HomeMy WebLinkAbout10-2758
ATTORNEY FOR PLAINTIFF
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Deutsche Bank National Trust :COURT OF COMMON PLEAS
Company, as Trustee for :CIVIL DIVISION
UDREN 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
L/-eHANDRA 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
Ameriquest Mortgage Securities €
Inc., Asset-Backed Pass- 'Cumberland
Through Certificates, Series
2002-C
P.O. Box 631730
Plaintiff
V.
Shawn E. Rickabaugh
County
Kimberly d. Rickabaugh a/k/a NO. 10 -01158
Kimberly Rickabaugh
899 Grahams Woods Road
Newville, PA 17241
Defendant(s)
a-wilTem
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. TH
4ga.60 PA A7t',/
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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
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
800-990-9108
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 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
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
I 1
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: Ameriquest Mortgage Company
Assignments of Record to: Deutsche Bank National Trust Co., as
Trustee of Ameriquest Mortgage Securities, Inc., series 2002-C
Asset-Backed Certificates under the Pooling and Servicing Agreement
dated as of October 1 2002, Without Recourse
Recording Date: 4/13/07 Book: 735 Page: 4974
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: 889 Grahams Woods Road
MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Frankford Township
COUNTY: Cumberland
DATE EXECUTED: 8/23/02
DATE RECORDED: 9/25/02 BOOK: 1774 PAGE: 2457
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
4/8/10:
Principal of debt due $173,088.52
Unpaid Interest at 8.92%
from 3/1/09 to 4/8/10
(the per diem interest accruing on
this debt is $42.30 and that sum
should be added each day after 4/8/10) 17,064.46
Title Report 325.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $224.51 and that sum should
be added on the first of each
month after 4/8/10) 2,272.11
Late Charges
(monthly late charge of $88.51
should be added in accordance
with the terms of the note
each month after 4/8/10) 795.99
Recoverable Balance 116.60
Attorneys Fees (anticipated and actual
to 5$ of principal) 8,654.43
TOTAL $202,597.11
*This interest rate is subject to adjustment as more fully
described in the note and mortgage.
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 "All, 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 $202,597.11 plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
UDR,P?N LAW OFFICES, P.C.
BYQ 1 Al IA/ V( A Z LALXA lu / `
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
ALL T14AT CERTAIN tract of land situate in Upper PranWord Township, County of
Cumberland and State of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point in line of land, now or formerly of J.C. Chronister; thence along land,
now or formerly of Guy R, Etter and Dorothy M. Etter, his wife, North sixty-eight (68) degrees
East, a distance of four hundred ten (414) feet to a point in line of land, now or formerly of
Charles Baughman; thence along lands now or formerly of the said Baughman, South twenty-one
(21) degrees East, a distance of seventy (70) feet to a point in line of lands, now or formerly of
the said Charles Raughman; thence along lands now or formerly of the said Charles Baughman,
South sixty-eight (68) degrees West. a distance of foul' hundred ten (410) feet to a point in the
Southern side of a public road and lands now or formerly of the said J.C. Chronister; thence
diagonally crossing the said public road and along lauds now or formerly of the said J. C.
Chronister, North twenty (20) degrees thirty (30) minutes West, a distance of seventy (70) feet to
a point, the place of BEOMMNG.
BEING THE SAME PREMISES WHICH Charles L. fitter and Marilyn L. Etter, his wife, for
any interest she may have, and Lillian L. Riebbaugh and. Glenn S. Ridcabaugh, h.cr husband, for
any interest he may have, and Arthur L. Etter and Connie Etter, his wife, for any interest she
may have, by Deed dated August 26, 1999, recorded September 1, 1999, in Book 206, page
1141, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania,
granted and conveyed unto Shawn E. Ricbbaugh, single person, Grantor herein.
SUBJECT TO A MORTGAGE to Americluest Mortgage Company, dated September 20, 2001,
recorded September 24, 2001, in Boole 1793, page 825, for the amount of $116,875.00. Said
mortgage was intended to be Mod aft this deed.
Under and subjcat to any and aX?wvenants, conditions, reservations, restrictions, limitations,
246 rtc• ,Ef?.J
J.. ? r
August 12, 2009
7104 5400 2100 2274 6359
0 0 0 3 2 3 8 7 1
Shawn E Rickabaugh
889 Grahams Wood Rd
Newville, PA 17241-9726 E August 12, 2009 91 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.
IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE THREE
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe 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 questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-1397. (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 an attorney in your area. The local bar association may be able to help you find
a lawyer.
LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN
SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N
INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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.
HOMEOWNER'S NAME(S): Shawn E Rickabaugh
PROPERTY ADDRESS: 889 Grahams Woods Rd
Newville, PA 17241
LOAN ACCT. NO.: 4000139289
ORIGINAL LENDER: Ameriquest Mortgage Company
CURRENT LENDER/SERVICER: American Home Mortgage Servicing, Inc.
EXHIBIT
Page two 4000139289
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOUMAYBE 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 consumer credit counseling agencies listed at the end of this
Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE.
IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP
IODATE . 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
property 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 forwarded to PHFA and received
within thirty (30) days of your face-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.
AGENCYACTION - 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 YOUARE CURRENTLYPROTECTED BY THE FILING OFA PETITIONIN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE
CONSIDERED AS ANATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistance.)
Page three
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date):
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
889 Grahams Woods Rd, Newville, PA 17241
IS SERIOUSLY IN DEFAULT because:
4000139289
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are
now past due:
(a) Monthly payments from 04/01/2009:
(b) Late charge(s):
(c) Other charge(s): NSF and Advances
(d) Less: Credit Balance
(e) Total amount required as of 08/11/2009:
$8,486.02
$264.93
($783.24)
$0.00
$7,967.71
HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7,967.71, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent
to:
American Home Mortgage Servicing, Inc.
1525 S. Beltline Rd. Coppell, TX 75019
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice,
the lender intends to exercise its right 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 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) DAYperiod, you will not be
required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY
(30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at
any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or
other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs
connected with the Sheriffs Sale as specified in writing by the lender and by performing any 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 Sheriff s Sale of the
mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the lender.
Page four 4000139289
HOW TO CONTACT THE LENDER
Name of Lender: American Home Mortgage Servicing, Inc.
Address: 1525 S. Beltline Rd. Coppell, TX 75019
Telephone Number: 1-866-612-3730
Fax Number: 1-866-497-1263
Contact Person: Trivonda Porter, Sara Haliko and Selena Moore
E-mail Address: Trivonda.porter@ahmsi3.com, Sara.haliko@ahmsi3.com,
selena.moore@ahmsi3.com
EFFECT OF SHERIFF'S SALE - 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.
ASSUMPTION OF MORTGAGE -You may not 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.
YOUMAYALSO 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.
° 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CAN BE FOUND ON PAGES S-7.
American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used
for that purpose.
Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it.
Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the
address below within the thirty day period that the debt, or any portion thereof, is disputed, we will:
1) Provide to you verification of the debt or a copy of any judgment entered against you.
2) Provide to you the name and address of your original creditor, if the original creditor is different from the
current creditor.
Sincerely,
American Home Mortgage Servicing, Inc.
