The URL can be used to link to this page

Home My WebLink About10-7381~• IIDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SIIITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ,,,, " ~ t"J '"i Ocwen Loan Servicing, LLC € COURT OF COMMON PLEAS ~ ~! 12650 Ingenuity Drive €CIVIL DIVISION ~ rn c;~ ,,~ ~-- Orlando, FL 32826 ~~ •c vr` Plaintiff €Cumberland County ~{~ o a° ~ n --~ca v. a cJ !~ ~ ~~ Leslie G. Hoffer ~ ~ _ ~~~ _ -°~ ~' 4520 Linden Avenue € NO. ~~ -~3 "+ '- Mechanicsburg, PA 17055 ~ r.~ 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. YOII SHOIILD TARE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTB BELOW. THIS OFFICE CAN PROVIDE YOII WITH INFORMATION ABOIIT HIRING A LAWYER. IF YOII CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOII WITH INFORMATION ABOIIT AGENCIES THAT 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 800-990-9108 ~~ 0.~ ~~ ~ ~~ ~~ ~~ Av=so Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 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 DE~~ANDA A IIN ABOGADO Ir~DIATANENTE, SI NO TIENE AHOGADO O SI NO TIENE EL DINERO SIIFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLANE POR TELEFONO A LA OFICINA CIIYA DIRECCION SE F:NCIIENTRA ESCRITA ABAJO PARA AVERIGIIAR DONDE SE PIIEDE CONSEGIIIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page, who is the legal holder of the Mortgage and is in the process of formalizing the Assignment of Mortgage to be sent for recording. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 4520 Linden Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township COUNTY: Cumberland DATE EXECUTED: 11/17/06 DATE RECORDED: 12/11/06 BOOK: 1975 PAGE: 3732 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 11/29/10: Principal of debt due $95,186.58 Unpaid Interest at 6.875 from 7/1/10 to 11/29/10 (the per diem interest accruing on this debt is $17.84 and that sum should be added each day after 11/29/10) 2,676.78 Title Report 300.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $180.13 and that sum should be added on the first of each month after 11/29/10) 17.98 Late Charges (monthly late charge of $33.18 should be added in accordance with the terms of the note after 11/29/10) 165.90 Suspense Balance (52.76) Property Inspection 31.50 Attorneys Fees (anticipated and actual to 5~ of principal) 4,759.33 TOTAL $103,365.31 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 $103,365.31 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:~- ~~ Attorney for Plaintiff OMMMM Es~~ ~G'ommossly a~ 45?A I.i~s Avg ~ PA I7055lit~. ~ CCELiTAIId ~ II~!'~tF.ST T!~ A C~71.-IDQ'Y~II7M ~G SITU~tx AT 4lSO AVS[tiYflFi G0~ ~~ '~'~ 1 O'9V1~, C[]pM.AbID C~V'I"Y'. P~Y~'-N~ ~ G'~iDCB~+BQ1~ A[a3 pA~N Pk.~S ~ 00~~ ~ ]N THE Ot~S b~+ Tf~ ~ I ~ Alm PCB C~ Clpt~Y, ~1SXt.'~TA~.+1~, II~T lrL'93t~.~3'~ ~CC?Q8` PAGE X41. A.9 ~Li~ Aim II+T ACOOHDANi"B ~VII'Pi THE ~ ~ P~3~[..V',I~fA AC'T GEt ]'i3~Y 2, 1980 fb8 F.9. 310z Sl" _ .~Q~~• ~i..y-Jyti7~+/a7y~~w ~1i~ i~LL.id 1fu7~i~s +s~++~~Y"lnL7V lRLG17-Gw~+ ii.~ !f[W Td ii=s+ ~~~~p F+A.1•A~Vi~.IT~~~p~~~~L~RF ~ ~ I ~ p ~T ~J1~«.~R .~lL~/ -74J1iC5~i~ ~~3 ~ riii~ +~4~~~ ~s,•sms u~ ~s~s o~ P~ gy'm' zHS P~avs. snm~ ccnr~,rirs A~ ~.~'~~s ~s 1 ~ aoa~ '~''? . ens~~~r~4 .