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HomeMy WebLinkAbout10-62479 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 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF Cl) c°- f y 1:>c rJ ?g '.o C-) --t 4 CJ ?o HSBC Mortgage Services, Inc. 'COURT OF COMMON PLEAS 636 Grand Regency Blvd. :CIVIL DIVISION Brandon, FL 33510 Plaintiff :Cumberland County V. Donna Crockett 11 South High Street NO. io - 607 ??v?ITerwr Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue s Carlisle, PA 17013 -+aol.op PA ATTY 717-249-3166 `?Oo2?1g 800-990-9108 C e " aVs9?4 AVISO Le han demandado a usted en la cbrte. 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 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 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 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: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: HSBC Mortgage Services, Inc. Recording Date: 10/21/08 Instrument # 200834597 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: 11 South High Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Mechanicsburg COUNTY: Cumberland DATE EXECUTED: 11/20/06 DATE RECORDED: 12/04/06 BOOK: 1975 PAGE: 386 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 8/18/10: Principal of debt due $124,192.66 Unpaid Interest at 9.5t from 3/1/10 to 8/18/10 (the per diem interest accruing on this debt is $32.32 and that sum should be added each day after 8/18/10) 5,526.72 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Corporate Advance 150.00 Previous Attorney Fees 4,545.50 Corporate Advance (Hazard Insurance) 1,286.00 Corporate Advance (Taxes) 418.45 Attorneys Fees (anticipated and actual to 5% of principal) 6,209.63 TOTAL $142,933.96 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 $142,933.96 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDRE NLAW OFFICES, P.C. BY: A-- -S-? Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE DANIEL SIEDMAN, ESQUIRE koloo 0 %wo 70-01889423 80818 ALL TEAT CMM= LOT Or OWM S1MATB 06 MM BAST SIM Of HZON STI09mr, in THE BORO80R Or mzMM=CSSORG, IN THE COMM OF cwdszRzam AND STATE OF RRNNBZLVA=, noun= AHD DESCRIBED AS IoLIAM, TO V=z BSGXMXHO AT A POINT ON TM BOZLDIRG LINE Or M= SODTR BZOR STREET AXD AT THE WORTMISS L2B8 OF STOMV= ALLEZI TIQCNCE =A RELY DIRECTION ALONG THE ROZLDAiO LIRE or SAID SOEITH RZGR .STREET IGORZERR AND ORE-TENTR (14.1) PHET TO AN %RON Pill AT COSBBR OF OMM LOT OF TB6 GRAMM or WRZCR TRIS IS A PART, 2SOMM IN AN B882IDIRDLY DZRX=Q f ALONG BUD TAT Or TRS ORANTOR 1122M AND 111 11 r I THE CERSM LIRE Or A WM= PUM DUI.UM B08SE 8RECTSD OR THE TAT Or OEOOHD BBRERZ Co(VBYBD A11D ON Tu LOT Or G9OORO I1D3ACERT Tumor on T8E wm=, mm BEYOND, Fn-tr-TAUM AND SIX-MKM (83.6) 1 - zo AR IRON PIN ow Tu LIIw. or CRPJ= E. Dxmw an %12=nm U. DIIDiBR, RIS 111m P TBEBCE m A somvm= bri=m ALONG THE LIRE or Los or sAm Cwmm Z. DIBNER AND vIRGIHSS K. Draw, RZS NZrffi, 1*=M 8H AND "lo-TEH= (14.2) FEET TO AN IRON PIR OR MM MMUMM LIRE Or SLID 89f0Or5IDl ALLEY VIPTY-THO (32) MW TO A POINT ON THE BBMXM LINE Or SAID swzH HIGH Sm1' AM AT mm PLACE Or 3E6IRNING. BAVIRC ERECTED vomm TEE SOOTEEIOi RALr or A Do8BL8 rRAm DiRO,LZN6 s00SE, Imm As IRO. 11 SOOTS RICH STREET, "WMIOICSSOR&, PBlntmvANIA. SRI= THE sum PROPBATY am== TO Dom ORomsIT, six" AMMT MWIV"m BY DEED "m RIORRRD T. STAN AND BLZZABRTR SEMI, SOSBAND MID 1IZPE RECORDED 03/09/2006 ZK DERD BOOR 273 YAGE 2438, IN TEE Off= OF THE RECORDER Or DEEDS OF COHBERLAIID COOBYY, PAHISZLVAHZA. TAE ZDR 16-23-OM-019 August 24, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE the attached na es. this Notice with you when you meet with the Counseling A ecU 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMARRIBA. A LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Donna_C_rockett_ __ 11 South High Street --i------- Mechanicsbu? M PAPA 17055 0016060451 ----- -- _Calusa Investments LLC HSBC Mortgage Services Inc 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 A stay of foreclosure on your mortgage for ?' you are ???? to a temporary (3) days for mailin thirty (30) days from the date of this Notice (plus three g). 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 TMRTV-TUDTv -11 r ..,n 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 desi ed consumer credit counsehn a encies for the coon in which the ro 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.) 