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HomeMy WebLinkAbout10-7181 SHERIFF'S OFFICE OF CUMBERLAND COUNTY a Ronny R Anderson m ° Z Sheriff ??Zr at 61jr1 't/? Zx r- c rn Jody S Smith end , 4 co y o ue p Chief Deputy --48 Richard W Stewart ra Solicitor C ter r rV ,# -C W Ocwen Loan Servicing, LLC Case Number vs. David Burkey (et al.) 2010-7181 SHERIFF'S RETURN OF SERVICE 11/18/2010 07:13 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 18, 2010 at 1913 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: David Burkey, by making known unto Kelli Burkey, Wife of defendant at 8 W. Pine Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. RONALD HOOVER, DE UTY 11/18/2010 07:13 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 18, 2010 at 1913 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kelli Burkey, by making known unto herself personally, at 8 W. Pine Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.50 November 19, 2010 RONALD HOOVER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ;ri Goun';,Siite ShFe?fC t-e,eoso'i. In:;. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Ocwen Loan Servicing, LLC :COURT OF COMMON PLEAS G, 12650 Ingenuity Drive :CIVIL DIVISION Orlando, FL 32826 :Cumberland County G a Plaintiff m( rC=) r ::MORTGAGE FORECLOSURE y? C-, -o© V. ter- N o P -" -40 David Burkey € NO. 10-7181 !-e© -a c:)n Kelli Burkey ?'n an 8 West Pine Street c w A? Enola, PA 17025 y Defendant (s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) David Burkey and Kelli Burkey 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 $181,911.55 Interest Per Complaint 1,724.47 From 10/22/2010 to 12/21/2010 Late charges per Complaint 104.98 From 10/22/2010 to 12/21/2010 Escrow payment per Complaint 668.76 From 10/22/2010 to 12/21/2010 TOTAL $184,409.76 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. Shine 1U0 gy UDREN LAW OFFICES, P.C. BY: Att DAMAGES ARE HEREBY ASSESSED AS DATE : Id-la z I to INDI ED PRO PROTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARS 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 cam; -_ 111 WOODCREST ROAD, SUITE 20 0 ="= CHERRY HILL, NJ 08003-3620 R" r 856-669-5400 , pleadings@udren.com Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS 12650 Ingenuity Drive :CIVIL DIVISION Orlando, FL 32826 Plaintiff :Cumberland County V. David Burkey Kelli Burkey NO. 8 West Pine Street Enola, PA 17025 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the. Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and. a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH`INFORMATION.ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy f Richard W Stewart Solicitor 4 PME or Ski: s s-€ Ocwen Loan Servicing, LLC vs, Case Number . David Burkey (et al.) 2010-7181 SHERIFF'S RETURN OF SERVICE 11/18/2010 07:13 PM - Ronald Hoover, Deputy Sheriff, who being duly swom according to law, states that on November 18, 2010 at 1913 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: David Burkey, by making known unto Kelli Burkey, Wife of defendant at 8 W. Pine Street, Enoia, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. j...G Z., ? RONALD HOOVER, DE UTY 11/18/2010 07:13 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 18, 2010 at 1913 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kelli Burkey, by making known unto herself personally, at 8 W. Pine Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. 22 2z //"' RONALD HOOVER, DEPUTY SHERIFF COST: $57.50 SO ANSWERS, l November 19, 2010 RON R ANDERSON, SHERIFF r..}Goirwn,riF,cy.,: ,2iEri5d,:, l 006,577 i ,rt..n f . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10100574-1 Ocwen Loan Servicing, LLC :COURT 01' COMMON PLEAS Plaintiff CIVIL DIVISION V. `:Cumberland County David Burkey Kelli Burkey :NO. 10-7181 Defendant(s) TO: Kelli Burkey 8 West Pine Street Enola, PA 17025 Date of Notice: December 9, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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 MAY 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 AGENCIES THAT MAY OFFER'LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION I14PORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME 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 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Denies S. Siedrnan, Esquire PA ID 306534 Woodcrest Corporate Center Ill Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10100574-1 