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Home My WebLink About10-1472UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.cvm ATTORNEY FOR PLAINTIFF Beneficial Consumer Discount :COURT OF COMMON PLEAS Company d/b/a Beneficial =CIVIL DIVISION Mortgage Co of Pennsylvania 961 Weigel Drive =Cumberland County Elmhurst, IL 60126 Plaintiff V. Troy John Chambers a/k/a Troy J. Chambers NO. Aimee L. Chambers 603 Pine Road Carlisle, PA 17015 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 0 s aD 3 3 N t+,f 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 S, PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL ex /4'&. .21P SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 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 PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 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 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: 603 Pine Road MUNICIPALITY/TOWNSHIP/BOROUGH: Dickinson Township COUNTY: Cumberland DATE EXECUTED: 06/23/08 DATE RECORDED: 06/25/08 INSTR NO.: 200821487 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 12/30/09: Principal of debt due $155,089.38 Unpaid Interest at 10.88 from 07/27/09 to 12/30/09 (the per diem interest accruing on this debt is $46.23 and that sum should be added each day after 12/30/09) 7,258.11 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthly late charge of $76.78 should be added in accordance with the terms of the note each month after 12/30/09) 307.12 Attorneys Fees (anticipated and actual to 5% of principal) 7,754.47 TOTAL $171,014.08 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. 11 . WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $171,014.08 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN TAW OFFICES-,--. . C . BY : .?-- ' Atto or Plaintiff MAR REN, ESQUIRE STUART NNEG, ESQUIRE 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 CI S trust of h? wBb the eta Berson asemA dwsle a Dieidnm towesrbip, Cam County, P4awlyiv Wa, bmmded and denibed a fdk"m: BWEVNING or an im pia in dine Rn4 at caraw of had now or U. G. Baran; ti caft by said road moat ? of the Esbeitc of sevaaty foar and one-fourth 4 i ) g had now or forsk?rly of George Staigiamma, (7 dqpvn 'R'at, a bitty-? (W) foot tD ,? Sciuce irm by iand now or fouw erfY of Ckwks F. Nom, Nior& deven (11) dean W + thaW feet severe (7) imduo to an taros pin; titeaee by lmd ww or brmeriy of Barry times and one-half (13 Ys) dopm Xnx4 oft hundred nhkmv (190) bet tbrx (3) kw:kw to a stw; trace by Iand of the Baratta bio&odW Cha rd4 Soath n +-a it ti in; tb a (72 %) dtem Evart, 9ms hrotdred twenty-two (122) fed sk (6) mites SD an iroma am"amwo now or pt; tete?by Ind nd no or fornserly of the F?tr of U. G. Baas *M bomb twelve (12) Wogt, two kmadred deven (.211) feet ? f) bmbas to the puce of BBGMMNG. 001*R,2NG one i WWted edgitt (106) pew. TIEING improved wbh at frame dweiffng hoeaae and oatb? BEING the same premises wieieh FUrence X S nerd rrcor+ied De?ber 1g, 1970 ? the p,? by heed looted Dwomber 15, 1M County' Pemtsy hs DMd Book X 23, P*p 216, of veye€ of Cn d Ea* and pri eft $ Eagte, Grantors here ?? a" coavcy? aa+to ?i? ?. f January 6, 2010 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. -I •1 EXHIBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Troy John Chambers aka Troy J. Chambers Aimee L. Chambers 603 Pine Road Carlisle PA 17015_...- 0018151654 . Benefcial_Consumer Discount Company-............ Benefcial_Consumer Discount Company HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE. ELIGIBLE FOR FiNANCiAi. ASSISTANCE, WHICH CAN SAVE. VOTTR HOME. FROM FORECLOSURE, AND HELP YOU MAKE. FUTURE. MORTGAGE. PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE DACTO), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit iN counseling agencies listed at the end of this Notice. THIS WETiNG MUST OCCUR WITH NOTICE CALLED OHOW TO Ci THE YOUR MORTGAGE. DEFAT Ti.TO, F.XPi,AiNS HOW TO BRING YOT TR MORTGAGE I1P 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-,, rldresses nd telephone numbers are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immMistelT of your intentions. APPLICATION FOR MORTGAGE, ASSiSTANCF, - 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.) NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 603 Pine Road Carlisle, PA 17015 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?Pa?ments of $1535,75 forAugust 27_, 20(19 through December 27,.2009=_$7678.75-.__.__ WX Late Ch__4r s of_?76.78 for August 27, 2009 throes December 27,_2009-. ,- $383.90..._..._.._-. Mont Other charges (explain/itemize): ...... _-_....... -.......... -.--.