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Home My WebLink About10-1476UDREN 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 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, National :COURT OF COMMON PLEAS Association, as Trustee for 'CIVIL DIVISION ACE Securities Corp. Home Equity Loan Trust, Series :Cumberland County 2006-NC1 4708 Mercantile Drive Ft. Worth, TX 76137 Plaintiff V. Terry L. Bryan 797 Old Silver Springs Road = NO. Mechanicsburg, PA 17055 Defendant(s) c o ? i j ? co I COMPLAINT IN MORTGAGE FORECLOSURE c 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 TARE 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 LJ4C .q,9:2.601 Cif N4.384, - .2 2 8.2W Q?l PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 C" 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 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 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 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. Current assignments of mortgage of record are as follows. Assignor: New Century Mortgage Corporation Assignments of Record to: Deutsche Bank Trust Company Americas, as Trustee and Custodian for HSBC Bank USA, NA ACE 2006-NC1 Recording Date: 4/9/07 Book: 735 Page: 3933 Plaintiff is in the process of formalizing the assignment of mortgage in its favor 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: 797 Old Silver Springs Road MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 8/26/05 DATE RECORDED: 9/16/05 BOOK: 1923 PAGE- 1FRA 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 C 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 2/19/10: Principal of debt due $67,125.36 Unpaid Interest at 6.99% from 5/1/09 to 2/19/10 (the per diem interest accruing on this debt is $12.86 and that sum should be added each day after 2/19/10) 3,750.48 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/ (Balance) (The monthly escrow on this account is $244.34 and that sum should be added on the first of each month after 2/19/10) 5,400.59 Late Charges (monthly late charge of $23.26 should be added in accordance with the terms of the note each month after 2/19/10) 209.34 Fees 163.50 Attorneys Fees (anticipated and actual to 5$ of principal) 3,356.27 TOTAL $80,610.54 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 C 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 $80,610.54 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ICES, P. C. Y' A e s Or Plaintiff MARK J. UDREN, ESQUIRE STU T INNEG, ESQUIRE LOR N DOYLE, ESQUIRE ALAN . MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ALL THAT CERTAIN taut in the property known, named and idendf ed in the Declaration ofd. a,.,.w! w Z JJ kW a.r " 91alaw Jtillaee C?nafanrindue+"ideated in tlta Bnrtargk ofMechanirrhurg Cmaay of Cumberland, Cammonweahk of.l'mwylvania. which has Itaw4fore been submttred pursuanr to the. provisions of the Unlformr Condominium Act. 68 PA C.S.A. §3101 et seq. (pupdom Supp. 1017), b1'the recording in 17:e acv of the .Rorarder of T}Prd s of ('a inhI71and Courriy, Panigylvania, of Declaration of Condominium dated July 30, 1915 and recorded llue csr 14, 1985 in Miscellaneous Book 305, Page 147, which Declaration has been amended by a First Amendment to Declaration of Condominium dated Lkeember 31. 19R S, and rrtmrded on December 31, 1955, in the aforesaid Ofxc at Miscellaneotem Book 313. Page 133, and finTher, atrtended by a Second Amendment to Declaratlat of Condominium dazed March 13 1987 and recorded March 17, 1987, in aforesaid O fleae arMiscellwaxws Book 331,' Page 933, and further amended by a Third Ar*%dinent to Declaration of Condwninuan dated June 12, 1987, and recorded on June 12, 1987 in the of aresaid Office at Miscallanooua Book 333, Page 283. and funk er amended by a Fourth Amendment to Declaration of Condominium dared November 10, 1987 and recorded on November 30, 1987 in the gforesaid Office at Miscelianeous Book 343, Pbge 368, and further amended by a Prh Amendment to Derlaration of Condominium dared April 14, 1988 and recorded Aprd11.8, 1988 in the afaresaid Offim at Miscellaneous Book 348, page 868, being designated in such Declaration as so amended as Unit No. 797, And further amended by a Sdsth Amendment dated October 1?, 1988 and recorded October 13, 1988 in the aforesaid Office at Miscellaneous