American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019, 1-866-612-3730
" Indicates Counties Serviced
Acorn Housing Corporation
84(?North Broad Street
Philadelphia, PA 19130
(215) 765-1221
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Action Housing Inc
425 6th Avenue, Suite 950
Pittsburgh, PA 15219
(412) 281-2102
'Allegheny, Beaver, Butler, Fayette, Greene,
Washington, Westmoreland
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
(717) 334-1518
'Adams, Cumberland, Franklin, York
Advocates for Financial Independence
1806 S Broad Street, Suite 113
Philadelphia, PA 19145
(215) 389-2810
'Philadelphia
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
(215) 389-2810
'Delaware
Allegheny County Acorn
5907 Penn Avenue, Suite 300
Pittsburgh, PA 15206
(412) 441-6551
'Allegheny
American Credit Counseling Institute
21 S Church Street
West Chester, PA 19380
(888) 212-6741
'Chester
American Credit Couseling Institute
526-528 Dekalb Street
Norristown, PA 19401
(610) 971-2210
(888) 212-6741
'Montgomery, Delaware
American Credit Counseling Institute
530 W Street Road, Suite 201
Warminster, PA 18974
(215) 4449429
(888) 212-6741
Tucks, Montgomery, Philadelphia
American Credit Counseling Institute
937 North Hanover Street
Pottstown, PA 19460
(888) 212-6741
'Barks, Bucks, Montgomery
American Credit Counseling Institute
229 East Chestnut Street
Coatesville, PA 19320
(888) 212-6741
'Chester, Lancaster
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
*Mifflin
American Financial Counseling Services
405 West Germantown Pike
Norristown, PA 19403
(267) 228-7903
'Mifflin, Montgomery
American Financial Counseling Services
2880 Bergey Road Suite 4
Hatfield, PA 19440
(267) 228-7903
'Barks, Chester, Montgomery
American Financial Counseling Services
175 Strafford Avenue, Suite One
Wayne, PA 19087
(610) 971-2210
(888) 2125741
'Bucks, Chester, Delaware, Mongomery,
Philadelphia
American Financial Counseling Services
906 Penn Avenue
Wyomissing, PA 19610
(267) 228-7903
(800) 490-3039
`Barks
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Montgomery
American Financial Counseling Services
1917 Welsh Road
Philadelphia, PA 19115, PA 19610
(267) 228-7903
'Bucks, Montgomery, Philadelphia
American Red Cross - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637-3768
'Adams, Franklin, York
American Red Cross of Chester
1729 Edgemont Avenue
Chester, PA 19013
(610) 8741484
'Chester, Delaware
APM
2147 Norht Sixth Street
Philadelphia, PA 19122
(215) 235-6788
'Chester, Delaware, Philadelphia, Bucks
Armstrong CO Community Action Agency
124 Armsdale Road, Suite 211
Kittanning, PA 16201
(724) 548-3405
"Armstrong
Base, Inc.
447 South Prince Street
Lancaster, PA 17603
(717) 392-5467
'Lancaster
Blair County Community Action Agency
2100 6th Avenue, Suite 102
P.O. Box 1833
Altoona, PA 16602
(814) 946-3651
'Blair
Booker T. Washington Center
1720 Holland Street
Ede, PA 16503
(814) 453-5744
'Crawford, Erie, Warren
Bucks County Housing Group
200 West Bridge Street
Morrisville, PA 19067
(866) 866-0280
'Bucks
Bucks County Housing Group
2324 Second Street Pike, Suite 17
Wrightstown, PA 18940
(866) 866-0280
'Bucks
Bucks County Housing Group
470 Old Dublin Pike
Doylestown, PA 18901
(866) 866-0280
'Bucks
Bucks County Housing Group
349 Durham Road
Penndel, PA 19047
(866) 866-0280
'Bucks
Bucks County Housing Group
515 West End Blvd
Quakertown, PA 18951
(866) 866-0280
'Bucks
Budget Counseling Center
247 North Fifth Street
Reading, PA 19601
(610) 375-7866
'Barks, Chester, Schuylkill
Carroll Park Community Council, Inc.
5218 Master Street
Philadelphia, PA 19131
(215) 877-1157
'Chester, Delaware, Philadelphia
Catholic Social Services
Saint Catherine Manor
5 Knox Road
Scranton, PA 18505
(570) 558-3019
'Wyoming, Wayne, Bucks, Lackawanna,
Monroe, Philadelphia
CCCS of Delaware Valley
1230 New Rodgers Road, Suite F1
Bristol, PA 19007
(215) 563-5665
'Bucks
CCCS of Delaware Valley
1777 Sentry Parkway W, Suite 200
Blue Bell, PA 19422
(215) 563-5665
'Montgomery
CCCS of Delaware Valley
280 North Providence Road
Media, PA 19063
(215) 563-5665
'Chester
CCCS of Delaware Valley
Marshal Building
790 E Market St, Suite 170
West Chester, PA 19382
(215) 5635665
'Chester, Bucks
CCCS of Delaware Valley
Catholic Social Services Building
7340 Jackson Street
Philadelphia, PA 19136
(215) 563-5665
'Bucks, Philadelphia
CCCS of Delaware Valley
One Cherry Hill, Suite 215
Cherry Hill, PA 08002
(215) 563-5665
'Philadelphia
CCCS of Lehigh Valley
3671 Crescent Court East
Whitehall, PA 18052
(610) 8214011
(800) 837-9815
'Barks, Bucks, Carton, Lancaster, Lehigh,
Northhampton, Schuylkill
CCCS of Northeastern PA
201 Basin Street, Suite 6
Williamsport, PA 17701
(570)323.6627
'Centre, Clinton, Lycoming, Northumberland,
Union
CCCS of Northeastern PA
202 W Hamilton Avenue
State College, PA 16801
(814) 238-3668
'Blair, Centre, Clearfield, Clinton, Huntingdon,
Juniata, Mifflin
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
(570) 602-2227
'Bradford, Carbon, Columbia, Lackawanna,
Lycoming, Monroe, Montour, Northumberland,
Pike, Sullivan, Tioga, Union, Wayne, Wyoming
CCCS of Northeastern PA
411 Main Street, Suite 104
Stroudsburg, PA 18360
(570) 420-8980
'Bradford, Carbon, Monroe, Pike, Wayne
CCCS of Western PA
1 North Gate Square #2
Garden Center Or
Greensburg, PA 15601
(888)511-2227
'Fayette, Greene, Indiana, Somerset,
Washington, Westmoreland
CCCS of Western PA
55 Clover Hill Road
Dallastown, PA 17313
(888) 511-2227
'Fulton, Crawford, Lancaster
* Indicates Counties Serviced
CCCS of Western PA
21500 Linglestown Road
Harrisburg, PA 17102
(886) 511-2227
'Adams, Cumberland, Dauphin, Franklin, Perry,
Synder, York
Chester Community Improvement Project
412 Avenue of the States
P.O. Box 541
Chester, PA 19016
(610) 876-8663
*Chester, Delaware, Montgomery, Philadelphia
Diversified Community Service
Dixon House
1920 South 20th Street
Philadelphia, PA 19145
(215) 3363511
*Bucks, Chester, Delaware, Philadelphia
Indiana Co. Community Action Prog.