Ocwen Loan Servicing, LLC Plaintiff V. David Burkey Kelli Burkey Defendant(s) TO: David Burkey 8 West Pine Street Enola, PA 17025 ATTORNEY FOR PLAINTIFF COURT OF' COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-7181 Date of Notice: December 9, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY 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 MAY 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 AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION I14PORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TQMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARAR.ECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME 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 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Daniel S. Siedman, Esquire PA ID 306534 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-:3620 _r. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRSr - 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 Ocwen Loan Servicing, LLC 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. David Burkey' Kelli Burkey 8 West Pine Street Enola, PA 17025 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. AFFIDAVIT OF NON-MILITARY SERVICE STATE OF Florida COUNTY OF Palm Beach SS 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: Age: Residence: Employment: Defendant: Age: Residence: Employment: Sworn to and s before me this of OCjDkv?_ Notary Publ David Burkey Over 18 As captioned above Unknown Kelli Burkey over 18 As captioned Unknown :scribed ?j day 201t) LwO Goodftn ab ie? A Na le: Company: Ocwen Loan Servicing, LLC sorr Rr Compliance & Claims Ej. Public State of Florida D Goodman mmiubn EE0 25748 s 09H3/2014 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Ocwen Loan Servicing, LLC :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. :MORTGAGE FORECLOSURE David Burkey :NO. 10-7181 Kelli Burkey Defendant(s) TO: David Burkey 8 West Pine Street Enola, PA 17025 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 Juc Judgment Judgment Judgment Judgment Judgment figment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: 3erome P Esquire PA iD -49736 ATTORNEY At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Ocwen Loan Servicing, LLC :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland. County :MORTGAGE FORECLOSURE David Burkey :NO. 10-7181 Kelli Burkey Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $184,409.76 Interest From 12/22/2010 4,579.74 to Date of Sale June 1, 2011 Ongoing Per Diem of 28.27 to actual date of sale including if sale is held at a later date (Costs to be added) pd. 4, ? t/-a& Ala n ? l055-7.so e6F P 1.?. GU S o ° C .- --+ rn m r r C-) ? -urn ?z =o P. C-) 3 ? n ZO C W OM UDREN LAW OFFICES, P.C. BY: Att #/10 - a o Pay . 4 d .D6 dat Lea 4 , so Glue Gr c r-g "L0gSS Vjh l A?efe JAI V-14- fS?c1.r? UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com O FOR PLAINTIFF coven Loan Servicing, LLC :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE David Burkey ENO. 10-7181 Kelli Burkey Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: ,w 0 -n M r, r m Z n Z -" ?v TV t O , o ow -v . c n c. 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. III. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation 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: UDREN LAW OFFICES, P.C. BY: Att UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 a pleadings@udren.com ,., Ocwen Loan Servicing, LLC : COURT OF COMMON PLEAS 3 O Ys?? Plaintiff : CIVIL DIVISION rn V. Cumberland County ? N o .? € MORTGAGE FORECLOSURE r" 0 '9 Zn David Burkey NO. 10-7181 O ?y p Ke l l i Burkey Defendant (s) -? AFFIDAVIT PURSUANT TO RULE _129.1 Ocwen Loan Servicing, LLC, 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: 8 West Pine Street, Enola, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name Address David Burkey 8 West Pine Street Enola, PA 17025 Kelli Burkey 8 West Pine Street Enola, PA 17025 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 Ocwen Loan Servicing, LLC Household Finance Consumer Discount Company 12650 Ingenuity Drive Orlando, FL 32826 25 Gateway Dr., Gateway Square Suite 107 Mechanicsburg, PA 17055 Americhoice Federal C.U. 20 Sporting Green Drive Mechanicsburg,. PA 17050 5. Name and address of every other person who has any record lien on the property: Name Address None 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. 1 Courthouse Square Carlisle, PA 3.7013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 1.7013 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 8 West Pine Street Enola, PA 17025 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 : UDREN LAW OFFICES, BY: Att -15M k, Esquire ID 4973b UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF Ocwen Loan servicing, LLC :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. €:Cumberland County :MORTGAGE FORECLOSURE David Burkey `:NO. 10-7181 Kelli Burkey Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: David Burkey 8 West Pine Street Enola, PA 17025 o v C? y c? .4 Your house (real estate) at 8 West Pine Street, Enola, PA 17025 is scheduled to be sold at the Sheriff's Sale on June 1, 2011, at 10:00am in the Commissioners Hearing Room, 2nd Floor, Courthouse. Carlisle, PA, to enforce the court judgment of $184,409.76, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be rel:isted 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.) r I 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. 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 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Ocwen Loan Servicing, LLC Plaintiff V. David Burkey Kelli Burkey Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-7181- TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): David Burkey Kelli Burkey PROPERTY: 8 West Pine Street Enola, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on June 1. 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 that 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. ALL THOSE THREE CERTAIN LOTS OR PIECES OF GROUND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE SOUTHERN LINE OF PINE STREET 50 FEET EAST OF A 15 FEET WIDE ALLEY; THENCE SOUTHWARDLY ALONG THE EASTERN LINE OF LOT NO. 12 ON THE HEREINAFTER MENTIONED PLAN OF LOTS 150 FEET TO THE NORTHERN LINE OF LINE STREET; THENCE EASTWARDLY ALONG THE NORTHERN LINE OF LINE STREET 75 FEET TO THE WESTERN LINE OF LOT NO. 8 IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE NORTHWARDLY ALONG THE WESTERN LINE OF LOT NO. 8, 150 FEET TO THE SOUTHERN LINE OF PINE STREET; THENCE WESTWARDLY ALONG THE SOUTHERN LINE OF PINE STREET 75 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOTS NOS. 9, 10 AND 11 IN THE PLAN OF LOTS LAID OUT BY JOHN Q. ADDAMS AND JOSEPH PAYNE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDING OF DEEDS IN AND FOR COUNTY OF CUMBERLAND IN PLAN BOOK 1, PAGE 17 AND HAVING THEREON ERECTED A BRICK SEMI-BUNGALOW CONTAINING FIVE ROOMS AND A BATH, AND A TWO CAR GARAGE. THE SAID BUNGALOW BEING 28 FEET BY 30 FEET. UNDER AND SUBJECT TO EASEMENTS, RIGHTS-OF-WAY, AND RESTRICTIONS AS SET FORTH IN PRIOR DEEDS. PARCEL ##09-16-1050-036 AS DESCRIBED IN MORTGAGE INSTRUMENT NO. 200808786 BEING KNOWN AS: PROPERTY ID NO.: 8 West Pine Street Enola, PA 17025 09-16-1050-036 TITLE TO SAID PREMISES IS VESTED IN DAVID BURKEY AND KELLI BURKEY BY DEED FROM BRET L. BENNETT AND TAMMY F. BENNETT, HUSBAND AND WIFE DATED 03/14/2008 RECORDED 03/24/2008 INSTRUMENT NO. 200808785. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Ocwen Loan Servicing, LLC 'COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. David Burkey Kelli Burkey :NO. 10-7181 Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification o n C o n o H rn-u N? tv rn o0 D Z -46 D zo -p s or' c 4? -tom ro? ?Ie?v Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED : ('411in UDREN LAW OFFICES, P. I ^ VERIFICATION I, the undersigned, an authorized representative of Plaintiff's servicing agent, Ocwen Loan Servicing, LLC ("Ocwen"), am authorized to make this verification on behalf of Plaintiff and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocwen's mortgage servicing business conducted on Plaintiff's behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do not believe to be true or which I know to be false. Date:10/25/2010 i : Jolene . St tton Title: Super, Repurchases, Compliance &Claims Ocwen Loan Servicing, LLC as servicer Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r7 T ?t 211I FEB -8 Ali I! c!) `3IJM6rF,! ,11 A Ocwen Loan Servicing, LLC Case Number vs. David Burkey (et al.) 2010-7181 SHERIFF'S RETURN OF SERVICE 02/07/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Udren on 2/3/11. SHERIFF COST: $94.35 SO ANSWERS, February 07, 2011 RON R ANDERSON, SHERIFF "? ' LAC)