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HomeMy WebLinkAbout10-4512RICHARD F. STERN, ESQu1RE (03315) STEVEN K. EISENBERG, EsQuIRE (75736) KEVIN P. DISKIN, EsQuIRE (86727) STERN AND EISENBERG, LLP TFIE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) _ ~: h ~ ~., ;~~ _. , r ; A ~ `t ~ `~ ~ '~ 4 t `: + ~ ~ ~ U ` ~, ` • rat A`ti . ~ ~~ ~<< IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Bank USA, N.A., as Indenture Trustee for the registered Noteholders of Renaissance Home Equity Loan Trust 2007-2, c/o Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Lorraine R. Reiley 505 Geary Avenue New Cumberland, PA 17070 And John Doe 505 Geary Avenue New Cumberland, PA 17070 Civil Action Number: COMPLAINT IN EJECTMENT llJ- c~s~a C~i'v~ ~ CIVIL ACTION -EJECTMENT This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or prope y of other rights important to you. S ~~ ~9~i~a J:\Angela\Eviction\Cumberland\Ocwen.Reiley.7.l0.doc ~~ ~C/~~%~ YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Angela\Eviction\Cumberland\Ocwen.Reiley.7. l0.doc NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ., YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU DO SO 1N WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN ADMISSION OF LIABILITY BY YOU. IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION OF THIS DEBT. THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. J:\AngelalEviction\Cumberland\Ocwen.Reiley.7.10. doc RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) KEVIN P. DISKIN, ESQUIRE (86727) STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIIvIILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY HSBC Bank USA, N.A., as Indenture Trustee for the registered Noteholders of Renaissance Home Equity Loan Trust 2007-2, c/o Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 v. Lorraine R. Reiley 505 Geary Avenue New Cumberland, PA 17070 And John Doe 505 Geary Avenue New Cumberland, PA 17070 Civil Action Number: COMPLAINT IN EJECTMENT COMPLAINT CIVIL ACTION -EJECTMENT 1. Plaintiff is HSBC Bank USA, N.A., as Indenture Trustee for the registered Noteholders of Renaissance Home Equity Loan Trust 2007-2, c/o Ocwen Loan Servicing, LLC (hereinafter referred to as "HSBC Bank USA, N.A.") with offices located at 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409. 2. Defendant is Lorraine R. Reiley, an adult individual residing at 505 Geary Avenue, New Cumberland, PA 17070 which Property is described in Exhibit "A" attached hereto and incorporated herein by reference. 3. Defendant(s) are also John Doe who are unknown adult individuals residing at 505 Geary Avenue, New Cumberland, PA 17070 which Property is described in Exhibit "A" attached hereto and incorporated herein by reference. J: \Angela\Eviction\Cumberland\Ocwen.Reiley.7. l0.doc 4. On March 3, 2010, 505 Geary Avenue ,New Cumberland, PA (the "Property")was sold by the Sheriff of Cumberland County at Sheriffs Sale after due advertisement according to law and under and by virtue of a Writ of Execution issued out of the Court of Common Pleas of Cumberland County, 2008-7178 at the suit of HSBC Bank USA, N.A., as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Loan Trust 2007-2 by its Attorney in Fact, Ocwen Loan Servicing, LLC vs Lorraine R. Reiley. 5. A deed to Plaintiff was issued on April 23, 2010. A copy of the deed is attached as Exhibit "A". 6. By virtue of Sheriff s Sale, Plaintiff is entitled to possession of the premises. 7. Defendants are presently in possession of the said premises. WHEREFORE, Plaintiff, HSBC BANK USA, N.A. demands that a Judgment in Ejectment be entered in its favor and against the Defendants. STERN AND EISENBERG, LLP 1_~~ BY: / RICHARD F. STERN, ESQUIRE STEVEN K. EISENBERG, ESQUIRE KEVIN P. DISKIN, ESQUIRE Attorney for Plaintiff J:\Angela\Eviction\Cumberland\Ocwen.Reiley.7. l0.doc VERIFICATION ROBERT KALTENBACH is the Senior Manager Office of the Ombudsman of OCWEN LOAN SERVICING LLC successor to Ocwen Federal Bank and is authorized to sign this Verification on behalf of same, and states that he verifies the foregoing Civil Action-Eviction against Lorraine R . Re i 1 e and John Doe and avers the statements of fact therein contained are made subject to th enalties of 18 PA C.S. Section 4904 relating to the unsworn falsification to 't e ,and that same are true upon the signer's personal knowledge or informatio d b~li~e . R~BT~LTENBACH Senior M a~ r ice of the Ombudsman Date: July 6 , 2010 