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Home My WebLink About10-1862UDREN 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 rc-,.33 -LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. ICAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER =`-rrg 111 WOODCREST ROAD, SUITE 200 f CHERRY HILL, NJ 08003-3620 856-669-5400 = ••,, pleadings@udren.com < -n Ocwen Loan Servicing, LLC -'COURT OF COMMON PLEAS 12650 Ingenuity Drive '=CIVIL DIVISION Orlando, FL 32826 Plaintiff Cumberland County V. Alan J. Anthony Carol J. Anthony. NO. 85 Walnut Dale Road Shippensburg, PA '17257 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. ® qd o0 M . a4 19?# D -357q571, C 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 demands 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 O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA 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, who is the legal holder of the Mortgage and is in the process of formalizing the Assignment of Mortgage to be sent 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: 85 Walnut Dale Road MUNICIPALITY/TOWNSHIP/BOROUGH: Southampton Township COUNTY: Cumberland DATE EXECUTED: 09/19/07 DATE RECORDED: 09/26/07 INSTR NO.: 200737234 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 02/08/2010: Principal of debt due $259,202.68 Unpaid Interest at 6.75 from 06/01/2009 to 02/08/2010 (the per diem interest accruing on this debt is $47.55 and that sum should be added each day after 02/08/2010) 11,956.48 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $243.69 and that sum should be added on the first of each month after'02/08/2010) 140.13 Late Charges (monthly late charge of $85.62 should be added in accordance with the terms of the note each month after 02/08/2010) 428.10 Suspense Balance (1,038.46) Attorneys Fees (anticipated and actual to 5%- of principal) 12,960.13 TOTAL $284,254.06 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $284,254.06 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDR W FILES, P.C. BY: 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 Dec-01-2008 02:15Pm Frw T-425 P.004/005 F-261 1,u 79A7 CEWAN poem or paaar Of WA ww ttw aelpfaearteataIn At. aalwta athe 7aNnwP of rAusaftno t.l2dtaey 0r QATA nbrw w tr Lot Nd, 11. "Ima PMtlsi nedy Wielded am f LOW aW*rgk^ ACM Near of + r osse" anss era win rret?rotlwlsesyndr rrsrfa o gN WAW(" SAN Ii irce0160 wl CrabstwMl CCU* hM emk e6. Page 03. as 0010- eEtsiNl(ertG m • WIYOPIta maatefMttt u cM ere! Lot Was. 2.10 and 11: WANIP an oofeedn mwdtdwY WA Of W NOL 2 am 11. erlg am li 2a/g? Mel nraAac rme?erts M1) aacsnds 1tMast. *A nwad ae w"y.Ama a nd rimaMml Hie v1e1 teal an MM ptrt alatrat ai r ief of No 2 end saessref lash now ar to winv fowt:rtartas a t taita. 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ALSO LIOMA AND $LMJ£Crn rearWJWW as seawn w, ins sheared 6*W. which w i opepwoffid'naem ny relareeae rat ve, Sam _a tT" by 1e? L pap%f by dead dead Juft 11. 1923. and hecaldad u 34. 'R-, 34. Pap 402• unity Rart{IY C 8lwllrn and.0 H *kavm aw As dtvw Wp Vpptaead all pin llod IA ow0aden4 Ow* Plan o- so 67. etlnYed'tsraa 8*1101 labae 0) C/eilaado0 AINM sew be smswfaa wow end Wepct?n 2r (olpwirlt MInWte and ass r+ts"e sic c err is en-0d?oltsr0 siv span talpta absw ?w(ar 10 Mw me grsntacs and t. dab staple Irltey drtaalrud ra>ddatailal wtrna0ds r+E adprdtraant aa?awery twidaagl. (parepe. horn elrn eta i snsd N aarwrn+dtad an reels Idt . =74"14 2. The pnm" use of each let atru be rowenUaL but fte; rW alas be araew as secondoay er aecupuy WWI tom"Mons arm of ps"warAptetsd?age" sr+ ems MMOPOWN WAA n" us" canon 10 a we moors or wgrtllorwe pfope01rs, 9 He tnattaa llaalai mr t+saMMd err aeeY tq fn Yak aeraewaldes. a. VPIAdr trlga asl2is slaw garteusn trig paw an Ills in use. suPdhrnen. nil OW T*A psnrllMlan of ttte Orwdrpar Nlar lwlasr wmtillarhml pose sy0ur t 9r hta dNtyasa. Apptowt wM rd Cs uemMnlaeW 1g{?rMa Yea taaN ttr waMe to days allatrladaslrtt. . rarrlat2tel aaatlurrs seas hasaf a rNtYingRt of 11100 ttq. R ax read,..i suMN lnnr arse 5 Al . Nolas s in atroatMrMPra s11s2 ae tlalaar Wdrala0d m any tldaa Oda 4A M *Oaf td nlltlaaer WO t=1 1 lus urall'srewsd vnhtcJ.