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HomeMy WebLinkAbout02-0113MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Ocwen Federal Bank, F.S.B. :COURT OF COMMON PLEAS C/O Moss, Codilis, Stawiarski, !CIVIL DIVISION Morris, Schneider & Prior, LLP : P.O. Box 24737 West Palm Beach, FL 33416-4737 Plaintiff v. Carol L. Bretz Marlin H. Bretz (Mortgagor) 5425 Wertzville Road Enola, PA 17025 Defendant(s) -Cumberland County i NO. _ ATTORNEY FOR PLAINTIFF 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 andNotice 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 OR CANNOT AFFORD ONE, ~O TO OR TELEPHONE TEE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 800-990-9180 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 o notificacion. Ademas, la corte puede decidir a favor del demandante y requiereque 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 UNABOGADO IMMEDIATAME1TTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE Dm PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTP. A ESCRITA ABAJO PARA AVERIGUA~ DONDE Sm PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013-3387 717-249-3166 800-990-9180 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. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Bogley, Harting, Mahoney & Lebling, Inc. Assignee: The Flrs~ Pgnnsylvania Banking & Trust Company Recording Date: 02/21/69 Book: 184 Page: 744 Assignor: The First Pennsylvania Banking & Trust Company Assignee: Secretary. Of. Housing .and Urban Development Of Washington Recording Date: 12/23/85 Book: 312 Page: 788 Assignor: Secretary Of Housing and Urban Development Of Washington Assignee: Ocwen Federal Bank, FSB Recording Date: 03/16/98 Book: 571 Page: 96 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 The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 5425 Wertzville Road MUNICIPALITY/TOWNSHIP/BOROUGH: Township Of Hampden COUNTY: Cumberland DATE EXECUTED: 11/08/68 DATE RECORDED: 11/12/68 BOOK: 509 PAGE: 227 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 refuses to comply with the terms of the Note as follows: (a) (b) fail or by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; by failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage as of ~r~ncipgl of debt due and unpaid nteres~ at 6.75% from Q7/Q1/00 to 11/13/01 (~be pqr. diem interest ~c~uing on unis aebt is $.51 and :nat sum shQuld b~ added each day after 11/13/01) Title Report Court Costs !a~ticipgt~d, excluding Sheriff's ~a±e costs; scrow Overdraft/(Balance} The monthly esg~o~ on thAs 9qcount is $150.82 and :~a: sum_snouAG be added on the first or each month after 11/13/01) Late Char~es (~on~ly Ia~ qharg~.of.$1~80 .. snou£a De a~e~ on t~e ~lfteen~n of each month after 11/13/01) Total Fees Securitized Interest ~ttg~neys F~es. (a~icipated and actual o ~ or pr~nc~pa±; TOTAL $3,845.68 305.20 250.00 280.00 1,377.36 101.37 239.84 2,192.50 $8,784.23 7. The attorney's fee set forth above are in confozmity 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 $8,784.23 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Attorney for Plaintiff Attorney I.D. No. 04302 ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE iN THE TOWNSHIP OF HAMPDEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOIIRDED AND DESCRIBED IN ACCORDANCE WITH SURVEY OF ERNEST J. WALKER, REGISTERED PROFESSIONAL ENGINEER, DATED SEPTEMBER 10, 1968, AS FOLLOWS, TO WITs BEGINNING AT A POINT ON THE SOUTHEI~N LI1TE OF WERTZVILLE ROAD, ROUTE 944, WHICH POINT IS .10 MILE EAST OF RANDALL ROAD~ THENCE ALONG THE SOUTHERN LINE OF SAID ROAD, NORTH EIGHTY-NINE (89) DEGREES EAST ONE ~uRDRED TWENTY (120) FEET TO A POINT~ THENCE SOUTH FOUR (4) DEGREES TWENTY (20) MInuTES WEST TWO ~u~DRED FIFTY-EIGHT AND FORTY-NINE ONE-HUNDREDTHS (258.49) FEET TO THE NORTHERN LINE OF LANDS NOW OR LATE OF JOHN EBERSOLE~ THENCE ALONG THE SAME NORTH EIGHTY (80) DEGREES FORTY (40) MIhuTES NEST ONE ~uNDRED NINETEEN ARD NINETY-FOUR ONE-HUNDREDTHS (119.94) FEET TO THE EASTERN LINE OF LANDS NOW OR FORMERLY OF ROBERT H. NENTZ~ THENCE ALONG THE SAME NORTH FOUR (4) DEGREES TWENTY (20) MIhuTES EAST TWO HURDRED THIRTY-SIX AND EIGHTY- EIGHT ONE-~u~'DREDTHS (236.88) FEET TO THE POINT OF BEGINNING. HAVING THEREON ERECTED A TWO STORY FRAME DWELLING WITH ATTACHED BLOCK GARAGE. November 14, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default~ and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see ff FIF~MAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name.~ sddress and phone number of Consumer Credit Colmseling Agencies serving your Count. are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). 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 AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES 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 SU HIPOTECA. Page 1 of 6 EXHIBIT'A .... HOMEO~VNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: MarI~n tt. Bretz CaroI L. Bretz 5425 Wert~411e Rd. EnoIa, PA 17025 29050~75 Bogley, I-Iarting, Mahoney & Lebling, Inc. Ocwen Federal Bank, FSB HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAY3dENTS IF YOU COMPLY ~rlTH 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 I:L~.S 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 ~ 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 fi:om the date of this Notice. 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 WlTItIN TIlE NEXT (30) DAYS. IF 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 LIP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one Of the consumer credit counseling agencies 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, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property, 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 ASSISTANCE - 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 fi:om 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 list&t 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 Page 2 of 6 Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- m-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAr[, 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 ~rl~L BE DENIED. 