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201010266 Recorded On 4/23/2010 At 3:36:1 6 PM * Total Pages - 6 * Instrument Type -DEED-SHERIFF'S Invoice Number - 64409 User ID - RZ * Grantor - REILEY, LORRAINE R * Grantee - IiSBC BANK USA NA * Customer - COMBERLAND CO SHERIFF * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES - $13.50 RECORDER OF DEEDS This page is now part PARCEL CERTIFICATION $10.00 FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 WEST SHORE SCHOOL $0.00 DISTRICT NEW CUMBERLAND BOROUGH $0.00 TOTAL PAID $64.00 I Certify this to be recorded in Cumberland County PA 4 C~ CUrye ,~ F ,O ° RECORDER O nso * -Information denoted by an asterisk may change during the verification process and may not be reflected on this page. EXHIBIT uuuuiiiifliiiAiiiiuii Tax Parcel No. 25-24-0811-133 Know all Men by these Presents ~i~ib~p~~~~~~~~ That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $ 1.00 (One Dollar), to me in hand paid, do hereby grant and convey to HSBC Bank USA N.A. as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Loan Trust 2007-2 l;V. it No. 20C8-71; S Civil Term HSBC Bank USA N.A. as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Loan Trust 2007-2 by its Attorney in Fact, Ocwen Loan Servicing, LLC VS. Lorraine R. Reiley ALL THAT CERTAIN piece or parcel of land, situate in theBorough of New Cumberland, Cumberland County, Pennsylvania, bounded and described in accordance with a survey by D.P. Raffensperger Associates, dated June 4, 1971 as;.follows, to wit: BEGINNING on the Northeast corner of Smith Avenue and Geary Avenue thence along the Eastern side of Geary Avenue North 45 degrees 45 minutes West 70 feet to a point at the division line between Lots Nos. 28 and 29 on the hereinafter mentioned Plan of Lots; thence along said last mentioned division line North 44 degrees 15 minutes East 115.5 feet (Plan shows 116.5 feet) to a point at the division line between Lots Nos. 28 and 36 on said Plan; thence along said last mentioned line and along the division line between Lots Nos. 28 and 37, South 58 degrees 15 minutes (Plan shows 14 minutes) East 71.69 feet to a point on the Northern side of Smith Avenue; thence along the Northern side of Smith Avenue South 44 degrees 15 minutes West 131 feet to a point, the place of BEGINNING. BEING Lot No. 28 on Plan of Lots of Hillside Manor, which Plan is recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 11, page 21. Parcel No. 25-24-0811-133 HAVING thereon erected premises known and numbered as 505 Geary Avenue. UNDER AND SUBJECT to all conditions, restrictions, reservations, and limitations of record against this property. TITLE IS VESTED IN: Lorraine R. Reiley, single person, by that Deed, dated August 13, 1990, and recorded on August 24, 1990, in Book S-34, at Page 1055, of the Cumberland County Records. The same having been sold by me to the said grantee on the 3rd day of March, Anno Domini Two Thousand and Ten (2010) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 17th of August Anno Domini 2009 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Eight (2008) Number 7178 at the suit of HSBC Bank USA N.A. as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Loan Trust 2007-2 by its Attorney in Fact, Ocwen Loan Servicing, LLC -vs- Lorraine R. Reiley. In Witness Whereof, I have hereunto affixed my signature this Arno Domini Two Thousand and Ten (2010) Commonwealth of Pennsylvania, ss. County of Cumberland 5th day of March Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 5th day of March Anno Domini Two Thousand and Ten (2010) '' ~!'~ ':. m ~,- '~=,'r~ ..~~=~'- : ~ sue. y.~ ~' ~ ~' ~~~ r r ~ , `ems . !'. a ^- s j H «.. ~,~;;l,~fiy igg4`,1E Prothonotary M won' tIM F~1~1' or~dar ~.ron. xOtt I hereby certify that the residence And Post Office address of the Within Grantee is 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 . ,-~ ~i Solicitor SHERIFFrS OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~,~txt~? 4~ t'r~+r~bFr~~~ ' i~rf~~~ ,~.:_ ,.;.. QFfIGE4F T~.E SrtERIFF HSBC Bank USA, N.A. vs. Case Number Lorraine R Reiley 2010-4512 HERIFF'S RETURN OF SERVICE 07/14/2010 Shawn Harrison, Depu1 1720 hours, he served to wit: Mark Reiley, can known unto himself per Pennsylvania 17070 its copy of the same. Sheriff, who being duly sworn according to law, states that on July 14, 2010 at true copy of the within Complaint and Notice, upon the within named defendant, nt occupant of 505 Geary Avenue, New Cumberland, P 7070 by making orally, at 505 Geary Avenue, New Cumberlan ,Cum rla d County, ontents and at the same time handing to hi p rson Ily th said true-and correct 4-11 ~~: ,..