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 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.) HOW TO CURE YOUR MORTGAGE DEFAULT Brin it u to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 11 South High Street Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Mont141Payments of $1076.30 for April 1, 2010 throuLh August 1, 2010 = $5381.50 Mont Late Charges of $0 for April 1. 2010 throah Asst 1L2010_ =so - Other charges (explainlitemize): Previous Attorney Fee=$1545.50 Property Inspection=$50.00 BPO-$100.00 TOTAL AMOUNT PAST DUE:_ __-W X10077.00 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): N/A 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 $10077.00 PLUS ANY MORTGAGE PAYMENTS AND LATE 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- Udren Law Offices. P.C. Woodcrest Corporate Center 111 Woodcrest Road. Suite 200 Cherry Hill. NJ 08003-3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable ): N/A 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 ].ender 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 nay 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 Sheriff's 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 anv other costs connected with the Sbenff's 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 Sheriffs Sale of the mortgaged property could be held would be approximately 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 lender. HOW TO CONTACT THE LENDER: Name of Lender/Servicer: Address: Phone Number: Fag Number: Contact Person: E-Mail Address: HSBC _Mortgage Services 636 Grand Regency Bvld Brandon, FL 33510 1-800-365-6730 1-813-571-8917 Loss Mitigation Department _ EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's 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 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. 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 as 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 YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • 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 Cumberland County HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10/16/200T 10:03:08 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Unglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 >rity Mail. Aafl. For Proof of a Retum :over the vaiver for weipt is )ssee or with the the arH- fied Mai? guiry. i i ca 0 Iv ..A N f?- m ni O 0 C3 C3 E IT Z rU o 0 0 t` 19 N Z' 2 m !i 7- W M to a ci p°??"f ° ° CR +i J CV : 0 LL a. W -0 a z .ra'sey s-. Q i M ru ..a O C! .,? co ru '-J Ir 0 m r vz uio?n 1L 0a w? S boo g ? 00 ?w?ui QU?U ?O C/ V ?o 0 V 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 -,-Z LL-- s---69 - Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE DANIEL S. SIEDMAN, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~ ~~,;~.~ t`trs C J~~. ~y~+atr, of ~rtrt+Grr/'rr4~d ~~#~ }ma.""~ I''Q~~~~~1~t Jody S Smith Chief Deputy ~~~ " ~~. L01i1 ~~~~ "~ ~~ ~~~ ~ ~ Richard WStewart -"- t, ~ ('{ ~~{ SoilC(tor t~~F Ct F 7hE S"ERIFF Ste't {A„' ~"`; ~• ~~ , ~'`~ l/ V ~.91~ f MoI ~E~~ 9iJr 4\.~h4rtr _4ti .. i . HSBC Mortgage Services, Inc. vs. Donna Crockett Case Number 2010-6247 SHERIFF'S RETURN OF SERVICE 10/01/2010 08:09 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 1, 2010 at 2009 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donna Crockett, by making known unto herself personally, at 11 S. High Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 05, 2010 i DENNIS RY, DEPUTY SO ANSWERS, ~~ RON ~~ R ANDERSON, SHERIFF (cj CouniySuito Shenft, Telecsoft, Inc. UDREN,LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARPC J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. =COURT OF COMMON PLEAS 636 Grand Regency Blvd. :CIVIL DIVISION Brandon, FL 33510 :Cumberland County Plaintiff :MORTGAGE FORECLOSURE v. a Donna Crockett €NO. 10-6247 11 South High Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: ..+,= ~ -~ :~- -~ ---a ~, ±'~n. ` .,,.,J :~ Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Donna Crockett for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $142,933.96 Interest Per Complaint 2,456.32 From 08/19/2010 to 11/02/2010 TOTAL $145,390.28 I hereby certify that (1) the addres f e Plaintiff and Defendant are as shown above, and (2) tha o as been g ven in accordance with Rule 237.1, a copy of whic s ac ed hereto. UDREN ~A~T~1~'FIC~S , P . C . BY: Attd~y f r Plaintiff K J. N, ESQUIRE UART WI G, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE • ~1~.op Pp p~1 DAMAGES ARE HEREBY ASSESSED AS INDICATE (-'~'I~ONo2!'S DATE: /!