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HomeMy WebLinkAbout10-7627UDREN LAW OFFICES, P.C. WOODCRSST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ple~dings@udren.com HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates 1161 Worthington Road, # 100 West Palm Beach, FL 33409 Plaintiff v. Charles W. Lynch 2560 Spring Road Carlisle, PA 17013 Defendant (s ) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS C q CIVIL DIVISION 'v 3 o 0 . -• Cumberland County ~~ ~ ~ -= -~ r „ `<~' w o° _r ~ 3y ~ A ~ ='TI ° :~Q ~ z ~ mzc o o~ --~ ca D -: ~r ~ -,; NO . ~ v - l ~ ~ l COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 U pa~ ~ ,,~~~~~ 5aaa ~ ~. a AVISO Le han demandado a usted en la torte. 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 notification. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la torte 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 notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO I1~IEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page, 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. Per an agreement dated 10/12/09, said loan was modified. A true and correct copy of the agreement is attached as Exhibit "A". Said Mortgage and Modification Agreement are 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: 2560 Spring Road MUNICIPALITY/TOWNSHIP/BOROUGH: North Middleton Township COUNTY: Cumberland DATE EXECUTED: 11/30/06 DATE RECORDED: 12/1/06 BOOK: 1974 PAGE: 3908 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 12/10/10: Principal of debt due $145,772.01 Unpaid Interest at 3.995 from 7/1/10 to 12/10/10 (the per diem interest accruing on this debt is $16.10 and that sum should be added each day after 12/10/10) 2,566.75 Title Report 300.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $326.34 and that sum should be added on the first of each month after 12/10/10) 2,947.30 Late Charges (monthly late charge of $31.20 should be added in accordance with the terms of the note after 12/10/10) 93.60 Property Inspection 10.50 BPO 111.00 Attorneys Fees (anticipated and actual to 5~ of principal) 7,288.60 TOTAL $159,369.76 *This interest rate is subject to adjustment as more fully described in the note and mortgage. 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 "B", 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 $159,369.76 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. :. UDREN W OFFI ES, P.C. BY : ~^ Attorney for intiff ~m L. Ksye~, esquire -PA ID ~64~8 J oc-u+an La.s.r ~~J P.O. Bar 2473 r_r~- L.........___.. Wasr Palm gr--r- Ffarfda 33sJ64737 ' o c w s C~Uo r+or gyred eerr+raPporrderroe or p,~y+.:rssv ro the ob~o.rs ed~rrrJ . ww~w c+r-ur 1. Mi[lco char3ta payable m Oertan Loan 3ervi©a 2- .41wrpe s....t. .~_ 1 _ ~ _ vviilz Qa I.I.C. 3. The dowa~payaisat meet be in tla~ form a~' OCWBN L AN AT'Y"N_ CA881~ItII3d D81rARTlV2EIV'I" 1661 Wo.tTsinetcm Roatt$aita l00 Went Palm Fae~-.t. I*L, 33„g09 RECEIVSlt CQ7D8: 3237 A~wTrr Yrrav PAY ~ ~• °- Tpr OCWBN LOAN 3lEAVICIIQC?. LLC SAMfG- ~MOrBaes Chase Sant NA C.iT'Ys ORLANL7O AHA: 01'1000027 a'1'A2Lt PL.OR1mA ACCOS.71V7• NA.A'IS: Oewae Lora 3elvisia8. Ll_G ItS7~'CRSNCE:L.OAN lvC3M8~8R' 80572043 AClC~O: VNTf~I$PL~.7M$18'Ra 8260 78 8 7 5 --....._..___...____.iY'~L:f}Ci1CY'6ri~"~Bd~J)'D21s~-PaO~' __ __ ~~aaRV~r+-Ra'me~~Y NOmtaby.p~:F~Lf~_A4traFtgaq _ Sv wrrrr• Smell: 'r -_---- _ __..... G~asae Cts.: Or_~wmr arrL®~vac - _ ____ _ witty the datai[r ___-_ Loan ttF Alto: Ao.ae 1[ialerstion Depaty~evt i.OAN MOD1FlC.A.'I30N AiGR.SE1~7'r tlr tsr~ms of y loa: o~ a: ° ]^ou .i.:e t.® Modiiiostioa .