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HomeMy WebLinkAbout09-7036UDREN 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 L,,"AM 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 The Bank of New York Mellon, :COURT OF COMMON PLEAS as Trustee for the registered :CIVIL DIVISION holder of the Renaissance Home Equity Loan Asset-Backed :Cumberland Certificates, Series 2003-2 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. Donna M. Comp County Marlin L. Comp NO. Ui- 703 1021 Teakwood Lane Enola, PA 17025 Defendant(s) w? t lerw? 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 f' PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 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 provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INNEDIATANLNTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLANE POR TELEFONO A LA OFICINA COYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 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 E 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: JPMorgan Chase Bank as Trustee, for the registered holder of the home equity loan asset-backed certificate series 2003-2 Recording Date: 9/13/06 Book: 730 Page: 1660 Assignor: JPMorgan Chase Bank as Trustee, for the registered holder of the home equity loan asset-backed certificate series 2003-2 Assignee: The Bank of New York Mellon, as Trustee for the registered holder of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2003-2 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: 1021 Teakwood Lane MUNICIPALITY/TOWNSHIP/BOROUGH: East Pennsboro Township COUNTY: Cumberland DATE EXECUTED: 4/23/03 DATE RECORDED: 5/5/03 BOOK: 1809 PAGE: 3648 The legal description of the mortgaged premises is attached hereto and made part hereof. F' 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 9/9/09: Principal of debt due $173,073.37 Unpaid Interest at 7.50% from 5/1/09 to 9/9/09 (the per diem interest accruing on this debt is $36.03 and that sum should be added each day after 9/9/09) 4,613.86 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 9/9/09) 4,087.96 Late Charges (monthly late charge of $55.70 should be added in accordance with the terms of the note each month after 9/9/09) 334.20 Property Inspection 21.00 BPO 111.00 Attorneys Fees (anticipated and actual to 5% of principal) 8,653.67 If TOTAL $191,500.06 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 $191,500.06 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 for P in:t f MARK J. UDREN, ES E STUART WINNEG, ES IRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ALL THAT CERTAIN TRACT OR LOT OF LAND SITUATE IN EAST PENNSBOR0 TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN LINE OF TEAKWOOD LANE, AT THE LINE OF ADJOINER BETWEEN LOT NOS. 75 AND 74 ON THE HEREAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID LINE OF ADJOINER NORTH 12 DEGREES 54 MINUTES . WEST, 105 FEET TO A POINT AT LOT NO.63;THENCE ALONG LOT NOS. 63 AND 64, NORTH 77 DEGREES 06 MINUTES EAST, 85 FEET TO A POINT ON THE LINE OF ADJOINER BETWEEN LOT NOS. 74 AND 73; THENCE ALONG SAID LINE OF ADJOINER SOUTH 12 DEGREES 54 M -AMS EAST, 105 FEET TO A POINT ON THE NORTHERN LANE LINE OF TEAKwOD LANE; 06 MINUTES WEST, 8FEET TO THE POINT AND PLACE OF SOUTH Ii 77 7 DEGREES BEGINNING. AS RECORDED LOT BEINC'g KNOWN AS N PLAN OOK 34, PAGE 13 01, IN THE CUMBERLAND COUNTY RECORDERS ? ' FFICE. B!(l809PG366I September 10, 2009 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 OHOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page 1 of 1 EXHIBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Donna M Camp _Marlin L Comte------ ---- - -- --------____----------------- 1021 Teakwood Lane _Enol% PA.17025--------------- ?. - --------.-............ .-_..... --- -------- _101802403 -Fidelity M"rt aa---------- -------...................... _ One West Bank -...... HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM VOIT MAV RE ELIGIBLE FOR FINANCIAL ASSISTANCE NMIC14 CAN SAVE, YOUR HOME. FROM FORECLOSURE. AND HELP VOLT MAKE, FUTURE. MORTGAGE. PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE OACTO), 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 FOREC-1,01,91TRF. - 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-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TMS MEETING MUST OCCUR WITHIN THE. NEXT (30) DAYS- IF Y01T DO NOT APPT.Y FOR E.ME.RGF.NC:Y MORTGAGE. ASSISTANCE,, Y61 J MT JST RRTNG YOT JR MORTGAGE. T JP TO DATE- THE. PART OF THIS NOTTCF CALLFD DHOW TO CT TRF YOUR MORTGAGF. DFFAT JT.TO, EXPLAINS HOW TO RRTNG Y01JR MORTGAGE. TTP TO DATE- CONSUMER CREDIT COUNSELING AGENCIES - 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 name a_rlciregsec and telephone n umbers ofd cignated consumer credit counseling agencies for the county in which the n r is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender irnmediatel 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 dace- to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CITRF. YOUR MORTGAGE DEFAULT (Bring it nil to dskte)- NATITRF. OF THE, DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1021 Teakwood Lane Enola, PA 17025 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: _Monthl Payments of $1354.56 for June 1, 2008 through September 1, 2008 = 5418.24 MontWLate Charges of $55.70 for June 1, 2009 through August is 2009 = 167.10__ Other charges (explain/itemize): Property Inspection = $21.00 Late Charge = $167.10 Property Valuation = $111.00 _Escrow Advance =34081% -------- ._-_.