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Home My WebLink About10-7035 UDREN LAW OFFICES, P. C. ATTOI MARK J. UDREN, ESQUIRE - ID #64302- STUART WINNEGE ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE- ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ,AMAM L. KAYES, ESQUIRE - ID #86408 '-? MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 JEROME B. BLANK, ESQUIRE - ID #49736 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 I)Ieadings@udren.com HSBC Mortgage Corporation -(USA) :COURT OF COMMON 2.929 Walden Avenue, CIVIL DIVISION Depew, NY,14043 Plaintiff € Cumberland Coun V. Gregory L. Crouse Wendy J. Crouse NO. ?? 2 c --? b '3-- 345`North Middlesex Road Carlisle, 'PA 17013 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU, HAVE BEEN SUED IN COURT. If you wish to defend set forth in the following pages, you must take actin days after this Complaint and Notice are served, by appearance personally or by attorney and filing in wr` your defenses or objections to the claims set forth a warned that if you fail to do so the case may procee judgment may be entered against you by the Court wit. for any money claimed in the Complaint or for any of requested by the Plaintiff. You may lose money or rights important to you --YOU SHOULD TAKE THIS PAPER TO YOUR-LAWYER AT ONCE. A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELO PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. I TO HIRE A LAWYER,. THIS OFFICE MAY BE ABLE TO PROVIDE Y ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELI REDUCED 'FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 FOR PLAINTIFF against the claims within twenty (20) entering a written ting with the Court ainst you. You are i without you and a out further notice zer claim or relief. property or other IF YOU DO NOT HAVE THIS OFFICE CAN F YOU CANNOT AFFORD U WITH INFORMATION GIBLE PERSONS AT A 2'? AVISO Le han demandado a'usted en la corte. Si usted uiere defenderse de estas demandas expuestas en las paginas sigui rites, usted tiene veinte (20) dias de plazo al partir de la fecha e la demanda y la notificacion. Hace falta ascentar una comparescia 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 cort tomara medidas y puede continuer la demanda en contra suya sii previo aviso o notificacion. . Ademas, la corte puede deci it a favor del demandante y requiere que usted cumpla con todas _as provisiones de esta demanda. Usted puede perder dinero o sus p opiedades u otros derechos importantes para usted. LLEVE ESTA,DEMANDA A UN ABOGADO IMMEDIATAMENTE, E. 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL PERSONA' 0 LLAME POR TELEFONO A LA OFICINA.C ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE`S ASISTENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NO TIENE ABOGADO IERVICIO, VAYA EN YA DIRECCION SE' PUEDE CONSEGUIR 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 his valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain a copy of a judgment against you, and mail it to you. If you do not an admission of liability on your part. Also, upon your written r period, we will provide you with the name and address of the original the current creditor. If you notify us in writing within the 30 day period as stated of your debt, or any disputed portion of it, until we obtain the and mail it to you. Once we have mailed to you the required continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and an attempt to collect a debt, and any information obtained will be i 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 tion of the debt or to the debt, it is not test within the 30 day if different from we will cease collection )n that is required we will then attached document is for that purpose. 