°~Ceaaest C"A - A. the M ~d4oioa as descrlBed is detail belOw_ "~. dated 10/12/09. whiaLt modifies na<l ort8q~e. Deed of Titast. or saatarity Dared Ctbas " ~Sort,~'~- dated and recon6ea ixa ttte Pulalio xeoarc7s of Glambcrlatsd Coamty~ 1E3. tlse No of tlae aaa.o ]neaUed atf2~60 ~ Etoadt CarIfseovas the ~nl atsd Qersodaal pzpp,prl3' d~ecl is itae Marq¢ay8r and as the Pveatiant to ore mvoaal agtesQ.eat to mpdifj, yea ~~ am M below. ttie parciea agiee as ibllovus_ °~8a atd in oonsidaeatioa of the Prosirisas, oonditltrus, gad terrl[s set forth 1- Iu oetfQ icr clay asmas oS alsia rriodiIIsatioa to boeorlie o~cti 10/23/09 itld two ("L) equal lmamthly ~~ Of ~ iDrCAp[LS ~t6 mB1cC ail lp{L{~ pa~~t of '51~OI 3_OO oa q~ ~p IxBiisnlLg 0a 12/1 /09, and ~~ ~ 0,~~~ t Use amogn[ orF X24.01 to Oowam ~"~1 ~~. due oa the ~~-- 2_ Yots. aQ:eee that. t the aad of the Taial lsalod. the etrw S month. ~ 5149,Y63.67_ Upon mndifiat;per yqa Nots will ba~aaxsd-~_ dwe valor yoga rnodi$ad Note: and the will be _ will not be in deArtalt M'Or~e 3. Arty Daynaaeta d.ae for raoMioa[isa-]'l eTat~.laaa Yo•a xm~aibil9tY is aAditfort to ibs pa.Ya.mres of _. _ _ _ si.a..tasms of ei.ia. slave with yotar taom.ebYY PiclacdPal and intetee! paymeut_ -~+wi3L sore ®a ~~ t ~?'~ <- rfyou ~.....-~.tiy e~Fyss tfr trial pmiod. Yoea loco wiu _._ ._. C~a'~°`;ig'o~~~-1ifv min~amstoand ~ M ~u t oa or~bafbre dna~ ~tarrns oPShla A the Thai Y~iod will ' dnacfmS the Trlal 8 ' Pa3+2naats daaa.g else TYiwl PQiod does not wrzve Oow®•s °`t~.;~.,~6a rnali and voiri and aDPYioatioa of~ Pgo[OClOatae ar o activities telaL4i to the delingtlepcy of the low Elie Toil Period lrulii the M...r.~.~..a~ or 1'esurae iOILjQ IIS 0211/8,{ tlfp7B. 3- You peelslse to inw>< oFm-;.....Y . ~ ~t~at ola the st®e 7 2/1/36, 81 wlriawl tinao s~TmeI balloon tisY of each svooee~ang laoath .mti1 Nom ar.d ModiBoation will bo due_ pb'~at amount egaaa[ to all 6 atrtovr[ta tmaw t1b hrow~s®y Cf rA.r de6r v o. EDO/ZOO-d S6ZZN or ,~~ Yrra~ a ~• ~ ~ r.or ~frrv~ae r,ow ool~lae ZbE 10'IId l ~ ~-~ -~~ obtyrrsd ws 7 6c tyrant, for pTjpr 9e- r~r.voziew7an ie iaor bae~eradfad~y ~ use 2.SOOObZ1lt b0~60 BOOZ/EZ/O[ ~XHII~I A POic w» Zw 3rd ZyG' Waet Pdl Baroli, ,F7os~im~ 334IaS~737 T.b trot xnd m yv..dmeer or p y..r«.rt ro si obnw add saJ 6. Uprm ModiiFotation, tlse vew mxaouott payabl¢ uradar yout• Note aad tba Maetgf~e will taa fxaca~sased to the total amouat of debt owed on yola loan. '~- Vpom ModiSoatiots, tlte'asvaual xats of iataaest ohargad on tine trnpatid priacspal balaace serf eta 1 y«a iazat pq~maat s32~ the Trla1 3 _993tYX.2Lis sate will a~ is a$iet tttatl iha and o~F a. $ve (~ _ye.r Period oe~n8 with Pa-i _ At ttsa road of this lata'iod. yoia mtraast r~ wtL be ~•i~rr.t sooonAiaag to tlse terms of yoga otisgnaal loser 8. If you sell Yoga peoPatty, xabHtssvice or oilaawise i _ PaY~f Y°La after dtalt~g the 12 mrataths fvi7vw~i~ tlee data of ModiSceiesa, alas Modi$oalioa 11 be voidable. a tlse sole option of Oawan sad all Qaoaaata Crv~ned der the obli~stions awstxaC Iaior m t7fa Modiftostisart will ba due stall Wig. 9. You ariIl aottlgaiy viii. ail other oowsatoaear a~x+ssusmnts esd oovatsaab Qad agae®ta m ....a.,. all payaaaatre of taaots. iasutsvoept~ti~ of ytxa M~~' ivcllx,diag witYsotxt littaitatlon, riser paytrsaubs that you e~ glslxgated to mdte ttasf~ the Moatgagq axcKpt as ot>seswa~~~ esrsnw iteo~s, impoutasffi stall all oiLSr Prtrvisiad haraaa_ 1 salt tYa'sd ®d a~rsp tLst: <a) Ali ilse ~tighta sad a reread mtsditlons ooataiaad in pgm~ts valor tlsa 1vlottys>iew~agsly'to sie®ult is tLe mddv; aafi tLie xtspayrrt~ batateodQ~ t>x '~•~u~.,e oP (b) All ovaeoa~s stspuladoos. esd ootadItioms in yve Note avd Mor~ge 'il aria is full faaw a9d at~ot. ~aoept. as Lsaam modiSai, ama mew of dre yota of laligestims err Itabiiities tmdr you Ns>ta and Mastgt~m will Tx siitrtiaishsd err rd~aod by ~Y pavviaeiotts LQ~eo~ taor will this m aaadrr tar rmadies ran °rY waY +=~'-, d3naiairh err a}°Rset tmO• ssf Osrbvsaa•s :iglrts yota Noes sad Motysg. asters righb sa comedies se eLaz uarJar a /also. all rifLts of xaoataaa to which axwrm is prgertb. entitled agadast say ps<aperty or av;y oaLss by of law. obli~atrad fir,_ oo- littbie ov. yota Nsxa esd Persons as any way (c) Arty israa:mQ 3a aottraacttaa wttB~c~~o doer, hoer noun Baia Agreement. may be ~-~- ~ to yeas rsoepam[ ~ tLa daee~of ttais .~,gxeetnanLe m yota ~•-•..