then due, reasonable attomeX's f .es an costs enrnn .cted with the foreclosure sale snd any other costs connected with the Sheriffs SIP, aS _ enified in writing by the lender and h; znerfnrming any other requirements under the mn_ rtooaa . 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. FARI,TF.ST POSSIBLE SHRRIFF'S SALE DATE. - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. 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 Address: 636 Grand Regency Blvd. Brandon FL 33510 Phone Number: _800-365-6730 Fag Number: 513-571-8917 Contact Person: Loss Mitigation EFFECT OF SHERIFF'S SALF. - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAC?F - 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 6 . , 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 PI Page 5 of 6 e 1 0 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CTIMBT.RI,AND C'nITNTY t Page 6of6 e 2 , HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report test updated: 1011512007 10:03:08 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334,1518 CCCS of Western PA 2000 Unglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captiai Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 Loveship, inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 10 '. 1 • ? N a w z j R Q N C3 \ W y L3 N . Q = Q l 13 ETJ o a ca C3 C } T tr' p 06 AJIIvbu! us 8ui?e,u ua"at -ooo-a -M/ NSd lest&Asy/ 9W, l,S V'OCee uao.4 Sd L'84 M luesaJd pue idlem sly} aneg :1NY1HQdlN! P. 'Itew Pug aBe,sod? s ge! 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AisA!lap )o prooau v weldllew jnoR .Io1 jelyluepr enb!un y Idaow 6u!I!ew V :sapiAa,# lie -W P8111118! • . 1 Q U 1 10 } CO o _a: ..G CO> C C3 0 O . 0 ?..?.. a ru a M; .. .. N 0 0 r .Hasler L OT nj cp ?M? d. N 971 , 4 , ? • 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 LAW OFFICES, P.C. BY : ?fo-r2?Yaintiff Attor eys MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE rADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 0- C-D r ???? 11n ', .?1v $7 ?-` 5-610 d J, Vdcc,, ci "l' /3 5-0 3 5- . . 12#., d-- a9/v;?-- Sheriffs Office of Cumberland County R Thomas Kline Sheri QFFiC.E OF"-rS"ERIFF FILEU---, i CE OF THE c ; ..r4 "`NOTARY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor HSBC Mortgage Services, Inc. vs. Daniel G. Poth 2004 AUG 28 Ph 12*. 51 r Case Number 2009-5601 SHERIFF'S RETURN OF SERVICE 08/25/2009 06:25 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on August 25, 2009 at 1825 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Daniel G. Poth, by making known unto himself personally, at 437 Shippensburg Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. 08/25/2009 06:25 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on August 25, 2009 at 1825 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jane M. Poth, by making known unto Daniel Poth, Husband at 437 Shippensburg Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $54.80 August 26, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By De ty Sheriff 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 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM KAYES, ESQUIRE - ID #86408 MARGUERITE THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Daniel G. Poth Jane M. Poth NO. 09-5601 Civil Defendant PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE. DATED:September 22, 2009 UDREN LAW OFFICES, P.C. Attorneys for la tiff MARK J. UDREN, SQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM KAYES, ESQUIRE MARGUERITE THOMAS, ESQUIRE C 0 UC L)g0'103'7/ -I Or THE F'? ' ".' 7?AR1' 2GG9 OCT 12 A.M 10. 1) a 11 . r..