1. Plaintiff is the Corporation designated as such in the caption on a preceding page, who is the legal holder of the Mortgage and is in the process of.formalizing he Assignment of Mortgage to be sent for recording. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request. of Defendant (s) Plaintiff '(or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 345 North Middlesex Road MUNICIPALITY/TOWNSHIP/BOROUGH: Middlesex Township COUNTY: Cumberland DATE EXECUTED: 11/22/06 DATE RECORDED: 12/5/.06 BOOK: 1975 PAGE: 1613 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 cha ges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fair 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 10/29/10: Principal of debt due $211,334.60 Unpaid Interest at 6.0 from 6/1/1.0 to 10/29/10 (the per diem interest accruing on this, debt. is $34.74 and that sum should be added each day after 10/29/10) 5,199.40 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $304.53 and that sum should be added on the 'first of each month after 10/29/10) Late Charges (monthly late charge of $85.26 should be added in accordance with the terms of the note ,after 10/29/10) Other Fees Attorneys Fees (anticipated and actua to 5% of principal) 325.00 280.00 215.47 1,208.83 175.00 10,566.73 TOTAL $229,305.03 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 Sheri f'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 egular 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 laintiff 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 $229,305.D3 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: Attorneys for Ilaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYL , ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. AR?EMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE DANIEL SIEDMAN, ESQUIRE JEROME B. BL K, ESQUIRE ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN MIDDLESEX TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT AN IRON PIN ON THE EASTERN DEDICATE] LINE OF NORTH 'VIIDDUESEX ROAD, SAID IRON PIN BEING ( LINE BETWEEN LOTS NOS. 4-D AND 5-D ON THE HEREINAF PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE, NOW MINUTES 30 SECONDS EAST, 425.00 FEET TO AN IRON PIN; I DEGREES 47 MINUTES 30 SECONDS EAST, 200.00 FEET TO AN DIVIDING LINE BETWEEN LOTS NOS. 5-D AND 6-D ON TI MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDIN DEGREES 12 MINUTES 30 SECONDS WEST, 425.00 FEET TO AN EASTERN DEDICATED RIGHT OF WAY LINE OF NORTH M THENCE' ALONG THE EASTERN DEDICATED RIGHT OF WAI MIDDLESEX ROAD, NORTH 21, DEGREES 47 MINUTES 30 SEC( FEET TO AN IRON PIN ON THE DIVIDING LINE BETWEEN LO' D ON THE HEREINAFTER MENTIONED PLAN OF LOTS, BEGINNING. UNDER AND SUBJECT, NEVERTHELESS, TO CONDITIONS OF PRIOR RECORD. BEING LOT NO. 5-D ON THE PRELIMINARY AND FINAL S FOR JOHN M. KNAUB AND JANET D. KNAUB, SAID PLAN BE. THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE PAGE 146. RIGHT OF WAY 'i THE DIVIDING 'ER MENTIONED 1 68 DEGREES 12 [ENCE SOUTH 21 [ION PIN ON THE HEREINAFTER LINE, SOUTH 68` RON PIN ON THE DDLESEX ROAD; LINE OF NORTH VDS WEST, 200.00 3 NOS. 4-1) AND 5- THE PLACE OF RESTRICTIONS RDIVISION PLAN I G RECORDED IN N PLAN BOOK 451, AS DESCRIBED IN MORTGAGE BOOK 1975 PAGE 1613 HSBC 11 D ff/21/3410 WENDY CROUSE 34S NORTH MIDDLESEX ROAD CARLISLE, PA 17013 Dear WENI)Y CROUSE, PLEASE NOTE THAT THU COLLECT A DEBT AND Ai OBTAINED WILL BE USE[ 75 AN ATTEMPT TO IY INFORMATION M FORTHAT PURPOSE. CT 91 NOTICE TAK-E ACTION TO SAVE YOUR HOB FROM FORECLOSURE This is an official notice that the mortgage on our home is n default a leader intends to foreclose. 