827 Water Street Box 187
Indiana, PA 15701
(724) 465-2657
*Armstrong, Cambria, Clearfield, Indiana,
Jefferson, Westmoreland
CCCS of Western PA
312 Chestnut Street, Suite 227
Meadville, PA 16335
(888) 511-2227
*Lawrence
CCCS of Western PA
41 East Chestnut Street
Washington, PA 15301
(888) 511-2227
'Westmoreland
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
(888) 511-2227
'Crawford, Erie, Warren
CCCS of Western PA
524 Franklin Avenue
Aliquippa, PA 15001
(888) 511-2227
*Cambria
CCCS of Western PA
917 A Logan Boulevard
Altoona, PA 16602
(888) 511-2227
'Armstrong, Bedford, Blair, Cambria, Centre,
Clearfield, Huntingdon, Juniata, Mifflin, Union
CCCS of Western PA
Pullman Commerce Center
112 Hollywood Dr
Butler, PA 16001
(888) 511-2227
*Butler, Clarion, Jefferson, Mercer, Venango
CCCS of Western PA
River Park Commons
2403 Sidney Street
Pittsburgh, PA 15203
(888) 511-2227
'Allegheny
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
(814) 337-8450
'Columbia, Venango
Centro Pedro Clever, Inc
627 West Erie Avenue
Philadelpia, PA 19140
(215) 227-7111
'Philadelphia
Comm. On Econ Opportunity of Luzeme Co.
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510
'Carbon, Luzeme, Schuylkill, Wyoming
Community Action Commission of Capital
Region
1514 Derry Street
Harrisburg, PA 17094
(717) 232-9757
*Cumberland, Dauphin, Franklin, Perry, Synder
Community Action Committee of the Lehigh
Valley
1337 East Fifth Street
Bethlehem, PA 18015
(610) 691-5620
'Barks, Carbon, Lehigh, Monroe,
Northhampton
Community Action Development Comm -
CADCOM
113 E Main Street
Norristown, PA 19401
(610) 277-0363
'Montgomery
Community Action Southwest
150 W Beau Street, Suite 304
Washington, PA 15301
(724) 225-9550
*Monroe
Community Action Southwest
58 E Greene Street
Waynesburg, PA 15370
(724) 852-2893
'Allegheny, York, Fayette, Greene,
Washington, Westmoreland
Comm. on Econ. Opportunity of Luzeme
County
163 Amber Lane
WilkesBarre, PA 18702
(570) 826-0510
(800) 822-0359
*Wyoming
Congreso
216 West Somerset Street
Philadelphia, PA 19133
(215) 763-8870
'Philadelphia
Council of Spanish Speaking Organization
705-09 North Franklin St
Philadelphia, PA 19123
(215) 627-3100
'Philadelphia
Credit Counseling Center
832 Second Street Pike
Richboro, PA 18954
(215) 3961880
*Bucks
Fair Housing Partnership of Greater Pittsburgh, Intercultural Family Services Inc
Inc. 4225 Chestnut Street
2840 Liberty Ave., Suite 205 Philadelphia, PA 19104
Pittsburgh, PA 15222 (215) 3861298
(412) 391-2535 'Philadelphia
'Allegheny
Fayette Co. Community Action Agency Inc
137 North Beeson Avenue
Uniontown, PA 15401
(724) 437-6050
'Fayette, Somerset
Korean Comm. Develop. Services Center
6055 North 5th Street
Philadelphia, PA 18505
(215) 276-8830
*Philadelphia
FOB CDC
1201 West Only Avenue
Philadelphia, PA 19141
(215) 649-8755
*Bucks, Chester, Delaware, Philadelphia
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
(412) 665-5200
'Allegheny
Germantown Settlement
5538 Wayne Avenue Bldg C
Philadelphia, PA 19144
(215) 849-3104
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Greater Erie Commun. Action Committee
18 West 9th Street
Ede, PA 16501
(814) 459-4581
*Crawford, Erie, Venango, Warren
HACE
167 W Allegheny Ave., 2nd Floor
Philadelphia, PA 19140
(215) 426-8025
'Bucks, Chester, Delaware, Philadelphia
Hispanic Alliance for Community Advancement
2740 North Front Street
Philadelphia, PA 19133
(215) 667-8932
*Monroe
Housing Assoc. of Delaware Valley
658 North Watts Street
Philadelphia, PA 19123
(215) 9760224
*Philadelphia, Monroe
Housing Opportunities of Beaver Co.
320 College Avenue, Unit 1
Beaver, PA 15009
(724) 7267511
*Beaver, Lawrence
Housing Partnership of Chester County
41 West Lancaster Avenue
Downingtown, PA 19335
(610) 5161522
*Chester, Delaware, Montgomery
Lawrence County Social Services, Inc.
241 West Grant Street
P.O. Box 189
New Castle, PA 16103
(724) 6567258
'Lawrence
Liberty Resources
714 Market Street, Suite 100
Philadelphia, PA 19106
(215) 6342000
*Philadelphia
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 1711
(717) 232-2207
'Cumberland, Dauphin, Perry
Lycom-Clntn Co Comm fo Comm Action
2138 Lincoln Street
P.O. Box 3568
Williamsport, PA 17703
(570) 326-0587
*Centre, Clinton, Lycoming, Union
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
(717) 762-3285
*Adams, Cumberland, Franklin, Fulton, Perry
Media Fellowship House
302 South Jackson Street
Media, PA 19063
(610) 565-0434
*Chester, Delaware
Mon Valley Unemployment Committee
1800 West St., 3rd Floor
Homestead, PA 15120
(412) 462-9962
'Allegheny, Washington, Westmoreland
Mt. Airy, USA
6703 Germantown Ave., Suite 200
Philadelphia, PA 19119
(215) 844-6021
'Philadelphia
Nazareth Housing Services
301 Bellevue Road
Pittsburgh, PA 15229
(412) 931-0996
'Allegheny
Indicates Counties Serviced
Neighborhood Housing Services of Reading
211N 5th St., Suite 1030
Reading, PA 19601
(610) 372-8433
'Becks
Neighborhood Housing Services, Inc.
710 5th Avenue, Suite 1000
Pittsburgh, PA 15219
(412) 281-9773
'Allegheny
New Kensignton Community Development
2515 Frankford Avenue
Philadelphia, PA 19125
(215) 427-0350
'Warren
The NORCAM Group
4200 Crawford Avenue Suite 200
Northern Cambria, PA 15714
(814) 9484444
"Cambria, Clearfield
Northam Tier Community Action Corp.
135 West 4th Street
P.O. Box 389
Emporium, PA 15834
(814)4861161
'Cameron, Elk, Mckean, Potter
Northwest Counseling Service
5001 North Broad Street
Philadelphia, PA 19141
(215) 324-7500
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Nueva Esperanza
4261 North 5th Street
Philadelphia, PA 19140
(215) 324-0746
'Philadelphia
Opportunity Inc.
301 East Market Street
York, PA 17403
(717) 424-3645
'Montgomery
The Partnership CDC
4020 Market Street, Suite 100
Philadelphia, PA 19104
(215) 662-1612
'Monroe
Pennsylvania Housing Finance Agency
2275 Swallow Hill Rd., Bldg 200
Pittsburgh, PA 15220
(412) 429-2842
'Allegheny
PHFA
211 North Front Street
Harrisburg, PA 17110
(800-) 342-2397
'Cumberland, Dauphin
Philadelphia Council for Comm. Advmnt.
100 N 17th St, Suite 600
Philadelphia, PA 19103
(215) 567-7803
(800) 930-4663
'Chester, Delaware, Montgomery, Philadelphia
Philadelphia Senior Center
509 South Broad Street
Philadelphia, PA 19147
(215) 546-5879
'Philadelphia
Schuylkill Community Action
225 N. Centre Street
Pottsville, PA 17901
(570) 622-1995
'Barks, Carbon, Lebanon, Lehigh, Luzeme,
Northumberland, Schuylkill
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(724) 981-5310
'Crawford, Lawrence, Mercer
South Philadelphia H.O.M.E.S.
