Loading...
HomeMy WebLinkAbout11-0003UDREN LAW OFFICESr P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank National Trust Company as Trustee for the Register Holders of Saxon Asset Securities Trust 2007-3 Mortgage Loan Asset Backed Certificates, Series 2007-3 1661 Worthington Road, #100 West Palm Beach, FL 33409 Plaintiff v. Shandra Ewing 5500 C Gloucester Street Mechanicsburg, PA 17055 Def.endant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County No . ~1 l - 3 ~ilii I T-e~'+~'~ COMPLAINT IN MORTGAGE FORECLOSURE c~ ru ~' '~ -.. r~~ :~ r~s-- ~~ ~© ~o ~ ~~ r c-~ =~` c? -n o '`- n ~,~ ~' ~ ~ -< 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 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 notificacion. 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 torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. 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 AHOGADO I1~Il~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. 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: 5500 C Gloucester Street MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Lower Allen COUNTY: Cumberland DATE EXECUTED: 12/15/2006 DATE RECORDED: 12/21/2006 BOOK: 1977 PAGE: 0255 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 12/29/10: Principal of debt due $138,045.39 Unpaid Interest at 9.14~* from 6/1/10 to 12/29/10 (the per diem interest accruing on this debt is $34.89 and that sum should be added each day after 12/29/10) 7,273.73 Title Report 300.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthly late charge of $57.70 should be added in accordance with the terms of the note after 12/29/10) 519.30 Suspense Balance (950.65) Property Inspection 52.50 Property Valuation/BPO 222.00 Prior Servicer Fees 54.00 Attorneys Fees (anticipated and actual to 5$ of principal) 6,902.27 TOTAL $152,698.54 *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 "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 $152,698.54 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. Attorney for Plaintiff Danlal 5. Sidman, Esquire PA ID 306534 ?~ ~ -~An Axi,, TA~~' t~TAEM lat or piece ay ~roeai ettrete d tie C4~eesa~ili ~ r~y>r~,,6erelded asd deeeriiY ~ efterrs on ebe fled rite ~ of ~' l~.er~.8°~, ~+~aas aid PY~r, ~d ti..~. d.rt or 3~orrary 15,1!79. stlli ~ 6ely neooeded lr fire Olive of t-~ Aecoeider o[ Deeit 4 sad 9or Clluiel~blepd t`olsltjy is fie 9las &~ Vols>se 3!ti Pape ~. aai beilp u>'t~ keno 11s WiYareaMui Nall, here psY iesleeiied>s itiilewe, to ~rtts ~G at ~ y~~.t.~~r~dr pent k located free d ire sad atnes~eiR4t (~3,~ }~ SOt<ti ~' (~ deSraee (41} suatee Mreabea (17~ ~ Beet h~ i Mb.glt) at ~! a~rtieset ellreel' 4~ rile isi>ivillr• Aleellaaefoee 1yl`1'Nd bpi' ~j point le 71M0 ~! e0alit+leaf' e017e1' e[ Lot Pl4r ~ ilsd a pa~'tt 411 t11e MR! d' >toid a4w oC ! of Cypllryd Lve~aalri tMleaee aiooi sllid MpYAi1 Mivw Ot fer~leteir p~ C~wlad Uviadeeate eaatll tweedy f~ Rees brfy~cae (4I) eaVeiee wastes Cif seesada Gct.. dledaoe of ' (24) feet to ^ pout, wta polar ivied tie eerWeet avwer of Lot Pie. ~ tieaee doad Lot PTso. 2, 6e11ti1 (~ ~a lid vainer ieRty`'tllree (~ aeolWe Wret, s dieteaer el' osa isdnd sbleteeo {119) feet tv s PeW. tsid pdit behi ~ sarflt~et 4oeaer 4i Let Na ~; tltiee hertil twert~ (20~ i~+eee lirq. aelo (4i) eeiaetea rea~eca (17) seceadr West, a dleener of tel~eaty-1fe1~ (?y feet eo a psW, a+M •poitt beiei' tea aoefbw~ert aeraer of LM Na I; theaa siouS erid in N4.4~ Nord afaygweiee (~ da feae a~ C11~ riesoas D~ LeeCN~a ~e~I- &~, s di~osoe sa asa 6aaderd alaeMea (11t9y poet be s poiet, ie !lave of ll~. Defif~ 7Qa. 6 ea 19aa al lferW firs ilbek ]i. pap N abs to ueoedaaee a:tU a Plan ai Survey br tierrit .7. Betz Aseodater, ~, dsird Afsy 4, 19w0 sad beau drawlsS Pro, f~iGQ. >iRDiG knorre sad ae®11end as 5'~f-C (lioseater ~ ~ ftBrIIriG '1'Hi~ 6AMB pestser wild Stereo A. Mst+d9 asd Dasaa idoesig fli7ia Dame 7'he~sr, Y>sbwd ud ~- by Deed beau dale tie 13fi day aP Deeelaber~ SM6- Beef sbwt ro be 6erartEb reoaeded a fie Ollioe u! tie lboeraer a[Dcede b erad !or fir C~aq~ sf Cnetiberlead, P'sa~lveai,~ tlsabed aed coeyc~ed eye ~iMladra ~*u& 17P1DE4i AND ffit$8.i1<t`T Tf) aaaditfoss and roes wbki ear appar M mead. ~AR~ rrla-x~-~a-o~ ~` l ~1~'~'G02b~ November 16, 2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaa~e on your home is in default. and the lender intends to foreclose. Saecific information about the nature of the default is urovided in the attached pales. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM fHEMAP} may be able to help to save your home ThYS Notice exQIains how the nroQram works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Cvunselina A~encv The name, address and shone number of Consumer Credit Counseling gencies serving your Cownty are Lsted at the end of this Notice If you have any questions. you may call the Pennsvlva~ua Housing Finance Agency toll free at 1-800-342 2397 {Persons with ' Haired hear~nQ can call 1717) 7$(i-1869} This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SL' CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NO'I'IFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA {PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO P(?R EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ~~ ~~~ '~ ~_:a:>' .; a l~ HOMEOWNER'S NAME(S): Shandra Ewin~__ _~ _ PROPERTY ADDRESS: 5500 C Gloucester Street -~~_..._....__~_~..__._...______.~_ Mechanics PA 17055 LOAN ACCT. NO.: _71.1.35065 ~~~ -------------_____-.__ ORIGINAL LENDER: CURRENT LENDER: Decision One Mo a e Company LLC __~~ Deutsche Bank National Trust Co. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL.ASSTSTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE; IF YOUR DEFAULT HAS BEEN CAUSED BY CIItCUMSTANCES BEYOND YOUR CONTROL, IF' YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU. MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30} days from the date of ties Notice (plus three (3} days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN 'T'HIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. 1F YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end o~this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone .numbers of desisnated consumer credit counseling agencies for the county in which the propertX ~is located are set forth at the end of this Notice. It is-only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE °A~SSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAY5 OF TAE POSTMARK DATE OF THIS NOTICE AND FII.E All' APPLICATION WITH PHFA R'ITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARII,Y PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO F E A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TffiS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed banla~uptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it ua to date). NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 5500 C Gloucester Street Mechanicsburg PA 17055 IS SERIOUSLY II~r DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $1154.01 for July 1 2010 through November 1 1A10_= $5770.05 .~._-......_.r-...---._.___.__ _Monthl_y Late Charges of $57.70 for July 1, 2A10 throu November 1, 2010 = $28$.50 ~~^ miner charges (ezplaiNitemize): Property Inspections = $52.50 ------~~----~------ BPO = $222.00 Other Fee = $54.00 Suspense = ($950.b5} _Other Unpaid.Late Charges = $230.80 TOTAL AMOUNT PAST DUE: ^-~~__--- ----.