~~?~!D ~~~7 . ~' PRO I~lo~Ce~ ~bu~P UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M.. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. RAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL 3. SIEDMAN, ESQUIRE - ID #306534 WOODCREST CORPQRATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinggWvdres~. com HSBC Mortgage. Services, Inc. :COURT OF COMMON PLEAS 636 Grand Regency Blvd. :CIVIL DIVISION Brandon, FL 33510 Plaintiff € Cumberland County v Donna Crockett 11 South High Street = NO. l0 - (,oat~~ Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE ~ na ~ ~ ,.~ ~ ~-i o~ _ c, ~ -1 - 'n ~'~. r""~ ~; ~ r-.. ~ ~~ { ~ ~° ~ ?,-n ~~ ~ ~~, o ~.~ r _~~ ~~ ~'~ v~ t Tex'ri 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 SHOIILU TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOII DO NOT SAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. ISIS OFFICE CAN PROVIDE YOU WITS INFORMATION ABOUT HIRING A LAWYER. IF YOII CANNOT AFFORD TO SIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TEAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDIICED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar'Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ~o~ ~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~,~~,s~s~' ~ ~~~~rf~~d .:';~w HSBC Mortgage Services, Inc, vs. Donna Crockett Case Number 2010-6247 SHERIFF'S RETURN OF SERVICE 10/01/2010 08:09 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to iaw, states that on October 1, 2010 at 2009 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donna Crockett, by making known unto herself personalty, at 11 S. High Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. J DENNIS RY, DEPUTY SHERIFF COST: $37.00 SO ANSWERS, October 05, 2010 RON R ANDERSON, SHERIFF {c~ Coim:y5uts Sherrff. ~e3eosxt, irr_. [/"'~~ D7~ ~ ~ C~~ ) .L~ V V ~ fNf~'~[~ t.~~J UDREN LAW OFFICES, P.C. MARK J. UDRSN, ESQUIRE - ID #04302 STt3'ART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #345?6 ALAN M. MTNATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 ADAM L. RAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID'#204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003 856-659-5400 u~nennn~~~_7 HSBC Mortgage Services Inc. ~Plainti~f v. Donna Crockett Defendant(s) TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Date of Notice: October 22,, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-6247 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BX ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR. DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAX LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCfE5 THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR 2J0 FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 7i7-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION UNQTIERMIDNODDESDIE~ (~~Q~DIASEDECESTA NOTIFICACIOId~ELCTR~BUNALIPODRA SONDE NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER 732ENES Y OTROS DERECHOS~, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMSDIATAMENTE SI USTED NO TIENE ABOGADO 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 8.00-990-9108 NOTICE: PURSUANT TO TSE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM I5 DEEMED TO BEs A DEBT COLLECTOR AND IBIS IS AN ATTEMPT TO COLLECT A REST. ANY INFORMATION OBTAINED WILL BE USSR FOR THAT PURPOSE. STUART WINNEG, ESt~Ullt~ LORRAINE DOYLE, ESQUIRE ALAN M. MINATO ES UIRE CHANDRA M. ARKENfA~SQ QRUEIRE ADAM L. KAYES, MARGUERITE L. TIiOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest road, Suite 200 Cherry Hill, New Jersey 08003-3620 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 CHANDRA M. AR.KEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 WOODCREST CORPORATE'CENTER 111 SnTOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-482-b900 HSBC Mortgage Services, Inc. 636 Grand Regency Blvd. Brandon, FL 33510 Plaintiff v. Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Defendant (s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE N0. AFFIDAVIT OF NON-MILITARY SERVICE STATE OF SS COUNTY OF THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Donna Crockett Age: Over 18 Residence: As captioned above Employment: Unknown ame : U r t a ~Lo4/- e Title: pp Sworn to and subscribed Company: xSBC Mortgage Services, Inc bef this., day o 20 ~~ jai P '~ota~y Pub~'C Efate of ~io~id~ ary 1 ~° ~ saran ~ `l~*b3daes ;v ~'=orn~,ssion ~~1~'G59?2 ~~'OVad~'~ ~-xl.Y~3~ ta3iU612!~?~ UI~REN 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 #75$60 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE Donna Crockett Defendant (s ) TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 NO. 10-6247 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION v. :Cumberland County :MORTGAGE FORECLOSURE ^ Donna Crockett ?NO. 10-6247 Defendant (s ) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due Interest From 11/03/2010 to Date of Sale March 2, 2011 Ongoing Per Diem of 32.32 to actual date of sale including if held at a later date (Costs to be added) O ~ a~(.oo pa p-rry ~'1. oo cam' 9a.oo 1.00 a.50 ~ ~ ~Q.50 ' PD A'rTy '~ off. 00 ,~)p 4p S0 LL c~ u~ta~~ r~* a5o~97 RE ~ ~=~ -„ ~~ ~~ ~ ; ..~~~w ~ .~.;,~, ~~ ., ;.s; ~k ~a °~~~ ~: $145,390.28 3,878.40 sale is UDR N OF CES, P.C. BY: Att ey for Plaintiff K REN, ESQUIRE UAR INNEG, ESQUIRE ORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION v. €Cumberland County :MORTGAGE FORECLOSURE Donna Crockett €NO. 10-6247 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: ~:" a 4 ~s _~~ r „y-:°~; ~~~a ~_ w ~., .-.~ ~.. ~.~ .~- ~~ F_rs ,..,:~ I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: X A. An individual B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: OFFICES, P.C. OYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE BY: Att- e for Plaintiff K UDREN, ESQUIRE UART WINNEG, ESQUIRE ORRAINE D .myr ~i ~~ -~; ~m,:~ `' _-_~ C~ ~r~°t :; UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. €COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION v. :Cumberland County :MORTGAGE FORECLOSURE Donna Crockett €NO. 10-6247 Defendant (s) C E R T I F I C A T E ~~ -= ~ _,~ A,~ ~ ~ ~ __., ~~ i ~ . _ . ~ J ~ fem. ~'' ~ ~ -a ~: {~, : ~ ~ ... ~ , . f ~::~ ~ ~a I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn fals~tion to authorities. P.C. BY: At tf~#ey/s for ~i~t-~.~"f K J. UDREN, ESQUIRE UART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE sP" " UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION v. :Cumberland County :MORTGAGE FORECLOSURE Donna Crockett €NO. 10-6247 Defendant (s) .-.,, , ~, =^.°f ~ } s°,,r} 4P' ~ °"'? =; c_a ~;~ ~~ ~:;:~ _- AFFIDAVIT PURSUANT TO RULE 3129.1 HSBC Mortgage Services, Inc., Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 11 South High Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Donna Crockett 11 South High Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address HSBC Mortgage Services, Inc. 636 Grand Regency Blvd. Brandon, FL 33510 rr• '• 5. Name and address of every other person who has any record lien on the property: Name Address Borough of Mechanicsburg W. Strawberry @ North Market St. Mechanicsburg, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq.,Carlisle, PA 17013 13 N. Hanover St.,Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 11 South High Street Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. ~7 _ DATED : November, 20(10 ~~ > ~. CES, P.C. BY: Att~ot e s ~Qr ~~ntiff K UDREN, ESQUIRE DART INNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ~,,` UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION v. €Cumberland County :MORTGAGE FORECLOSURE Donna Crockett €NO. 10-6247 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Your house (real estate) at 11 South High Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $145,390.28, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate actioa: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) "~'~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARS THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SSRVIC$ Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ., r UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsGudren.com FOR PLAINTIFF HSBC Mortgage Services, Inc. 2COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION v. :Cumberland County 'MORTGAGE FORECLOSURE Donna Crockett €N0. 10-6247 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 ,,. ~ 7• '7 ....