1444 Point Breeze Avenue
Philadelphia, PA 19146
(215) 3344430
'Philadelphia
Southwest Community Development Corp.
6368 Paschall Avenue
Philadelphia, PA 19142
(215) 729-0800
'Montgomery
St. Martin Center
1701 Parade Street
Ede, PA 16503
(814) 452-6113
'Crawford, Erie, Venango, Warren
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
(814) 445-9628
'Cambria, Fayette, Somerset, Westmoreland
Tabor Community Services
308 E King Street, Suite 1
Lancaster, PA 17602
(717) 397-5182
(800) 788-5062
'Chester, Lancaster, Lebanon
The Trehab Center of Northeastern PA
10 Public Avenue
P.O. Box 366
Montrose, PA 18801
(570) 278-3338
(800) 982-4045
'Susquehanna
The Trehab Center of Northeastern PA
115 SR 92S
Tuckhannock, PA 18657
(570) 836-6840
(800) 982-4045
'Wyoming
The Trehab Center of of Northeastern PA
1225 Main Street
Honesdale, PA 18431
(570) 253-8941
(800) 9824045
'Bradford, Sullivan, Susquehanna, Tioga,
Wayne, Wyoming
The Trehab Center of Northeastern PA
144 E East Avenue
Welisboro, PA 16901
(570) 724-5252
(800) 982-4045
'Tioga
The Trehab Center of Northeastern PA
German Street
P.O. Box 389
Dushore, PA 18614
(570) 928-9667
(800) 9824045
'Sullivan
The Trehab Center of Northeastern PA
The Enterprise Center
703 S. Elmer Ave., Suite M-6
Sayre, PA 18840
(570) 888-0412
(800)982.4045
'Bradford
United Communties Southeast Philadelphia
2029 South 8th Street
Philadelphia, PA 19148
(215) 467-8700
'Philadelphia
United Neighborhood Centers of Northeastern
PA
425 Alder Street
Scranton, PA 18505
(570) 346-0759
'Lackawanna, Wyoming, Wayne, Luzeme
Urban League of Philadelphia
1818 Market Street
Philadelphia, PA 19103
(215) 561-0070
'Bucks, Delaware, Philadelphia
Urban League of Philadelphia
610 Wood Street
Pittsburgh, PA 15229
(412)931.6996
'Allegheny
Voices for Independence
1107 Payne Avenue
Ede, PA 16503
(814) 874-0064
(800) 838-9890
'Erie
Warren-Forest Counties Economic Opportunity
Council
1209 Pennsylvania Ave W.
P.O. Box 547
Warren, PA 16365
(814) 726-2400
'Forest, Waren
West Oak Lane CDC
6259 Limekiln Pike
Philadelphia, PA 1914
(215) 224-0880
'Monroe
August 12, 2009
7104 5400 2100 2274 6342
g,131 l iq
0 0 2 3 8 7 1
Kimberly D Rickabaugh
889 Grahams Wood Rd
Newville, PA 17241-9726 E August 12, 2009
E 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.
IMPORTANT INFORMATION CONCERNING YOUR RIGHTS IS CONTAINED ON PAGE THREE
The HOMEOWNER'S EMERGENCY 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 questions, 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 an attorney in your area. The local bar association may be able to help you find
a lawyer.
LA NOTIFICACIO'N EN ADdUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN
SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N
INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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.
HOMEOWNER'S NAME(S): Kimberly D Rickabaugh
PROPERTY ADDRESS: 889 Grahams Woods Rd
Newville, PA 17241
LOAN ACCT. NO.: 4000139289
ORIGINAL LENDER: Ameriquest Mortgage Company
CURRENT LENDER/SERVICER: American Home Mortgage Servicing, Inc.
Page two 4000139289
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOUMAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOUMAKE 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 consumer credit counseling agencies listed at the end of this
Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE.
IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP
IODATE . 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
property 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 forwarded to PHFA and received
within thirty (30) days of your face-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.
NOTE: IF YOU ARE CURRENTL Y PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE
FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE
CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have Bled bankruptcy you can still apply for
Emergency Mortgage Assistance.)
Page three 4000139289
, , . HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date):
NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at:
889 Grahams Woods Rd, Newville, PA 17241
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 payments from 04/01/2009:
(b) Late charge(s):
(c) Other charge(s): NSF and Advances
(d) Less: Credit Balance
(e) Total amount required as of 08/11/2009:
$8,486.02
$264.93
($783.24)
$0.00
$7,967.71
HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY
PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7,967.71, PLUS ANY MORTGAGE
PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent
to:
American Home Mortggage Servicing, Inc.
1525 S. Beltline Rd. Copp ell, TX 75019
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice,
the lender intends to exercise its right 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 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) DA Yperiod, you will not be
required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY
(30) DAYperiod and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at
any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or
other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs
connected with the Sheriffs Sale as specified in writing by the lender and by performing any 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 Sheriff s Sale of the
mortgaged property could be held would be approximately five (5) months from the date of this Notice. A notice of the
actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly what the required payment or action will be by
contacting the lender.
Page four
4000139289
, , .
HOW TO CONTACT THE LENDER
Name of Lender: American Home Mortgage Servicing, Inc.
Address: 1525 S. Beltline Rd. Coppell, TX 75019
Telephone Number: 1-866-612-3730
Fax Number: 1-866-497-1263
Contact Person: Trivonda Porter, Sara Haliko and Selena Moore
E-mail Address: Trivonda.porter@ahmsi3.com, Sara.haliko@ahmsi3.com,
selena.moore@ahmsi3.com
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 not 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.
YOUMAYALSO 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.
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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CAN BE FOUND ON PAGES S-7.
American Home Mortgage Servicing, Inc. is attempting to collect a debt, and any information obtained will be used
for that purpose.
Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it.
Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify us in writing at the
address below within the thirty day period that the debt, or any portion thereof, is disputed, we will:
1) Provide to you verification of the debt or a copy of any judgment entered against you.
2) Provide to you the name and address of your original creditor, if the original creditor is different from the
current creditor.
Sincerely,
American Home Mortgage Servicing, Inc.