~ ,~ +~ r" a~ ~ W _ `. -~ a ~. ZQ~~ ~'~~ ~ ~ ~it~ ~'~ ~~ ~~ i { ~i~+r ~1 a1 .~ r 07/14/2010 05:24 PM -Shawn Harr 2010 at 1720 hours, he defendant, to wit: Beth making known unto Ma County, Pennsylvania 1 correct copy of the sam 07/15/2010 Ronny R. Anderson, Sh and inquiry for the withi bailiwick. He therefore Lorraine R. Reiley. Mai at Manor Care Nursing SHERIFF COST: $80.30 July 15, 2010 WN HAF~1R'}6t~, DEPUTY in, Deputy Sheriff, who being duly sworn according to law, states that on July 14 :rued a true copy of the within Complaint and Notice, upon the within named ~gen, current occupant of 505 Geary Avenue, New Cu nand, PA 17070 by Reiley, adult in charge at 505 Geary Avenue, New Cu b nand, Cumberland 170 its contents and at the same time handing him r Wally the said true anc HARRISON, DEPUTY riff, who being duly sworn according to law, states that he made a diligent search named defendant to wit: Lorraine R. Reiley, but was unable to locate her in his turns the within Complaint in Ejectment as not found as to the defendant Reiley, defendant's son advised Deputies, Lorraine R. Reiley is current resident SO ANSWERS, RON R ANDERSON, SHERIFF {c) CountySuite Sheriff, Teleosoft. Inc. IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY HSBC Bank USA, N.A., as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Docket#: 2010-4512 CIVIL TERM Loan Trust 2007-2, c/o Ocwen Loan Servicing, LLC TEN DAY NOTICE (Plaintiff) V. Lorraine R Reiley and John Doe (Defendant(s)) A. B. ca ANSWER TO COMPLAINT C= N I signed a lease in February 2010 with my landlord, Mr. Reiley. My daughter and gran = moved in and then due to an abusive marriage I moved in and my youngest daughter around the end of May beginning of June. --? During this time, my rent has been paid on time each month, from March until present c?X xh, A? Beth C. Hagen (Occupant) 'fj Xue- '441 Residential Lease Clause 1. Identification of Landlord and Tenant This agreement is entered into between 8p-+ -{ ? ?}?tgeY1 [Tenant] and Each Tenant is jointly and severally liable for the payment of rent and p'erforrnance of all other terfris of this Agreement. Clause 2. Identification of Premises Sabject to the terms and conditions in this Agreement, Landlord rents to Tenant, and Tenant rents from Landlord, for residential purposes only, the premises located at Sd, G-e4,,l qL/-e, NFUJ C?? ' -? 7 d together with the following furnishings and appliances: / ??? t.U ?5?7 Pr ? GV 2 L? ? ? x:5? ?+.^ ?t Ll ?" y tO r ? -- Rental of the premises also includes Clause 3. Limits on Use and Occupancy The premises are to be used only as a private residence for Tenant(s) listed in Clause 1 of this Agreement, and their minor children. Occupancy by guests for more than prohibited without Landlord's written consent and will be considered a breach of this Agreement. Clause 4. Term of the Tenancy The rental will begin on A;or? 1 Z o 1 Q and end on Z6 i If Tenant vacates before the term ends, Tenant will be liable for the balance of the rent for the remainder of the term. Clause 5. Payment of Rent. is Regular month rent Tenant will pay to Landlord a monthly rent of S ?f GG. CC payable in advance on the first day of each month, except when that day falls on a weekend or legal holiday, in which case rent is due on the next business day. Rent will be paid in the following manner unless Landlord designates otherwise: Delivery of Payment. Rent will be paid: ?..f by mail, to Win person, at (g n dr X11, 5' Form of payment. Landlor will accept payment in these forms: ' 1 aoiz-TaP° ? cashier's check made payable to ? dit card money order EV cash LF310 Residential Lease 12.08 Pg. 1 Dnolo C?- www.nolo.com Prorated first month's rent. For the period from Tenant's move-in date. ?1-- through the end of the month, Tenant will pay to Landlord the prorated monthly rent of S i -? L- This amount will be paid on or before the date the Tenant moves in. Clause 6. Late Charges If Tenant fails to pay the rent in full before the end of the /jf day after it's due, Tenant will pay Landlord a late charge as follows: C, Landlord does not waive the right to insist on payment of the rent in full on the date it is due. Clause 7. Returned Check and Other Bank Charges if any check offered by Tenant to Landlord in payment of rent or any other amount due under this Agreement is r turned for lack of sufficient funds, a "stop payment," or