-•-~s as of tba dst¢ of (d) Nothigg is this Agxncasmrt will be uadca-rtood or cwtastetaad m be a satis~otisrn ~',~a..oo.. in wLole or in axed Mrsxtga~ga. pert of your Note (e) ixt Ilse evaoc that a fvaealosaae is paadaag. the iiimeolosaae aoHott affil :,cat be dismisssxl_ Hoawsvar,0owea wit] talee tmsooeble action to plate it on laid Peratiag yoga oanpietisaa of the '1'Yial Perusal. If the Trial Period is sucrossitally completed. ergo persdioa !lxaoiusa>:.e aolion will be ditmtissod. (fl ~g the 'trial Peiod~ 7'our' lo® wi17 ooaainua to be daiinquemt- 19s a xzsatit. late f1 m r*aaY Ix ot>e;giea3 a+d caedis wi11 oa~nsiar.c pausa>wut to tlaa atigarsal farms ssfyoaa Note. ~tiv8 (~ You agrw re mralre m.d eareoute saseh satlser ~doetntasmts or paperer es axay be raecaDasey Q taslatia+sd to a the coe®s aasd aslttfiafstxatoes sad ~. rY ap~pcoy~ and ~ hY t'Jawa~ will bind and tauter to yota ~. iota. (Lj You imd~ad that tLia ggreeraetat is legally bdndiag sad that -t agbors yoga rights. You a~nt'irm tLat you Lave i~ad the o~pporaaslty m obtain i iegat awitsel oononmiag fiats s;go g Agtreaa~t volvatarily stall w~itia 11x11 amdetalaadi~ taf xaoontiaetts sad meeming_ '°'~°~t and ate in this ._ -_ C13. _ ~cw.ac-duos . s®3 C~ntlasi~o~- Yru~ ~o-tp- such doo~ataes~-m-essay iss-:m.w+abty-Qe.araxy-m -- - ooosatmmaes the stsflsrot3cros eanteimpLtied iaeaeia err to psafaaY 1' aasd ae~rrity ire eeoded saeaare tLe payment of the loan evidsasoad by tLe Note. Oesvtt i..csea SQVxoaa¢. LZ.G Claalue W Lynch _ ~~ ~ v / Hy: aas~swa •errezrats 77rfs eaoutrwas.ayovaYnst~ ra effebt sazrrwystrrrg m 4r a - srny 1 dJ~orv.~rorr obratraae~ wlA r Liasd xow,a„®-, rj ur olsryr to - oerxtir 8~.beg~aCy oar /uer v«.er -~ --- -gi rlrror~IF [awswbt~scyy w;s Qo..epgrirbonet,t Ia ,mot e,~,eer. ~t~~. rrrssr« sot .>motgpr rv aortae a ~edr_ E00/E00-d 56ZZ#t ZbE lOlId lSOOObZi li b0:60 6002/EZ/04 ~~ a All that certain triangular tract of land situate in North Middleton Township, Cumberland County,. Pennsylvania, bounded and described as follows: BEGINNING at an existing iron pin at the southeastern corner of Tract No. 1 herein; thence along land now or formerly of Claude C. Britell, et ux, North 40 degrees 38 minutes 50 seconds West, 51.66 f t to an existing iron pin; thence along land now or formerly of H e, Lebo and Hooke, North 49 degrees 06 minutes 55 seconds East, 90.75 t to an existing iron pin; thence along Tract No. 1 herein, ~ou grew 35 minutes 55 seconds West, 96.02 feet to an existing s i ~ place of BEGINNING. CONTAINING 0.045 acres, according to a survey it Clifton, Registered Surveyor, dated May 31, 1979, and reco ed Deed Book 28 M 565. BEING the same. premises which Kimberly h and Fox E. Horne by deed dated march 4, 1993 and recorded in rland Cou corder of Deeds Office Book D--36, Page 1132, ant convey Kimberly L. Horne and Fox E. Horne, her husb~, rant s erei~C~ AND the said grantors hereby c ~ e ~/ tl specially the property hereby c d. 0 0 O 0 0 0 ~ 1 ~ ~ g 0 ~_ GGNN • ~ d e~pp Z Q • _ #17 N gQ~ V~ []~ ...~ M Y b M W ~-. .... (yy WW1 .+ iY d ~ C.1 hi O .+ iI~ IL!1 O .~ d O00pC+Pa~ObO will warrant O G h~i K ~ 7a K' M d -r Aii "~~' '~ R~i.! 1+ Vv..J~ ~~ ~. ^ 4/I N •8 ... ... 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.) September 30, 2010 ~'WVV.OCWEN COM VIA First Class Mail VIA Certified Mail (return receipt requested} Certified Number: 71069017515136370705 Reference Code: 1007 Charles W. Lynch 2560 Spring Road Carlisle, PA 17013-8734 Loan Number: 80572043 Property Address: 2560 Spring Road ,Carlisle, PA 17013-0000 PLEASE SEE THE ENCLOSED DOCUMENT EXHIBIT B 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 ---~-~~°~-~~' West Palm Beach, Florida 3341 6-4 73 7 O C W E N (Do not send correspondence or payments to the above address.) w'1A%W'.OC WEN "OM APPENDIX A September 30, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an o information fficial notice th about the natur at the mo e ~f the de rtgage on v fA••lt ~ pro our home is in default, and h vided in the attAChed pgg~ e lender int nn to orecloce Specific The HOME OWNER'S MO RT A A I T N CE Th N PRO RAM MAP~~ y be able to heln ve your h om~ rs otice To see if H explains how th EM AP can h l e,programw ork~ + MFFT ' _ _ . _ e p vnu m<c W ITH A ( [INQiTMF Fni T O 1NSFi iN(` A(`Ftvw WITHIN Counseling Auencv_ a e thic Nnfir n wi you when you ..