~ 5 ..,. ~> C~~ ~~° ~ S; ~ -~ I"~ i c~ Y, ~ v'>~ ~ ~'~ .~ ~== N ~ ~ ~ ; ~;? .. ~ ~ - r~ " Your house (real estate) at 11 South High Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $145,390.28, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER ' RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside 'the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OIIT WHERE YOII CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT IS CERTAIN LOT OF GROUND SITUATE ON THE EAST SIDE OF SOUTH HIGH STREET, IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE BUILDING LINE OF SAID SOUTH HIGH STREET AND AT THE NORTHERN LINE OF STOUFFER ALLEY; THENCE IN A NORTHWARDLY DIRECTION ALONG THE BUILDING LINE OF SAID SOUTH HIGH STREET FOURTEEN AND ONE-TENTH(14.1)FEET TO AN IRON PIN AT CORNER OF OTHER LOT OF THE GRANTOR HEREIN, OF WHICH THIS IS A PART; THENCE IN AN EASTWARDLY DIRECTION ALONG SAID LOT OF THE GRANTOR HEREIN AND THROUGH THE CENTER LINE OF A DOUBLE FRAME DWELLING HOUSE ERECTED ON THE LOT OF GROUND HEREBY CONVEYED AND ON THE LOT OF GROUND ADJACENT THERETO ON THE NORTH, AND BEYOND, FIFTY-THREE AND SIX- TENTHS(53.6)FEET TO AN IRON PIN ON THE LINE OF CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE; THENCE IN A SOUTHWARDLY DIRECTION ALONG THE LINE OF LOT OF SAID CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE, FOURTEEN AND TWO-TENTHS(14.2)FEET TO AN IRON PIN ON THE NORTHERN LINE OF SAID STOUFFER ALLEY FIFTY-TWO(52)FEET TO A POINT ON THE BUILDING LINE OF SAID SOUTH HIGH STREET AND AT A PLACE OF BEGINNING. HAVING ERECTED THEREON THE SOUTHERN HALF OF A DOUBLE FRAME DWELLING HOUSE, KNOWN AS NO.11 SOUTH HIGH STREET, MECHANICSBURG, PENNSYLVANIA. BEING THE SAME PROPERTY CONVEYED TO DONNA CROCKETT, A SINGLE ADULT INDIVIDUAL BY DEED FROM RICHARD T. BEAM AND ELIZABETH BEAM, HUSBAND AND WIFE RECORDED 03/09/2006 IN DEED BOOK 273 PAGE 2458, IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA. TAX ID# 16-23-0567-015 BEING KNOWN AS: 11 South High Street Mechanicsburg, PA 17055 PROPERTY ID NO.: 16-23-0567-015 TITLE TO SAID PREMISES IS VESTED IN DONNA CROCKETT, SINGLE ADULT INDIVIDUAL BY DEED FROM RICHARD T. BEAM AND ELIZABETH BEAM, HUSBAND AND WIFE DATED 02/28/2006 RECORDED 03/09/2006 IN DEED BOOK 273 PAGE 2458. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6247 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC MORTGAGE SERVICES, INC., Plaintiff (s) From DONNA CROCKETT (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $145,390.28 L.L.$.50 Interest from 1113/10 to 3/2/11 ongoing per diem of $32.32 to actual date of sale including if sale is held at a later date -- $3,878.40 Atty's Comm Atty Paid $169.50 Plaintiff Paid Date: 11 /2/10 (Seal) ' Due Prothy $2.00 Other Costs David D. Buell, rothonotary By: Deputy REQUESTING PARTY: Name: STUART WINNEG, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 45362 UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION €Cumberland County v. Donna Crockett Defendant(s) =NO. 10-6247 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: ,`m.h " `f~ ~W . f ~..,~ ~ '"~7 -~ ~ t~~ ` ~~ °_-,t ~ " e r~ ~ a ~.. - ~~ ,-~~ ,,,,, r ....,,,{ Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: November ~, 2010 vvv ~~~_ 1 BY: P.C. Attr~rf~3s~y~ 1Ea~~laintiff K J. REN, ESQUIRE UART WINNEG, ESQUIRE ORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE V E R I F I C A T I O N The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the. servicing agent of Plaintiff, and being authorized to make this verification on behalf of the Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date : ~~ ~j C~ Name : ~~ ~ ~ U ,ale Title: 1" Company: HSBC Mortgage Services, Inc. Donna Crockett MJU #08090223-2 {Cumberland County, Pennsylvania) C ATTORNEY FOR PLAINTIFF WREN LAW OFFICES, P. . WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 _ -t HSBC Mortgage Services, Inc. =COURT OF COMMON PL- "*z p 636 Grand Regency Blvd. =CIVIL DIVISION Brandon, FL 33510 :Cumberland County tN Plaintiff •Cd "v p-r V. =C7 p' CD Donna Crockett `-i :X 11 South High Street ENO. 10-6247 Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 2,/)W/) UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff CkJ"ft M. Arkom, Esqulm M ID 203437 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 HSBC Mortgage Services, Inc. Plaintiff V. Donna Crockett Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-6247 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Donna Crockett PROPERTY: 11 South High Street, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 2. 