flood; 35S, Page 1084; and further amended by a 5evero Amendment dated Jtme 1, 1988 and recorded Junc 2, 1988 and recorded arMiscdlaneous Book 361, Page 1066; and further amended bit an Pighr AmrndmPtrr dared.limv,, ZQ, 1969 and recorded June 23, 1989 in Aiscellaneous Book 365, Page 899, As morefully dararibed in such Declaration. as so amended,. tagarher with a proportionate undivided interest do the Common -'laments of such Condominium as set forth in such Declaration as so amended acrd further amended by any further amendments thereto hereafter recorded in the aforesaid office BFJNC the saute promdsas which karen A. Murawskt, a single parson of Boroutth of Mcchandcsburg, Cumberland County, Pennsylvania by trey Deed dated ,September it, 1995. recorded September 20, 1995 to the Office of the Recorder of Deeds in and for Cumberland Couruy, Pennsylvania in Dead Back 128, Page S12, granted and canveyed to lane E. Dolson, the Grantor herein- ACT 91 NOTICE DATE OF NOTICE: 12/29/2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 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 guestions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) 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 any 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 contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes 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 redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 EXHIBIT P, Date: 12/29/2009 Homeowners Name: TERRY L. BRYAN Property Address: 797 Old Silver Springs Road, Mechanicsburg, PA 17055 Loan Account No.: 2000152458 Original Lender: SAXON MORTGAGE SERVICES INC. Current Lender/Servicer: SAXON MORTGAGE SERVICES INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE 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. 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 (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) 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 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 telephone numbers of designated consumer credit counseling agencies for the county in which the pronertv 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.) 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. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 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. iiviz: tr YUU AXE UUKRENTLY 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.) V HOW TO CURE YOUR MORTGAGE DEFAULT Brine it up to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 797 Old Silver Springs Road, Mechanicsburg, PA 17055 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: (a) Monthly payment from 06/01/2009 thru 12/29/2009 (7 mos. at $742.59/month) $5,198.13 (b) Late charges from 06/01/2009 thrul2/29/2009 (7 mos. at $23.26/month) $162.82 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $5,360.95 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 $5,360.95, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: SAXON MORTGAGE SERVICES INC. 4708 Mercantile Drive North Fort Worth, TX 76137 IF YOU DO NOT CURE 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 ri hts 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 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 brings 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 required to pay attornev's fees C, 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 the default and prevent the sale at an time up to one hour before the Sheriffs Sale You may do so by paving the total amount then past due plus anv late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing by the lender and by performinganv other 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 Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SAXON MORTGAGE SERVICES INC. Address: 4708 Mercantile Drive North Fort Worth, TX 76137 Phone Number: 888-325-3502 Contact Person: Loss Mitigation Department 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 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. YOU MAY ALSO HAVE THE RIGHT: 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. BEHALF. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR * 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. Contact: Loss Mitigation Department Phone Number: 888-325-3502 HEMAP Consumer Credit Counseling Agencies Report last updated: 11/27/2009 2:32:10 PM CCCS of Western PA 4402 Peach Street Erie, PA 16509 888.511.2227 ext 108 888.511.2227 ext 108 DAUPHIN County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 814.337.8450 Greater Erie Community Action Committee 18 West 9TH Street Ede,PA 16501 814.459.4581 Shenango Valley Urban League. Inc. 601 Indiana Avenue Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DELAWARE County Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 215.389.2810 American Credit Counseling Institute 175 Strafford Avenue Suite 1 Wayne, PA 19087 610.971.2210 888.212.6741 American Credit Counseling Institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 888.212.6741 American Financial Counseling Services Inc. 1080 N. Delaware Avenue Suite 200 Philadelphia, PA 19125 267.228.7903 800.4903039 American Financial Counseling Services Inc. 405 West Germantown Pike Norristown, PA 19403 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 175 Strafford Avenue Suite One Wayne, PA 19087 267.228.7903 800.490.3039 Page 8 of 21 0 Form 3877 Domestic USPS Firm Mailing Book Name and Address of Sender: Permit Number Sequ ence Number -------------- JOSEPH A GOLDBECK JR 3103A MELLON INDEPENDENCE CENT 701 MARKET ST STE 5000 Ascent - MAC v7.90.7.90.M PHILADELPHIA, PA 19106 ----------------------------------- ------------------ Piece ID Article R Delivery Address SS Fee Postage value Sender Charges Addressee Name Type Insur./Register Due Total -------------------------------------- ------------------------------------------ 92426ACT-MC 71114342363000786332 CHAMBERLAIN, MICHELLE M. C 2.80 0.61 9.51 1123 Broadway Avenue ERR 1.10 Clifton Heights, PA 19018 92426AC'I'-OC.0171114342363000786349 CHAMBERLAIN, OLIVER C. C 2.80 0.61 4.51 1123 Broadway Avenue ERR 1.10 Clifton Heights, PA 19018 92426ACT-OC.0271114342363000786356 CHAMBERLAIN, OLIVER C. C 2.80 0.61 4.51 1123 Broadway Avenue ERR 1.10 Secane, PA 19018 92426ACT-MC.0171114342363000786363 CHAMBERLAIN, MICHELLE M. C 2.80 0.61 4.51 1123 Broadway Avenue ERR 1.10 Secane, PA 19018 92426ACT-MC.0271174342363000786370 CHAMBERLAIN, MICHELLE M. C 2.80 0.61 4.51 1123 Broadway Avenue ERR 1.10 Clifton Heights, PA 19018 92457ACT-GM 71114342363000786387 MICKOLICK, GEORGE A. C 2.80 0.61 4.51 180 Coulter Street ERR 1.10 Dunlo, PA 15930 9241BACT-TB 71114342363000786394 BRYAN, TERRY L. C 2.80 0.61 9.51 797 Old Silver Springs Road ERR 1.10 Mechanicsburg, PA 17055 92416ACT-CF 71114342363000786400 FUSCA, CATHERINE C ' 2.80 0.61 4.51 408 Woodland Hill Drive ERR 1.10 n Pittsburgh, PA 15235 - - ----------------- --------------- ----------- ------------------ -------------- Page Totals: 8 ---------- ---------------------_ 31.20 4.88 36 08 Cumulative Totals: 24 " . 93.60 74.64 108.24 Page 3 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 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. CES, P. C. BY. _ Attor ys for Plaintiff MARK J. U EN, ESQUIRE STUART EG, ESQUIRE LORRAINE YLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE C SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy .'ay°~,t}, o[ ~~~irti~~~,~~ *~• jrt F1~(~~-i:~r~~-~c Lr it I r ~l= ~r'~1 [ ~.1;"~~~4 , ZQIO ~~~ i I ~,~_ ~~ 2;~ Edward L Schorpp Solicitor F: F , ~ ...~~.r Ct~;~~ ii~Iz`~' HSBC Bank USA vs. Case Number Terry L. Bryan 2010-1476 SHERIFF'S RETURN OF SERVICE 03/09/2010 08:25 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 9, 2010 at 2020 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Terry L. Bryan, by making known unto himself personally, at 797 Old Silver Springs Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 March 10, 2010 GE LD WORTHINGT ,DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF c G'euniySuitu; 5h[~r'd'4. Teir:.csoYt. ir..,_ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 HSBC Bank USA, National : COURT OF COMMON PLEAS Association, as Trustee for : CIVIL DIVISION ACE Securities Corp. Home : Cumberland County Equity Loan Trust, Series 2006-NC1 CD 4708 Mercantile Drive NO. 10-1476 Civil Term Ft. Worth, TX 76137 «v3 w Plaintiff rnM M M. r� V � Terry L. Bryan 797 Old Silver Springs Road A -z Mechanicsburg, PA 17055 :c► gr. Defendant (s) y' •• --3'T PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. Atto e or intiff DATED: September 6 , 2013 HARR PAID E 10 01Qu 10020443-1