5 eifie informati bout the a re of the i provided in the attached a? gess. The HOMEOWNER'S EMERGENCY MORTGAGE ASSN 'ACE PRI (HEMAtP) may be able to hel to save our home. This Noti a ox lams Program works. To see if HEMAP can help. you must MEETWITH A ICON MER 1 COUNSELING AGENCY WITHIN 33 DAYS F THE DAT OF THIS i Take this Notice with you wren you meet with the Counseling Age n The' tam address and bone number of CoRsyMe Credit Counseling .aa.a .SON vrwa ?..vw0 % waa. ¦aaa.u /La tsac a:iaaa ara au "LVC Kn You may call the Penn ivanin Housln Finance A at 1 3397.(P+e ns with Impalred hearing can coil (717) 78( IS621. This Notice contains important legal lafvrmatleni.- if you hay a any questions, representatives at the Consumer Credit Counseling Agency ay be able to help explain it. You may also want to contact an attorney is Yctur rea. The local bar association maybe able to help you final a la er. 9241076 s EXHIBIT 1f8BC.N1urtRe Curperadm (us,%) Fn?s1Howlnp Suite 3201. B offole. NY 142W-321 1 La ndur HSBC 11 D-7 Wrigage Account Number. $2411076 Page 2. W21/2010 LA NOTIMCAC116N EN ADJUNTO ES DE SUM A IMPORTANCI DERECHO CONTINUAR VIVIENDO EN SET CASA. SI NO COMPRI DE ESTA NOMFICACON OBTENGA UNA TRADUCCION Lla'LM 1Y ESTA AGF.NCIA (PENNSYLVANIA HOUSING FIN CARGOS AL NETMERt3 !4'iENCIONADO ARRIBA, FUEDE SER PR$SrTANIO POR EL I'I;iOGRAMA LLAL4IADO "H(3MEfIW MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALId PERDIDA? DEL DERECHO ;A? REDIMIR SU HIPOTECA. HOMEOWNER'S KANF4,q): WENDY CROU'S E r, FUSS AFEt CA SU NDIE+: EL CONTLNIDO INMEDIATAMENTE IIWCE AGENCY) SIN :LEGIBLE PARA UN 11% EMERGENCY ER SU CASA DE LA PROPERTY ADDRESS: M NORTH MMDLRSIKX ROAD, CARLISLE, PA j i'013 LOAN ACCT. NO.: 8341876 ORIGINAL LENDER: (If original lender blank then original lender and curr mt lender are the me.) CURRENT LENDERISERVICER: HSHC (MORTGAGE CORPORATION (USA) HOMEOWNER'S EMERGENCY MORTGAGE SISTAN E PROGRAM IF You Commy +wm Tug PROvlsioNs or THE HOMEOWNER'S EVIERGENCY hloK GAGia ASSISTANCE ACT OF 159 fI'U "ACr% YOU MAY U ELIGIBLE FORE ERGENCY moRTGAGE ASSISTANCE: ¦ IF YOUR DEFAULT HAS BEEN CAUSED HY CJ1tcums 'AI+ICES REV ND YOUR COI'NT1104 IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENT, A IND IF YOU NIEET OTHER ELIGIBILM ItEiQUBREMEI' TS ?TARLISHED BY THE PENNSYLVANIA HORSING FINAKE AGENCY. 'rENIFORARY STAY QF FORECLDSUII<E Under the Act. you are entitled to a temporary 'Itay of knw1osure on yozs mortgage for thirty {30) 6yx from the elate of this NWce (plus hrrc (3) days for mWling). During that time you must arrange mA attend a "face-te-face" meeting with one of the onsumw credit counseling lgencitm listed at the card of this Notice. THIS MEETING l usT OCCUR W1714 N THIRTY.-rR eUN MAI UNBiC'Murtnape Cwparatim itlq)k?' Suix 3201. Diffalm NY 1 207-33MI 12,111176n Egvd HewaAg Lander t&aga A of M, HSBC iD Mortgage Account Nwnb= &M1.076 Page 3. QQNW?tRR CREDrr COUNE SELING AGENCIES - if you meet with one oftlx agency listed at the end of this notice, the lender may NOT take action against you date of this meetin& The names addresses and teWbooe umol= of desist to schedule one face-K4tcc mccOng, Advisc your lender immediate of your APPLICATION FOR NgRTL:.t1y;Gg_dS$T1"ITA. g - Your mortSage is in def Iota in this Notice (see foliowing pagrs for apecific infenm ion about the wture of fight to apply for financial assistance fmmlt the Hanwownds Ettmervmy Ma Mppo so, you must fill out, siga and filc a cos picied Homeowners ErnaWncy Assistacu one of the desigoted consuCn'W' credit counseling agencies listed at the end of this b uawtseliag apocks have alapliradons fow the program and they will assist yo appliicati*n to tht Pontssylvania Housing Finance Agency. To tempo3rnrUy stop the le aeti m„ your upplim6c iu MUST br forwar&d. tv PHF (filed or postmarked) within to-face tweeting with the counseling agency c nmumer credit counseling for thirty (30) days after the It is only mvessmy t for the rea=z set forth ur default.) You have the ssiswnce Pr+Crgratr7. To do Prazmm AppGt auOx