The URL can be used to link to this page

Home My WebLink About10-3574Supreme Court of Pennsylvania Court of Common. Pleas Civil Cover Sheet S E C T I Q N A County For Prothonotary Use Only. (T'THE Docket No: 2010 JUN I AM 10 11 10--S5'74 vi f rm The information collected on this form is used solely for court administration purposes. rhi$' fi r#•68.,not sunnlement or replace the tiling and service ofnleadinvs or other naners as reauired by law or rules ofcourt_ Commencement of Action: 9 Complaint ? Writ of Summons ? Petition ? Notice of Appeal Transfer from Another Jurisdiction ? Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: Ocwen Loan Servicing, LLC Kara L. Brough ? Check here if you are a Self-Represented (Pro Se) Litigant Name of Plaintiff/Appellant's Attorney: Are money damages requested? : ? Yes ?X No Dollar Amount Requested: ? within arbitration limits (Check one)_ outside arbitration limits Is this a Class Action Suit? ? Yes No Nature of the Case: Place an "X to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. S E C T I O N I; TORT (do not include Mass Tort) Intentional Malicious Prosecution Motor Vehicle ? Nuisance Premises Liability Product Liability (does not include mass tort) Slander/Libel/ Defamation ? Other: MASS TORT Asbestos H Tobacco Toxic Tort - DES ? Toxic Tort - Implant Toxic Waste Other: PROFESSIONAL LIABLITY Dental Legal Medical Other Professional: CONTRACT (do not include Judgments) Buyer Plaintiff Debt Collection: Credit Card Debt Collection: Other Employment Dispute: Discrimination Employment Dispute: Other ? Other: REAL PROPERTY Ejectment Eminent Domain/Condemnation Ground Rent ? Landlord/Tenant Dispute Mortgage Foreclosure Partition Quiet Title Other: Pa.R.e P. 205.5 CIVIL APPEALS Administrative Agencies Board of Assessment Board of Elections Dept. of Transportation ? Zoning Board Statutory Appeal: Other Judicial Appeals MDJ - Landlord/Tenant MDJ - Money Judgment Other: MISCELLANEOUS Common Law/Statutory Arbitration Declaratory Judgment Mandamus Non-Domestic Relations Restraining Order ? Quo Warranto [] Replevin Other: 212010 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF ARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 C7 C"? o zi ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 i =lt? 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 TO 856-669-5400 pleadings@udren.com Ocwen Loan Servicing, LLC :COURT OF COMMON PLEAS 12650 In enuit Drive :CIVIL DIVISION g Y Orlando, FL 32826 Plaintiff :Cumberland County V. Kara L. Brough 284 Steelstown Road ::NO. ?D - 35-74 a-ty, t-Tenn Newville, PA 17241 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO 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 S 2 Liberty Avenue Carlisle, PA 17013 44a.00 Pp AEI 800-990-9108 &-f IsaE84 &a4a9co 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 IM IEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 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 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: 284 Steelstown Road MUNICIPALITY/TOWNSHIP/BOROUGH: North Newton Township COUNTY: Cumberland DATE EXECUTED: 5/22/08 DATE RECORDED: 5/23/08 INSTRUMENT NO: 200817062 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 5/26/10: Principal of debt due $148,105.34 Unpaid Interest at 6.00% from 11/1/09 to 5/26/10 (the per diem interest accruing on this debt is $24.68 and that sum should be added each day after 5/26/10) 5,035.26 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $192.91 and that sum should be added on the first of each month after 5/26/10) 487.59 Late Charges (monthly late charge of $45.27 should be added in accordance with the terms of the note each month after 5/26/10) 90.54 Suspense Balance (1.77) Property Inspection 21.00 Attorneys Fees (anticipated and actual to 5% of principal) 7,405.27 TOTAL $161,748.23 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 $161,748.23 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. OFF„ICE$, P.C. BY UDREN, ESQUIRE VMINATO, or Plaintiff INNEG, ESQUIRE DOYLE, ESQUIRE ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ALL THAT CERTAIN tract of land situate in North Newton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the Stecistowa Road, also known as L.R. 21003, at Ilne of properly of Frank J. and E'Iizabcth Noun Hoke; thence along said propsnY South 27 302 feet, rrzorc or less, to a point- thence b degte?s 06 mitxutcs west I' 02 feet, 60 de P by property now or formerly of Randy and Jill Shuman, orrh grees 54 minutes Vilest 84.97 feet to a point, thcnee by lauds formerly of the estate of Lizzie B. Hoover, now or formerly OfRenneth L. and Gladys Virginia Hoover, North 30 degrees 02) minutes 40 seconds East 48 feet to a point; thence by the same North 27 degrees 06 minutes East 2I 5 feet to a point in the center of the Steelstown Road; thence by the =tear of the Steelstown. Road, South 96 degrees 31 minutes East 90 feet to the place of BEGINNING- Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4737 C C W E N (Do not send correspondence or payments to the above address) W WN'.nCWBN.C M March 20, 2010 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515132402127 Reference Code: 1003 Kara Brough 284 Steelstown Rd Newville, PA 17241-0000 Loan Number: 71575070 Property Address: 284 Steelstown Rd, Newville, PA 17241-0000 PLEASE SEE THE ENCLOSED DOCUMENT EXHIBIT A DACT91.16 This communication is from a debt collector attempting to collect a