American Home Mortgage Servicing, Inc. 1525 S. Beltline Rd. Coppell, TX 75019, 1-866-612-3730
* Indicates Counties Serviced
Acorn Housing Corporation
8419North Broad Street
Philadelphia, PA 19130
(215)765.1221
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Action Housing Inc
425 6th Avenue, Suite 950
Pittsburgh, PA 15219
(412) 281-2102
'Allegheny, Beaver, Butler, Fayette, Greene,
Washington, Westmoreland
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
(717) 3341518
'Adams, Cumberland, Franklin, York
Advocates for Financial Independence
1806 S Broad Street, Suite 1B
Philadelphia, PA 19145
(215) 389-2810
'Philadelphia
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
(215) 389-2810
'Delaware
Allegheny County Acorn
5907 Penn Avenue, Suite 300
Pittsburgh, PA 15206
(412) 441-6551
'Allegheny
American Credit Counseling Institute
21 S Church Street
West Chester, PA 19380
(888)212.6741
'Chester
American Credit Couseling Institute
526-528 Dekalb Street
Norristown, PA 19401
(610) 971-2210
(888) 212-6741
'Montgomery, Delaware
American Credit Counseling Institute
530 W Street Road, Suite 201
Warminster, PA 18974
(215) 444-9429
(888) 212-6741
'Bucks, Montgomery, Philadelphia
American Credit Counseling Institute
937 North Hanover Street
Pottstown, PA 19460
(888)212.6741
'Barks, Bucks, Montgomery
American Credit Counseling Institute
229 East Chestnut Street
Coatesville, PA 19320
(888) 212-6741
'Chester, Lancaster
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Mifflin
American Financial Counseling Services
405 West Germantown Pike
Norristown, PA 19403
(267) 228-7903
'Mifflin, Montgomery
American Financial Counseling Services
2880 Bergey Road Suite 4
Hatfield, PA 19440
(267) 228-7903
'Barks, Chester, Montgomery
American Financial Counseling Services
175 Strafford Avenue, Suite One
Wayne, PA 19087
(610) 971-2210
(888)212.6741
'Bucks, Chester, Delaware, Mongomery,
Philadelphia
American Financial Counseling Services
906 Penn Avenue
Wyomissing, PA 19610
(267) 228-7903
(800) 490-3039
`Barks
American Financial Counseling Services
871 N. Easton Road
Glenside, PA 19038
(267) 228-7903
'Montgomery
American Financial Counseling Services
1917 Welsh Road
Philadelphia, PA 19115, PA 19610
(267) 228-7903
'Bucks, Montgomery, Philadelphia
American Red Cross - Hanover Chapter
529 Carlisle Street
Hanover, PA 17331
(717) 637-3768
'Adams, Franklin, York
American Red Cross of Chester
1729 Edgemont Avenue
Chester, PA 19013
(610) 8741484
'Chester, Delaware
APM
2147 Norht Sixth Street
Philadelphia, PA 19122
(215) 235-0788
`Chester, Delaware, Philadelphia, Bucks
Armstrong CO Community Action Agency
124 Armsdale Road, Suite 211
Kittanning, PA 16201
(724) 548-3405
'Armstrong
Base, Inc.
447 South Prince Street
Lancaster, PA 17603
(717) 392-5467
'Lancaster
Blair County Community Action Agency
2100 6th Avenue, Suite 102
P.O. Box 1833
Altoona, PA 16602
(814) 946-3651
'Blair
Booker T. Washington Center
1720 Holland Street
Erie, PA 16503
(814) 453-5744
`Crawford, Erie, Warren
Bucks County Housing Group
200 West Bridge Street
Morrisville, PA 19067
(666) 866-0280
'Bucks
Bucks County Housing Group
2324 Second Street Pike, Suite 17
Wrightstown, PA 18940
(866) 866-0280
'Bucks
Bucks County Housing Group
470 Old Dublin Pike
Doylestown, PA 18901
(866) 866-0280
'Bucks
Bucks County Housing Group
349 Durham Road
Penndel, PA 19047
(866) 866-0280
'Bucks
Bucks County Housing Group
515 West End Blvd
Quakertown, PA 18951
(866) 866-0280
'Bucks
Budget Counseling Center
247 North Fifth Street
Reading, PA 19601
(610) 375-7866
'Barks, Chester, Schuylkill
Carroll Park Community Council, Inc.
5218 Master Street
Philadelphia, PA 19131
(215) 877-1157
'Chester, Delaware, Philadelphia
Catholic Social Services
Saint Catherine Manor
5 Knox Road
Scranton, PA 18505
(570) 558-3019
'Wyoming, Wayne, Bucks, Lackawanna,
Monroe, Philadelphia
CCCS of Delaware Valley
1230 New Rodgers Road, Suite F1
Bristol, PA 19007
(215) 563-5665
'Bucks
CCCS of Delaware Valley
1777 Sentry Parkway W, Suite 200
Blue Bell, PA 19422
(215) 563-5665
'Montgomery
CCCS of Delaware Valley
280 North Providence Road
Media, PA 19063
(215) 563-5665
`Chester
CCCS of Delaware Valley
Marshal Building
790 E Market St, Suite 170
West Chester, PA 19382
(215) 563-5665
`Chester, Bucks
CCCS of Delaware Valley
Catholic Social Services Building
7340 Jackson Street
Philadelphia, PA 19136
(215) 563-5665
'Bucks, Philadelphia
CCCS of Delaware Valley
One Cherry Hill, Suite 215
Cherry Hill, PA 08002
(215) 563-5665
'Philadelphia
CCCS of Lehigh Valley
3671 Crescent Court East
Whitehall, PA 18052
(610)821.4011
(800) 837-9815
'Barks, Bucks, Carbon, Lancaster, Lehigh,
Northhampton, Schuylkill
CCCS of Northeastern PA
201 Basin Street, Suite 6
Williamsport, PA 17701
(570) 323-6627
`Centre, Clinton, Lycoming, Northumberland,
Union
CCCS of Northeastern PA
202 W Hamilton Avenue
State College, PA 16801
(814) 238-3668
'Blair, Centre, Clearfield, Clinton, Huntingdon,
Juniata, Mifflin
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
(570) 602-2227
'Bradford, Carbon, Columbia, Lackawanna,
Lycoming, Monroe, Montour, Northumberland,
Pike, Sullivan, Tioga, Union, Wayne, Wyoming
CCCS of Northeastern PA
411 Main Street, Suite 104
Stroudsburg, PA 18360
(570) 420-8980
'Bradford, Carbon, Monroe, Pike, Wayne
CCCS of Western PA
1 North Gate Square #2
Garden Center Dr
Greensburg, PA 15601
(888) 511-2227
'Fayette, Greene, Indiana, Somerset,
Washington, Westmoreland
CCCS of Western PA
55 Clover Hill Road
Dallastown, PA 17313
(888) 511-2227
'Fulton, Crawford, Lancaster
* Indicates Counties Serviced
CCCS of Western PA
0 ' 0 2ALinglestown Road
Harrisburg, PA 17102
(888) 511-2227
'Adams, Cumberland, Dauphin, Franklin, Perry,
Synder, York
Chester Community Improvement Project
412 Avenue of the States
P.O. Box 541
Chester, PA 19016
(610) 8768663
'Chester, Delaware, Montgomery, Philadelphia
Diversified Community Service
Dixon House
1920 South 20th Street
Philadelphia, PA 19145
(215) 3363511
'Bucks, Chester, Delaware, Philadelphia
Indiana Co. Community Action Frog.
827 Water Street Box 187
Indiana, PA 15701
(724) 465-2657
*Armstrong, Cambria, Clearfield, Indiana,
Jefferson, Westmoreland
CCCS of Western PA
312 Chestnut Street, Suite 227
Meadville, PA 16335
(888) 511-2227
'Lawrence
CCCS of Western PA
41 East Chestnut Street
Washington, PA 15301
(888) 511-2227
'Westmoreland
CCCS of Western PA
4402 Peach Street
Erie, PA 16509
(888) 511-2227
*Crawford, Ede, Warren
CCCS of Western PA
524 Franklin Avenue
Aliquippa, PA 15001
(888) 511-2227
'Cambria
CCCS of Western PA
917 A Logan Boulevard
Altoona, PA 16602
(888) 511-2227
'Armstrong, Bedford, Blair, Cambria, Centre,
Clearfield, Huntingdon, Juniata, Mifflin, Union
CCCS of Western PA
Pullman Commerce Center
112 Hollywood Dr
Butler, PA 16001
(888) 511-2227
'Butler, Clarion, Jefferson, Mercer, Venango
CCCS of Western PA
River Park Commons
2403 Sidney Street
Pittsburgh, PA 15203
(888) 511-2227
'Allegheny
Center for Family Services, Inc.