______._.____~ w~~_ ~-._-- $5667.20 - B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30}DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH. IS 5667.20 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to Udren Law Offices. P.C. Woodcrest Coraorate Center _1.11 Woodcrest Road_ Suite 200 Cherry Hill, NJ 08003-3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable 1: N/A IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within. THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgsge debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. if the lender refers your case to its attorneys, but you cure the delinquency before the lender begins Iegal 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 aII reasonable attomey'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 the THIRTY (30} DAY period, you will not be required to oav attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, ov u still have the ri t to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by pa~n~ the total amount then past due plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Shenff's Sale ass cified in wiitin b the lender and b rformin an other uirements under the mortgage. Curing your default in the manner set forth in this notice wi71 restore your mortgage to the same position as if you ha,d never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It. is estimated that the earliest date that such a Sheri#f s Sale of the mortgaged property could be held would be approximately 6 months from the date of this Noiice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender/Servicer: Address: Phone Number: Fax Number: Contact Person: E-Mail Address: Ocwen 12650 Integrity Drive ~~-- ~" ---~_____.____ Orlando FL 32826 877-596-8580 .-__._.____~__~ .._.._.._.__..____.____ 4U7-737-5693 Customer Service -~~~~~-~ EFFECT OF SHERIFF'S SALE -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 Sheriff's Sa}e, a lawsuit to remove you and your furnishings and other belongings could be started. by the lender at any time. ASSUMPTION OF MORTGAGE -You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that ail the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is awed 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. AIso, upon your written request within the 30 day period, we wilt 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 (85b}669-5400 YOU MAY ALSO HAVE THE RIGHT• • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTTTUTION 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 TIIVIES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOGS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland Countv HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 10/15!2007 10:03:08 AM Adams County interfaitfi housing Authority 40 E High Street Gettysburg, PA 17325 717.334,1518 CCCS of Westero PA 2000 Lingiestown Road Harrisburg, PA 17102 888.511.2227 Community Acfion Commission of Capfiai Region 1514 Derry Street Hanrisburg, PA 17104 717.232.9757 Loveship, ine. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17266 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 ority Mail: Mail. For proof of a Retvm ' ooverthe . vaver for •eceipt is assee or with the the arti- ied Mail )tttry, zi -- . ~ - _ . . ~ ~ g, ^ ~ a o^ U ~. ~' v d ~ oo m w a , ra ~~~ ~ m 0 ~ O~ O o; ~ ~~~ N •- mo~ ~ ~~~ ~~~ ~~_~ '~ ~~~~o ~ ~.. .. _ - - w o _ c ~ E c O U 1 ~. t1.t ~ "Q ^ 0 ,~ ~~7 ~ ~ ~ I~- 1'iJ ~~ ~~ ^ ~ ni a. ~ °j v C] c>D ~ ~ y ~ ~ ~, O ,c n ~ ~ ~ j ~ ~ ~ J L ~} f t 4 F d O J ~ ~ i~ E a S ~. ~~ Z M m ~ ~ ~. N a f~ n e,~ ! +~~ ~ •~-- #. r~ ` - ,:o <- "' ~ '~ .- ~ s~gs~y.~ .