~ 11123t20f0 2;33:7p?M CUMBERLAND CbUNTY -- ~: I nst,# 2006dde5o" • pagc 1 c+f C ~~ • Ocwen Loan Servicing, LLC P.O. Box 24737 V O C w E N West Palm Beach, Florida 3341 6-4 73 7 (Do not send correspondence or payments to the above address.) N'WVi% OCWEN COM September 30, 2010 VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515136368382 Reference Code: 1009 Leslie Hoffer 4520 Linden Ave Mechanicsburg, PA 17055-0000 Loan Number: 71540751 Property Address: 4520 Linden Ave ,Mechanicsburg, PA 17055-0000 PLEASE SEE THE ENCLOSED DOCUM NT EXHIBIT A DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt Ocwen Loan Servicing, LLC P.O. Box 24737 ~-~-~°~°--~-~-~ West Palm Beach, Florida 3341 6-4 73 7 OCWEN (Do not send correspondence or payments to the above address.) W W W OC WEN COM September 30, 2010 APPENDIX A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an o ffici 1 notice t hat th e m ortgagee on your home is in d efa alt, and the lender 'n tend to foreclo a necific information about the nat• ~re of t he d fa~~~t • pr ovided in the attac hed naggc ~ The HOME OWNER' M ORT A(' F A44i4TA NCE PRO AM ElVLAP) may be able t ~ ~+Plu ~ ~s~P you r home This Notice exnlams how t he p~ gra m wor To see if H THIRTY (3 EIVLAP can hel 0) DAYS OF p you TFiF. mu DA st T TF OF T WITH A ONSiiM HI NOTi('F Tak FR ('RFni OUATSF e thi Notice with you i iN[" A('FN(`y W when you n,PP* w ITffiN ith the o •n ing . The name a end of this N (800) 342-23 ~; ncv ddress nd ph otice. If you h 97 (Persons wi one nu ave an th imp mb y_qu aire er of on ti eshons,you d hearing c mer redit ounce L may call the Penn a n cau (717) 780 1 ing Agencies serving yo sylvania Housing. Financ 8691 ur County are hctP e Aggp~y toll free a - d 9t }}gyp t This Notice C contains impo rtant l egal informatio n If you have any questions, r~presentativ ec at th nncumar (`rpn,t onnsebn¢ AQencv may b e able to h gln~gnlain it You may also w ant to contact an attorn y~ 9ur area T he l l bar associati on may be abl e to he l}w ou find a la wygrl, y oca LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA 5U DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. USTED PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR 5U HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Leslie Hoffer 4520 Linden Ave Mechanicsburg, PA 17055-0000 71540751 OCWEN DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt • Ocwen Loan Servicing, LLC P.O. Box 24737 O C W E N West Palm Beach, Florida 33416-4737 (Do not send correspondence or payments to the above address.) W~t'V1-.OCWEN COM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU AY BE E I IB F FOR FINAN Ai I T NcF WHI H C N AVE YO It HOME FROM FO F O LTRF. HELP YO MA F F TL~F MORT A PA NT 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. TEMPO RARY 4TAY OF FORF['i O4iTRF nder the ert, you nrp anfifipd *n A +p.n norarv~y of foreclosure on vour mo rtgage for thirty (30) daps fr om the date of this Notice. During that time you m . st arr~ge and atiend a "face- to-face" MIDST O meeting with nnp of the rnn CCUR WiTHiN THE. NE e~~mpr nradi* nn» »QOting~gencies Iist_ed at the end o XT (r~Q) DAYS. iF YO T nn NnT APPi,V F()R f this Notice. i'tlli 1• r:F:TINt' rj`MTj D!`_L•ivr•v w i~RT`~' ~ ^z' ASSIST CALLED ANCE. YOU MU T B iN "HOW TO CU F. VniTR (' YO TR MnuTrArF TP TO DAT T F MnRTf_enF. nF.Ferrr T~~~ EXPL.AiNS H_[_1W TO r . .. P RT OF T r~ NOTI F B i11T(: Y[)i1R MnuTr_sr_F UP TO D ATE. ('ONSUMER CREDIT COUNSFi iN(' A('FNCiFC _ If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addres a and telenhon numbers of designated cone»mpr rrpdir on»»cnP.»n a..o.....ve a ,. aa.,. »»»~~ ,,. wnacn one proF~y is iocatea are cet forth at the end of hi Notice. It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORT .ALiF. ACCiCTANf"T• _ your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and fde a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR iF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH l1V THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY A TION -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 sizty (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 )N BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt . . . . . . . . . . . . . . . _ . . . : y, • Ocwen Loan Servicing, LLC P.O. Box 24737 O-C W E N West Palm Beach, Florida 3341 6-4 73 7 (Do not send correspondence or payments to the above address.) V4'W W.OCV+;'EN.C'OM HOW TO CU E YOUR MnRT(`A('F iIFFAiTi T /Rringj~~~ to datel. NAT F. OF TH . D .FA 1i .T _The MORTGAGE debt held by the above lender on your property located at: 4520 Linden Ave ,Mechanicsburg, PA 17055-0000 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 2 payments in the amount of $ 843.63 from August Ol. 2010 through DET >T. SiTMMARY Principal and Interest ................................. Interest Arreazage ..................................... Escrow .................................................. Late Charges ........................................... Insufficient Funds Charges ........................... Fees /Expenses ........................................ Suspense Balance (CREDIT) ........................ Interest Reserve Balance (CREDIT) ................ TOTAL DUE .......................................... $ 1,327.00 $ 0.00 $ 360.26 $ 132.72 $ 0.00 $ 10.50 $ 52.76 $ 0.00 $ 1,777.72 HOW TO CU F. TuFr DEFA .T -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 $1,777.72, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by Money ramp g~hinr'c [`hn~k, o.~a:o heck or Mon y Order made payable and sent to: ' OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO NOT TRF. T . nF.FAiTi T - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to ezerci a 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 frill 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 ups~your mortgggg~p~pgr~, IF THE MORTGAGE iS FnRF.('i.nCFT• r ON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were .actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they ezceed $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 THIR Y (301 DAY period. you w~ not be req sir .d o pay attorney' fee . OTHER ..ND .R F DI -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RiGHT TO CU F. THE, nFFAiii T PRiOR Tn eu~•ur~~~e e s r ,c _ 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 un to one hour befor the 4heriff c ale You may do so by_pa~Rng the total amo ant thP~ IlaSt ~i1e. D1uS anV late or other chnrapc than dno .•eeQ..,,..6i.. ~s~,.........r., e___ __~ ___._ _ _ ... .. _ _ ' orner requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt • Ocwen Loan Servicing, LLC P.O. Box 24737 `-~---~°~~-°°` West Palm Beach, Florida 3341 6-4 73 7 OCWEN (Do not send correspondence or payments to the above address.) t~'WW.OCWEN.COM EA i IE T PO IB 4H iFF' 4 LE DAT - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the servicer. HOW TO CONTACT THE SERVICER: Name of Servicer: OCWEN Address: P.O. BOX 24737 WEST PALM BEACH, FL 33416-4737 Phone Number: 800-310-9229 Fax Number: 407-737-6300 Contact: Early Intervention Dept EFFECT OF SHE iFF'S CAi.F. _ you should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORT A -You may or X may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, )F YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (3) TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSLTMER CREDIT O NRF.i,iNC` ACFN['~iFC c~'pVIN YO TR ('OiTNTV DACT91.17 This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that purpose. However, if the debt is in active bankruptcy or has been discharged through bankruptcy, this communication is not intended as and does not constitute an attempt to collect a debt V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents. The statements made in the foregoing pleading are true and correct to the best of his/her 