+.lantc yaMs er Jtrdt mds am Pamaard en any l01 et aatY tirr+e, .. - .. ..... tt. Tetras moo tee rrs atamtptatt2 d erk raaledal, measQt drowned un am ter at any *m. PARC:ft hO 39-14-0197-048 .. . 1210112009 11:44:22 ANA CUMBERLAND COUNTY J hest-w I asoa8se . page 3 OF 3 February 9, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE your County Ar listed at th ?Le end of this Notice if inn haves ins any all?pgtlnnq' VOII mAV (`All PenncvlvanlA Honcina the ?r- 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. "°"' EXHIBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Carol J. Anthony 85 Walnut Dale Road --- -- .......... _....... _.......... _....... _.__........... -- --...__.... _._._.. ._- h1PPMh-urZ.j!A.17257 __70735378.............. ...... ___ a-y_lor Bean & W>ihitaker____ - -- -----._._..._....__...._ ................_.__...._._...._......._......._...._. Ocwen_Loan_Servicng_LLC HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MA V RF. Fi IC.IRi F FOR FINANCIAL AS IS ANCE SIST HELP YOIT MAKE FTTTITRF MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS 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 FORFrr nSURE _ 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 MF,.RM NO JST OCCITR WI THIN FOR FMFR r ? THE MOR TGe CT ASSTSTANCF YOIT IIATTST RRTN(T YOTTR ?ORTC'AC'F TTP TO T, ] T penT nF T NOTTC'F CAT T FT) OHO ?T TO r'TmF ynr JR X4()R -.G AJ-r •• ?..?..R ? H ?,r nFF e r rr T?,?XPT ATLAS HOW TO RR INC, YOT TR MOR TCTA CTF I TP TO D A TF CONSiTMFR (`RFT'1IT C'OITNCFi run A ?. NCIFS - 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 narnes addresses and tel Anne numbers edit cnnnc ling agencie: fnr the ,n , ;n ., ?. the are cet fnrth at the end of th,e AT -?? • } nlr=nV tc 1,? ..r4+i7 It is only necessary to schedule one face-to-face meeting. Advise your lender imm_ ed_ ,?atPl; of your intentions. APPLICATION MNLEOR 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 MUS 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 ACTIO _ 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. 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: 85 Walnut Dale Road Shippensburg, PA 17257 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: Other charges (explain/itemize): Escrow Advance-$140.13ua LUtu_=.428.10-` Suspense= ($1038.46) _propm InsPectiQR-- 00 _ TOTAL. AMOiJ1VT TM: --._.-._.....__.-._._.--.--......... _......... -.___._. ...._.........._ ...... _ -- X1521 Z 6o B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (1)n not nce if not aP? li?ah_1P): h" -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDE ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THETA Y 0) DAY PERIOD. pa entc mnet he made Part, t, v each, rahier'c chPrl certifiP? t, and cent tn• P.rl. nr mnne? order mariP ?? You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (1?? not nce if not li ahle l: &A Page 3 of 3 IF YOU Do NOT nrroF DFF . --- - __ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to ex r ke Its rightc to areelerAtP 4hn morr means that the entire outstanding balance of this debt will be considered due immediately andy 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 for .lose noon your mfthged property- YE THE MniaTr An_>, m rOr,,,,:....ER UPON `The mortgaged property to pay off the mortgage debt. If the lender refers your case to its attorneys, but youcure 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 yo l cur the default within th TNTRTV t renulred t0 ?V gttA?71e5'? 0) SAY nprind 11 not h c fnne Q.THFR L.F. FR RFMFnn'e _ The lender may also sue you personally for the unpaid balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy w thou your having reaffirmed it, then lender cannot pursue this remedy. RIIsflT Tn CURE THE DEFALJT T PRLnR TO SHFRLFF -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, yn, still have the right +. the, , e at any time nn to nn hn it )ffQrftA=-Sherffrs Salt- YM X do costs coon ctPrl with th for clnc ,rP sa1P and any nthPr cngc cnnnectP.a=?