~po* with tin - LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU 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 PARR 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 SU HIPOTECA. HOMEOWNER'S NAME(S): Charles W. Lynch PROPERTY ADDRESS: 2560 Spring Road Carlisle, PA 17013-0000 LOAN ACCT. NO.: 80572043 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CURRENT LENDER/SERVICER: OCWEN This communication is from a debt collector attempting to collect a debt; any information obtained will be used for thatl.~' 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 °°--~°--°-°' West Palm Beach, Florida 33416-4737 OCWEN (Do not send correspondence or payments to the above address.) W W W.OC;Vb'EN "C}M HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGiRr.F Fnri FLNAN I I4TAN('F WgI u AN AVE YO TR HOME FROM FORECL.OSiTIt P YO MAKF T Ti2F MORT .AC'F PAy~;~S_ IF YOU COMPLY WITH THE PROVISIONS OF TAE 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 ARY STAY OF FORF.['i OciTRF Under the A~+~ yon ArP P..+:+ln~l rn tero st ~lna,.rn n orarv of f your wo rt a e for thirty (30) day~fr om the date of thlc Notic . Dnr'ng that time yon mu F ~y ~ or st arran e~tnd att d "f to-face" MAST O meetinmeeting with one of the con CCUR WITHIN THE NE umer credit counsging agency li4te.-! at the end o XT tsn~ HAYS iF YOU DO NOT APPi y Fnit g en a ac f his Noticp_ THI 11'~FFTIN~ t- r ASSIST CAi L ED ANCE. YOU MUCT BRiN "H . . G YOUR MnRTrArF UP TO DA TuF , ~Dr~>ci-rrv ,.~.,nT... ~r F. PART OF T Ic NOTI F • • OW TO TRF. VniiR M(1RT(_erF, ra~~~rrr T~~~ EXPi.AiNS HO TO BRiNC' VtIiTR MnuT[•sr~r UP TO D ATF. CONSUMER CREDIT O N N(' A AFC _ 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. TJIg _names. addresses and telephone number of designated consumer credit ~n~~n~pueg~gp..~...Q fnr the county in which the prope~y i„c located are et forth at th pnd of hi Notic . It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORT('A['F AcciCTeN!`F _ 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 file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. 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 IN 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 sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you Gave met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). 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 "--°-'°~~--• West Palm Beach, Florida 33416-4737 OCWEN (Do not send correspondence or payments to the above address. Vi'W W.OCWEN C'OM HOW TO CURE. vni1R MnRT!` sr~ "CFA T ringj~ tO~eiQ1. NATURE, OF THE D .FA ii T _The MORTGAGE debt held by the above lender on your property located at: 2560 Spring Road ,Carlisle, PA 17013-0000 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 $ 95035 from August Ol, 2010 through September 30 2010 DET i iMMARY Principal and Interest ................................. $ 1,248.02 Interest Ari'eazage ..................................... Escrow $ 0.00 .................................................. Late Charges ... $ 652.68 ........................................ Insufficient Funds Charges ........................... $ 93.60 $ 0.00 Fees /Expenses ....................................... Suspense Balance (CREDIT) . $ 0.00 ...................... . Interest Reserve Balance (CREDIT) ................ $ 0.00 $ 0.00 TOTAL DUE .......................................... $ 1,994.30 HOW TO F. THE nFFaitr 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 $1,994.30, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments muct be made either by Money Gram achier'c hevl., Certified Check nr 11;ongy Order n,9a.. payable and sent to. OCWEN P.O. BOX 6440 CAROL STREAM, IL 60197-6440 IF YOU DO N[1T TRF. THE nrFern m _ If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender 'mend to zerci a its rights to accelerate the mortgage .3e~r, This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose up9gyour mortgggg~p~p r~. , IF THE MORT('A(''F is FORF('i [)4F PON -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 exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within thn THIRTY (301 DAY oeriodLyou wi 1 not be required to pa attorney's fees. OTHER •ND R FMFDI R -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. BIGHT TO tRF THE nFFerii'r DDil1D TA OiiTTiTT~i ~Ai .; _ 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 al a any tim ••o to one hour b fore he heriff Cale You may do co y~syjpg the total amn .n~ thPn past due piss any late or other charges then dnn r..flQn..otilo sa..........