HomeMy WebLinkAbout10-1187UDREN 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 i
ADAM L. KAYES, ESQUIRE - ID #86408 W r
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MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620 •== v-?
856-669-5400
pleadings@udren.com
Household Finance Consumer :COURT OF COMMON PLEAS
Discount Company CIVIL DIVISION
961 Weigel Drive
Elmhurst, IL 60126 Cumberland County
Plaintiff
V.
Michael S. Hillegas
Julie Hillegas _ NO. /? - `!g ?!V ?
501 Walton Street
Lemoyne, PA 17043
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20)
days after this Complaint and Notice are served, by entering a written
appearance personally or by attorney and filing in writing with the Court
your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice
for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD
TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
LAWYERS REFERRAL SERVICE 1P
Cumberland County Bar Association
2 Liberty Avenue qq-? .OU I
Carlisle, PA 17013 Y LL
717-249-3166
800-990-9108
IZ-4 a3 7?
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
C,
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
C
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. Plaintiff is the legal holder of the
Mortgage that is the subject of this action.
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: 501 Walton Street
MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Lemoyne
COUNTY: Cumberland
DATE EXECUTED: 3/13/07
DATE RECORDED: 3/16/07 BOOK: 1985 PAGE: 1762
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Mortgage as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
12/31/09:
Principal of debt due $189,735.29
Unpaid Interest at 6.7749.
from 3/19/09 to 12/31/09
(the per diem interest accruing on
this debt is $35.21 and that sum
should be added each day after 12/31/09) 10,140.48
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
NSF Fees 40.00
Corporate Advance (Taxes) 5,530.21
Uncollected Late Charges 362.70
Corporate Advance 37.50
Attorneys Fees (anticipated and actual
to 5% of principal) 9,486.76
TOTAL $215,937.64
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 $215,937.64 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 1 I CCU W ?(A I -lA?1?-
Attorneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
C
ALL THAT CERTAIN lot or parcel of land situate in the Borough of Lemoyne, County of
Cumberland and State of Pennsylvania, more particularly bounded and described as
follows, to wit,
?jJBEGINNING at a point on the northern line of Walton Street, on the dividing line between
;r
Dots Nos. 80 and-81 on the hereinafter mentioned plan of lots, said point being Eight
hundred forty (840) feet treasured eastwardiy from the northeast corner of Seventh and a.:
Walton Streets, on the hereinafter mentioned plan; thence along said dividing line North
thirty-six (36) degrees thirty (30) minutes West One hundred forty (140) feet to a point on
line of lands, now or late of Lemoyne School District; thence along said lands North
fifty-three (53) degrees thirty-one (31) minutes East one hundred seven (107) feet to a
point on the western line of Walton Street; thence along the western line of said Walton k
Street on a line curving to the left One hundred forty-eight and ninety-six hundredths
(148.96) feet to an angle in said Walton Street: thence in a westerly direction along the m
northern line of Walton Street South fritY three (.53) degrees thirty one (31) minutes - p
West Sixty-two and twenty-one hundredths (62.21) feet to the point or place of beginning. :' f„
Being Lot No. 80 on the plan of Chatham Viliage, which plan is recorded in the
Cumberland County Recorder's Office, in Plan Book 4, Page 77.
i Alt.
HAVING thereon erected a one story brick and frame dwelling, known as No. 501 Walton a,.
Street, Lemoyne, PA. ,.
C,
V
January 8, 20 10
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
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER:
Michael S. Hillegas, Jr.
_Julie Hgeg_as--_._......- _._......... _.__..............................
._.
- -------- ............. -----
501 Walton Street
_ Lemo..yne?PA 17043
-----........................................................ --_ ............
_ 0016638355
Household_Finance Consumer Discount Company
HFC or BFCEntity
HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
VOIT MAY RF, F.i IGIRi.F. FOR FINANCIAL ASSISTANCF
WHICH CAN SAVE. VOITR HOME FROM FORECLOSURE AND
HELP VOIT MAKE. FUTURE MORTGAC=F 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 FORF,Ci,OSITRF. -- 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 MUST OCCUR WITHIN
0
CONSITME,R 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 names, addresses and tele= hone numbers
of designated consumer credit counseling agencies for the. county in which the nronerty 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 immediatell of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature
of your default.) If you have tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies have applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
Page 2 of 2
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.)