---------- .---- _-_._._ TOTAL AMOUNT PAST -DUE: ..__?u_ _ ._._.-_._._._-.__---- ,_.-.... -------- ----_--1997?-44.. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (I)o not use if not applicable): WA HOW TO CURE. THE, DEFAULT - 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 "172-40_ PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pa=en s must he made either by ac , cashier's check, certifi .d check or money order made payable and cent to* Udren Law Offices,p.C. Wonderest CaMrate Center I I I Wondered Rnad; Snite 200 Chera Hill, NJ 08063-3620 Page 3 of 3 YOU can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not awlicahle-l: MA IF YOii no NOT CURE. TIFF. DF,FATTLT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends n sereise its rights to accelerate the mnrtgsge debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mn aged p nom, iF THE, MORTGAGE, IS FORECLOSED 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 yn . cure he default within he THIRTY (30) DAY priod, run will not he required to pav aTttarna''s fees. OTHER i.F.NDF.R RE,ME,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. RIGHT TO CI1RE, THE. DEFAULT PRIOR TO SHERIFF'S SALE. - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun; you still have the right to cur the d fa ult and prevent the gale at any im . up to nn e hour hefore the Sheriff's Sale_ You may do cn hT paying the total amnimt then find due li? m any la P nr other charges then due, reasonable attnmey's fees and costs connected with the foreclosure gale and any other costs connected with the Sheriff's Sale as • meified in writing by the lender and by peg any other requirements order the mart_ga_g . Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SAi.E. DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 6 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 ford out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: ._Ocwen Address: 12650 Integrity Drive Orlando, FL 32826-_----- ----- _._..._.__ Phone Number: _877-596-8580 _._._._._...._._._.__ Fax Number: 407_737-5693 ----------_...._...... _....... _._._-. - Contact Person: _-Customer Service __............... _._...--.-................ F.FFF.CT OF SHERIFF'S SAi,F. - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGF. - 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 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 the9riginal 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 of 5 • 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. Page 6 of 6 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10/15/2007 10:03:08 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry 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 P' I WOH )Pewlsod 3. '' W 04 °r N_ N Lfi Q E 20 © U. CL ? O 0'C3 .. C3 a aftsod 18101 sMu3) C3 C3 nbed iuew* ! tieMlea pepNleeH : O 0 lnbey luewes?o U3) G C3 3dieoeN wMOW i j O O loommums powpo`J -? N rU $ 968190d f 3 . Er cr W W W W L-i L_j mlllmwt? C3 C3 Ln Ln MMMMYEN i L ' ^ ^^ W y cc LLI FW. U1a,N']c) o0 co cc Cl ui 1 40' w LL 0- cc Z! 0 3s 00 >- W?? CC '(Z cr T Q Q ? 0 E ,J . , b / Cf) r C C C Certified Mail Provides: ¦ A mailing receipt ¦ A unique Identifier for your mailpiece ¦ A record of delivery kept by the Postal Service for two years Important Reminders: • Certified Mail may ONLY be combined with First-Class Maile or Priority Mails. ¦ Certified Mail is not available for any class of international mail. ¦ NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For valuables, plefise consider Insured or Registered Mail. ¦ For an additional fee a Retum Receipt may be requested to provide proof of R celp .