-.-------------_------._-- _TOTAL AMOUNT PAST DUE: ----------- ----................... _.... _.......... .._.... ..------ ------- -..S8062-65 _. B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not ar=licahle): NIA 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 U, 062.65 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PaMents must he made either by each, cashier's check, certifiers check or money order made pay able 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 ap licahle_l: DU IF YOU DO NOT CITRF. THE, DEFAULT -- If you do not cure the default within THIRTY (30) DAYS Page 3 of 3 of the date of this Notice, the l.nd .r intends to .x .r is its rights to accelerate the molUage 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 foreclnse upon your mnrtgaued property, 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 von cure the default within the THIRTY (30) DAY period. yAu will not he, required to pay army'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 SALE. - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the Tight to cure the default and prevent the gale at any time i p to one hour hefore the Sheriffc Sale- Vol] may doso-by payig the total amount then past due, lz Ls any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure gale and any other costs connected with the Sheriffc Sale as specified in writing by the lender and hyV erforming any other rearirementg order 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 FARLIE,ST PnSSIRTE SHERIFF'S SALF, DATE. - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 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 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: _Ma_Ultate_Woodworth_-_--------------- EFFECT OF SHF.R11FFIS SALF. - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSIMUMON 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 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10/1512007 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 Deny Street Harrisburg, PA 17104 717.232.9757 Loveship,Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 ority Mail® Mail. For Proof of a Return coverthe vaiver for receipt is )ssee or with the the artt- ied Mail wiry o ?Z r 13 13 > ?? I `o 3 ? _ E? _ E d 2 vn O v 134,1 y ir = d ?( ao o 4ro o ¢ of ?; m m ?m ? > a 0 0:4 U \\? ,0 C'm E_ .. f E0. d' M _t U C m ??\ O O O _SC? ? c a W : O lqz;zl? Cj a N s co ru ?O ca r- O O a O 0 ¢ O E C3 f nLj U C3 r- & C3 0 r` 0 N 7 1 T I L! g CrD, M CO 0 o o°0 Gt3 ? f o 2 0 _ V [i. Ge• aa??sp? o o -- w r3 M o 03 r ni m K.3 18.1 rj ? 00 LurQcr-O Laa..m Q ?• ? p o?c Z ? ul caO m o` v? ?i y A' 4 f E ° z ?? ?? ? o- U ^ L E d r? g?O t? cc 0 ?? w ?z C > _ m - > -0 m$? N g ?m o ? W C 13 C3 d x ao 0 of v p 0 ru m -d m r= moE ` M to ? ? '2 o Y v > -0 a 7 cc w V)E a? T ? L Y m \ \ ? ? m '?j C'L U Q U V a- -0 -Qj a E i S N LL oo M O a C3 (U S S !? 0 0 oG } 0 J 2 C) C T r ro jal'SPI4 O W = r= o? o- o o- o- o- m ru 0LLA ? ?. k- o cc ? LU W. -o v 1-? -Nt -73 c O L TZ 7113 q- w 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. UDREI#J TAW (OFF P . C . BY: Attd? h intiff MARK';J. REN, ESQUIRE STUAR?T INNEG, ESQUIRE LORRA E 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 ._.,. ~~~t of 4rrtrrGrt'f~r~~F ~~ ,qtr ~i~ { [ 4 Beneficial Consumer Discount Company Case Number vs. Aimee L. Chambers (et al.) 2010-1472 SHERIFF'S RETURN OF SERVICE 03/16/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Aimee L. Chambers, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Aimee L. Chambers. Request for service at 603 Pine Road, Carlisle, PA 17015 is vacant. The Carlisle Postmaster has advised the defendant has moved and left no forwarding address. 03/16/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Troy John Chambers, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Troy John Chambers. Request for service at 603 Pine Road, Carlisle, PA 17015 is vacant. The Carlisle Postmaster has advised the defendant has moved and left no forwarding address. SHERIFF COST: $59.40 March 16, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c Co~.rttySuite Sheriff. T~!E;osoft. O~c. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 Beneficial Consumer Discount : COURT OF COMMON PLEAS G Company d/b/a Beneficial : CIVIL DIVISION ? k Mortgage Co of Pennsylvania : Cumberland County M r- 961 Weigel Drive Elmhurst, IL 60126 Plaintiff :: NO. 10-1472 Civil Terms-- � V. Troy John Chambers a/k/a �� s Troy J. Chambers Aimee L. Chambers 603 Pine Road Carlisle, PA 17015 Defendant (s) PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. Att r e or tiff ARRY B..R E,,ESQUIRE DATED: September 6 , 2013 P&J 310501 09120655-1