~ ". ~, -.a ~ ~~ ~ ~~ ~ ~_ °' o ,; CI ~ ~~~ © ~~~ W ~ ~~ ~~ ~~ Q' ~ u Q' ~ ~. f.J'1 .~"~..~" ~ ~~ i i~ ~"_ '~` G3 't1.! ~ t'r? ~ ~ ~ i..~~2 LL! L O ~ U ~onz ~-v-p¢ ~s~i ?o~c., c° b y y ~ ~ ~ ~' `, X ~ u ~ J ~ d s ., S. ~ V ^~ V 1) ,~ r Priority M 'd .Mail. wide prop ltac:h a Ret o po cover te.. waiver flail receip tCldrL'SSBE. deco with. sent the ~ :ertitied A' ait. ~ snquir) ... $ '~' ~ O4 ~ ~ z° ^~ CU ~, O, r v :a $ ~ y d X m .~ d m ~ U ~ a ~m~E ~~ar .... ~ ~~ o=' v I~ ~ `~~ ~~m~ T~~ ~~ ~ ~ ~° ~, ~_ ~ ~ ~~~~ `' ~ w ~ ~ c ~ ~c~mo ~ c~z~ ~~ ~ ^ ^ ^ ~ . ._ ... ~ Q. E G '~ ~ ~ I ri O U ~ ~ .!] ~~~ ~ a ~ ~ [1- f1J ~ 0 ~ O ~ ~' o ~ ~ O ~[3 ~ dJ 1 o- .~ o ~ w ~ .~ k.~ u ~ ,. y '~ a ~ , ~ ~ ~ >~ 0 0 r` a 8 N ~m r ~~ r Z M 7~4 dT l0 ~ a C~.J ,~,,,. C] ~ ~.. `~ `~~ ~~ «, ~ ~; ~ ~. ~ , a. ~ r ~.~w~ T ~~/ W (:: b' .~ ~,.~ . . ¢~, ~. ~s O t-~ a ~o 0 w . ns ^.1 a„ Ir a^ ~.w ,~ ;- ,~'~op~ u, Qo ~ :~~~ ~ ~ E- -~ ~n z o~¢ s ~~- ~ ©~ z~c~ cu ~ ~ u= c•~ ~. ~ ~ o~~"~ ~o 0 f l~ (~~ ~ 1.1.1 ~ ~ ~ ~ V ~ ~ d ~ f ~ (!? ~ .9 J .~ J >v .~ ~' -_ ~.~. 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 LAW OFFICES, P.C. BY : ~~--- ~ ~_ Attorney for Plaintiff DaniN S. Skdman, [-squire PA ID 306534 . , UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 3TUART 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 ~ ~ o MARGUERITE L. THOMAS, ESQUIRE - ID #204460 ADAM L. RAYES, ESQUIRE - ID #86408 ~~ ~ _-~ DANIEL S. SIEDMAN, ESQUIRE - ID #306534 ~~ ~ ~r`- -v JEROME B. BLANK, ESQUIRE - ID #49736 ~ D w ~~,~? WOODCREST CORPORATE CENTER t o ~ ~ 111 WOODCREST ROAD, SUITE 200 Dn ~o ~ q a~ CHERRY HILL, NJ 08003-3620 ~~ ~? "' ~~ s' 856-669-5400 pleadings@udren.com ~ ~ - - ~ Deutsche Bank National Trust Company as --. < '_COURT OF COMMON PLEAS Trustee for the Register Holders of :CIVIL DIVISION Saxon Asset Securities Trust 2007-3 :Cumberland County Mortgage Loan Asset Backed Certificates, Series 2007-3 ~ `/ al~- 3 ~ ~ ~',~ /-L 1661 Worthington Road, #100 . NO. West Palm Beach, FL 33409 Plaintiff v. Shandra Ewing 5500 C Gloucester Street Mechanicsburg, PA 17055 Defendant(s) ENTRY OF APPEAR.ANCB 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, Deutsche Bank National Trust Company as Trustee for the Register Holders of Saxon Asset Securities Trust 2007-3 Mortgage Loan Asset Backed ~ M Certificates, Series 2007-3 in the above-captioned matter. UDREN LAW OFFICES, P.C. BY : ~„---_ ~'~ ~~~ PAID 3 6534 squire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff b FILE D-O FIC".. r HE Jody S Smith Chief Deputy Richard W Stewart Solicitor N)11 JAN 12 AM 9: 1'Ir NNS`t'I. VP1.11;`% Deutsche Bank National Trust Company vs. Case Number Shandra L. Ewing 2011-3 SHERIFF'S RETURN OF SERVICE 01/07/2011 10:55 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on January 7, 2011 at 1055 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Shandra L. Ewing, by making known unto herself personally, at 5500 Gloucester Street, Unit C, 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. zzgg? /v`Z.?z STE EN BENDER, DEPUTY SHERIFF COST: $37.00 January 10, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 ATTORNEY FOR PLAINTIFF Deutsche Bank National Trust :COURT OF COMMON PLEAS Company as Trustee for the :CIVIL DIVISION Register Holders of Saxon :Cumberland County Asset Securities Trust 2007-3 Mortgage Loan Asset Backed Certificates, Series 2007-3 'NO. 2011-3 1661 Worthington Road, #100 West Palm Beach, FL 33409 Plaintiff V. Shandra Ewing 5500 C Gloucester Street Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: c M ? z cnr .?A -- r-n Ica c r-z --?? 3 2d L 33 C-z 4 M Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: July 11, 2011 . A Attorney fo Plaintiff stwm 1. Braunstein, Esquire PA ID 90675 10100861-1