with ice. Only ccrosunxr credit in submitting a sotopicte er from filing a foreclosure ,rty (30) days of your facc- YOU SHOULD FILE A? HkMAP APPLICATION AS SOON AS POS. I? BLE. IF YOU HAVE A MEEnNG WITH A COUNSELING AGENCY WrrHtN 33 DAYS OF T HS POSTMARK DATE OF IS NOTICE A FILE' AN APPLICATION wrrH PivA WITHIN 30 DAYS OF THAT MEETING. THEN THE LEN ER WILL BE TEMPO RAMLY PREVENn!) FROM STARTING A FORECLOSURE 14GAI1;IST Youlk PitoPI RTY, AS EXPLAINED ABOVE IN THE SBr"T ON CALLED 'TEMPORARY STAY OF FOII,ECL LIRE`. YOU JIAVE THE RIGIIf PE$ S. A LATE AFFLICATIONN WILL NOT PREVENT THE LENDER FROM STARTING A FO CLOSURE ACTION. BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHE IFF1 SALF. THE FORXCLOSURE WILL BE STflPPED. AGENCY ACTION - Availoble fiords feu emergency rnwtgage essistsnee am very limited. They will be disbursed by the Agency under the eligibility criteria established, by the Act The P ylvania Ho ding rime Agency has sixty (60) days to matte a docision after it receives your application. During that time. no forectcoure proceedings will be pursued against you if you have rt7mt the time requirements et forth rabovt. You will by notifyed directly by the Pennsylvania Housing Finmm Agency of its decision on your Wliication- i 924iQ7 11SOC I%longage Carppratton WSA) ? $!? suite 3201. Buffalo. NY 1?#'L07-32151 WzLgs % off s} HSBC i <> LViortpSe Account Number: 1341076 Pago 4, 09121f291tt NOTE-. IF YOU ARE CURRENTLY PRO'T'ECTED BY THE FILING OF A PETIT[LI IN BANtfRUFFCY, THE FOLLOWING PAT OF THI$ N(ff[CE 1S FOR INFORMATION PURPOSES ONL AND SHOULD NOT BE CONS[DFERED AS AN ATTENLFT TO COLLECT THE DE (If you have Cited bonktu can 00 Wply for Emergency N Asdaauce.) j%A7`URE OF THF, OF-FAULT ..*rbe MORTGAGE debt held by the above lender 345 NORTH MIDDLESEX ROAD CAWSLE. PA 17D13 IS 5E[i OUSLY IN DEFAULT because: A. YOU HAVE N017 MADE MONTHLY MORTGAGE PAYMENTS for the following amounts arc now Pat do*; %6,023.92 07M 0010 dwagh 0910112010 Other Cluu-Sm S0.00 Cmarate Advance $1123.57 Late Charrs - S150.00 Inspection Fccs S7,302A9 TOTAL AMOUNT PAST DUE HOW TO CURE THE DEFAULT -You may cure the default within TRIM (: nntica BY PAYING THE TOTAL ,a?'MOUNT PAST DUE TO THE LENDER. I ANY 1++ ORTGAOE PAYMENTS AND LATE CHARGES WHICH BECOME 01 (30) DAY PERI<IDfi. Payrtsents must be made either by cub, gashices chealt_ cer made HSBC Iv[wipge Corporation (USA) 2929 Walden Avenue Dcpawr NY 14043 IF YOU [fit NOT CURE THE DEFAULT--It yen do not cure the default within date of this Notice, the tender inters Is to exercise its. ? to accelermte the mraM entire votsinuWag balance of dos debt will. be considered due iminedlutdy and }say the me"pse in ntottthly installments. If full payment of the total amount TI[IRTY (30) DAYS. the lender also intends to Instruct its atttwrnm to start H your mortgamed arxmerty. HSBC 141ortgaKe Corporation (USAI Suim 3201, eukfnto. NY 1430.3201 I your property located at: following months wd the DAYS of the date of this ICH IS 57.302.40. PLUS DURING THE THIRTY IRTY (30) DAYS of the & This means that the I may iose the chance to k duo is not mach within notion to foreclose Mrs .4241076 w: EauN+ia?rhi tsndar HSBC I D Martpga Ace Hunt Num6cr: ;9241076 Page 5. IF TII& M2MMAGE I5 FORECLOSED VPGF_- The marrgapd property will off the mongaga dept. If the Icadcr m6ers your case to its attorneys, but you cu lender begins legftl procacdiM against you. you will still he iequixed to pay the rti were actually incurred, up Iv $SO, However, if legal pmceedinp are started agai all rrPasomable attorney's fees actually incurred by the lender even if they exceed 0 be added to the amount you owe *e lender. which may also include other reason OTHER L.EINDER RJEMEDIE ?' -- The lender rimy also sue You petsusnally for the all other sums due