(PS Fain Reiu j to a eipt article padder complete and attach a Return fee. Endorse mailpiece'Return Receipt Request pd"". Too rece postage wacover the ver for a duplicate return receipt, a USPS® postmark on your Certified Mail receipt is required. ¦ For an additional fee, delivery may be restricted to the addressee or addressees authorized agant. Advise the clerk or mark the mailpiece with the endorsement 'Restdcted Delivery'¦ If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT. Save this receipt and present it when making an inquiry. PS Form 3800, August 2006 (reverse) PSN 7530-02-DOO-9047 I E Z Ik u ¢ 18 N 21 LL OD M I E r0 CL 4 Ocwen Loan Servicing, LLC P.O. Box 785063 Orlando, Florida 32878 -5063 (Do not send correspondence or payments to the above address) WWW.OCWEN.COM July 31, 2009 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515127778718 Reference Code: 0906 Donna M. Comp 1021 Teakwood Lane Enola, PA 17025-0000 Loan Number: 101802403 Property Address: 1021 Teakwood Lane, Enola, PA 17025-0000 PLEASE SEE THE ENCLOSED DOCUMENT DACr91.13 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy; this communication is not intended as and does not constitute an attempt to collect a debt E G °? Ocwen Loan Servicing, LLC P.O. Box 785063 _. Orlando, Florida 32878 -5 063 0 C W c " (Do not send correspondence July 31, 2009 or payments to the above address) WWW.OCWEN.COM APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE e LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDP IIR SU HIPOTECA. HOMEOWNER'S NAME(S): Donna M. Comp PROPERTY ADDRESS: 1021 Teakwood Lane Enola, PA 17025-0000 LOAN ACCT. NO.: 101802403 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CURRENT LENDER/SERVICER: OCWEN DACT91.13 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt a Ocwen Loan Servicing, LLC P.O. Box 785063 - - - Orlando, Florida 32878 -5063 t " (Do not send correspondence or payments to the above address) WWW.OCWEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM If YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act you are entitled to a tem,porary stay of foreclosure on your -6- f- +161..4.. 12M d-.,. 46-- +l.- A.*- -f +.i.. N.d:..- il....iw- +{...+ +1-- .,-.. ......* -.-.-...... -..d -44--A - Ilf-.... - C-99 YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CAL LED"HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. 11M names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the l1raRt v is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately 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 face-to-face meeting. YOU MILT FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). I his communication is, from a debt collector attempting to collect a debt; any infon However, if the debt is in active bankruptcy or has been discharged through bankruq does not constitute an attempt to collect a DACT91.13 m obtained will be used for that purpose. this communication is not intended as and Ocwen Loan Servicing, LLC P.O. Box 785063 Orlando, Florida 32878 -5063 (Do not send correspondence or payments to the above address) WWW.OCWEN.COM HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to datel. NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 1021 Teakwood Lane, Enola, PA 17025-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 1,354.56 from June 01. through July 31. DETAIL SUA94ARY : Principal and Interest ................................. $ 2,228.12 Interest Arrealage ..................................... $ 0.00 Escrow .................................................. $ 481.00 Late Charges ........................................... $ 278.50 Insufficient Funds Charges ........................... $ 0.00 Fees / Expenses ........................................ $ 54.82 Suspense Balance (CREDIT) ........................ $ 0.00 Interest Reserve Balance (CREDIT) ................ $ 0.00 TOTAL DUE .......................................... $ 3,042.44 HOW TO CURE THE DEFAULT - 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 $3,042.44, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PAMC = must be made either by Money Gram Cashier's Check. Certified Check or Money Order made pajable and sent to: OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197.6440 IF YOU DO NOT CURET E DEFAULT - 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 accelerate the morn= debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your m9ft=d prop IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred up to $50.00. However, if legal proceedings. are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (330) DAY period, you will not bey iced to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - 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 he default and prevent the sale at any time up to one hour before the Sheri_tFs Sale. You may do so by_payjng the total amount then past due.. ____ •_-_ _- _at__ J_-. ?_-....Lt.. ..aa....-..-.1.. ! --A ......M ........ -4&4. 4.1- {'-L.w....e .-J. n-d -, requirements 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. EARLIEST POSSIBLE SHERIFF'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 six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. DAM1.13 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt E jo? Ocwen Loan Servicing, LLC P.O. Box 785063 - Orlando, Florida 32878 -5063 Ere « c " (Do not send correspondence or payments to the above address) W W W.OCWIN.COM HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 33416-4737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Performing Collections Dept. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COtLN7 DACT91.13 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt f' September 10, 2009 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 WMEDITAMENTE LLANIANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO DHOMEOWNERGS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page. 1 of 1 E' HOMEOWNER'S NAME(S): Donna M Comp Marlin L. Comp_ PROPERTY ADDRESS: 1021 Teakwood Lane EBol& PA 17 15___,- LOAN ACCT. NO.: 101802403 __-..._-. ORIGINAL LENDER: Fid Mortgage CURRENT LENDER: . One W_...._ est Bank HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE RI,TGIBI.F. FOR FINANCTAT. ASSISTANCE WHICH CAN SAVE, YOTTR HOME, FROM FORFCT.OSTTRR AND FFELP YOU MAKE. F1JTTTRV MORTGAGE. PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE OACTO), 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 FORECI.01,91TRE -- 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-faceO meeting. with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING UST OCCITR WITHIN NOTICE CAT ED DHOW TO CiIRF,YOTTR MORTGAGE DF.FAITT.TO, EXPLAINS HOW TO RRINC: YOT TR MORTGAGE ITP TO T) ATF_ CONSITMF.R CRFDTT COUNSELING AGF.NCWS -- 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 erg you for thirty (30) days after the date of this meeting. The names, addresges anal to urbane numb are get firth at the end of this, Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender imrnedi tely 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 e face- to-face meeting. YOU mus,T FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER IBM PERIODS SET FORTH IN THIS LETTER, FORECLOSURE . MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. ACS7.NVV AC'TTON - 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.) HOW TO CURE Vn TR MORTGAGF. DEFAULT (Bring it nil to nte)_ NATTTRF OF THF, DEEATTLT - The MORTGAGE debt held by the above lender on your property located at: 1021 Teakwood Lane Enola, PA 17025 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: Monthlv Payments of $135456 for June 1,20088 through fttember 201)$?S5418.24 _Monthly Late Charges of $55.70 for June 1, 2 thro agh A gnstt 1. _M09_ = 16LI Other charges (explain/itemize): Property Inspection = $21.00 Late Charge = $167.10 Property Valuation = $111.00 Escrow Advance = 87.96 ?. TOTAL AMOUNT PAST DUE B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not mmlicable): NA HOW TO C:ITRF. TAE DEFAULT -- 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 $,9972,40. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pamnents, meat he mAde either hy„?Qh,snchier'c check, nerlifieri check ar mnneYy order made psi johle and cent to, ITdren I.Aw Off em, P.C. Wnndertst Cnrnnrate Center 111 Wnnderest Rnsdr Suite 200 C.hg= Hill, NJ 0860-3620 Page 3 of 3 You can cure any others default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if no applicable_): NZA IF YOU DO NOT CITRF. THE DF.FAITI.T -- 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 reelerate the mnrtgagc debt- This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in. monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose up= your mortgaged property, iF THE MORmAcw is FORECLOSEIIr 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 cur the d fan t within the THIRTY (10) PAY period, you will not he _Mnired to pay attorney's fees. OTHER LENDER 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 bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT TO CITRF THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun; yon still have the right to enre the default and amymt the sale at any time z to nne hour lie fn the Cherifl's 4ale Ynrr may do co hT naydng the tot^i amnnnt then past due p1 m; a y late or other charges then dne,, reasonable- attorney's fees- anti costs crmnected with he fn ^las ure sale and ^ny other,cnctc rnnnactrsi with the 4heriff'c We as sac=ffied in writing by the lender and hyme n any other requirements order h , 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. EARLIEST POSSiRIE SHF.RiFF'S SAI.F DA- It is estimated that the earliest date that such a. Sheriff's We of the mortgaged property could be held. would be approi:imately 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. HOW TO CONTACT THE LENDER Name of Lender/Servicer: _ c en-_ Address: 12650 Integrity Drive Orlando , FL 32826 Phone Number: 877-5596-85SO Fax Number: 407-737-5693 Contact Person: _ Custom er EFFECT OF SHERIFF'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. ARRI M"JON OF MORTGA- 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 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 as 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 of 5 F 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 7 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. Page 6of6 E HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10/15!2007 10:03:08 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717,334.1518 CCCS of Western PA 2000 Lingiestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captiat Region 1514 Deny Street Harrisburg, PA 17104 717.232.8757 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 f F '?' cx• c°S LUJ7 INC- G m< c ° F- cs C) eb 4! id _ y ? 