2011, at 10:00am, at the Commissioners Hearing Room, 2nd floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. IT Pk 0 O O n CD MO W O CD 0 N N w N n c 0- CD M 7 Q .I cn O 3 w co V CD tS sv co (O 0 3 3 c w n 0 <D CL cy ?c 0 7 M 0 CD 7 r .? CO OD -4 M CT A W N D pZj yo W N O CD (n(1 a? j@CD vc ZD a(con nt CD m 36 C m AD 0.0 mv D J rn Wo s? oo Ww= Kim M OmO ? Onm0 0 0)W COD ?c m°c?-' Zm c = ?? aG?n ?o D of o mm o D =?? mC v =r M•? c ?•3z Nc0 a z rnoZ a? 0 5 °c ? ?O -n0-0 & 2(n _ oomZ ?? T? ° n Cn D c"= co O -oi oom y ? ?m? CD ;o y m c(i)m ?? Om O ?n Do Cy m 3=-? v ton r 0m CD --j (1) DZm O? D? D 4?D2 _ 0-n on t_ M m m j= wcn -4 z 1 0) c0 z v -1 coyer n o m O m -? ??O-n a 0 'D v (n -0 (n Z 9-CD C < Ul N w T? v p BCC O -1 _ C CD 0> O w w :3 o 0 o M. 3 ?mN CD m ?C) - m N ..W am o K ::4 -0 :1 _0 cnc CD _00 m °o ?- -i D m DZD CD n m -4 -4 CDZ0 a w w CDm y ? ? ?? W z a o C CD -t @ y 0 n C1 N CD T N G. m ??9? o / 0161-126519216 X 5 ? ? ° ?=c M L. M $02.520 N 0 CL= ± 4 N O N Zl ? O N to 1 2 11 v. W O CD CL ? ?. r0ailed From 08003 US POSTAGE 0M 2 30y° ID =r 23 ° °2: tD7 ??X0 °.m3=? fOa CCflI _. $ ?.O p 7 S R 01 C -0 (D -0 5? VONA "`N n ? N ? m 3m o y c N a. •-v+m va - to N NyNo°c+nm N N C CJ O 3=°OM ° R °o c n n 01oo?3d ?a? tD o = N Nm?m S n vy?• yn c c CD Ec3 N cia^ m -.nw c[?1mn d {j M. CL C7M y G.?X ?ay3w° O 00 a x E63 m05RaO? CAD d C)0? voo° 4 v.3C=D 2 2-i °o3iodN?3m w Dy ? cd -?m T?J N- O 0 v... O5? ,? N o i ?p CD .U ?_'CO y O? y 0 d T _? O' y 5F°1mm'3 m N 8.= =. ? CD ? n 0 w d Si m D ° N n» > N LOW 62L' E53 A 3@j C.- . 5c nTg??3 dd3?yn 3 ?C°6^m yl N°og? inn N °a r J 7Z• v U. y m P x,,..41 @ Y to 'n 11, > > jSLY i N p0 f iiM N SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor HSBC Mortgage Services, Inc. vs. Donna Crockett Case Number 2010-6247 SHERIFF'S RETURN OF SERVICE 12/30/2010 06:05 PM - Deputy Robert Bitner, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 11 South High Street, Mechanicsburg, PA 17055, Cumberland County. 12/30/2010 06:05 PM - Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Donna Crockett at 11 South High Street, Mechanicsburg, PA 17055, Cumberland County. SHERIFF COST: $898.94 SO ANSWERS, February 09, 2011 RON R ANDERSON, SHERIFF EXH e! E t' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 'ILED Sheriff I T, - -OFFICE % p PRCTHO 0-,p Jody S Smith ?'1 ?? f? Chief Deputy : IS Richard w Stewart Solicitor CUMBERLAND COUNTY - ` PENNSYLVANIA HSBC Mortgage Services, Inc. Case Number vs. Donna Crockett 2010-6247 SHERIFF'S RETURN OF SERVICE 12/30/2010 06:05 PM - Deputy Robert Bitner, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 11 South High Street, Mechanicsburg, PA 17055, Cumberland County. 12/30/2010 06:05 PM - Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Donna Crockett at 11 South High Street, Mechanicsburg, PA 17055, Cumberland County. 03/02/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, PA, on March 2, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Stuart Winneg, on behalf of HSBC Mortgage Services, Inc, 636 Grand Regency Blvd, Brandon, FL 33510 being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $951.68 March 31, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF I/ ? . 00 1w, 04 < ©D ed - SLR ?--?Pd a 5"7 yo 7 c; of?i ,Suit Sheen i86 osctt 6 UDREN LAW OFFICES, P.C. - . ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART'WINNEG, ESQUIRE - ID #45362 LORRAINE nOYLE, ESQUIRE - ID #34576 ALAN M. MINAT-O, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff ;CIVIL DIVISION V. :Cumberland County ;MORTGAGE FORECLOSURE Donna Crockett :NO. 10-6247 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 HSBC Mortgage Services, Inc., Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 11 South High Street, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Donna Crockett 11 South High Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address HSBC Mortgage Services, Inc. 636 Grand Regency Blvd. Brandon, FL 33510 .. 