under the reengage. within the THIRTY (30) DAY peiiod and foreclnsure be sold by the, Sheriff to pays the delinquency belb a the bsonable attorney's fees that iat you, you will bave to pay M. Any atwuffly"s tees will able casks. It you emm the principal balance and If yai have not cured tho default lender and by 2crf'nrming,AL other magirenaenm under th; gWRame. Curing youi default in the manner set forth In this nedw will restore your martgaage to the samr~ position as if you had never defaulted. EARLIEST POSSIBLE SIMANI'F'S SALE PATE , It is eatimated that the ewrliest date that such a Sheriffs Sale of the mortgaged pmpffW could be held would be opproabmattely six (6) m nibs from the date of this Notice. A notice of the actual elate of the Sheriffs Sale will be sent to you befrxe th sale. Of co=t. Clue amount needed to cure the default will increase the longer you wait. You may fund out any time exactly what the required payment or action will be by contacting the least. HOW TO CONTACT T'IIE LENDER: !fume or Lender: Address: Phone Number- Feat Xumber: cooft4t Persons: E-Mail Address: 1ISBC Meripp Corpomflon (USA) Suite 37-'41. Bu Palo. NY 141-07-3301 14SIRC Mortgage Corpom icm (LJSA) 2929 Wadden Avenue. Depe+w, NY L 1-900-338-WI 1-732-352-751 Peter J. Gotow3ki peterj.gutowsltif r us.hsbc.eorn !124107 n a:a?aa Hoi..eg Lender {&aq?t B vff V} HSBC I -L> i4' cejpga Accomi [4uatbw.. 112 1?Q7$ Pale 6. EFFECT OF SHERIFF'S SALE - You should realize that a Sltiet'if!'s Sale will monga pmxrty and your riot to occupy it. If you ooatinm to live in the props lawstdG to mnwve you and your limdshings and other belongings could be started by d your ownmitip of the hitter the SheaifPs Sale, a leader at any titres. ASS" I P'1PION Of MQRTGAGE -- You _ may or X May not (CHEC ONE) sell or transfer your hme race h buyer or mnstrrse who will assmw the mortgage debt, provided' that at the outstanding paytmmts, rhargcs mud atWnwy's foes and coo ate paid prior to or at the sale and that other rpquir =ls of the mottPF ere satisfied. YOU iNIAV ALSO HAn THE R[Gg[- a TO SELL THE PROPER-OC TO OBTAIN MONEY TO PAY OFF THE M ORTGAGE DEBT ()I. TO BORROW MONEY FROM Ay+IMER LENDING INSTITUTION TO PAY Ce F THIS DEBT. ¦ TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON R BEHALF. • TO HAVE THE MORTUA??CrE RESTORED TO THE SAME POSITION A IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEVER. YOU VO.N HAVE THIS RIGHT TO CUREYOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR-) ¦ TO ASSERT THE NONEXISTENCE OF A DEFAULT' IN ANY FORECLO SURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOC'UM ¦ TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE T SUCH ACTION BY THE LENDER. ¦ TO SEE[ PROTECTION U DE3R THE FEDEPAL BANKRUPTCY LAW. Sincerely. E}ew J. Gutowsw Default Servicing _ ;3241070 H8 5C INImrtaw Curpardlon r USA) ? ?+? 9 t ttttidel Suite 3201, Buffalm NY 14207-3201 I HSBC i -K> MarkpSc Awaunt Number. 524107+6 Page 7. MAMs Ously Interfaith Housing Anthorit+6; 40 L Higb .'fly Ce#WsbwT, PA it 7325 717.334-1519 ccf-9 a[ w2d"n P,? 5000 Linglestown ltoW, Harrisburg Pit 17 IN 11MS11-2227 14ommmnity Action Cnmmisdwit of Ivaeitol 1314 Derry St, HarrUbarL 1'A 17104 717-132-9757 L°veshw Ioc. 2324 North Sth S#, HairHiburg, PA 17110 717-231-2207 !Naraaetha 43 Philedelphiso Ave, Waynesbaoro, PA 17260 717-762-3235 au 211 North Front Slrevt, Harrisisur0, PA 171.10 717=7W390 $00-342-2397 HSBC,Ni # nrlWge Corpwation 11.13141 F.,qur Flwdng 5uim 32161. BufYuln. WY 14207-.1-M l lendw (page 1 of 7) I-ISBC 4:-`?'°t' 0711512010 PLEASE NOTE THAT THIS IS AN ATTEMPT TO COLLECT" A DEBT AND k INFORMATION OBTAINED WILL BE USED OR THAT PURPOSE. t m if 'H th help to save your home.' This Notl?e explains program works. In_ you must MEET WITH A CON UMIER C iv 2397.