~.. e___ __ ~ _ _ _ .....~.. Cau.remenis unaer the mort acre, 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. This communication is from a debt collector attempting to collect a debt; any information obtained will be used foD tha 1.1~ 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 i € .. P.O. Box 24737 `-~-~-~°--- ~ West Palm Beach, Florida 33416-4737 OCWEN (Do not send correspondence or payments to the above address.) VVV4'N'.OCVVEN COM FARi_.IEST PO IB H RIFF' AI F D_ ATE - 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 H .RiFF'fi 4Ai F _ you should realize that a Sheriff's 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 Y 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. YOU AY i 0 A T F I HT• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE (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. DAC1'91.17 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 CAT 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 W OnFFI S , P . C . BY : r ~(!~ Attorney for Pla~i tiff Adam L. KaYe~, ~squ~e PA ID 864p8 ~ . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 ~ STUART WINNEG, ESQUIRE - ID #45362 ..off o -~ LORRAINE DOYLE, ESQUIRE - ID #34576 ~W ~.°,~ rx*s ALAN M. MINATO, ESQUIRE - ID #75860 ~ ~ ~ -°m CHANDRA M. ARKEMA, ESQUIRE - ID #203437 r~ _ w ~~ SHSRRI J. BRAUNSTEIN, ESQUIRE - ID #90675 <~ y„ _"*~ ° MARGUERITE L. THOMAS, ESQUIRE - ID #204460 _ZO ~_ z ~ ADAM L. KAYES, ESQUIRE - ID #86408 3>z ~ D~ DANIEL S. SIEDMAN, ESQUIRE - ID #306534 ~ .,w,~ z~ 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 HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Trustee on Behalf of ACE :CIVIL DIVISION Securities Corp. Home Equity :Cumberland County loan Trust and for the Registered Holders of ACE ~ ti ~~ I securities Corp. Home Equity €NO. lJ~ 7 Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates 1161 Worthington Road, # 100 West Palm Beach, FL 33409 Plaintiff v. Charles W. Lynch 2560 Spring Road Carlisle, PA 17013 Defendant (s ) ENTRY OF APPEARANCE TO THE PROTHONOTARY: 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, HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity i loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates in the above-captioned matter. UDRE LAW OFF CES, P.C. BY: Adam L. Kays, ~~ PA ID ~p0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-7627 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC BANK USA, N.A., AS TRUSTEE ON BEHALF OF ACE SECURITEIS CORP. HOME EQUITY LOAN TRUST AND FOR THE REGISTERED HOLDERS OF ACE SECURITES CORP. HOME EQUITY LOAN TRUST, SERIES 2007-WM2, ASSET BACKED PASS THROUGH CERTIFICATES Plaintiff (s) From CHARLES W. LYNCH (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 $160,386.40 L.L.$.50 Interest FROM 01/19/2011 TO DATE OF SALE ONGING PER DIEM OF $16.10 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE -- $2,157.40 Atty's Comm % Atty Paid $165.90 Plaintiff Paid Date: 1/19/11 (Seal) Due Prothy $2.00 Other Costs TO BE ADDED "?A 1 40 id D. BuelT'rothonotary By: REQUESTING PARTY: Name: JEROME B. BLANK, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Deputy Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 49736 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 HSBC Bank USA, N.A., as : COURT OF COMMON PLEAS Trustee on Behalf of ACE : CIVIL DIVISION Securities Corp. Home Equity : Cumberland County loan Trust and for the Registered Holders of ACE securities Corp. Home Equity :: NO. 10-7627 Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates Plaintiff V. Charles W. Lynch J: Defendant (s ) ? PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification for.- Verification attached to the Complaint in Mortgage Foreclosure with regard to the captioned matter. DATED : ?yI ? i V E R I F I C A T I 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 falsification to authorities. Date : La L UM 10 Charles W. Lynch MJU #10110548-1 (?O?dajo N ? Ti le : JOt.EN STRATTON Company: Ocwen Loan Servicing, LLC as servicer on behalf of HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates (Cumberland County, Pennsylvania) 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 HSBC Bank USA, N.A., as Trustee :COURT OF COMMON PLEAS on Behalf of ACE Securities Corp. CIVIL DIVISION - } Home Equity loan Trust and for :Cumberland County 3-'? - the Registered Holders of ACE r«t ''r securities Corp. Home Equity Loan :MORTGAGE FORECLOSURE Trust, Series 2007-WM2, Asse t Backed Pass-Through Certificates 1161 Worthington Road, ## 100 - _? West Palm Beach, FL 33409 C Plaintiff D -7 v. ?• Charles W. Lynch NO. 10-7627 2560 Spring Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Defendant(s) Charles W. Lynch for failure to Complaint within 20 days from service thereof the mortgaged premises, and assess Plaintiff's As set forth in complaint Interest Per Complaint From 12/11/2010 to 01/18/2011 Late charges per Complaint From 12/11/2010 to 01/18/2011 Escrow payment per Complaint From 12/11/2010 to 01/18/2011 TOTAL I hereby certify that (1) the addresses of as shown above, and (2) that notice has been 237.1, a copy of which is attached hereto /t Iola DAMAGES ARE HEREBY ASSESSED AS DATE : _/ f ? /I I UD BY At the Plaintiff and against the file an Answer to Plaintiff's and for foreclosure and sale of damages as follows: $159,369.76 627.90 62.40 326.34 $160,386.40 the Plaintiff and Defendant are given in accordance with Rule INDICAT l _W7WI PRO Y UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, N.A., as ;COURT Trustee on Behalf of ACE :CIVIL Securities Corp. Home Equity ATTORNEY FOR PLAINTIFF OF COMMON PLEAS DIVISION loan Trust and for the :Cumberland County Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through n c Certificates -? 1161 Worthington Road, ## 100 MM r ?'n West Palm Beach, FL 33409 x n av r c-) "Ur- Plaintiff s n _ - --+4= 0 Charles W. Lynch ??a l : =CD z.-- rn 2560 Spring Road : 1V NO. Carlisle, PA 17013 -- ?' -C Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPEONE'.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 FEB. LAWYERS REFERRAL, SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 5. ? •y Ly- 4Ffl?E 7r ?'f'? ?FRrFE' HSBC Bank USA, N.A. vs. Charles W. Lynch Case Number 2010-7627 SHERIFF'S RETURN OF SERVICE 12/15/2010 06:31 PM - Noah Cline, Deputy Sheriff, who being duly swom according to law, states that on December 15, 2010 at 1831 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Charles W. Lynch, by making known unto Linda Lynch, Wife of defendant at 2560 Spring 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. f,r.. NOAH CLINE, DEPUTY _ SHERIFF COST: $33.40 December 16, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF Cf Cou V1ior. Shp,iff To-lwne+d l' 1n UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10110548-1 HSBC Bank USA, N.A., as Trustee on :COURT OF COMMON PLEAS Behalf of ACE Securities Corp. Home :CIVIL DIVISION Equity loan Trust and for the :Cumberland County Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates Plaintiff V. Charles W. Lynch Defendant(s) :NO. 10-7627 TO: Charles W. Lynch 2560 Spring Road Carlisle, PA 17013 Date of Notice: January 5, 2011 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 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 717-249-3166 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. DaniW S. ShOnan, Esquire . PA ID 306534 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAN OFFICES, P.C. WOODCRSST CORPORATE CENTER 111 W00DCR88T ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-482-6900 pleadinge/udren.com HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Hoare Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-NM2, Asset Backed Pass-Through Certificates 1161 Worthington Road, # 100 West Palm Beach, FL 33409 Plaintiff V. Charles W. Lynch 2560 Spring toad Carlislle, A 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County 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: Charles W. Lynch Age: Over 18 Residence: As captioned above Employment: Unknown This statement is made sub]'ect to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. 