6 447 . - ------ ON XOe od C3 C3 r ----- ? ? of EM 1 s qee?j $ "Mwd RPI k-J waawpu3) C3 ?e 80 e1 o0 POP OU O C3 (Xnbeti luawesJ0Pu3) t3 O TA t eaj ?d!eney wmski O Q ?sf<' as ?i ......?. eu d a6d PeUA+aO flu N 5 eBa{eod v W ?_• W W Q MOMEM x = C3 L r.0 ...11 cc LO C a k.E..i ="5 Cl) Q U U? U- CL a -J © CC ?Q©r ?- p Mr Z LIy J 3: C. Lam. \i T ...A.. rr 'V? ?S ?:-- F ,n .ICJ r pl- ? C C C I E Certified,fail Provides: r A mailing receipt s A unique Identifier for your mailplecs f A record of delivery kept by the Postal Service for two years Important Remirulam! It Certified Mail may ONLY be combined with First-Crass Mail, or priority Mai6'. a CeWtied Mall is notavallabie for arty class of international mail. is NO INSURANCE COVERAGE IS PROVIDED with Ceriltied Mail. Foi valuables, plYase consider insured or Registered Mafl. rt For an additional fee, a Retum Receipt may be requested to rovide proof of delivery. To obtain Return Receipt serviceeas complete and attach a Return Receipt (PS Form 38111 , p s to the article and add appllc ibie postage to cover the fee. Endorse maiiplece Return Receipt Requested'. To receive a fee waiver for a duplicate retum receipt, a USPSo postmark on your Certified Mail receipt is required. 0 For an additional fee, delivery may be restricted to the addressee or addressee's authorized? aggs?ort. Advise the clerk or mark the maifpfece with the endorsement Restricted Delivery". B It a apostmark on the Certified Mail receipt is desired, please present the arti- rec fie pnot ost needed, for posttnaridng. If a postmark on the Certified Mail p detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when malting an inquiry. PS Fumy 31M August 2tm6 (Rvs"m,! PSN 75 i6{12-0(Kl SDA7 f n 3 ri R't Art 11 fu o t? 13 ir 3- E Q 'R 5$t C3 O T ? c0 2 V tZ C 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 ?dZ4?r f Attorneys for Pl i tiff MARK J. UDREN, ESUIRE 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 C Q 11 ` ! 1 ;. r m -TA 25 . C *,m so Po ATYY RTC` a3ao,1a Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor oti++1t+` uY ~~r~t~Gcrf~,~i ~,,~ , 7 ; ... ,`~~~f - i ,_ - The Bank of New York Mellon vs. Donna M. Comp Case Number 2009-7036 SHERIFF'S RETURN OF SERVICE 10/19/2009 05:38 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 19, 2009 at 1738 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donna M. Comp, by making known unto Marlin L. Comp, husband of defendant at 1021 Teakwood Lane Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. 10/19/2009 05:38 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 19, 2009 at 1738 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Marlin L. Comp, by making known unto himself personally, at 1021 Teakwood Lane Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $57.50 ~ ~~. Si~ ss October 20, 2009 R THOMAS KLINE, SHERIFF >3y -~~ Deputy 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 L. KAYES, ESQUIRE - ID #86408 ~ ~,~_~, MARGUERITE L. THOMAS, ESQUIRE - ID #204460 `- ~. WOODCREST CORPORATE CENTER ~,,, , "i:~, 111 WOODCREST ROAD, SUITE 200 ' CHERRY HILL, NJ 08003-3620 ; 856-669-5400 _ - The Bank of New York Mellon, as Trustee for =COURT OF COMMON PL AS ~ the registered holder of the Renaissance Home ,_. :CIVIL DIVISION Equity Loan Asset-Backed Certificates, Series :Cumberland County ^- 2003-2 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff v. Donna M. Comp Marlin L. Comp NO. 09-7036 Civil Term 1021 Teakwood Lane Enola, PA 17025 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 r-a c~ c_._ = _¢ :~ i ., s ~_ . ~ {,,., ~.c , . ;., ~, ~_~ ~ 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: January 22, 2010 REN ICES, P.C. BY: Atto Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE C.7e6''LTIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE 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 L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com The Bank of New York Mellon, :COURT OF COMMON PLEAS as Trustee for the registered .CIVIL DIVISION holder of the Renaissance Home €Cumberland County Equity Loan Asset-Backed Certificates, Series 2003-2 :MORTGAGE