(rersons,00th impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you hi representatives at the Consumer Credit Counseling Agency i explain it. You may also want to contact an attorney in your association may be able to help you find' a lam HW INIortgage Corporation (USA) 2919 W aldcn Avenue. I3epew. NY 14043 any questions, be able to help a. The local bar 924107 6 i2l Equal Housing Lender (Page of 7) HSBU" <116; A 'y. Mortgage Account Number: 11241076 Page 2. 0711512010 HOMEOVMR'S NAME(S). GREGORY CROUSE PROPERTY ADDRESS; 345 NORTH MEDDLESEX ROAD, CARLISLE, PA LOAN ACCT. NO.: 8241076 ORIGINAL LENDER: (1f original lender blank then original lender and current lender are the st CURRENT LEri'DER/SERVICER. HSBC MORTGAGE CORPORATION (US) HOMEOWNER'S EMERGENCY MORTGAGE PROGRAM BE IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR ASSISTANCE;' • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYC IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS E PENNSYLVANIA HOUSING FINANCE .AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitl foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus During that time you must arrange and attend a "face-to-facee' meeting with one of the agencies listed at the end of this Notice. THIS MEETING `MUST OCCUR Wl? t HSBC nortgage Corporation (USA) 2929 Walden Avenue. Depew. NY 14043 STANCE MORTGAGE MORTGAGE ID YOUR CONTROL, AY YOUR MORTGAGE D BY THE d to a temporary stay of three (3) days for mailing). consumer credit counseling IN THIRTV.TI R1F`.R (331 8241076 IEJ Equa! Housing Lender (Page 3 of 7) r17 k I Al Mortgage Account Number; 8241076 Page 3. 07115/2®10 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the agency listed at the end of this notice, the lender may NOT take action against you f date of this meeting. The names, addresses and telephone numbers of designated agencies for the county in which the property is located are set forth at the end of this to schedule one face-to-face meeting.. Advise your lender immediately of your intentio APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in defatt later in this Notice (see following (sages for specific information about the nature of yt right to apply for financial assistance from the liotneowner's Emergency Mortgage A so, you must fill out, sign and file a completed Homeowner's Emergency Assistance one of the designated consumer credit counseling agencies listed at the end of this No counseling agencies have applications for the program and they will assist you application to the Pennsylvania Housing Finance Agency. To temporarily stop the lent action, your application :MUST be forwarded to PHFA (filed or postmarked) within th to-face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF Y( WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF T APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENT TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLC LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A FORECLOSURE WILL BE STOPPED. AGENCY ACTION Available funds for emergency mortgage assistance are ) disbursed by the Agency under the eligibility criteria established by the Act. The Per Agency has sixty (60) days to make a decision after it receives your application. Duri proceedings will be pursued against' you if you have met the time requiremcnts_se notified directly by the Pennsylvania Housing Finance Agency of its decision on your HSBC Mortgage Corporation (USA) 2929 Walden Avenue. Dpew. NY 14043 nsumer credit counseling thirty (30) days after the it is only necessary for the reasons set forth default.) You have the tistance Program. To do rogram Application with e. Only consumer credit i submitting a complete from filing a foreclosure y (30) days of your face- HAVE A MEETING 's NOTICE AND FILE AN I WILL BE tOPERTY, AS 'TIME PERIODS.' A UR.E ACTION, BUT IF SALE, THE ry limited. They will be sylvania Housing Finance g that time, no foreclosure forth above. You will be 8241076 Equal Housing Lender (Pace 4 of 3) 100*1114 r, .. ,? H Mortgage Account Number: 82410,76 Page 4. 