NATITRE OF THF, DEFAULT - The MORTGAGE debt held by the above lender on your property
located at:
501 Walton Street
Lemoyne, PA 17043
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
Monthly Payments of $1261.35 for April 19, 2009 through September 19, 2009 = $7568.10
_Monthly Payments of $1722.21 for October 19. 2009 through December 19, 2009 = $5166.63..____
Monthly Late Charges of $0 for Anril_19,,_2009, through December 19 2009.. =50.00
Other charges (explain/itemize): Unpaid Late Charge $362.70
Uncollected Fees Receivable=$77.50
TOTAL AMOUNT PAST DUE: 513174.93
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): NJA
NOW TO C'ITRF. THE. DF.FAIJLT - 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 513174.93_ PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. PP yrnents must be made either by .as cashier's check, certified check or money order made payable
and sent to-
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 aznlicable_l: NA
Page 3 of 3
M YOII DO NOT CURE THE DFFATILT __ If you do not cure the default within THIRTY (30) DAYS
of the date of this Notice, the lender intends to .x x is its rightly to a l ra h mo gagedeht- 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 propert .
IF THF, MORTGAGF. 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 he
required to p" 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 CURE THE. DEFAULT PRIOR TO SHERIFF'S SALF, - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to
payLg the total amount then past due, plus any late or other charges hen due, reasonable attorney's fees and
costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified
in writing by the lender and by nag any other re ruirements under the mortgag . 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 DATF. - It is estimated that the earliest date that such a
Sheriff s Sale of the mortgaged property could be held would be approximately h months from
the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale.
Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment or action will be by contacting the lender.
Name of Lender/Servicer: _HSBC_Consumer Lending_._._._.__...._._._._......._.
Address: 961 Weigel Drive
Elmhurst IL 60126 -----...--_._.............................................. -._...----..............
----
Phone Number: 1-800-333-5848
Fax Number: 1-630-617-6891
Contact Person: MaU-kate Woodworth
F,FFF.CT OF SHERIFF'S SALF. - 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 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 the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
Page 5 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
AEMAP 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
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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 make 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.
Atl?brneys for Plaintiff
MARK J. UDREN, ESQUIRE
STUART WINNEG, ESQUIRE
LORRAINE DOYLE, ESQUIRE
ALAN M. MINATO, ESQUIRE
CHANDRA M. ARKEMA, ESQUIRE
LOUIS A. SIMONI, ESQUIRE
ADAM L. KAYES, ESQUIRE
MARGUERITE L. THOMAS, ESQUIRE
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
Household Finance Consumer Discount Co.
vs.
Michael S. Hillegas (et al.)
~~,,;;p pi 4wuubrrl~'~D
Case Number
2010-1187
SHERIFF'S RETURN OF SERVICE
02/25/2010 05:27 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February
25, 2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Julie Hillegas, by making known unto herself personally, at 540
Brentwater Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time
handing to her personally the said true and correct copy of the same.
02/25/2010 05:27 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February
25, 2010 at 1727 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Michael S. Hillegas, by making known unto Julie Hillegas, wife of
defendant at 540 Brentwater Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and
at the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $87.20 SO ANS
~~~""'_
February 26, 2010 RO R ANDERSON, SHERIFF
BY` ~
Deputy Sheriff
~o) CountySuite :"eviF~. Te~eon±t. Inc.
~~F THE h~AAY
2010 MAR -3 AM 9:43
VVIYt~~~~ vL„+
~~
David D. Buell 14A e p Renee X Simpson
Prothonotary 1St Deputy Prothonotary
v 1,4`
,� J/lorrow
�irkS. Sohonage, ESQ
Irene E.
Solicitor 1750 2nd Deputy Prothonotary
Office of the Prothonotary
Cum6erCancdCounty, Pennsylvania
/Q — fie 7 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
PA R.C.P.230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
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