213 Center Street
Meadville, PA 16335
(814) 337-8450
'Columbia, Venango
Centro Pedro Clever, Inc
627 West Erie Avenue
Philadelpia, PA 19140
(215) 227-7111
'Philadelphia
Comm. On Econ Opportunity of Luzeme Co.
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510
*Carbon, Luzeme, Schuylkill, Wyoming
Community Action Commission of Capital
Region
1514 Derry Street
Harrisburg, PA 17094
(717) 232-9757
*Cumbedand, Dauphin, Franklin, Perry, Synder
Community Action Committee of the Lehigh
Valley
1337 East Fifth Street
Bethlehem, PA 18015
(610) 691-5620
*Barks, Carbon, Lehigh, Monroe,
Northhampton
Community Action Development Comm
CADCOM
113 E Main Street
Norristown, PA 19401
(610) 2775363
'Montgomery
Community Action Southwest
150 W Beau Street, Suite 304
Washington, PA 15301
(724) 225-9550
'Monroe
Community Action Southwest
58 E Greene Street
Waynesburg, PA 15370
(724) 852-2893
'Allegheny, York, Fayette, Greene,
Washington, Westmoreland
Comm. on Econ. Opportunity of Luzeme
County
163 Amber Lane
WilkesBarre, PA 18702
(570) 826-0510
(800) 822-0359
`Wyoming
Congreso
216 West Somerset Street
Philadelphia, PA 19133
(215) 763-8870
'Philadelphia
Council of Spanish Speaking Organization
705-09 North Franklin St
Philadelphia, PA 19123
(215) 627-3100
'Philadelphia
Credit Counseling Center
832 Second Street Pike
Richboro, PA 18954
(215) 3961880
'Bucks
Fair Housing Partnership of Greater Pittsburgh, Intercultural Family Services Inc.
Inc. 4225 Chestnut Street
2840 Liberity Ave., Suite 205 Philadelphia, PA 19104
Pittsburgh, PA 15222 (215) 3861298
(412) 391-2535 *Philadelphia
*Allegheny
Fayette Co. Community Action Agency Inc
137 North Beeson Avenue
Uniontown, PA 15401
(724) 4375050
*Fayette, Somerset
Korean Comm. Develop. Services Center
6055 North 5th Street
Philadelphia, PA 18505
(215) 276-8830
'Philadelphia
FOB CDC
1201 West Only Avenue
Philadelphia, PA 19141
(215) 549-8755
'Bucks, Chester, Delaware, Philadelphia
Garfield Jubilee Associates
5138 Penn Avenue
Pittsburgh, PA 15224
(412) 6655200
'Allegheny
Germantown Settlement
5538 Wayne Avenue Bldg C
Philadelphia, PA 19144
(215) 849-3104
'Bucks, Chester, Delaware, Montgomery
Philadelphia
Greater Erie Commun. Action Committee
18 West 9th Street
Erie, PA 16501
(814) 459-4581
'Crawford, Ede, Venango, Warren
HACE
167 W Allegheny Ave., 2nd Floor
Philadelphia, PA 19140
(215) 426-8025
'Bucks, Chester, Delaware, Philadelphia
Lawrence County Social Services, Inc.
241 West Grant Street
P.O. Box 189
New Castle, PA 16103
(724) 658-7258
'Lawrence
Liberty Resources
714 Market Street, Suite 100
Philadelphia, PA 19106
(215) 6342000
'Philadelphia
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 1711
(717) 232-2207
'Cumberland, Dauphin, Perry
Lycom-Clntn Co Comm fo Comm Action
2138 Lincoln Street
P.O. Box 3568
Williamsport, PA 17703
(570) 3260587
*Centre, Clinton, Lycoming, Union
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
(717) 762-3285
'Adams, Cumberland, Franklin, Fulton, Perry
Hispanic Alliance for Community Advancement
2740 North Front Street Media Fellowship House
Philadelphia, PA 19133 302 South Jackson Street
(215) 667-6932 Media, PA 19063
`Monroe (610) 565-0434
'Chester, Delaware
Housing Assoc. of Delaware Valley
658 North Watts Street
Philadelphia, PA 19123
(215) 978-0224
'Philadelphia, Monroe
Housing Opportunities of Beaver Co.
320 College Avenue, Unit 1
Beaver, PA 15009
(724) 7267511
'Beaver, Lawrence
Housing Partnership of Chester County
41 West Lancaster Avenue
Downingtown, PA 19335
(610) 5161522
'Chester, Delaware, Montgomery
Mon Valley Unemployment Committee
1800 West St., 3rd Floor
Homestead, PA 15120
(412) 462-9962
*Allegheny, Washington, Westmoreland
Mt. Airy, USA
6703 Germantown Ave., Suite 200
Philadelphia, PA 19119
(215) 8446021
'Philadelphia
Nazareth Housing Services
301 Bellevue Road
Pittsburgh, PA 15229
(412) 931-0996
*Allegheny
* Indicates Counties Serviced
Neighborhood Housing Services of Reading
r ' 2A3 N 5th St., Suite 1030
Reading, PA 19601
(610) 372-8433
'Barks
Neighborhood Housing Services, Inc.
710 5th Avenue, Suite 1000
Pittsburgh, PA 15219
(412) 281-9773
'Allegheny
New Kensignton Community Development
2515 Frankford Avenue
Philadelphia, PA 19125
(215) 427-0350
'Warren
The NORCAM Group
4200 Crawford Avenue Suite 200
Northam Cambria, PA 15714
(814) 948-4444
'Cambria, Clearfield
Northam Tier Community Action Corp.
135 West 4th Street
P.O. Box 389
Emporium, PA 15834
(814)4861161
'Cameron, Elk, Mckean, Potter
Northwest Counseling Service
5001 North Broad Street
Philadelphia, PA 19141
(215) 324-7500
'Bucks, Chester, Delaware, Montgomery,
Philadelphia
Nueva Esperanza
4261 North 5th Street
Philadelphia, PA 19140
(215) 324-0746
'Philadelphia
Opportunity Inc.
301 East Market Street
York, PA 17403
(717) 424-3645
'Montgomery
The Partnership CDC
4020 Market Street, Suite 100
Philadelphia, PA 19104
(215) 662-1612
'Monroe
Pennsylvania Housing Finance Agency
2275 Swallow Hill Rd., Bldg 200
Pittsburgh, PA 15220
(412) 429-2842
'Allegheny
PHFA
211 North Front Street
Harrisburg, PA 17110
(800-) 342-2397
'Cumbedand, Dauphin
Philadelphia Council for Comm. Advmnt.
100 N 17th St, Suite 600
Philadelphia, PA 19103
(215) 567-7803
(800) 930-4663
'Chester, Delaware, Montgomery, Philadelphia
Philadelphia Senior Center
509 South Broad Street
Philadelphia, PA 19147
(215) 546-5879
'Philadelphia
Schuylkill Community Action
225 N. Centre Street
Pottsville, PA 17901
(570) 622-1995
'Barks, Carbon, Lebanon, Lehigh, Luzeme,
Northumberland, Schuylkill
Shenango Valley Urban League, Inc.
601 Indiana Avenue
Farrell, PA 16121
(724) 981-5310
'Crawford, Lawrence, Mercer
South Philadelphia H.O.M.E.S.
1444 Point Breeze Avenue
Philadelphia, PA 19146
(215) 334-4430
'Philadelphia
Southwest Community Development Corp.