any other reason, Tenant will pay Landlord a returned check charge of S Clause 8. Security Deposits On signing this Agreement, Tenant will pay to Landlord the sum of S. as a security deposit. Tenant may not, without Landlord's prior written consent, apply this security deposit to the last month's rent or to any other sum due under this Agreement. Within _ after Tenant has vacated the premises, returned keys, and provided Landlord with a forwarding address, Landlord will return the deposit in full or give Ten- ant an itemized written statement of the reasons for, and the dollar amount of, any of the security deposit retained by Landlord, along with a check for any deposit balance. Clause 9. Utilities Tenant will pay all utility charges, except for the following. which will be paid by Landlord: Clause 14. Assignment and Subletting Tenant will not sublet any part of the premises or assign this Agreement without the prior written consent of Landlord. Clause 11. Tenant's Maintenance Responsibilities Tenant will: (1) keep the premises clean, sanitary, and in good condition and, upon termination of the tenancy, return the premises to Landlord in a condition identical to that which existed when Tenant took occupancy, except for ordi- nary wear and tear; (2) immediately notify Landlord of any defects or dangerous conditions in and about the premises of which Tenant becomes aware; and (3) reimburse Landlord. on demand by Landlord, for the cost of any repairs to the premises damaged by Tenant or Tenant's guests or business invitees through misuse or neglect. Tenant has examined the premises, including appliances, fixtures. carpets, drapes, and paint, and has found them to be in good. safe, and clean condition and repair, except as noted in the Landlord-Tenant Checklist. Clause 12. Repairs and Alterations by Tenant a. Except as provided by law, or as authorized by the prior written consent of Landlord, Tenant will not make any repairs or alterations to the premises, including nailing holes in the walls or painting the rental unit. b. Tenant will not, without Landlord's prior written consent, alter, rekey, or install any locks to the premises or instal l or alter any burglar alarm system. Tenant will provide Landlord with a key or keys capable of unlock- ing all such rekeyed or new locks as well as instructions on how to disarm any altered or new burglar alarm- system. Clause 13. Violating Laws and Causing Disturbances Tenant is e titled to quiet enjoyment of the premises. Tenant and guests or invitees will not use the premises or adja- cent areas in such a way as to: (1) violate any law or ordinance, including laws prohibiting the use, possession, or sale of illegal drugs, (2) commit waste (severe property damage); or (3) create a nuisance by annoying, disturbing, incon- veniencing. or interfering with the quiet enjoyment and peace and quiet of any other tenant or nearby resident. Clause 14. Pets No animal, bird, or other pet will be kept on the premises, even temporarily, except properly trained service animals needed by blind, deaf, or disabled persons and under the following conditions: Clause 15. Landlord's Right to Access Landlord or Landlord's agents may enter the premises in the event of an emergency, to make repairs or improvements, or to show the premises to prospective buyers or tenants. Landlord may also enter the premises to conduct an annual inspection to check for safety or maintenance problems. Except in cases of emergency, Tenant's abandonment of the premises, court order, or where it is impractical to do so, Landlord shall give Tenant __ 2 1 OAI Is notice before entering. Clause 16. Extended Absences by Tenant Tenant will notify Landlord in advance if Tenant will be away from the premises for or more consecutive days. During such absence, Landlord may enter the premises at times reasonably necessary to maintain the property and inspect for needed repairs. Clause 17. Possession of the Premises Tenant 5, f iihtre to take possession. If, after signing this Agreement, Tenant fails to take possession of the premises, Tenant will still be respon- sible for paying rent and complying with all other terms of this Agreement. b. Landlordslailitre to deliverpossession. If Landlord is unable to deliver possession of the premises to Tenant for any reason not within Landlord's control, including. but not limited to, partial or complete destruction of the premises, Tenant will have the right to terminate this Agreement upon proper notice