'rrtle : JOL.ENE A. STRATTON Company: Ocwen Loan Servicing, LLC as servicer on behalf of HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-NM2, Asset Backed Pass-Through Certif icates 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 HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Trustee on Behalf of ACE € CIVIL DIVISION Securities Corp. Home Equity ::Cumberland County loan Trust and for the Registered Holders of ACE :MORTGAGE FORECLOSURE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates Plaintiff V. Charles W. Lynch NO. 10-7627 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due Mw C.,... W M = M -- _o cnr- f $160,386.40 Interest From 01/19/2011 2,157.40 to Date of Sale June 1, 2011 Ongoing Per Diem of 16.10 to actual date of sale including if sale is held at a later date (Costs to be added) ,pd ?9a?U fu Cif -p' /' 7(r UDREN LAW OFFICES, P.C BY: At t PAID-0736 FV_# q -3s''i(" 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 HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Trustee on Behalf of ACE '_-CIVIL DIVISION Securities Corp. Home Equity :Cumberland County loan Trust and for the Registered Holders of ACE :MORTGAGE FORECLOSURE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates Plaintiff V. Charles W. Lynch -NO. 10-7627 Defendant(s) C E R T I F I C A T E ca _ rn M -c =7D m U cn - 7 C tz, 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. BY At 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 HSBC Bank USA, N.A., as :COURT OF COMMON PLEAS Trustee on Behalf of ACE :CIVIL DIVISION Securities Corp. Home Equity =Cumberland County loan Trust and for the Registered Holders of ACE :MORTGAGE FORECLOSURE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Q, r Asset Backed Pass-Through ' Certificates " -r ? Plaintiff V : 1 4' s ? Charles W. Lynch NO. 10-7627 Defendant(s) AFFIDAVIT PURSUANT TO RULE :3129.1 HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates, 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: 2560 Spring Road(North Middleton Township)Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Charles W. Lynch 2560 Spring Road Carlisle, PA 17013 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 IF 4. Name and address of record: Name of the last recorded holder of every mortgage HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates MERS as nominee for WMC Mortgage Corp. Address 1161 Worthington Road, # 100 West Palm Beach, FL 33409 Address to Follow 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. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq.,Carlisle, PA 17013 13 N. Hanover St. Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 2560 Spring Road (North Middleton Township) Carlisle, PA 7.7013 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 : uli BY At av,,?,o of AA ' 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 HSBC Bank USA, N.A., as : COURT OF COMMON PLEAS Trustee on Behalf of ACE : CIVIL DIVISION Securities Corp. Home Equity : Cumberland County loan Trust and for the Registered Holders of ACE : MORTGAGE FORECLOSURE securities Corp. Home Equity r Loan Trust, Series 2007-WM2, Asset Backed Pass-Through ; --- Certificates w ter' Plaintiff V. P, Charles W. Lynch NO. 10-7627 Q C-; _n Defendant(s) = _1 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Charles W. Lynch 2560 Spring Road Carlisle, PA 17013 Your house (real estate) at 2560 Spring Road(North Middleton Township)Carlisle, PA 17013 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 $160,386.40, 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.) It 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 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 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN TRIANGULAR TRACT OF LAND SITUATE IN THE NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT AN EXISTING IRON PIN AT THE SOUTHEASTERN CORNER OF TRACT NO. 1 HEREIN; THENCE ALONG LAND NOW OR FORMERLY OF CLAUDE C. BRITELL, ET UX, NORTH 40 