++t. l , q&SpeCjffije-dA default in the manner set forth in this notice will restore your mortgage to the same si on id by Curing your had never defaulted. p° Y FARL IEST P(ISSLRi F SAFRLFF'S SALE DATF _ It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 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: _ Ocwen Federal Bank Address: 12650 Integrity Drive _ Orlando?FL 32826_-- Phone Number: - __._._._..._....---.-.--_-.-.--..---._......._._...._.__._-._-- Fax Number: ? ?---------------------------..-...._.........._......_-..__.._......--------......._._........ --1-40-7--M-$693 Contact Person: ---................... ..... _..... -.---.---.._-____-. _ustomer_Service_ EFFECT OF SHERIFF'S SAT Y _ 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. ASST ID MUN OF' M<7RTf' • nF _ 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 Counseiinq Agencies DELAWARE County Report last updated: 1212312008 1:54:26 PM - -1 "- JiV "UFpuf duun Chester Community Improvement Project 846 North Broad Street 412 Avenue of the States Philadelphia, PA 19130 PO Box 541 215.765.1221 Chester, PA 19016 Advocates for Financial Independence 610.876.8663 202 East Hinkley Avenue Diversified Community Services Ridley Park, PA 19078 Dixon House 215.389.2810 1920 South 20th Street American Credit Counseling Institute Philadelphia, PA 19145 175 Strafford Avenue 215.336.3511 Suite 1 FOB CDC Wayne, PA 19087 1201 West Olney Avenue 610.971.2210 Phialdelphia, PA 19141 888.212.6741 215.549.8755 American Credit Counseling Institute Germantown Settlement 526-528 Dekalb Street 5538 Wayne Avenue Norristown, PA 19401 Bldg C 610.971.2210 Philadelphia, PA 19144 888.212.6741 215.849.3104 American Financial Counseling Services HACE 175 Trafford Avenue 167 W. Allegheny Avenue Suite One 2nd Fl Wayne, PA 19087 - Philadelphia, PA 19140 267'226.7903 215.426.8025 800.490.3039 Housing Partnership of Chester County American Red Cross of Chester 41 West Lancaster Ave 1729 Edgemont Avenue Downingtown, PA 19335 Chester, PA 19013 610.518.1522 610.874.1484 Media Fellowship House APM 302 South Jackson Street 2147 North Sixth Street Media, PA 19063 Philadelphia, PA 19122 610.565.0434 215.235.6788 Northwest Counseling Service Carroll Park Community Council, Inc. 5001 North Broad Street 5218 Master Street Philadelphia, PA 19141 Philadelphia, PA 19131 215.324.7500 215.877.1157 Opportunity Inc. CCCS of Delaware Valley Two Bala Plaza 280 North Providence Road Suite 300 Media, PA 19063 Philadelphia, PA 19004 215.563.5665 610.660.6687 CCCS of Delaware Valley Phiia Council For Community Advmnt 790 E. Market St. 100 North 17th Street Suite 170, Marshall Building Suite 600 West Chester, PA 19382 Philadelphia, PA 19103 215.563.5665 215.567.7803 CCCS of Delaware Valley 800.930.4663 1608 Walnut Street Urbar, League of Philadeiphia 10th Floor 1818 Market Street Philadelphia, PA 19107 20th Floor 215.563.5665 Philadelphia, PA 19103 215.985.3220 W CO m r-I Ln r- Ln Ln M a M C3 C3 r M fU CO U Ir O C u M 1 119 T 2 ? M o cv a. cD ? U l C`1 11'? A? . ? ? ? q 1 t.j a 4 D C3 _0 ru m ru C3 O C3 W r N L W s V ?W?swHao o L A a x A ? 5 J G i 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. UD 0 ICES, P.C. BY: Attorne r Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE !_429UIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~- r- Sheriff ~ ~! t~~C.r~+~~r' "'~' Y ~yttltty' ~1 Ltrm~rr~f~A ~~ !F7t: ~i i~Jli~ll'M't1 Jody S Smith ~ v Chief Deputy - ZD ~ ~ MAR ~ !~M 9~ t~0 Edward L Schorpp Solicitor - (~,~,;~~• ;~,~}~ ~~'~~ Ocwen Loan Servicing, LLC vs. Case Number Alan J. Anthony (et al.) 2010-1862 SHERIFF'S RETURN OF SERVICE 03/22/2010 03:38 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 22, 2010 at 1535 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Alan J. Anthony, by making known unto Carol J. Anthony, Wife of defendant at 85 Walnut Dale Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of s e. MARK CONKLIN, DEPUTY 03/22J2010 03:38 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 22, 2010 at 1535 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Carol J. Anthony, by making known unto herself personally, at 85 Walnut Dale Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. ARK CONKLIN, DEPUTY SHERIFF COST: $62.00 March 23, 2010 SO ANSWERS, ---.._. RON R ANDERSON, SHERIFF ts~,a ~~r;~,rr rE ~ °r ~_..