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 :~`;" SAC.. Attorney for Plaintiff ~AiMM , EsIN+Mf UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: 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 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 ADAM L. RAYES, ESQUIRE - ID #86408 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 pleadings@udren.com Ocwen Loan Servicing, LLC 'COURT OF COMMON PLEAS 12650 Ingenuity Drive :'CIVIL DIVISION Orlando, FL 32826 :Cumberland County Plaintiff v. ~~¢~ Leslie G. Hoffer NO, ~ b JU 4520 Linden Avenue Mechanicsburg, PA 17055 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: .~ C N ° ~ ~ --f _~ ~ ~!'- '~ a t -- ~ ~ ~~ Z° ~'T1 ~,c o °r~ ~ _ ~,c3 ~ :~? Kindly enter the appearance of the following counsel: 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 and Jerome B. Blank, Esquire on behalf of the Plaintiff, Ocwen Loan Servicing, LLC in the above-captioned matter. UDREN LAW OFFICES, P.C. BY . ~- .S~.a__._ a~~+, M 1b-J~i~S~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor FILED-OFFICE ff THE PROTHONOTARY 2010 DEC -9 PM 4: D CUMBERLAND COUNTY PENNSYLVAOI A Ocwen Loan Servicing, LLC vs. Leslie G. Hoffer Case Number 2010-7381 SHERIFF'S RETURN OF SERVICE 12/02/2010 05:21 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010 at 1721 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Leslie G. Hoffer, by making known unto herself personally, at 4520 Linden Avenue, 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. RYAN BUR T, PUTY SHERIFF COST: $37.00 December 03, 2010 SO ANSWERS,, RONNY R ANDERSON, SHERIFF 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 C= -o ?-? Plaintiff € CIVIL DIVISION rnF -?o Cumberland County , Leslie G. Hoffer Defendant(s) NO. 10-7381 fro Zo - . -,-- PRAECIPE TO SUBSTITUTE VERIFICATION CD TO THE PROTHONOTARY: Kindly substitute the attached Verification for the Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED: ???`? ?? ?1a?i UDREN LAW OFFICES, P.C. Attorneys for Plaintiff ? BY: Daniel S. Siedman, Esquire PA ID 306534 V E R I F I C A TI O N The undersigned is authorized to make this verification on behalf of Plaintiff and hereby verify that the facts set forth in the foregoing pleading are true and correct: to the best of my information and belief. This statement is made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn fal 'cation to authorities. Date: Ito CALL- "f, N JOLENE . STRATTON Title: Company: Ocwen Loan Servicing, LLC Supmisor, Repurchases, compliance & Claims Leslie G. Hoffer MJU #10110718-1 (Cumberland County, Pennsylvania) ???s?t???q??# . ?Q?v?+2 ?fi?? {? ???Ic?r 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 12650 Ingenuity Drive :CIVIL DIVISION Orlando, FL 32826 Cumberland County Plaintiff ::MORTGAGE FORECLOSURE rim V. M Leslie G. Hoffer € NO. 10-7381 -?' -- ' 4520 Linden Avenue - Mechanicsburg, PA 17055 c, s„ - Defendant (s) c- -- =?; 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) Leslie G. Hoffer 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 $103,365.31 Interest Per Complaint 713.60 From 11/30/2010 to 01/08/2011 Late charges per Complaint 33.18 From 11/30/2010 to 01/08/2011 Escrow payment per Complaint 360.26 From 11/30/2010 to 01/08/2011 TOTAL 1104,472.35 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. UDREN LAW OFFICES, P.C. BY: °- Attorneys for Plaintiff Daniel S. Stedman, Esquire PA ID 306534 DAMAGES ARE HEREBY ASSESSED AS DATE: INDICATED ]? I Cal PRO PRO *14-00 PO A7rf 0114 p.1 ?'a53476 No'hes "Cl UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsoudren.com ATTORNEY FOR PLAINTIFF Ocwen Loan Servicing, LLC :COURT OF COMMON PLEAS 12650 Ingenuity Drive =CIVIL DIVISION Orlando, FL 32826 Plaintiff :Cumberland County V. R Leslie G. Hoffer e--,v nLt 4520 Linden Avenue ` NO. IO t Mechanicsburg, PA 17055 Def endant (s) COMPLAINT IN MORTGAGE FORECLOSURE aTe D a ?c w O xa r- ?a S -ry: ?S r 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 Carlisle, PA 17013 800-990-9108 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor C'PF: Err'.'?=t'---'Nr. Ocwen Loan Servicing, LLC vs. Case Number Leslie G. Hoffer 2010-7381 SHERIFF'S RETURN OF SERVICE 12102/2010 05:21 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 2, 2010 at 1721 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Leslie G. Hoffer, by making known unto herself personally, at 4520 Linden Avenue, 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 December 03, 2010 RYAN! BURG-ETT-O PUTY SO ANSWERS, RONKY R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003 856-669-5400 #10110718-1 Ocwen Loan Servicing, LLC :COURT OF' COMMON PLEAS Plaintiff :CIVIL DIVISION v. ,Cumberland County Leslie G. Hoffer Defendant (s) :NO. 10-7381 TO: Leslie G. Hoffer 4520 Linden Avenue Mechanicsburg, PA 17055 Date of Notice: December 23, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO EYTER 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 800-990-9108 NOTIFICACION IMPORTANTE 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 800-990-9108 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. Siedrnan, Esquire PA ID 306534 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-=>620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 856-482-6900 pleadingeludren.com Ocwen Loan Servicing, LLC 12650 Ingenuity Drive Orlando, FL 32826 Plaintiff V. Leslie G. Hoffer 4520 Linden Avenue Mechanicsburg, PA 17055 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states, upon information and belief, 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: Leslie G. Hoffer Age: Over 18 Residence: As captioned above Employment: Unknown This statement is made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. T le: JOL STRATTON Company: Ocwen Loan Servicing, LLC Supervim, Repurchases, Compliance & Claims ?s?a?u???t ,?osi?c 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 Leslie G. Hoffer :NO. 10-7381 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: rte` ._.. 70 c:a C? ? - r .1 Please issue Writ of Execution in the above matter: Amount due $104,472.35 Interest From 01/09/2011 2,568.96 to Date of Sale June 1, 2011 Ongoing Per Diem of 17.84 to actual date of sale including if sale is held at a later date (Costs to be added) 05 40.oo PO A7W 37.00 CBF 9a. 00 14•oo " cZ.50 " UDREN LAW OFFICES, P.C. s BY: Attorneys for Plaintiff 4 1(09.60 - PO ATT`/ $a.00 hue Co .50 Lj. ?4a7 W.2"Z4710 QE LQak 4wac/ Daniel S. Siedman, Esquire PA ID 306534 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 Leslie G. Hoffer :NO. 10-7381 Defendant(s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: s ue =rrI . rr'J -?Cw) " r- F11 reT1 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: UDREN LAW OFFICES, P.C. <y- S BY.> c:.a Attorneys for Plaintiff Daniel S. Siedman, Esquire PA ID 306534 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 -4 , -- , MORTGAGE FORECLOSURE a Leslie G. Hoffer NO. 10-7381 ., w-- Defendant (s) C E R T I F I C A T E w ` 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 36 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. r. Attorneys for Plaintiff Daniel S. Siedman, Esquire PA ID 306534 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 Fz_ -7c' ::MORTGAGE FORECLOSURE ' - CD Leslie G. Hoffer NO. 10-7381 Defendant(s) ' - e.T.; . C _ .. AFFIDAVIT PURSUANT TO RULE 3129.1 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: 4520 Linden