debt, any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4 73 7 OCWEN (Do not send correspondence orpayments to the above address) W WW.OCWEN.COM APPENDIX A March 20, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends t o foreclose Specific information about the nature of the default is provided in th The HOMEOWNER'S MORTGAGE ASSISTANCE PROG e attached pages RAM (HEMAP) ma y 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 C ONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTIC E 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 Cou nty are listed at the end of this Notice If you have any questions. you may call th e Pennsylvania Housi ng Finance Agen cy toll free at (800) 342-2397 (Persons with impaired hearing can call (717 This Notice contains important legal information If you ha ) 780-1869). ve any questions, rep resentatives at t he Consumer Credit Counseling Agency may be able to help explain it. You ma y 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 CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Kara Brough PROPERTY ADDRESS: 284 Steelstown Rd Newville, PA 17241-0000 LOAN ACCT. NO.: 71575070 ORIGINAL LENDER: CURRENT LENDER/SERVICER: OCWEN DACT91.16 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 0West Palm Beach, Florida 33416-4 73 7 O C W E N (Do not send correspondence orpayments to the above address) WWW.OCWEN.COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on. your mortgage for thirty (30) days from the date of this Notice. 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 THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency 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 proper 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.) 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 face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). DACT91.16 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt " Ocwen Loan Servicing, LLC P.O. Box 24737 o .__................. : West Palm Beach, Florida 33416-4737 D C W E N (Do not send correspondence or payments to the above address) W W W.OCWEN.COM HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to datel NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 284 Steelstown Rd, Newville, PA 17241-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 4 payments in the amount of $ 1,098.23 from December 2009 through March 20, 2010 DETAIL SUMMARY : Principal and Interest ................................. $ 3,621.28 Interest Arrearage ..................................... $ 0.00 Escrow .................................................. $ 771.64 Late Charges ........................................... $ 0.00 Insufficient Funds Charges ........................... $ 0.00 Fees / Expenses ........................................ $ 10.50 Suspense Balance (CREDIT) ........................ $ 1.77 Interest Reserve Balance (CREDIT) ................ $ 0.00 TOTAL DUE .......................................... $ 4,401.65 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,401.65, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by Money Gram. Cashier's Check. Certified Check or Money Order made. payable and sent to: OC WEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights 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) DAY period. 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) DAY period 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 paving 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. DACT91.16 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 33416-4737 O C W E N (Do not send correspondence or payments to the above address) WWW.OCWEN.COM EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 33416-4737 Phone Number: 877-596-8580 Fax Number: 561-682-7325 Contact: Early Intervention Dept 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 or X may not (CHECK ONE) 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. 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 (3) 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 DACT91.16 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt 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. ICES, P. C. too ey?s/for Plaintiff J. UDREN, ESQUIRE ST T WINNEG, ESQUIRE LO INE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~4t++titp cf ~'iurr~~~~~~A C~ fps ~,r rlr~ ~~ ~~'~ ,W, C7F~ IGE ' ' ` '~ H~ S ~£R1FP ~~ ~ILEC~ I r `` Jody S Smith Chief Deputy Richard W Stewart Solicitor 20111.l~ld 14 Phi 1 ~ ~~ ~Ci d~'~:~'r L.~~~"vl~! , Ocwen Loan Servicing, LLC Case Number vs. Kara L. Brough 2010-3574 SHERIFF'S RETURN OF SERVICE 06/10/2010 07:01 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2010 at 1901 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kara L. Brough, by making known unto herself personally, at 284 Steelstown Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the said true and correct copy of the same. i DENNIS Y, DEPUT SHERIFF COST: $38.80 June 11, 2010 SO ANSWERS, '~ RON R ANDERSON, SHERIFF {Cl CountySuite ShenTf. Teleosoft, Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 n Ocwen Loan Servicing, LLC €: COURT OF COMMOM LEAS i 12650 Ingenuity Drive € CIVIL DIVISI,OQrn -fit Orlando, FL 32826 : Cumberland Cour -- i Plaintiff V. € NO. 10-3574 3Pn Kara L. Brough . 284 Steelstown Road J' CP �•_ 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. Atto ne f P,rlaintif or f AR EESE, ESQUIRE DATED: September 6 , 2013 310501 10050525-1