07/1512010 NOTE; IF You ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT (if you have filed bankruptcy you can still apply for Emergency Mortgage N BANKRUPTCY, THE ND SHOULD NOT BE IOW TO CSI ''Y U MORTGAGE DEFAULT [Bri4 it t NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on 345 NORTH MIDDLESEX ROAD CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the i following amounts are now past due: 56,028.92 05/01/2010 though 07/0112010 Other Charges: $0.00 Corporate Advance 5867.79 Late Charges 5125.00 inspection Fees $0.00 --Insufficient -Funds $7,021.71 TOTAL AMOUNT PAST DUE HOW TO CURE THE DEFAULT -You may cure the default within THIRTY i notice BY PAYING TIME TOTAL AMOUNT PAST DUE TO THE LENDER, ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME E (30) DAY PERIOD. Payments must be trade either by cash cashier's check; cc made payable and sent tc HSBC Mortgage Corporation (USA) 2929 Walden Avenue Depew, NY 14043 IF YOU DO NOT CURE THE DEFAULT--If you do not cure the default within T date of this Notice, the lender intends to exercise its rights to accelerate the mortgage- entire outstanding balance of this debt will be considered due immediately and y pay the mortgage in monthly installments. If full payment of the total amount p THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start leg your mortsascd or y. HSBC A4ortgage Corporation (USA) 2929 Walden Avenue. Depew. NY 14043 property located at: months and the ) DAYS of the date of this RICH IS $7,021.71; PLUS DURING THE THIRTY RIRTY (30) DAY'S of the debt. This means that the ou may lose the chance to tst due is not made within al action to foreclose upon 8241076 i2y EQuB. Housing. /renter {Page 5 csP ,7Y IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be off the mortgage debt. If the lender refers your case to its attorneys, but you cure d lender begins legal proceedings against you, you will still be required to pay the reds were actually incurred, up to 550.00. However, if legal proceedings are started against all reasonable attorney's fees actually incurred by the lender even if they exceed $50.0€ be added to the amount you owe the lender, which may also include other reasonab OTHER LENDER REMEDIES - The lender may also sue you personally for the all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou s _ , 1- .Y__ [.L_?M_ c-,_ v lld by the Sheriff to pay delinquency before the able attorney's fees that )u, you will have to pay Any attorney's fees will casts. If you care the id principal balance and not cured the default is •,s. ,.av sr.-_.=_?__ _?__ - -___. 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 some position as if you had nl?_ver defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earlie Sale of the mortgaged property could be held would be approximately six (6) mou Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the s needed to cure the default will increase the longer you wait. You may find out at required payment or action will be by contacting the lender. ;t date that such a Sheriffs tits from the date of this ale. Of course, the amount any time exactly what the HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: E-Mail Address: HSBC Mortgage Corporation (USA) 2929 Wdden Avenue, Depew, NY 14043 HSBC Mortgage Corporation (USA) 2929 Walden Avenue, Depew, NY 1400 I-800-338-6441 1-732-352-7544 Peter J. Gutowski peterj.gutowski@us.hsbc.com 8241076 i2ll Equal Housuig tender «a e 6 ?) EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will e d