FORECLOSURE Plaintiff v. Donna M. Comp €NO. 09-7036 Civil Term Marlin L. Comp Defendant (s ) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York Mellon, as Trustee for the registered holder of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2003-2, 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: 1021 Teakwood Lane Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Donna M. Comp 1021 Teakwood Lane Enola, PA 17025 Marlin L. Comp 1021 Teakwood Lane Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Citibank (South Dakota) NA 701 East 60th Street, North, Sioux Falls, SD 57104 4. Name and address of the last recorded holder of every mortgage of record: Name Address The Bank of New York Mellon, 12650 Ingenuity Drive as Trustee for the Orlando, FL 32826 registered holder of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2003-2 5. Name and address of every other person who has any record lien on the property: Name Address East Pennsburg Township 98 South Enola Drive Enola, PA 17025 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. 1 Courthouse Sq., Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 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 1021 Teakwood Lane Enola, PA 17025 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: January 22, 2010 UDR N F~ES, P.C. i BY: Attorneys ~ Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ms's` A . S IMONI , ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #4.5362 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 The Bank of New York Mellon, as Trustee for the registered holder of the Renaissance Home Equity Loan Asset- Backed Certificates, Series 2003-2 Plaintiff v. Donna M. Comp Marlin L. Comp Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 09-7036 Civil Term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Donna M. Comp and Marlin L. Comp PROPERTY: 1021 Teakwood Lane, Enola, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 3. 2010, at 10:00 A.M., in the Commissioner's 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. 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'~ _ a7 y-wN O O , .~ BSc m N ~fn ~ Q . ' a~ ; ^ ~ m m ~;_. 1D o a m fD0 d cD = a. ~ ?±. . . ~dN ~x -mm~ ~ T ~ m y m o~ W 3 ~c3~~;~ c p m 2 m v m n to ~ t~ o ~ ~ ~ mom ~ ' ~ ~ m~ o ~ N 3 m w o~ ° ~r~, .•'°~ ~~ ~ " (k~~,l IY ' `' ~) i.{ V ! o ~ ~ o ~ fti' .s . > > v, c o~~ fD y N ~ _ m o N ~ ~.._ , SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~ ~~ Ronny R Anderson Sheriff • ~~;,,~',~, ~~ ~ruu~,~,rla~i Jody S Smith ~ Chief Deputy _ Edward L Schorpp Solicitor <~F~ ~ ~- ~~~ ~~« The Bank of New York Mellon vs. Donna M. Comp Case Number 2009-7036 SHERIFF'S RETURN OF SERVICE 12/23/2009 04:04 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1604 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donna M. & Marlin L. Comp, located at, 1021 Teakwood Lane, Enola, Cumberland County, Pennsylvania according to law. 12!23/2009 Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 200 at 1825 hours, he served a true copy of the within Reaf Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Donna M. Comp, by making known unto, Marlin L. Comp, husband of defendant, at, 1021 Teakwood Lane, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/23/2009 06:25 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1825 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Marlin L. Comp, by making known unto, Marlin L. Comp, personally, at, 1021 Teakwood Lane, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to him personalfy the said true and correct copy of the same. ~ . ~`~ '~ ~ ~~ . ~ ~.~ -^ Cow?iy>ute Shecff. l-eieos~fi. In^.. SHERIFF'S OFFICE OF CUMBERLAND CQ LINTY Ronny R Anderson Fll.E? ~~~~~ ''E Sheriff Jody S Smith ~~~rti~t~~ oC ~~ur+6rr~~rt~ 20Ia APR (9 r~~ S~ 47 Chief Deputy t~, -. Edward L SchorPP Cilv~~':~' >~.`'U 4~~~u~'Y Solicitor c~ ~ ~ ~ ° ~~~;~~~r P~J~;$~SY~.`,l u #d The Bank of New York Mellon vs. Case Number Donna M. Comp (et al.) 2009-7036 SHERIFF'S RETURN OF SERVICE 12/23/2009 04:04 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1604 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donna M. & Marlin L. Comp, located at, 1021 Teakwood Lane, Enola, Cumberland County, Pennsylvania according to law. 12/23/2009 Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 200 at 1825 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Donna M. Comp, by making known unto, Marlin L. Comp, husband of defendant, at, 1021 Teakwood Lane, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/23/2009 06:25 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1825 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Marlin L. Comp, by making known unto, Marlin L. Comp, personally, at, 1021 Teakwood Lane, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 03/02/2010 Property sale postponed to 6/2/2010. 