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 THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fried bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATLrRE OF Tm*~ DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 5425 Wertzville Rd. Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following mounts are now past due: Monthly Payments of $241.00 for August 2001 through November 2001 = $964.00 Monthly Late Charges of $1.80 for August 2001 through October 2001 = $101.37 Other charges (explain/itemize): Escrow Advance $137736 Certified Mail $87.09 Property Inspection $46.50 LRS Requested BPO $95.00 Unconverted Expenses $11.25 HUD Interest Arrearage $2192.50 TOTAL AMOUNT PAST DUE: $4875.07 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): .N/A HOW TO CURE ~ DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING TttE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4875.07, 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: Mark J. Udren & Associates 1040 N. Kings Highway, Suite 500 Page 3 of 6 Chert' ~ffi, NS 08034 You can cure any other default by taking the following action within THIRTY (30) DAYS of the dale of this letter: (Do not use if not applicable.): N/A IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIR~ (30) DAYS of the date of this Notice, the lender intends to exercise 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 full pa)~nent of the total mount 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 TgIE 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 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 the THIRTY (30) DAY period, you will not be required to pay 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. If your debt has been discharged in bankruptcy without your having reaffu-med it, then lender cannot pursue this remedy. RIGHT TO CURE TRE DEFAULT PRIOR TO SHERIFF'S SALE - 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 up to one hour before the Sheriff's Sale. You may do so by paying 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 Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE Sltqe~RIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately. 6 months from the date of this Notice. 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 fred 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: Ocwen Federal Bank FSB P.O. Box 24737 West Palm Beach, FL 33416-4737 (800) 310-9229 N/A Ed Van Sciver EFFECT OF SFlle~RIFF'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 Sale, 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 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. Page 4 of 6 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. LAW OFFICES OF MARK J. UDREN /s/Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry glill: NJ 08034 (856) 482-6900 Page 5 of 6 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 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 TI-IE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAK) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTI-IER 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 COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 541-4670 Financial Counseling Services of Franldin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 FAX n/a Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 YNVCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Community Action Corem of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 Page 6 of 6 : ~. ' ']..:]. ?:' ; '! "; :i.' :'.? 301 1940 0004 6516 9452 VERIFICATION reports of Plaintiff'.s agents. this statement herein is made Pa.C.S. Section 4904 relating authorities. Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and The undersigned understands that subject to the penalties of 18 to unsworn falsification to MARK J. UDREN & ASSOCIATES SHERIFF'S RETURN - REGULAR C~SE NO: 2002-00113 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND OCWEN FEDER3kL BANK FSB VS BRETZ CAROL L ET AL ROBERT FINK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon BRETZ CAROL L the law, DEFENDANT , at 1835:00 HOURS, on the llth day of January , 2002 at 5425 WERTZVILLE ROAD ENOLA, PA 17025 WENDY BUCHER, DAUGHTER a true and attested copy of COMPLAINT by handing to - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this ~ ~ day of A.D. ; / Prothonotary So Answers: R. Thomas Kline 01/25/2002 MARK UDREN By:~ Deputy Sheriff SHERIFF'S RETURN - CA'SE NO: 2002-00113 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERIJIND OCWEN FEDERAL BANK FSB VS BRETZ CAROL L ET AL REGULAR KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BRETZ MARLIN H the DEFENDANT , at 1950:00 HOURS, at 5177 E TRINDLE ROAD MECHANICSBURG, PA 17055 MARLIN H. BRETZ on the 24th day of January , 2002 by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 24.28 Sworn and Subscribed to before me this ~ - day of -/P/rothonotary , t So Answers: R. Thomas Kline 01/25/2002 MARK UDREN By: SHERIFF'S RETURN - U.S. MAIL C~SE NO: 2002-00113 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND OCWEN FEDERAL BANK FSB VS BRETZ CAROL L ET AL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT BRETZ MARLIN H on the 25th day of January 5177 E TRINDLE ROAD MECHANICSBURG, PA 17055 , by United States Mail postage prepaid, 2002 , at 0000:00 Hours, at a true and attested copy of the attached COMPLAINT - MORT FORE Sheriff's Costs: Docketing 6.00 Postage 1.03 Affidavit .00 Surcharge 10.00 .00 17.03 So answers: R/ Thomas Kline Sheriff of Cumberland County MARK UDREN 01/25/ 00 Sworn and subscribed to before me this ~ day of J~ ~- A.D. Pro~h/onot ary 'MARK J. UDREN & ASSOCIATES BY: Mark J. Udren , Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 Ocwen Federal Bank, F.S.B. C/O Moss, Codilis, Stawiarski, Morris, Schneider & Prior, LLP P.O. Box 24737 West Palm Beach, FL 33416-4737 Plaintiff Carol L. Bretz Marlin H. Bretz (Mortgagor) 5425 Wertzville Road Enola, PA 17025 Defendant(s) ATTOP-NEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 02-00113 Civil Term ~Rz~CIPE TO MARK SETTLED. DISCONTINUED AND ENDED TO THE PROTHONOTARY: Please mark the above captioned matter SETTLED, DISCONTINUED and ENDED, upon payment of your costs only. Mark J Udr~n , Esquire Mark J. Udren & Associates Attorney for Plaintiff Dated: