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Home My WebLink About09-8848/10-1 RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Bank USA, N.A., as Trustee for the registered holders of Renaissance Home Equity Loan Trust 2006-1, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Laco L. Carr, Sr. 201 Summit Branch Road Millersburg, PA 17061 Defendant(s) Civil Action Number: D ? my k- I COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION - MORTGAGE FORECLOSURE NOTICE This is an attempt to collect a debt and any information obtained will be used for that purpose. You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. J:\Supriya\Complaints\Cumberland\Ocwen.Carr. 12.09.doe IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Supriya\Complaints\Cumberiand\Ocwen.Carr.12.09.doc NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ., YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN ADMISSION OF LIABILITY BY YOU. IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION OF THIS DEBT. THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. J:\Supriya\Complaints\Cumberland\Ocwen.Carr. 12.09.doc RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIN41LE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Bank USA, N.A., as Trustee for the registered holders of Renaissance Home Equity Loan Trust 2006-1, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Laco L. Carr, Sr. 201 Summit Branch Road Millersburg, PA 17061 Defendant(s) Civil Action Number: COMPLAINT IN MORTGAGE FORECLOSURE COMPLAINT CIVIL ACTION - MORTGAGE FORECLOSURE 1. Plaintiff is HSBC Bank USA, N.A., as Trustee for the registered holders of Renaissance Home Equity Loan Trust 2006-1, by its attorney in fact, Ocwen Loan Servicing, LLC (hereinafter referred to as "HSBC Bank USA, N.A.") with offices located at 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409. 2. Defendant is Laco L. Carr, Sr., adult individuals with a last-known address of 201 Summit Branch Road, Millersburg, PA 17061. 3. Under date of 01 /05/2006, defendant executed and delivered to MERS, Inc., as nominee for Delta Funding Corp. a mortgage upon the property 201 Summit Branch Road, Millersburg, PA (the "Property") to secure the payment of the sum of $126,000.00. The said mortgage is recorded in the Office for the Recording of Deeds in and for Cumberland County on 01/18/2006 at Book 6367 at Page 171 and is incorporated herein by reference J:\Supriya\Complaints\Cumberland\Ocwen.Carr.12.09. doc as though set forth at length herein. A copy of the legal description of the Property is attached hereto and made a part hereof as Exhibit "A". 4. The said mortgage was assigned to HSBC Bank USA, N.A., the within Plaintiff, by Assignment which has been duly recorded or is in the process of being recorded. 5. Ocwen Loan Servicing LLC, successor to Ocwen Federal Bank FSB is the attorney in fact authorized to act for Plaintiff. 6. Said Defendant is the real owner of Property 201 Summit Branch Road, Millersburg, PA 17061. 7. In accordance with Act 91 of 1983, as amended, a combined notice providing the information required by §403 of Act No. 6 of 1974, and Act 91, aforesaid, was sent to the defendant and no response was made in the appropriate period of time. A true and correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B". 8. The said loan is in default as a result of the failure to pay the monthly installments of $1,301.59 due on September 1, 2009 and on the same day of each month thereafter. 9. The following is due on the loan: PRINCIPAL BALANCE ....................................................... $122,319.59 INTEREST accrued thru 12/22/2009 of ............................... $4,198.75 Interest after 12/22/2009 shall accrue at the per diem rate of $29.94.) LATE CHARGES accrued thru 12/22/2009 of ..................... $399.76 Late charges after 12/22/2009 shall accrue at the monthly rate of $49.97.) ESCROW ADVANCES ........................................................ $1,391.18 FEES BILLED ....................................................................... $520.78 COSTS ................................................................................... 300.00 ATTORNEY'S FEE .............................................................. $6,100.00 TOTAL .................................................................................. $135,230.06 The attorney fees 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 Sheriffs Sale. If the mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually performed. WHEREFORE, Plaintiff, HSBC Bank USA, N.A. requests this Court to enter judgment for foreclosure of the mortgaged property for the sum of $122,319.59 plus interest thereon of $4,198.75 plus $29.94 per day from 12/22/2009 until judgment is paid in full, late charges of $399.76, plus late charges of $49.97 per month from 12/22/2009 until judgment is paid in full, escrow advances of $1,391.18, fees billed of $520.78, costs of $300.00, attorney's fees of $6,100.00 and all other J:\Supriya\Complaints\Cumberland\Ocwen.Carr. 12.09.doc amounts set forth above, less any suspense as set forth above, together with record costs and any other amounts to which Plaintiff is entitled to recover. BY: Date: December 22, 2009 STERN AND EISENBERG LLP IR)CHARD F. STERN, ESQUIRE TEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE Attorney for Plaintiff J:\Supriya\Complaints\Cumberiand\Ocwen.Carr.12.09.doc VERIFICATION JOHNNA MILLER is Authorized signer of OCWEN LOAN SERVICING LLC and is authorized to sign this Verification on behalf of same, and states that she verifies the foregoing Civil Action-Mortgage Foreclosure against the within defendant and avers the statements of fact therein contained are made subject to the penalties of 18 PA C.S. Section 4904 relating to the unsworn falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief. JOHNNA MILLER Date: DEC 16 2009 Authorized signer LOAN #5510300861144 Carr &"*" T* IZUSM* CM001 Ganrn Number, t005ttt m SCHEPt" C PftOMTY DE8Ct+t MON The ime mbmw to in ibis caiumipllent is dtetallted AIR fpAm&, ALL tbet eeE lh of nlgwnrax, moots in iNii rt Ts>rri+snfR. Dwpain Cm*, f?emn?MVA ,, ? more o ff* e . 0lri ed - Lot - . -' a "w' "m Plea p?amd by K J t7sEiiel doled 0*bw 22, ltI82, bears g d ae f 1** is attitdted hereto and hMendett to be roWMW hWVA*, bowmbd and 960"Ma at tlb"s bond, rMrch is Ve SauMwsetaoWmr of r of fra 2 OA ?e ttbotre nltalionied idun gten thnladlt lends now arlprtnery of fMhRtee"*ft 8 MMUS tAhtet• Faint NM d w t"atirkddQ"` feet (! e" drw. 4iit 7 b ad?,rR shandy Mi?,+?e Rip?r? aaer nwt or and ttpep er ko*odit imt 04 2r ? ?t-00-Ml *nft food at ft itip owmw oti lw of Mfbh w ortarmogyiY"jw, 01 a as garmding aft $w jm trade mftlh algh*om ft j a aftos a* an hundred kw* and ""ft "?td twendmp * ket IN, 81• 3W E M.31) to an imn oh eet at tip iftmi sit Mmoral Lot ft 2 of the abnrtt mentioned StleVay AiW theme cos &*, WV smne 800 etgbleea deoem "4t miettttpt Eeet om ftawd nine tkmdred nineteen attd "W herklredthe het fS 18' W W. 1,11 i1f.84'j lit scones %w1d, !Mr pabd aed plaoe of DE6iMNN0a W EffWG AM REMIONG elf of the eght 9e and k&mt t eay Bobo rW Neva in and to the fdemar bed 0 f ft SW"M t &aneh t?sttroed, rrhl h Is cummlfy idupt4M AB Tet wrgokwg A' j* #88438 3. +E {?;AINING a tow sw 21.307 as mL L PmOW41"W3 End Of Report Ocwen Loan Servicing, LLC P.O. Box 24737 'O West Palm Beach, Florida 33416-4737 o c w E N (Do not send correspondence or payments to the above address.) WWW.OCVVEN.COM October 31, 2009 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515129387642 Reference Code: 0909 Laco L. Carr SR. 201 Summit Branch Road Millersburg, PA 17061-0000 Loan Number: 103008611 Property Address: 201 Summit Branch Road, Millersburg, PA 17061-0000 PLEASE SEE THE ENCLOSED DOCUMENT DACT91.15 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 Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4737 C C W E N (Do not send correspondence or payments to the above address.) WWW.OC)N'EN.COM October 31, 2009 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose S ific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMM may be able to help to save your home This Notice explains how the pram works. To see if HEMAP can hel). you must MEET WITH A CONSUMER EDIT COUNSELING AGENCY WITHIN THIRTY (39) DAYS OF THE DATE OF THIS NOTICE, Take this Notice with you when you meet with the Counseling Agency, The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions oly_; may call the Pennsylvania Housing Finance Agency toll free at (800) 342-2397 (Persons with impaired hearing can call (712) 780-18691 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 aftorney in your area The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNI'O ES DE SUMA E%IPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAM ENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUIVIERO 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 REDEVIIR SU HIPOTECA. HOMEOWNER'S NAME(S): Laco L. Carr SR. PROPERTY ADDRESS: 201 Summit Branch Road Millersburg, PA 17061-0000 LOAN ACCT. NO.: 103008611 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CURRENT LENDER/SERVICER: OCWEN DACT91.15 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 Ocwen Loan Servicing, LLC •O. P.O. Box 24737 West Palm Beach, Florida 33416-4737 OCWEN (Do not send correspondence or payments to the above address.) WWW.OCWEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH AN AVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS 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. OCCUR WITHIN THE NEXT (39) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE Up TO DATE. CONSUMER EDIT 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. Jhg names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the prQptrtv 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 MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). DACT91.15 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 Ocwen Loan Servicing, LLC P.O. Box 24737 =O' West Palm Beach, Florida 33416-4737 O C W E N (Do not send correspondence or payments to the above address) WWW.OCWEN.COM HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to daW NATURE OF THE. DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 201 Summit Branch Road, Millersburg, PA 17061-0000 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 $ 1,301.59 from September 01. through October 31. T Principal and Interest ................................. $ 1,998.70 Interest Arrearage ..................................... $ 0.00 Escrow .................................................. $ 604.48 Late Charges ........................................... $ 349.79 Insufficient Funds Charges ........................... $ 0.00 Fees / Expenses ........................................ $ 209.70 Suspense Balance (CREDIT) ........................ $ 0.00 Interest Reserve Balance (CREDIT) ................ $ 0.00 TOTAL DUE .......................................... $ 3,162.67 HOW TO THE 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 $3,162.67, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bey Gram Cashier's Check Certified heck or Mon@y Order made payable and cant to OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-0440 IF YOU DO NOT THE THE 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 mortgage 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 mortgaged roperth: 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 (30) DAY period. you will not be inquired 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 SAE - 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 before the Sheriffs Sale You may do so by aving the total amount then past due.. plus any late or other char:'es then due reasonable attorney's fees and costs connected with the foreclosure ale and any other costs connected with the Sheriffs Sale a specified in writing by the lender and by performing any other_ mquirements under the mo_da 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 Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. DACT91.15 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 Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4737 o c w E N (Do not send correspondence or payments to the above address) WWW.OCWEN.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: Early Intervention 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 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 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 COTTNTY DACT91.15 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 ACT 91 AGENCY LISTING PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES ACORN HOUSING CORPORATION COMM. ON ECONOMIC OPPORTUNITY FOR LUZEIZNE COUNTY 846 North Broad Street 163 Amber Lane Philadelphia, Pa., 19130 Wilkes-Barre, Pa., 18702 (215) 765-1221 (570) 826-0510 or 1-800-822-0359 Counties: Bucks, Chester, Delaware, Montgomery and Philadelphia Counties: Carbon, Luzeme, Schuylkill and Wyoming Action Housing, Inc 4256 1b Avenue, Suitt 950 Pittsburgh, Pa, 15219 (412) 391-1956, (412) 281-2102 or (800) 792-2801 Counties: Allegheny, Beaver, Butler, Fayette, Greene Washington and Westmoreland COMMUNTIY ACTION SOUTHWEST 22 West Sigh Street Adams County Interfaith Housing Authority Waynesburg, Pa., 15370 (412) 852-2893 AMERICAN RED CROSS - HANOVER CHAPTER FAX: (412) 627-7713 529 Carlisle Street Contact Doug Wagner Hanover, Pa-, 17331 Counties: Allegheny, Fayette, Greene, Washington (717) 637-3294 and Westmoreland FAX: (717) 637-3294 Contact: Stephanie Calp CONSUMER CREDrr COUNSELING SERVICE Counties: Adams, Franklin and York OF DELAWARE VALLEY 1515 Market Street, Suite 1325 BLAIR COUNTY ECONOMIC OPPORTUNITY COUNCIL Philadelphia, Pa., 19102 5433 Industrial Avenue (215) 563-5665 Altoona, Pennsylvania, 16601 FAX: (215) 864-2666 (814) 946-3651 Contact Tom O'Neill FAX: (814) 946-5451 Counties: Bucks, Chester, Delaware, Montgomery Contact: Paul Rennie and Philadelphia Counties: Blair only CONSUMER CREDIT COUNSELING SERVICE BOOKER T. WASHINGTON CENTER OF LEHIGH VALLEY 1720 Holland Street 3671 Crescent Court East Erie, Pennsylvania, 16503 Whitehall, Pa., 19107 (814) 453-5744 (215) 821-4011 or FAX (814) 453-5749 1-800-220-2733 (717 & 814 Area codes only) Contact Bob Huhta FAX: (215) 821-0137 Counties: Crawford, Earl and Warren Contact Al Kotcb Counties: Berks, Bucks, Carbon, Lancaster, BUCKS COUNTY HOUSING GROUP, INC. Lehigh and Northhampton 140 East Richardson Avenue Langhorne, Pa., 19047 CONSUMER CREDrr COUNSELING SERVICE (215) 750-4310 OF WESTERN PENNSYLVANIA, INC. FAX: (215) 750-4318 A) 309 Smithfield Street, Suite 2000 Contact: Pat Dyson Pittsburgh, Pa., 15222 Counties: Bucks only (412) 471-7584 Contact: Jack Onorad BUDGET COUNSELING CENTER B)1 North Gate Square 247 North Fifth Street #2 Garden Center Drive Reading, Pa., 19601 Greensburg, Pa., 15601 (215) 375-7866 (412) 838-1290 FAX: (215) 376-6575 - Main Office C) 500-02 3rd Avenue, P.O. Box 278 Contact: Deborah Strunk Duncansville, Pa., 16635 Counties: Berks, Chester, Montgomery and Schuylkill (814) 696-3546 D) 1 st Federal Plaza, Suite 406 CENTRO PEDRO CLAVER North Mill Street 3565 North 7th Street New Castle, Pa., 16101 Philadelphia, Pa., 19130 (412) 652-8074 (215) 227-7111 E) 524 Franklin Avenue FAX: (215) 227-7117 Franklin Center Contact: Roberto Santiago Aliquippa, Pa., 15001 Counties: Philadelphia, Bucks, Chester, Delaware and Montgomery (412) 652-8074 txf ACT 91 AGENCY LISTIN G CONTINUED CONSUMER CREDIT COUNSELING OF WESTERN PENNSYLVANIA, INC. (CONT.) F) 2000 Lingiestown Road Harrisburg, Pa., 17102 (717) 541-1757 Counties: Adams, Cumberland, Dauphin, Perry and York G) YMCA Building 339 North Washington Street Butler, Pa., 16001 Counties: Allegheny, Armstrong Beaver, Bedford, Blair, Butler, Cambria, Cameron, Centre, Clarion, Clearfield, Fayette, Frankin, Fulton, Greene, Huntingdon, Indiana, 3efferson, Juniata, Lawrence, Mercer, Miffiin, Snyder, Somerset, Union, Venango, Washington and Westmoreland. H) 912 South George Street York, Pa-, 17403 (717) 846-4176 Counties: York, Adams, Franklin and Lancaster CONSUMER CREDIT COUNSELING SERVICE OF NORTHEASTERN PENNSYLVANIA A) Human Services Building 541 Wyoming Avenue, Box 168 Scranton, Pa-,18501 (717) 342-1072 or(800)922-9537 FAX: (717) 342-8040 B) 31 West Market Street Wilkes-Barre, Pa., 18702 (717) 821-0837 or(800)922-9537 FAX (717) 821-1785 Contact Mike Elick Counties: Bradford, Carbon, Columbia, Lackawanna, Luzern, Lycoming Monroe, Montour, Northumberland, Pike, Sullivan, Susquehanna, Tioga, Wayne and Wyoming ECONOMIC OPPORTUNITY CABINET OF SCHUYLKILL COUNTY 118 Norwegian Street Pottsville, Pa., 17901 (717) 622-1995 FAX: (717) 622-0429 Contact: Marybeth Dohman Counties: Beft, Carbon, Lebanon, Lehigh, Luzeme, Northumberland and Schuylkill FAYE= COUNTY COMMUNITY ACTION AGENCY, INC. 137 North Beeson Avenue Uniontown, Pa., 15401 (412) 437.6050 ext. 38 or (800) 427-INFO FAX: (412) 437-4418 Contact: Jennifer Canada FINANCIAL SERVICES UNLIMITED 117 West 3rd Street Waynesboro, Pa., 17268 (717) 762-3285 Contact: Natalie Newcomer Counties: Adams, Cumberland, Franklin, Fulton and Perry GREATER ERIE COMMUNITY ACTION COMMITTEE 18 West 9th Street Erie, Pa., 16501 (814) 4594581 FAX: (814) 456-0161 Contact: Robert Lamary Counties: Crawford, Erie, Venango and Warren INDIANA COUNTY COMMUNITY ACTION PROGRAM 827 Water Street, Box 187 Indiana, Pa-, 15701 (412) 465-2657 FAX (412) 465-5118 Contact Randy Foster Counties: Armstrong Cambria, Clearfield, Indiana, Jefferson and Westmoreland HOME MORTGAGE PROTECTION GROUP A) 19 West 3rd Street Chester, Pa, 19013 (215) 247-4712 B) 8634 Provident Street Philadelphia, Pa-, 19150 (215) 447-9568 FAX (215) 872-4856 Contact AA Muhammed Counties: Becks, Chester, Delaware, Lancaster, Montgomery and Philadelphia HOUSING COUNCIL OF YORK 116 North George Street York, Pa., 17401 (717) 854-1541 FAX (717) 854-7934 Contact Diana Walker County. York only HOUSING ASSOCIATION OF DELAWARE VALLEY A) 1314 Chestnut Street, Suite 900 Philadelphia, Pa., 19107 (215) 545-6010 FAX: (215) 790-9132 B) 658 North Watts Street Philadelphia, Pa-, 19123 (215) 978-0224 FAX: (215) 765-7614 Contact Khalil Walker County- Philadelphia only HOUSING OPPORTUNITIES, INC. 133 Seventh Street, P.O. Box 9 MckeespoM Pa., 15134 (412) 6641590 FAX: (412) 664-0873 Contact Allen Sethman Counties: Allegheny, Beaver, Butler, Washington and Westmoreland JOHN F. KENNEDY CENTER, INC. 2021 East 20th Street Erie, Pa., 16510 (814) 898-0400 FAX: (814) 998-1243 Contact: Mary Gavin Counties: Crawford, Elk, Erie, Jefferson, Mckean and Venango KEYSTONE ECONOMIC DEVELOPMENT CORP. 1954 Mary Grace Lane Johnstown, Pa., 15901 (814) 539-1688 FAX: (814) 539-1688 Contact: David Kennedy Counties: Bedford, Blair, Cambria, Clearfield, Indiana, Somerset and Westmoreland tX,f ACT 91 AGENCY LISTING CONTINUED LA CASA DEL PUEBLO 815 W. Baltimore Turnpike Kennet Square, Pa., 19348 (215) 4443731 FAX (215) 444-3178 Contact Dawn Vega Counties: Chester, Delaware, Montgomery, Lancaster and Berks LYCOMING-CLINTON COUNTIES COMMISSION FOR COMMUNITY ACTION 2138 Lincoln Strect, PO Box 1328 Williamsport, Pa, 17703 (717) 326-0587 FAX: (717) 322-2197 Contact Dan Merk Counties: Clinton and Lycoming MEDIA FELLOWSHIP HOUSE 302 South Jackson Street Media, Pa, 19063 (215) 565-0846 Contact: Joyce Kane Counties: Chester, Delaware, Montgomery and Philadelphia MONTGOMERY COUNTY OPPORTUNITY BOARD 530 Church Street, 2nd Floor Norristown, Pa, 19401 (215) 277-6363 FAX: (215) 277-2123 Contact: Charles Mason County: Montgomery only MON-VALLEY UNEMPLOYED COM1vIITIEE 116 Fifth Avenue MckeespoM Pa., 15132 (412) 678-1409 Contact: Ray Ganczk Counties: Allegheny, Beaver, Butler, Fayette, Green Washington and Westmoreland NORTHERN TIER COMMUNITY ACT10N CORP. 135 West 4th Street Emporium, Pa, 15834 (814) 486-1161 FAX: (814) 486-3370 Contact: Fred Fish Counties: Cameron, Elk, Mckean and Potter PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 100 North 17th Street, Suite 600 Philadelphia, Pa., 19103 (215) 567-7803 FAX: (215) 963-9941 Contact: Henry Cruz Counties: Chester, Delaware, Montgomery and Philadelphia SHENANGO VALLEY URBAN LEAGUE, INC. Housing Counseling Services 39 Chestnut Street Sharon, Pa., 16146 (412) 981-5310 Contact: James Long Counties: Crawford, Lawrence and Mercer TABLELAND SERVICES, INC. 131 North Center Avenue Somerset, Pa-, 15501 (814)445-9628 FAX (814) 443-3690 Contact Mary Ann Strong Counties: Bedford, Cambria, Fayette, Somerset and Westmoreland TABOR COMMUNITY SERVICES, INC. 439 East King Street Lancaster, Pa., 17602 (717) 397-5182 or (800) 788-5062 (Homeowners only) FAX (717) 399-4127 Contact Nevin Horst Counties: Chester, Lebanon and Lancaster THE TREHAB CENTER OF NORTHEASTERN PENN. A) 7 Lake Avenue, Box 366 Montrose, Pa, 18801 (800)982-4045 FAX: (717) 278-1889 B) 185 Elmira Street, P.O. Box 218 Troy, Pa-, 16947 (717)297-2101 Contact: Carole Munn Counties: Bradford, Sullivan, Susquehanna, Tioga, Wayne and Wyoming URBAN LEAGUE OF METROPOLITAN HARRISBURG 25 North Front Street Harrisburg, Pa, 17101 (717) 2345925 FAX (717) 232-4985 Contact Kelly Sloane URBAN LEAGUE OF PHILADELPFIIA Urban Education Foundation 4601 Market Street, 2nd Floor/South Wing Philadelphia, Pa., 19139 (215) 476-4040 FAX: (215) 476-4667 Contact: Herb Brunson County: Philadelphia only URBAN LEAGUE OF PITTSBURGH, INC. One Smithfield Street Pittsburgh, Pa., 15222-2222 (412) 261-1130 FAX: (412) 261-5207 Contact: Lee Fuqua County: Allegheny only WARREN-FORREST COUNTIES ECONOMIC OPPORTUNITY COUNCIL 1209 Pennsylvania Avenue West, P.O. Box 547 Warren, Pa, 16365 (814) 726-2400 FAX: (814) 723-0510 Contact: Doris Swan Counties: Forrest and Warren YWCA OF CARLISLE 301 G Street Carlisle, Pa, 17013 (717) 243-3818 FAX: (717) 243-3948 Contact: Pamela Line Counties: Cumberland, Frank)in and Perry txf n-51 nrit d t€! ?8 66R to,#y ckl)7336 e?o23sy8'G SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor HSBC Bank USA, N.A. vs. Laco L. Carr, Sr. SHERIFF'S RETURN OF SERVICE Case Number 2009-8848 12/29/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Laco L. Carr Sr., but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 01/08/2010 11:49 AM - Dauphin County Return: And now January 8, 2010 at 1149 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Laco L. Carr Sr. by making known unto Amber Wolford, Adult in charge at 201 Mohr Road, Millersburg, PA 17061 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 12, 2010 rARY 2Q1Q JAN 14 tjN 8.45 r? ? aL r-,vl,t SO ANSWERS R. /HOMAS KLINE, SHERIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW KEVIN P. DISKIN, ESQUIRE STERN AND EISENBERG The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #86727 HSBC Bank USA, N.A., as Trustee for the registered holders of Renaissance Home Equity Loan Trust 2006-1, by its attorney in fact, Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Laco L. Carr, Sr. 201 Summit Branch Road Millersburg, PA 17061 Defendant(s) 0 C. Z?Ih ?f- Z? N _a 4 t.. c1.? co Civil Action Number: 09-8848-CIVIL COMPLAINT IN MORTGAGE FORECLOSURE ORDER TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE To the Prothonotary: Kindly mark the above captioned matter as settled, discontinued and ended, without prejudice, upon payment of your costs only. STERN AND EISENBERG BY: "IN ]?. I51-SKIN /Attorney for Plaintiff 1/12/2010 1T 77 ?7rn -V a rn