Avenue, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Leslie G. Hoffer 4520 Linden Avenue 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 Ocwen Loan Servicing, LLC 12650 Ingenuity Drive Orlando, FL 32826 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 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street 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 4520 Linden Avenue 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 : `l vv^r1 10, Rot k UDREN LAW OFFICES, P.C. BY: S At orneys for Plaintiff paniel S. Stedman, Esquire PA ID 306534 Y 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 Leslie G. Hoffer :NO. 10-7381 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leslie G. Hoffer 4520 Linden Avenue Mechanicsburg, PA 17055 Your house (real estate) at 4520 Linden Avenue, Mechanicsburg, PA 17055 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 $104,472.35, 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.) V 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 Sheriffs 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 TARE 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 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 COMMONLY KNOWN AS: 4520 LINDEN AVENUE, MECHANICSBURG, PA 17055. ALL THAT CERTAIN ONE-HALF INTEREST IN A CONDOMINIUM DWELLING UNIT SITUATE AT 4520 LINDEN AVENUE CONDOMINIUM, LOWER ALLEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA. BEING DESIGNATED AND KNOWN AS UNIT NO. 4520 IN THE DECLARATION OF CONDOMINIUM AND DECLARATION PLANS OF SAID CONDOMINIUM AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN MISCELLANEOUS BOOK 337, PAGE 391, AS REQUIRED AND IN ACCORDANCE WITH THE PROVISIONS OF THE PENNSYLVANIA CONDOMINIUM ACT OF JULY 2, 1980 (68 P.S. 3101 ET SEQ.). TOGETHER WITH ALL RIGHT, TITLE AND INTEREST IN AND TO THE COMMON ELEMENTS AS MORE FULLY SET FORTH IN THE AFORESAID DECLARATION OF CONDOMINIUM AND DECLARATION PLANS, AS AMENDED FROM TIME TO TIME. UNDER AND SUBJECT, NEVERTHELESS TO ALL AGREEMENTS, CONDITIONS, EASEMENTS AND RESTRICTIONS OF PRIOR RECORD AND TO THE PROVISIONS, EASEMENTS, COVENANTS AND RESTRICTIONS AS CONTAINED IN THE DECLARATION OF CONDOMINIUM AND DECLARATION PLANS. BEING KNOWN AS: 4520 Linden Avenue Mechanicsburg, PA 17055 PROPERTY ID NO.: 13-24-0795-146-04520 TITLE TO SAID PREMISES IS VESTED IN LESLIE G. HOFFER, AS SOLE OWNER BY DEED FROM MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE OF EQUITY ONE, INC. DATED 1.1/10/2006 RECORDED 12/11/2006 IN DEED BOOK 277 PAGE 4684. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7381 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due OCWEN LOAN SERVICING LLC, Plaintiff (s) From LESLIE G. HOFFER (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 $104,472.35 L.L.$.50 Interest from 1/9/11 to 6/1/11 Ongoing Per Diem of $17.84 to actual (late of sale including if sale is held at a later date -- $2,568.96 Atty's Comm Atty Paid $169.50 Plaintiff Paid Date: 1/11/11 (Seal) Other Costs avid D. Buell, rothonotary By: Deputy REQUESTING PARTY: Name: DANIEL S. SIEDMAN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 306534 % Due Prothy $2.00 I LAW OFFICES P C ATTORNEY FOR PLAINTIFF UDREN ' WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Ocwen Loan Servicing, LLC -:COURT OF COMMON PLEA 12650 Ingenuity Drive :CIVIL DIVISION rnW Orlando, FL 32826 :Cumberland County - Plaintiff tar o v Z c) Leslie G. Hoffer 4520 Linden Avenue ::NO. 10-7381 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: O N c? rn r- rn 0 o, -4c:) ?n-n c:) M c? 