5.,-Name,and address of every other person who has any record lien on the property: Name Address Borough.of Mechanicsburg W. Strawberry @ North Market St. Mechanicsburg, PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq.,Carlisle, PA 17013 13 N. Hanover St.,Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 11 South High Street Mechanicsburg, PA 17055 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: November( 2010 F,ICES, P.C. BY:, ` At tbf e sBye[int i f f K UDREN, ESQUIRE UART INNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M.'MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsCudren.com HSBC Mortgage Services, Inc. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Donna Crockett :NO. 10-6247 Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Donna Crockett 11 South High Street Mechanicsburg, PA 17055 Your house (real estate) at 11 South High Street, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $145,390.28, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. , If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside'the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT IS CERTAIN LOT OF GROUND SITUATE ON THE EAST SIDE OF SOUTH HIGH STREET, IN THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS,,TO WIT: BEGINNING AT A POINT ON THE BUILDING LINE OF SAID SOUTH HIGH STREET AND AT THE NORTHERN LINE OF STOUFFER ALLEY; THENCE IN A NORTHWARDLY DIRECTION ALONG THE BUILDING LINE OF SAID SOUTH HIGH STREET FOURTEEN AND ONE-TENTH(14.1) FEET TO AN IRON PIN AT CORNER OF OTHER LOT OF THE GRANTOR HEREIN, OF WHICH THIS IS A PART; THENCE IN AN EASTWARDLY DIRECTION ALONG SAID LOT OF THE GRANTOR HEREIN AND THROUGH THE CENTER LINE OF A DOUBLE FRAME DWELLING HOUSE ERECTED ON THE LOT OF GROUND HEREBY CONVEYED AND ON THE LOT OF GROUND ADJACENT THERETO ON THE NORTH, AND BEYOND, FIFTY-THREE AND SIX- TENTHS (53.6) FEET TO AN IRON PIN ON THE LINE OF CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE; THENCE IN A SOUTHWARDLY DIRECTION ALONG THE LINE OF LOT OF SAID CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE, FOURTEEN AND TWO-TENTHS(14.2) FEET TO AN IRON PIN ON THE NORTHERN LINE OF SAID STOUFFER ALLEY FIFTY-TWO(52)FEET TO A POINT ON THE BUILDING LINE OF SAID SOUTH HIGH STREET AND AT A PLACE OF BEGINNING. HAVING ERECTED THEREON THE SOUTHERN HALF OF A DOUBLE FRAME DWELLING HOUSE, KNOWN AS NO.11 SOUTH HIGH STREET, MECHANICSBURG, PENNSYLVANIA. BEING THE SAME PROPERTY CONVEYED TO DONNA CROCKETT, A SINGLE ADULT INDIVIDUAL BY DEED FROM RICHARD T. BEAM AND ELIZABETH BEAM, HUSBAND AND WIFE RECORDED 03/09/2006 IN DEED BOOK 273 PAGE 2458, IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA. TAX ID# 16-23-0567-015 BEING KNOWN AS: 11 South High Street Mechanicsburg, PA 17055 PROPERTY ID NO.: 16-23-0567-015 TITLE TO SAID PREMISES IS VESTED IN DONNA CROCKETT, SINGLE ADULT INDIVIDUAL BY DEED FROM RICHARD T. BEAM AND ELIZABETH BEAM, HUSBAND AND WIFE DATED 02/28/2006 RECORDED 03/09/2006 IN DEED BOOK 273 PAGE 2458. I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6247 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC MORTGAGE SERVICES, INC., Plaintiff (s) From DONNA CROCKETT (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $145,390.28 L.L.S.50 Interest from 11/3/10 to 3/2/11 ongoing per diem of $32.32 to actual date of sale including if sale is held at a later date -- $3,878.40 Atty's Comm % Atty Paid $169.50 Plaintiff Paid Date: 11/2/10 (Seal) REQUESTING PARTY: Name: STUART WINNEG, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 45362 Due Prothy $2.00 Other Costs David D. Buell, Pr thonotary By: Deputy TRUE CO" FROM RECORD I and" ? C "k at C01W f f?nd K. ply Protlr On November 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 11 South High Street Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 22, 2010 By: Real Estate Coordinator lniui't lwaa sTir?tf : _+t9 t ,' ar+tyrtvr?iisT fd 10 VIb -, NAT rs?;Wnrr?rikrt'i PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 28, February 4, and February 11, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Li Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this ,11 da of Februar 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-6247 Civil band and wife recorded 03/09/2006 in Deed Book 273 Page 2458, in the HSBC Mortgage Services, Inc. Office of the Recorder of Deeds of VS. Cumberland County, Pennsylvania. Donna Crockett TAX ID# 16-23-0567-015. Atty.: Stuart Winneg ALL THAT IS CERTAIN lot of ground situate on the east side of South