your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSU l)N OF MORTGAGE - You _ may or X may not (CHECK home to a buyer or transferee who will assume the mortgage debt, provided that all charges and attorney's fees and costs are paid prior to or at the sale and that the mortgage arc satisfied. YOU MAY ALSO HAVE THE RIGRT: i) sell or transfer your outstanding payments, ,r requirements of the • TO SELL, THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MI RTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OF THIS DEBT. TO HAV`2 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, YUU 'DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR., e TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE.MORTGAGE-DOCUME TS, ® TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY TIME LENDER. o TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Peter J. Gutowski Default Servicing HSHC MorIgagr Corporation (USA) 2929 NV,11den Avenue, Depew. NY 14043 82410?G i2l - Equal HOU34V Lender e rte, v : ? L .. Mortgage Account Number: 8241076 Page 7. Adams County Interfaith Housing Anthority 40 E High St, Gettysburg, PA 17325 717-334-1518 CCCS of Western PA 2000 Linglestown Road, Harrisburg, PA 17102 888-511-2227 Community Action Comcnissiot> of Capital Region 1514 Merry St, Harrisburg, PA 117104 717-232-9751 Loveshin, Inc. 2320 North 5th St, Harrisburg, PA 17110 717-232-2207 Maranoths 43 Philadelphia Ave, Waynesboro, PA 17268 717-762-3285 PHFA 211 North Front Street, Harrisburg, PA 11110 717-780-3940 800-342-2397 11SBC Mortgage Corporation (USA) 2929 Walden Avenue. Depew. NY 14043 V E R I F I C A T I O N The undersigned, hereby states that he/she is1 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 h?s/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 mad subject to the penalties of 18 Pa.C.S. Section 4504 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Att rneys foi-77 aintif`f MARK J. UDRE SQUIRE STUART WINNE ESQUIRE LORRAINE DOY E, ESQUIRE; ALAN M. MINA ,0, ESQUIRE CHANDRA M. A KEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L THOMAS, ESQUIRE DANIEL S SI'DMAN, ESQUIRE JEROME B BLANK, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff t? of titnbrr/ -O:K Jody S Smith ? 'r S-rt rn co C"D ?- - Chief Deputy r rn C:) Richard W Stewart " -<> 70 ' -' ? ? Solicitor OFFICE _.F i E S?ERiFF r C-; 7 c::)? ajai",. 1} HSBC Mortgage Corporation (USA) Case Number vs. 2010-7035 Gregory L. Crouse (et al.) SHERIFF'S RETURN OF SERVICE 11/16/2010 07:21 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2010 at 1921 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Wendy J. Crouse, by making known unto herself personally, at 345 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. RONALD HOOVER,DEPUTY 11/16/2010 07:21 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2010 at 1921 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Gregory L. Crouse, by making known unto Wendy J. Crouse, Wife of defendant at 345 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. C? RONALD HOOVER, EPUTY SHERIFF COST: $49.40 November 17, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (o) Coun?ySulte Sheriff, I eieosoft. hic. MARK J. UDREN & ASSOCIATES WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200, ATTORNEY FOR PLAINTIFF CHERRY HILL, NJ 08003 856-669-5400 HSBC Mortgage Corporation :COURT OF COMMON PLEAS (USA) :CIVIL DIVISION 2929 Walden Avenue :Cumberland County Depew, NY 14043 Plaintiff ::NO. 10-7035 V. Gregory L. Crouse Wendy J. Crouse 345 North Middlesex Road Carlisle, PA 17013 Defendant(s) PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: h `O3c 4 4 .t ? r? r'?.? oti p G? Kindly mark the above DISCONTINUED WITHOUT PREJUDICE. DATED: December 1, 2010 /- ? <1? Attorney for Plan iff Adam L. Kayas, ft" PA 10 A649 MJU# 10110004-1