6368 Paschall Avenue
Philadelphia, PA 19142
(215) 729-0800
'Montgomery
St. Martin Center
1701 Parade Street
Erie, PA 16503
(814) 452-0113
'Crawford, Erie, Venango, Warren
Tableland Services Inc.
535 East Main Street
Somerset, PA 15501
(814) 445-9628
'Cambria, Fayette, Somerset, Westmoreland
Tabor Community Services
308 E King Street, Suite 1
Lancaster, PA 17602
(717) 397-5182
(800) 788-5062
'Chester, Lancaster, Lebanon
The Trehab Center of Northeastern PA
10 Public Avenue
P.O. Box 366
Montrose, PA 18801
(570)278.3338
(800) 982-4045
'Susquehanna
The Trehab Center of Northeastern PA
115 SR 92S
Tuckhannock, PA 18657
(570) 836-6840
(800) 982-4045
'Wyoming
The Trehab Center of of Northeastern PA
1225 Main Street
Honesdale, PA 18431
(570)253.8941
(800) 982-4045
'Bradford, Sullivan, Susquehanna, Tioga,
Wayne, Wyoming
The Trehab Center of Northeastern PA
144 E East Avenue
Wellsboro, PA 16901
(570) 724-5252
(800) 982-0045
'Tioga
The Trehab Center of Northeastern PA
German Street
P.O. Box 389
Dushore, PA 18614
(570) 928-9667
(800) 982-4045
'Sullivan
The Trehab Center of Northeastern PA
The Enterprise Center
703 S. Elmer Ave., Suite M-6
Sayre, PA 18840
(570) 888-0412
(800) 982-4045
'Bradford
United Communties Southeast Philadelphia
2029 South 8th Street
Philadelphia, PA 19148
(215) 467-8700
'Philadelphia
United Neighborhood Centers of Northeastern
PA
425 Alder Street
Scranton, PA 18505
(570) 346-0759
'Lackawanna, Wyoming, Wayne, Luzeme
Urban League of Philadelphia
1818 Market Street
Philadelphia, PA 19103
(215) 561-6070
'Bucks, Delaware, Philadelphia
Urban League of Philadelphia
610 Wood Street
Pittsburgh, PA 15229
(412) 931-6996
'Allegheny
Voices for Independence
1107 Payne Avenue
Erie, PA 16503
(814) 874-0064
(800) 838-9890
'Erie
Warren-Forest Counties Economic Opportunity
Council
1209 Pennsylvania Ave W.
P.O. Box 547
Warren, PA 16365
(814) 726-2400
'Forest, Waren
West Oak Lane CDC
6259 Limekiln Pike
Philadelphia, PA 1914
(215) 224-0880
'Monroe
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.
BY
Attorneys for P aintiff
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
r
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: 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
Deutsche Bank National Trust Company, as € COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities € CIVIL DIVISION
Inc., Asset-Backed Pass- Through =Cumberland County
Certificates, Series 2002-C
Plaintiff -
NO. 10-2758
V.
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Shawn E. Rickabaugh
f,~
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Kimberly D. Rickabaugh a/k/a Kimberly ~- ~-
Rickabaugh {~"`
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Defendants ~
NOTICE OF INTENT TO SERVE ~
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
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Deutsche Bank National Trust Company, as Trustee for Ameriquest Mortgage Securities Inc.,
Asset-Backed Pass-Through Certificates, Series 2002-C intends to serve a subpoena identical to the
one that is attached to this notice. You have twenty (20) days from the date listed below in which
to file of record and serve upon the undersigned- an objection to the subpoena. If no objection is
made the subpoena maybe served.
Date: June ~ i , 2010
UD L FICES, P.C.
BY
Margu omas, Esquire
Atto v or Plaintiff
~, j
COMMONWEALTH OF PENNSYLVANIA
~~-v f"'Sche 13o.n ~ .. // COUNTY OF CUMBERLAND
Iv0.~-,one
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~'''''~~~`~ D~ ~~`~P~~NA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: V l
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things:
at /,~{l'n~le~e~~-('n ~~c- c~ltl bn-~b/- I J I Lets-telC~e Sf Q.c~. C' h~rrv H ~ 1 ~ /V ~ 0 ~~3
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party malriag this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
SUPREME COURT ID # -
ATTORNEY FOR:
Daze: _ f
' Sea n tk~e Court
BY ' COURT:
0 0 evil Division
Deputy
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadingsnudren.com
Deutsche Bank National Trust Company, as :COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities € CIVIL DIVISION
Inc., Asset-Backed Pass- Through :Cumberland County
Certificates, Series 2002-C
Plaintiff '
v. € NO. 10-2758
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a!k/a Kimberly
Rickabaugh
Defendants
CERTIFICATE OF SERVICE
I, Marguerite L. Thomas, Esquire, hereby certify that I have served or caused to be served
a true and correct copy of the Notice of Intent to Serve a Subpoena to Produce Documents and
Things for Discovery Pursuant to Pa.R.C.P. 4009.21, in the above-captioned matter, the
original of which has been upon the following person(s) named herein at their last known
address or their attorney of record.
xxxxxx Regular First Class Mail
Date Served: June ~ ~ , 2010
TO: Shawn E. Rickabaugh
889 Grahams Wood Rd.
Newville, PA 17241
Defendant
Kimberly Rickabaugh
889 Grahams Wood Rd.
Newville, PA 17241
Defendant
P.C.
Attorney ~6z1 Plaintiff
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
ATTORNEY FOR PLAINTIFF
856-669-5400, pleadings@udren.com
Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities CIVIL DIVISION
Inc., Asset-Backed Pass-Through Certificates,
Series 2002-C Cumberland County
Plaintiff
V.
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly € NO. 10-2758
Rickabaugh
f")
C o
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4• w_J
Defendants --
-r rv
NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENT OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
Plaintiff, Deutsche Bank National Trust Company, as Trustee for Ameriquest Mortgage
Securities Inc., Asset-Backed Pass-Through Certificates, Series 2002-C, intends to serve a
subpoena identical to the one that is attached to this notice. You have twenty (20) days from the
date listed below in which to file of record and serve upon the undersigned an objection to the
subpoena. If no objection is made the subpoena may be served.
Date: UQREN I# PFFICES, P.C.
I IN
Plaintiff
Ifs L Thomas, Esquire
M 0 204460
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UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400, pleadings@udren.com
ATTORNEY FOR PLAINTIFF
Deutsche Bank National Trust Company, as € COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities CIVIL DIVISION
Inc., Asset-Backed Pass-Through Certificates,
Series 2002-C Cumberland County
Plaintiff
V.
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly NO. 10-2758
Rickabaugh
Defendants
CERTIFICATE OF SERVICE
The undersigned attorney, hereby certifies that I have served or caused to be served, true
and correct copies of Notice of Intent to Serve a Subpoena to Produce Documents and Things for
Discovery Pursuant to Pa.R.C.P. 4009.21 upon the following person(s) named herein at their last
known address or their attorney of record.
xxxxxx
Regular First Class Mail
Date Served: January 1@, 2011
TO: Shawn E. Rickabaugh Kimberly D. Rickabaugh a/k/a Kimberly Rickabaugh
889 Grahams Wood Road 889 Grahams Wood Road
Newville, PA 17241 Newville, PA 17241
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
-f k¢ f k? ahn ,C Trust .
Plaintiff •
vs.
Defendant
File No. 10-e?, 75-f
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: V 1 T(.ll1° (lac f
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things:
at I I I WUUU L/ tJ T N XI U I s-) t1,GTZ 2/ L f IV / W ttZ/fj
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: L j
ADDRESS: V/// Ilmn l
SUPREME COURT ID #.