High Street, in the Borough of Mechanicsburg, in the County of Cumberland and State of Pennsyl- vania, bounded and described as follows, to wit: BEGINNING at a point on the building line of said South High Street and at the northern line of Stouffer Alley; thence in a northward- ly direction along the building line of said South High Street fourteen and one-tenth (14.1) feet to an iron pin at comer of other lot of the grantor herein, of which this is a part; thence in an eastwardly direction along said lot of the grantor herein and through the center line of a double frame dwelling house erected on the lot of ground hereby conveyed and on the lot of ground adjacent thereto on the north, and beyond, fifty-three and six-tenths(53.6) feet to an iron pin on the line of Charles E. Diener and Virginia M. Diener, his wife; thence in a southwardly direction along the line of lot of said Charles E. Diener and Virginia M. Diener, his wife, fourteen and two-tenth s(14.2) feet to an iron pin on the northern line of said Stouffer Alley fifty-two(52) feet to a point on the building line of said south high street and at a place of BEGINNING. HAVING erected thereon the southern half of a double frame dwelling house, known as No 11 South High Street, Mechanicsburg, Pennsylvania. BEING the same property con- veyed to Donna Crockett, a single adult individual by deed from Richard T. Beam and Elizabeth Beam, hus- 11 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechaniicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 i4tPatriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid- that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since,- That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true. and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 1/28/11 2/4/11 1 2/11/11 ( r o ,1 r' t Sworn to and ;subscribed before me thi! r'22 day of February. 2011 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIf? Notarial Seal Sherrie L j lower Paxton r"? PuWic MY cAmm Dauphin County `tembf; p sSlOn I- Nov. 25, 2011 r Pnncv+ _ Association 2010.6247 Civil Term HSOC 00408V sorvloes, Inc Vs Donna Crockett Atty- ft WA n" ALL THAT IS CERTAIN LOT OF GROUND SITUATE ON THE EAST SIDE OF SOUTH HIGH STREET, IN THE BOROUGH OF MECHANI(SBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT. BEGINNING AT A POINT ON THE BUILDING LINE OF SAID SOUTH HIGH STREET AND AT THE NORTHERN LINE OF STOUFFER ALLEY; THENCE IN A NORTHWARDLYDIRECTION ALONG THE BUILDING LINE OF SAID SOUTH HIGH STREET FOURTEEN AND ONE-TENTH(14A)FEET TO AN IRON PIN AT CORNER OF OTHER LOT OF THE GRANTOR HEREIN, OF WHICH THIS IS A PART, THENCE IN AN EASTWARDLY DIRECTION ALONG SAID LOT OF THE GRANTOR HEREIN AND THROUGH THE CENTER LINE OF A DOUBLE FRAME DWELLING HOUSE ERECTED ON THE LOT OF GROUND HEREBY CONVEYED AND ON THE LOT OF GROUND ADJACENT THERETO ON THE NORTH, AND BEYOND, FWIY- THREE AND SIX-TENTHS(53.6)FEET TO AN IRON PIN ON THE LINE OF CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE; THENCE IN A SOUTHWARDLY DIRECTION ALONG THE LINE OF LOT OF SAID CHARLES E. DIENER AND VIRGINIA M. DIENER, HIS WIFE, FOURTEEN AND TWO.1VfM(14.2)FEET TO AN IRON PIN ON THE NORTHERN LINE OF SAID STOUFFER ALLEY FIFTY- TWO(52)FEET TO A POINT ON THE SOUTH HIGH STREET ALINE OF ND AT A PLACE OF BEGINNING. HAVING ERECTED THEREOT DOUBLE SOUTHERN HALF OF A FRAME DWELLING HOUSE; KNOWN AS NO.11 SOUTH HIGH STREET, MECHANICSBURG, PENNSYLVANIA. BEING THE SAME PROPERTY CONVEYED TO DONNA CROCKET, A SINGLE ADULT INDIVIDUAL BY DEED FROM RICHARD T BEAM AND EuZABETH BEAM, HUSBAND AND WIFE RECORDED 03,,'"f 06IN DEED BOOK 213 PAGE 1458, IN THE OfFICE THE RECORDER OF DEEDS OFF CUMBERLAND COUNTY, PENNSYLVANIA. IAX TD# 16-23-0567-015 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which HSBC Mortgage Ser Inc is the grantee the same having been sold to said grantee on the 2nd day of March A.D., 2011, under and by virtue of a writ Execution issued on the 2nd day of November, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6247, at the suit of HSBC Morl;aae Sers Inc against Donna Crockett is duly recorded as Instrument Number 201109959. IN TESTIMONY WHEREOF, I have hereunto set my hand -it and seal of said office this day of A.D. 2V& J? C of Deeds Recorder of Deeds, Cumberlend Cairdy, Ce r&, PA My Commission Hires the First Monday of Jan. 2014