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: February LK, /2011 UDREN LAW OFFICES, P.C. Attorneys for Plaintiff Alan M. Minato, Esquire PA ID 75860 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 Leslie G. Hoffer NO. 10-7381 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO Pa.R.C.P. 3129.1 and 76 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: 4520 Linden Avenue, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Leslie G. Hoffer 4520 Linden Avenue 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 Ocwen Loan Servicing, LLC 12650 Ingenuity Drive Orlando, FL 3.2826 5. Name and address of every other person who has any record lien on the property: Name Address Lower Allen Township Auth. 120 Limekiln Road New Cumberland, PA 17070 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 1.7013 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 4520 Linden Avenue Mechanicsburg, PA 17055 The statements are true and correct, based upon 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: February 8, 2011 UDREN LAW OFFICES, P.C. BY' _ Attorney for la- ntift Alan M. Minato, Esquire PA ID 75$60 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Ocwen Loan Servicing, LLC Plaintiff V. Leslie G. Hoffer Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-7381 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Leslie G. Hoffer PROPERTY: 4520 Linden Avenue Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on June 1. 2011, at 10:00am, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A r - CD CD' U/ O CD -1 0 v Qo n c a- CD 7 >Z r -1 -n am O ?c m q t (-? =v 5,2 ao C O V V FD' n 0 (D N Q n v co Z (D 0.3 4?6 Wcr N O T 0 i S. c fOD in O 3 w c ?I O 'O eD CL 47 N 7 pr O Im O T O O -it OI '°I °°I -I °'I Ix I .1, I "I N 'D 0 3 0 2 CD 0 W tnD I m 1 1 a -1 ?? 1 1 1 1 I 1 ;03 E, 1 mmcmm o?`?mc 1 3°°- - qrc^Oa `123$yO? c- n_ Wamffm ocm3°_5 ma3,.:0 0 m3m"m 3------ ail '", oi -c m N 00 nm n ooc 00 °ooo0y ama=S3 M O N m nCD ?5m3?_. _ W N 3 x. rtiy ?ny3y° >;?mZ1D m n"mn ?i w 09.3 =9 m 03:3.n? m0°Q?m ,mmvm@m m .0 g m n3 w ffa °%., aL-j a j N N? N omm m3 - --m3@ o°-ijmm?c wmC°7?m3 v 'c 3 u 01dm Am EP n<p Oj m 3 r C51Z o.ZOmm 'Ru >> 10 i C Z N CD N = C D a) Z> c a CL 0 m(0 7a 35 (D N i ??O O- X O-O A =-0;00 Z W n o" CD Ivm 0) OmO 3 ?.z3 ac v = c? 3oZ o m? a spy co 0 m `??mn svr m 2? ..cn -- x Z D :1 mpm v? -m ov _ o ? -r 0a-? NCO a ? Z Do ;0 D? CD ;a ?? p _ wm? y ?m? ? BCD --I We C ?NCm v -I? v .IUD) Nr. fA >0 Do D _-* o-o o? 0 Np? -0:3 C ?m? a rX wCD w w a) CD o?' >c -0 <CD D NCD C m `>- m cD .. cD CO c -Zi 1 0) 0 o h m o_ r- CA r- term N w3 ?? 3' Q o' C7 oD y w:O mc•) OK m 6 N -0 m O < D? a CD Z O n c v0, CD m N ? ? ?? n n 5 ;p (D O N CD ;? o c 55 N T (D O. N C N o N n d ')16H265192,6 co El cl 11 • A^ 0 m 5 Z3;0 0 O c c y N G3 Mailed FromJJ O (D a CD 0 y US POSTAGE n o C o :rw wG ??'FS CD? fO > s rn ?, C O GC w D?j n 0 ,N.. a N m D) 7 - N N N C O C O n n ?a> j 0 A N 0 c O D ?p =ZO 00 a?D OCCD N n.7,X Om m 0) CL x °-'m3 N ' O 0- o. '0. 3 m T p N ?. (D Z1 CDC O ?tGy C N -"(n CD Q O G COD o -1 N -n (n N 2 N W 3 - C IBIT N N r - CD a CD O CD CD Cl O v 00 n c cr CD v Q T O 3 w co V v -n CD Q c v CO co O C y a 0 n Ol V1 1 CI 1 Q ? 1 V f en 7 O W 01 A r 1 -? f0 M -1 0) CT .A W N -' D z NO (D W O N a C ( CL C D a ( D ac l< 3 Z> ?(D? CL 0) ?yCL ?m CL ? ? N N N ? ?r z CD 0 o CD CD g c 0 0 2. 6 CD 0 - 0 D MOm Z M 3 D D mvm r v 3 3 ` a - z ??Z CD CD :=3 y e s 0 G1170 CD p v m MCA* v . 7 O r'1 0 F' 0 CD N y -v ? ? io Z y" o D v v v M ° v D n oytn < a v O N 7 OCR N o c mn d ,f m ° m N O ? m O CL m _ Z m N ? ? ?? O n C (D N N ° sip, o CD c0 D C C F O a N _ ? icy ? tF (}16H2S. ? O a m Q N . m I, El F-I El 31!2 m 5 3: R o"01,3 carc, F ? - 'a ; r. m , r ' E?4alFc_r1 TAGE 1 ; S POS N O N1 O m 1 f ? N N - 1 a v' 1 ? o 1 - 1 "`gy m 3° CAS aw °'j t9 <.W c°: N 7 Boa ? ?' 