DEGREES 38 MINUTES 50 SECONDS WEST, 51.66 FEET TO AN EXISTING IRON PIN; THENCE ALONG LAND NOW OR FORMERLY OF HOOKE, LEBO AND HOOKE, NORTH 49 DEGREES 06 MINUTES 55 SECONDS EAST, 80.75 FEET TO AN EXISTING IRON PIN; THENCE ALONG TRACT NO. 1 HEREIN, SOUTH 16 DEGREES 35 MINUTES 55 SECONDS WEST, 96.02 FEET TO AN EXISTING IRON PIN, THE PLACE OF BEGINNING. CONTAINING 0.045 ACRES, ACCORDING TO A SURVEY OF WILBUR H. CLIFTON, REGISTERED SURVEYOR, DATED MAY 31, 1979, AND RECORDED IN DEED BOOK 28 M 565. BEING THE SAME PREMISES WHICH KIMBERLY L. MYERS AND FOX E. HARNE BY DEED DATED MARCH 4, 1993 AND RECORDED IN THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE BOOK D-36, PAGE 1132, GRANTED AND CONVEYED UNTO KIMBERLY L. HARNE AND FOX E. HARNE, HER HUSBAND, GRANTORS HERIN. AND THE SAID GRANTORS HEREBY COVENANT AND AGREE THAT THEY WILL WARRANT SPECIALLY THE PROPERTY HEREBY CONVEYED. BEING KNOWN AS: 2560 Spring Road (North Middleton Township) Carlisle, PA 17013 PROPERTY ID NO.: 29140868037 TITLE TO SAID PREMISES IS VESTED IN CHARLES W. LYNCH, ADULT INDIVIDUAL BY DEED FROM KIMBERLY L. HARNE AND FOX E. HARNE DATED 11/20/2006 RECORDED 12/01/2006 IN DEED BOOK 277 PAGE 3969. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 HSBC Bank USA, N.A., as Trustee on Behalf of COURT OF COMMON PLEAS ACE Securities Corp. Home Equity loan Trust ; CIVIL DIVISION and for the Registered Holders of ACE : Cumberland County securities Corp. Home Equity Loan Trust, `•f Series 2007-WM2, Asset Backed Pass-Through c Certificates -' -- 1161 Worthington Road, ## 100 West Palm Beach, FL 33409 Plaintiff rr - == 3> C) CD ? v. =Ca . ?. C) Charles W. Lynch 2560 Spring Road E NO. 10-7627 Cn , Carlisle, PA 17013 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ( , J-`( UDREN LAW OFFICES, P.C. M. Minato, Esquire - PA ID 75860 `Attorneys for Plaintiff UDREN LAW OFFICES, P.C. WOODQREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsOudren.com HSBC Bank USA, N.A., as Trustee COURT OF COMMON PLEAS on Behalf of ACE Securities Corp. :CIVIL DIVISION Home Equity loan Trust and for 'Cumberland County the Registered Holders of ACE securities Corp. Home Equity Loan :MORTGAGE FORECLOSURE Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates Plaintiff V. Charles W. Lynch :NO. 10-7627 Defendant(s) ATTORNEY FOR PLAINTIFF o? rn --; ?p AMENDED AFFIDAVIT PURSUANT TO Pa.R.C.P. 3129.1 and 76 HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates, 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: 2560 Spring Road, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Address Charles W. Lynch 2560 Spring Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates 1161 Worthington Road, # 100 West Palm Beach, FL 33409 MERS as nominee for WMC Mortgage Corp. 3100 Thornton Avenue Burbank, CA 91504 PO Box 2026 Flint, MI 48501-2026 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. Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 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 2560 Spring Road Carlisle, PA 17013 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 : Y? ) -1( UDREN LAW, ..OFFI£-E-S-,__. P. C . Cry Alan M. Minato, Esquire PA ID 75860 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 HSBC Bank USA, N.A., as Trustee on Behalf of ACE Securities Corp. Home Equity loan Trust and for the Registered Holders of ACE securities Corp. Home Equity Loan Trust, Series 2007-WM2, Asset Backed Pass-Through Certificates Plaintiff V. Charles W. Lynch Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-7627 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Charles W. Lynch PROPERTY: 2560 Spring Road, Carlisle, PA 17013 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. 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Home Equity :NO. 10-7627 Loan Trust, Series 2007-WM2, 3 Asset Backed Pass-Through W W Certif .cates m 1161 Worthington Road, # 100 -LL -sa West Palm Beach, FL 33409 Plaintiff " J. Charles W. Lynch 2560 Spring Road Carlisle, PA 17013 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. DATED: October 17, 2011 10110548-1 Attorney for Plaintiff >t+man, Esgia'-e_ !0 306534 '•C'L? IV? . c