as required by law. In such event. Landlord's liability to Tenant will be limited to the return of all sums previously paid by Tenant to Landlord. Clause 0. Tenant Rules and Regulations Tenant acknowledges receipt of, and has read a copy of, tenant rules and regulations, which are attached to and incorporated into this Agreement by this reference. Clause 19. Payment of Court Costs and Attorney Fees in a Lawsuit In y action or legal proceeding to enforce any part of this Agreement, the prevailing party shall not / ? shall recover reasonable attorney fees and court costs. Clause 20, Disclosures Tenant a nowledges that Landlord has made the following disclosures regarding the premises: Disclosure of lnfonnation on Lead-Based Paint and/or Lead-Based Paint Hazards ? Other disclosures: Clause 21. Authority to Receive Legal Papers The Landlord, any person managing the premises, and anyone designated by the Landlord are authorized to accept service of process and receive other notices and demands, which may be delivered to: LF310 Residential Lease 12-08 Pg. 2 The Landlord, at the following address: 5? ? The manager, at the following address: ? The following person, at the following address: ;d' ?/?' LL ?' L?Y• ?,4- l,,4 //? /,7c,7,1 Clause 22, Additional Provisions Additional provisions are as follows: Clause 23. Validity of Each Part If any portion of this Agreement is held to be invalid, its invalidity will not affect the validity or enforceability of any other provision of this Agreement. Clause 24. Grounds for Termination of Tenancy The failure of Tenant or Tenant's guests or invitees to comply with any term of this Agreement, or the misrepresenta- tion of any material fact on Tenant's rental application, is grounds for termination of the tenancy, with appropriate notice to Tenant and procedures as required by law. Clause 25. Entire Agreement This document constitutes the entire Agreement between the parties, and no promises or representations, other than those contained here and those implied by law, have been made by Landlord or Tenant. Any modifications to this Agreement must be in writing signed by Landlord and Tenant. fl Z-0141 Date Coq r S C-5 Address Landlord or dlord's Anent Title 1 76 7C City ??` State Zip Code Phone Date T nt Phone Date Tenant Phone Date Tenant Phone SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ~ ~~~ Sheriff ~~;~ ~; ~' ~ ~,t,r, ~' T}-f ~~ ~,:,~r,~- Jody SSmith %Y~;t~ -~'~ '•~Y chief Deputy J ,5~~ - 3 p~ t ~ 2 Richard W Stewart CUM6~1 Solicitor - ~- 7..r-~ ~ ~ { 'r~V~, F'EI \(r~1~'F'1.~r`~(~1 ~ HSBC Bank USA, N.A. Case Number vs. Mark Reiley (et al.) 2010-4512 SHERIFF'S RETURN OF SERVICE 09/02/2010 01:50 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1350 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Beth Hagen, by making known unto Bevin Reiley, Adult in Charge, at 505 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/02/2010 01:50 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1350 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Mark Reiley, by making known unto Bevin Reiley, Adult in Charge, at 505 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $55.74 September 03, 2010 SO ANSWERS, ~._ RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy FILE-OFFICE OF THE RRC € HONOTARY Richard W Stewart Solicitor ?s E F 2010 SEP 21 PM 4: 06 CUMBERLAND COUNT' PE!N,*4SYLVA NNA HSBC Bank USA, N.A. vs. Case Number Mark Reiley (et al.) 2010-4512 SHERIFF'S RETURN OF SERVICE 09102/2010 01:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1350 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Beth Hagen, by making known unto Bevin Reiley, Adult in Charge, at 505 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/02/2010 01:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1350 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Mark Reiley, by making known unto Bevin Reiley, Adult in Charge, at 505 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/20/2010 By virtue of this writ, on the 20th day of September, 2010, Sheriff Ronny R. Anderson caused the within named HSBC BANK USA, N.A., as Indenture Trustee for the registered Noteholders of RENAISSANCE HOME EQUITY LOAN TRUST 2007-2, c/o OCWEN LOAN SERVICING, LLC, to have possession of the premises described as 505 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. SHERIFF COST: $103.51 September 21, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF B Sharon R. antz 7f%? (C) COLOTYSLAO Sherff, teieosoit. Inc,