04/15/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Lorraine Doyle on 4/7/10 SHERIFF COST: $815.11 SO ANSWERS, April 16, 2010 RON R ANDERSON, SHERIFF ,:~ .~ P~ . Co . ,~ rya ~~5, (c;= Goun!ySuite ShEr*f. Te!ecu`t. h^c. f . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ~ MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEr, 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com The Bank of New York Mellon, :COURT OF COMMON PLEAS as Trustee for the registered :CIVIL DIVISION holder of the Renaissance Home :Cumberland County Equity Loan Asset-Backed Certificates, Series 2003-2 :MORTGAGE FORECLOSURE Plaintiff v. Donna M. Comp 5N0. 09-7036 Civil Term Marlin L. Comp Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 The Bank of New York Mellon, as Trustee for the registered holder of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2003-2, 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: 1021 Teakwood Lane Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address Donna M. Comp 1021 Teakwood Lane Enola, PA 17025 Marlin L. Comp 1021 Teakwood Lane Enola, PA 17025 2. Name and address Name SAME AS #1 ABOVE 3. Name and address a record lien on th Name of Defendant(s) in the judgment: Address of every judgment creditor whose judgment is e real property to be sold: Address Citibank (South Dakota) NA Address to follow { . 4. Name and address of the last recorded holder of every mortgage " of. record: Name ~ Address The Bank of New York Mellon, 12650 Ingenuity Drive as Trustee for the Orlando, FL 32826 registered holder of the Renaissance Home Equity Loan Asset-Backed Certificates, Series 2003-2 5. Name and address of every other person who has any record lien on the property: Name Address East Pennsburg Twp. Address to follow 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 1021 Teakwood Lane Enola, PA 17025 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: November 21, 2009 UDREN LAW OFFICES, P.C. Attorneys for aintiff 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 ' UDREN •LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 QUART WINN~G, 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 WOODCREST CORPORATE CENfiER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com The Bank of New York Mellon, :COURT OF COMMON PLEAS as Trustee for the registered :CIVIL DIVISION holder of the Renaissance Home.€Cumberland County Equity Loan Asset-Backed Certificates, Series 2003-2 :MORTGAGE FORECLOSURE Plaintiff v. Donna M. Comp NO. 09-7036 Civil Term Marlin L. Comp Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Donna M. Comp 1021 Teakwood Lane ' Enola, PA 17025 Your house (real estate) at 1021 Teakwood Lane Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 3, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $194,297.35, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. s 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will-remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty .Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J,,, UDREN, ESQUIRE - ID #04302 S7.''('~,RT 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com The Bank of New York Mellon, 'COURT OF COMMON PLEAS as Trustee for the registered :CIVIL DIVISION holder of the Renaissance Home :Cumberland County Equity Loan Asset-Backed Certificates, Series 2003-2 MORTGAGE FORECLOSURE Plaintiff v. Donna M. Comp =NO. 09-7036 Civil Term Marlin L. Comp Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO:, Marlin L. Comp 1021 Teakwood Lane Enola, PA 17025 Your house (real estate) at 1021 Teakwood Lane Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on March 3, 2010, at 10:00 A.M. in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $194,297.35, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS. YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS. EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's-Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not. paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 ALL THAT CERTAIN TRACT OR LOT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN LINE OF TEAKWOOD LANE, AT THE LINE OF ADJOINER BETWEEN LOT NOS. 75 AND 74 ON THE HEREAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID LINE OF ADJOINER NORTH 12 DEGREES 54 MINUTES WEST, 105 FEET TO A POINT AT LOT N0.63; THENCE ALONG LOT NOS.63 AND 64, NORTH 77 DEGREES 06 MINUTES EAST, 85 FEET TO A POINT ON THE LINE OF ADJOINER BETWEEN LOT NOS. 74 AND 73; THENCE ALONG SAID LINE OF ADJOINER SOUTH 12 DEGREES 54 MINUTES EAST, 105 FEET TO A POINT ON THE NORTHERN LINE OF TEAKWOOD LANE; THENCE ALONG THE NORTHERN LINE OF TEAKWOOD LANE SOUTH 77 DEGREES 06 MINUTES WEST, 85 FEET TO THE POINT AND PLACE OF BEGINNING. BEING KNOWN AS LOT NO. 74 AND FINAL PLAN NO.1 OF TREEMONT, AS RECORDED IN PLAN BOOK 34, PAGE 131, IN THE CUMBERLAND COUNTY RECORDER'S OFFICE. BEING KNOWN AS: 1021 Teakwood Lane, Enola, PA 17025 PROPERTY ID NO.: 09-13-0998-026 TITLE TO SAID PREMISES IS VESTED IN DONNA M. COMP AND MARLIN L. COMP, HER HUSBAND BY DEED FROM DONNA E. MYERS DATED 10/31/00 RECORDED 11/2/00 IN DEED BOOK 233 PAGE 145. . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-7036 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON, as Trustee for the registered holder of THE RENAISSANACE HOME EQUITY LOAN ASSET-BACKED CERTIFICATES, SERIES 2003-2, Plaintiff (s) From DONNA M. COMP and MARLIN L. COMP (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 $194,297.35 L.L. $.50 Interest 11/22/09 to 3/3/10 ongoing per diem of $36.03 -- $3.675.06 Atty's Comm % Due Prothy $2.00 Atty Paid $176.50 Other Costs Plaintiff Paid Date: 11/23/09 (Seal) REQUESTING PARTY: Name: LORRAINE DOYLE, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 On November 30 2009 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered, 1021 Teakwood Lane, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November.. 30, 2009 By: ~~ rt ~ Real Estate Coordinator i \~ Ll,~ r ~,{ ; ~~.;: 5.' d~~ -~~`, ~~l ~ ' C~~~ ;~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22 Januarv 29 and Febru 5 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this 5 day of February, 2010 - Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 Writ Ifo. 2009-7036 Civil The Bank of New York Mellon Trust Company ,National Association fka The Bank of New York Trust Company, N.A. As Successor to JPMORGAN Chase Bank, N.A., SBM Bank One National Association, as Trustee for RAMP 2004KR1 vs. Donna M. Comp Marlin L. Comp Attty: Lorraine Doyle ALL THAT CERTAIN tract or lot of land situate in East Pennsboro Town- ship, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Teakwood Lane, at the line of adjoiner between Lot Nos. 75 and 74 on the hereafter mentioned plan of lots; Thence along said line of adjoiner North 12 degrees 54 minutes West, 105 feet to a point at Lot No.63; Thence along Lot Nos.63 and 64, North 77 degrees 06 minutes East, 85 feet to a point on the line of adjoiner between Lot Nos. 74 and 73; Thence along said line of adjoiner South 12 degrees 54 minutes East, 105 feet to a point on the northern line of Teakwood Lane; Thence along the northern line of Teakwood Lane South 77 degrees 06 minutes West, 85 feet to the point and place of BE- GINNING. BEING KNOWN AS Lot No. 74 and Final Plan No.l of Treemont, as recorded in Plan Book 34, Page 131, in the Cumberland County Record- ers Office. BEING KNOWN AS: 1021 Teak- wood Lane, Enola, PA 17025. PROPERTY ID NO.: 09-13-0998- 026. TITLE TO SAID PREMISES IS VESTED IN Donna M. Comp and Marlin L. Comp, her husband by deed from Donna E. Myers dated 10/ 31/00 recorded 11/2/00 in Deed Book 233 Page 145. PROPERTY ADDRESS: 1021 Teakwood Lane, Enola, PA 17025. The Patriot-News Co. 81.2 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE ~e~latriot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /22/10 01 /29/10 ~/ 02/05/10 Sworn to and sGbscribed before me this 24 ay of February, 2010 A.D. Public COMMONWEALTH OF PENNSYLVANIA Notariai Seal Sherrie i.. Kisner, Notary Public City Of Harrisixirg, Dauphin County My Commission E~ires Nov. 26, 2011 Member, Pennsylvania Association of Notaries ,D~Iwt ' MN~oh 'f#~nt C,~p~s~ , !~lWollsl ~Rq~p~gon ~KAT,~a ink o~'NYw~Yhlk ~1ru~t Cpmpeny, N.A. As Sucoe~sorto '. .IPAN Chas B~-k, N.A., SSM:BaMc Onr ftAMp ~OG4KR va, Donrar M. Comp ; ; Mar11n L~ Cgptp Atgy: L.o~lns.~oyle AL1 •'i~T C~1'AIN .TRACT O~ I;OT' OF LAN1? 3TfUATE, IN BRST PEIQNSBORO TOWNSFIIIIP, `CUINBERLANI) (.Y1t3NTY, PENN3XI.AANIA, MARE PAlt3TCiItA1~ Y BOiJ~~ ~;AN1Y DBSC1iIB$i$ -A3 FOLLOWS, TO WfT: BEGINNING AT ~A POIIVT, ON .THE' NOK!'HPRN LINE OF '~RK1Yi0~ ,LAIC, AT 'tHE~.LINB ,OF ALIJOIlVER SETWPF:~I LOT NOS. 75 AND 74 ON 1'fffi ~R;IY4~'IQl~Ib-PLAN OF LOTS; TfBIVCE ALONG SAID LEVE OF PiDlO~R .~NOR~i ]2 ~ 12H~EE$' 54 I~E1fF~ : 145 FE!£1' 7'0 A POIIVT AT LOT N0:63; THENCE ALONG LOT NOS.63 AN[3 64, NORTH 77 DBGl2EES 06 MUVIJTES' EA~7; 85. 10 A Iap1~1T ON THE LINE OF;A~iGI~ BIi'IW'Fl?~i LOtf NOS. 74 AND 73„~ THENCE"ALONG SAID L1N6 afr ADI$R SOlPTH i2 I~ 34 MiE3 EAST, 105 PEgI"I'0A POIIdTAN- THE NORTHERN LINE OF TEAICIVQOA LAt$EE; THINCE At:ONG THE NORTH~tN LIIrTf? OF TEAIS~i'OOD LANE $Oi}~'fi :' giE3 05 MQ~MFSWESt; 85 k~l'~7~0,, TH8 f'OIN'f AND PL/~CB 01{ R. B~i bNON1NAS Lf7f Di0 74 AMID; P ; N0.1 AP '~I7iBP3~013'1; AS RE~DRD~iD IN<PLAN BOOR 34, PAGE 131, IN ., ,. 'PFffi CUM~Bit1:MND GOUIyTY R~(1Rts OFFICE. BB~1Q KNUWN A:S; ld2i'3~twbod lase, Enola, PA 17025 , PEIIPBR'I7,ID"1~.: x'13 TO SAID;PREM{EFS IS ~'F'IlV DDI~FNh M. , ANf1 MAli~i.W L. COMP, HER Hf988AtHfi BY DEiill' AROA4 DONNA.;E, MYERS RATED 2431100.. 12C1IA0 iN AEkD .HOUJ~ 233 !'~ A iaQl Est }7~,!! ' _ ,