0= N 3 ?a3=gy p 7 m O tQ n 7 G ^.O 10 d m S S !R ^? 7< O -0 M O _ CL'a ?°c'CpWm W N H t - ?GD N . v N ?o N H?d „ mm ? r C m d g -ui - p ?C O O N 77(T N-• m C .y. o N N N ] C a ?Q°n C c O m °21C0 <q ' A° jS3 QO Gag Gag @ O 0 CD o ? , - 0 a CD -1 ?Ws d0m Wa. 'm 7.7 m m =. m _.a a ? 'o 3m? O? y O . .X mn.ag 3 °m m 0o0 iw mn?.3-'m n x °-CD 3 m 03 R: COL O O?m m w 00 O'oO. a ?"' v v 3 N ,Z (D ID L °-'Q_'? m; m og? •??omc?Di'm o ? a m ?1 O ?O N =rq -? o 2 m _.?tf o n a CL a,3 7$ c ,°= 914 O 0 llln O' m° _ O 'y ?. CL =M, 3 m 7 000 ' ? - ? ?3 ?u!niis x T7(n m @c m y gsm 3 m 2 vc3?m? = , 3 W U . 0 M 6= N 3:E`$a E H1B T A Oz?Wm 7 Q N T7 7 , A (p °wd p ll UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF Ocwen Loan Servicing, LLC :COURT OF COMMON PLEAS 12650 Ingenuity Drive :CIVIL DIVISION Orlando, FL 32826 :Cumberland County Plaintiff V. :NO. 10-7381 Leslie G. Hoffer 4520 Linden Avenue Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: C rnCD =rn r- ? zQ Kindly file the attached Proofs of Service with regard to the captioned matter$ Date: February L%, 2011 UDREN LAW OFFICE_S,P.C_ Attorney for Plaintiff Nian M. Minato, Esquire PA ID 75860 N -*t r? 77 ca c.-:7; C -44=, =C-r co : ,, cD -ice' EXHIBIT B Ocwen Loan Servicing, L<LC. CL al.. Plaintiff(s) .S. Leslie G. Hoffer, et. al.. Defendant(s) UDR.EN LAW OFFICES Sts. Danielle Devlin 111 W ooderest Rd.. Ste. 200 Cherry Hill, NJ 08003-3620 Service of Process by 4 APS International, Ltd. 1-800-328-7171 i APS JNTVI :ATtOXAL j APS International Plaza 7800 Glenroy Rd. Minneapolis, 111N 55339-3122 APS File #: 109811-0001 AFFIDAVIT OF SERVICE --Individual Service of Process on: -Leslie G. Hoffer Court Case No. 10-7381 t - ? State of: \ ! C. - - i- - - - - - - - - - - - - - - - - - - - - - - - County o U1'? i- ?l.^r 1 Name of Server: L ?f S?; a n lwe 4 e , undersigned, being duly sworn, deposes and says that at the time of service, s/he was of legal age and was not a par"this act n; par" P Date/Time of Service: that on the day of ?ct nu e t -7,1 , 20 at r cock M Place of Service: at 3520 Linden Avenue in 6lechanicsburtt. PA 17055 Documents Served: Service of Process on; Person Served, and Method of Service: the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property A true and correct copy of the aforesaid document(s) was served on: Leslie G. Hoffer Jam, By personally delivering them into the hands of the person to be served. ? By delivering them into the hands of . a person of suitable age. who verified, or who upon questioning stated, that he/she resides with Leslie G. Hoffer at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Sex JIL: Skin Color IA.) L,4 4 2 : Hair Color Rya -n Facial Hair. •iV O Approx. Age 50 _ ss ; Approx. Height S'S - S ` 7" : Approx. Weight 1,2 0 )65 To the best of my knowledge and belief said person was not engaged S Military at the time of service. V- J Signature of Server: Undersigned declares under penalty of perjury Sub d a to before me this that the fore oing is true and correct. y 'f ? 20 Signature of Server N ublic (Commission APS International, Ltd. :,OMMONWEALTH OF PENNSYLVANIA Notarial Seal k i :itchelle Guyton, Notary Public Carl s.e Boro, Cumberland County My Commission Expires July 1. 2012 . 1- it=.r Pennstvania Association of NotarisE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 CZ r 4'.( Ocwen Loan Servicing, LLC :COURT OF COMMON PLEAS rnm _ 12650 Ingenuity Drive :CIVIL DIVISION r Orlando, FL 32826 :Cumberland County to Plaintiff w r ? ?a v. NO. 10-7381 ^? f •? Leslie G. Hoffer cap 4520 Linden Avenue Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. A A Attorney for P aintiff DATED: June 16, 2011 Sherri J. Braunstein, Esquire PA IO 90675 10110718-1