ATTORNEY FOR: rV i
Trust BY THE COURT:
Prothonotary, Civil Division
Date:
Seal of the Court
Deputy
A&603
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UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
ATTORNEY FOR PLAINTIFF
856-669-5400, pleadings@udren.com
Deutsche Bank National Trust Company, as € COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities CIVIL DIVISION
Inc., Asset-Backed Pass-Through Certificates,
Series 2002-C ' Cumberland County
Plaintiff
V.
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly = NO. 10-2758
Rickabaugh
Defendants
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CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Plaintiff, Deutsche Bank National Trust Company, as Trustee for Ameriquest Mortgage
Securities Inc., Asset-Backed Pass-Through Certificates, Series 2002, certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena attached
thereto was mailed or delivered to each party at least twenty days prior to the date
on which the subpoena is sought to be served,
(2) a copy of the notice of intent, including the proposed subpoena, is attached to this
certificate,
(3) no objection to the subpoena has been received, and
(4) the subpoena which will be served is identical to the subpoena which is attached
to the notice of intent to serve the subpoena.
Date:
BY:
iG
CES, P.C.
Esquire
r'
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Plaintiff
vs.
Defendant
xttmf?rty ?i?KCl?ufh
File No. ?0'0? 11S
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: V 1 T(?U ? m df
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things:
at I I I 1,41UUU LJ tJ7 /V 1 (r) 1(/ A,, C_A LIU / (- r /-1 f U f77Ai(
(Address) L"
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: L,
ADDRESS: // / u )1117
SUPREME COURT ID #
ATTORNEY FOR: iV i
Tyvlf? BY THE COURT:
Prothonotary, Civil Division
Date:
Seal of the Court
Deputy
od"6 63
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
III WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400, pleadinga@v.dren.com
Deutsche Bank National Trust Company, as
Trustee for Ameriquest Mortgage Securities
inc., Asset-Backed Pass-Through Certificates,
Series 2002-C
Plaintiff
V.
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly
Rickabaugh
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County c ?
a
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C5
CD i
NO. 10-2758
>
Defendants
NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
Plaintiff, Deutsche Bank National Trust Company, as Trustee for Ameriquest Mortgage
Securities Inc., Asset-Backed Pass-Through Certificates, Series 2002-C, intends to serve a
subpoena identical to the one that is attached to this notice. You have twenty (20) days from the
date listed below in which to file of record and serve upon the undersigned an objection to the
subpoena. If no objection is made the subpoena may be served.
f h?111-
Date:
BY:
, P.C.
Plaintiff
to L Thomas, Esquire
PA 10 204460
Copy
J h cd
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: MARGUERITE L. THOMAS, ESQUIRE - ID #204460
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadin-as(a),ndren.com
Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities _ CIVII, DIVISION
Inc., Asset-Backed Pass- Through Cumberland County
Certificates, Series 2002-C
Plaintiff
V. € NO. 10-2758
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly
Rickabaugh
Defendants
CERTIFICATE OF SERVICE
I, Marguerite L. Thomas, Esquire, hereby certify that I have served or caused to be served
a true and correct copy of the Notice of Intent to Serve a Subpoena to Produce Documents and
Things for Discovery Pursuant to Pa.R.C.P. 4009.21, in the above-captioned matter, the
original of which has been upon the following person(s) named herein at their last known
address or their attorney of record.
xxxxxx Regular First Class Mail
Date Served: June i I , 2010
TO: Shawn E. Rickabaugh
889 Grahams Wood Rd.
Newville, PA 17241
Defendant
Kimberly Rickabaugh
889 Grahams Wood Rd.
Newville, PA 17241
Defendant UDRI;N LAW PFFICES, P.C.
BY:
Attorney ?64 Plaintiff
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
ATTORNEY FOR PLAINTIFF
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400, pleadings@udren.com
Deutsche Bank National Trust Company, as COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities € CIVIL DIVISION
Inc., Asset-Backed Pass-Through Certificates,
Series 2002-C Cumberland County
Plaintiff
V.
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly € NO. 10-2758
Rickabaugh
Defendants
CERTIFICATE OF SERVICE
The undersigned attorney, hereby certifies that I have served or caused to be served, true
and correct copies of Certificate of Prerequisite to Serve a Subpoena Pursuant to Pa.R.C.P.
4009.22 upon the following persons named herein at their last known address or their attorney of
record.
xxxxxx Regular First Class Mail
Date Served: (;V r6 h 1 f Z G I
TO: Shawn E. Rickabaugh Kimberly D. Rickabaugh a/k/a Kimberly Rickabaugh
889 Grahams Wood Road 889 Grahams Wood Road
Newville, PA 17241 Newville, PA 17241
OFFICES, P.C.
Esquire
to Thomas, Esquire
PA 204460
UDREN LAW OFFICES, P.C.
III WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
Deutsche Bank National Trust Company, as
Trustee for Ameriquest Mortgage Securities
Inc., Asset-Backed Pass-Through Certificates,
Series 2002-C
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 10-2758
V ---
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Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly
Rickabaugh < -Q
c,
Defendants _ C=•'
PRAECIPE TO RELEASE DEFENDANT, KIMBERLY D. RICKABAUGH, a/k/a
KIMBERLY RICKABAUGH, WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Pursuant to Pa.R.C.P. 1144(b), Plaintiff hereby releases Defendant, Kimberly D.
Rickabaugh, a/k/a Kimberly Rickabaugh, from liability for the debt secured by the mortgage,
subject of the above captioned Mortgage Foreclosure action, without prejudice.
UDRENtLt] W OFFICES, P.C.
BY-'-"
Marguerite . Thomas, Esquire
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UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
Deutsche Bank National Trust Company, as € COURT OF COMMON PLEAS
Trustee for Ameriquest Mortgage Securities CIVIL DIVISION
Inc., Asset-Backed Pass-Through Certificates, Cumberland County
Series 2002-C
Plaintiff € NO. 10-2758
V.
Shawn E. Rickabaugh
Kimberly D. Rickabaugh a/k/a Kimberly
Rickabaugh
Defendants
CERTIFICATE OF SERVICE
The undersigned, hereby certifies that true and correct copies of Praecipe to Release
Defendant, Kimberly D. Rickabaugh a/k/a Kimberly Rickabaugh, Without Prejudice was served
upon the following person(s) named herein at their last known address or their attorney of record.
xxxxxx Regular First Class Mail
Date Served: June.)_,, 2011
TO: Shawn E. Rickabaugh
889 Grahams Wood Rd.
Newville, PA 17241
Defendant
Kimberly Rickabaugh
889 Grahams Wood Rd.
Newville, PA 17241
Defendant
UDREN rL,AWIQFFICES, P.C.
A
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
Deutsche Bank National Trust '::COURT OF COMMON PLEAS
Company, as Trustee for 'CIVIL DIVISION
Ameriquest Mortgage Securities :Cumberland County
Inc., Asset-Backed Pass-
Through Certificates, Series
2002-C ::NO. 10-2758
P.O. Box 631730
Plaintiff
V.
Shawn E. Rickabaugh
899 Grahams Woods Road
Newville, PA 17241
Defendant (s)
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above DISCONTINUED WITHOUT PREJUDICE,
upon payment of your costs only.
DATED: February 8, 2012
v
Attorney for Plaintiff
HARRY S. REESE, ESQUIRt
PA ID 310501
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