HomeMy WebLinkAbout11-6340
UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675
DANIEL S. SIEDMAN, ESQUIRE - ID #306534
HEATHER RILOFF, ESQUIRE - ID #309906
SHERNESE V. WOODBINE, ESQUIRE - ID#91209
PAIGE M. PRONOVOST, ESQUIRE - ID#309091
LEE SCHOTTENFELD, ESQUIRE - ID#91654
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings(ir udrenxom
Ocwen Loan Servicing, LLC
C/O Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Plaintiff
V.
ALEXANDRA M. GREENFIELD
236 WALTON STREET
LEMOYNE, PA 17043
MICHAEL J. GREENFIELD
236 WALTON STREET
LEMOYNE, PA 17043
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
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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.
ATTORNEY FOR PLAINTIFF
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COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
NO.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
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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
AVISO
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 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 IMMEDIATAMENTE, 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 PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
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
I. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the
legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the
current mortgagee of record, is the legal holder of the Mortgage by virtue of being
successor in interest to the current mortgagee of record, or is the legal holder of the
Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the
Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of
Mortgage, all of which have either been recorded or Plaintiff is in the process of
formalizing the actual Assignment of Mortgage in Plaintiff s favor:
Assignor: Mortgage Electronic Registration Systems, Inc. as nominee for Taylor, Bean & Whitaker
Mortgage Corp.
Assignee: Ocwen Loan Servicing, LLC
Date of Assignment:
Recorded Date:
Book/Instrument
Page:
2. Upon information and belief Defendant(s) and/or their predecessor:
Alexandra M. Greenfield & Michael J. Greenfield
(hereinafter "Defendants"), are the owners of property located at 236 Walton Street,
Lemoyne, PA 17043, by virtue of Deed dated 04/26/2005 and recorded 05/12/2005 in
Official Records Book 268 at Page 4159 of the Public Records of Cumberland County,
Pennsylvania (hereinafter the "Property").
3. On 08/03/2007, Defendant(s) and/or their predecessor:
ALEXANDRA M. GREENFIELD & MICHAEL J. GREENFIELD
promised to pay to the order of Taylor, Bean & Whitaker Mortgage Corp., the
principal sum of $ 105,950.00 payable with interest thereon provided in the Note.
4. By Mortgage dated 08/03/2007, Defendant(s) and/or their predecessor:
ALEXANDRA M. GREENFIELD & MICHAEL J. GREENFIELD
to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc.
as nominee for Taylor, Bean & Whitaker Mortgage Corp., the Property which
is the subject of this action. The Mortgage was recorded on 08/10/2007 in Official
Records Book Document No. 200731376 at Page Na . Said Mortgage is
incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal
description of the mortgage premises is attached hereto and made a part hereof.
5. Said mortgage is in default in that the payment due 12/01/2010, and all subsequent
payments have not been made, and by its terms, upon breach and failure to cure said
breach after notice, all sums secured by said Mortgage, together with the other charges
authorized by said Mortgage and itemized below, shall be immediately due.
6. After demand, the Defendant(s) continues to fail or refused 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.
The following amounts are due on the said Mortgage or modification agreement as of the
date stated below
Unpaid Principal Balance $100,880.00
Accumulated Interest $4,938.47
Accumulated Late Charges $231.35
Title Report $300.00
Property Inspection $42.00
Attorney Fees $1,300.00
Grand Total $107,691.82
The above figures are calculated as of 8/9/2011:
The interest rate is subject to adjustment if more fully described as such in the note and
mortgage. The interest rate on the subject note is at 6.37500 %. The per diem interest accruing
on this debt is $17.42 and that sum should be added each day after the above date.
The late charge is subject to adjustment if more fully described as such in the note and
mortgage. The late charge rate on the subject note should be added in accordance to the terms of
the note and mortgage charged monthly at $33.05.
7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the
subject mortgage, The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and
the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983.
Copies of the breach letters are attached hereto as Exhibit "A".
WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the
sum of $107,691.82 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDREN LAW OFFICES, P.C.
BY: -d? _-
DarJel ` fE'?Ti:fY, Es qu'7re
17 t?, 7i..) 30',,--)1534
Apr 1 2011 02:44am P013/016
03-31-' 11 13:40 FROM- T-625 P0023/0016 F-096
ALL THAT CERTAIN lot of ground.
SITUATE in the Borough of Lemoyne, Cumberland County, Pennsylvania, more particularly bounded and
described as follows, to wit:
HEO(NNING at an iron pin on the Southern side of Walton Street at the dividing fine between Lots Nos. 46
and 47 on the hereinafter mentioned plan of Lots, said point being 400 feet when measured Westwardly
from a monument at the intersection of Walnut Street and Warren Street; thence along said dividing line
South 36 degrees East, a distance of 217.80 feet to an iron pin; thence South 54 degrees West a distance of
45 feet to an iron pin; thence North 36 degrees West a distance of 217.80 feet to a point on the Southern
side of Walton Street; thence along the Southern side of Walton Street, North 54 degrees East a distance of
45 feet to a point, the place of beginning.
Parcel# 12-22-0820-065
April 11, 2011
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on vour home is in default, and the lender
intends to foreclose. S ecific information about the nature of the default is provided in
the attached paces.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) ma be able
to help to save vour home This Notice explains how the program 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 Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving
your Countv are listed at the end of this Notice If you have any questions, you may call the
Pennsylvania Hous Finance Agency toll free at 1-800-342-2397. Persons with im aired
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 ADJUNTO 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.
EXHIBIT A
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER:
Michael J, Greenfield
Alexandra M. Greenfield
.y236 Walton Street
_ Lemoyne, PA 17043
71559116
_ Ta lor, Bean & Whitaker Mortgage Corporation
Ocwen Loan Servicing LC
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 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 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.
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 this 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 THIRTY-THREE (33) DAYS OF THE DATE OF THIS
NOTICE. 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 UP 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 properly
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.) 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 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING,
THEN THE LENDER WELL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP
APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WELL 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 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.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date)
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at:
236 Walton Street
Lemoyne, PA 17043
IS SERIOUSLY IN 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 $660.99 fo_r_December _1, 2010 through April 1? 2011 = $_3304.95_
Monthly Late Charges of $33.05 for December 1, 2010 thronh A?ri1?6, 2011 = $132.20
Other charges (explai lwit &): Property Inspection $- 11.50
TOTAL AMOUNT PAST DUE: $3468.65
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 $3468.65 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 pavable and sent to:
Udren Law Offices, P.C.
Woodcrest Corporate Center
III 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.): 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 tender intends to exercise its riehts to accelerate the mortQas!
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 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 attornev'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, 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
Sheriffs 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 SHERIFF'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 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: Ocwen_ Loan Servicing
Address: 12650 Ingenuity Drive
Orlando, FL 32826
Phone Number: 1-877-596-8580
Fax Number: 1407-737-5693
Contact Person: Customer Service
E-Mail Address:
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the
lender at any time.
ASSUMPTION OF 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.
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
Wooderest Corporate Center
111 Wooderest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 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 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 TREE 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
Cumberland County
HEMlAP Consumer Credit Counseling Agencies
CUMBERLAND County
Report last updated: 1011 512007 10:03:08 AM
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Lingiestown Road
Harrisburg, PA 17102
888.51 1.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
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VERIFICATION
The undersigned, hereby states that he/she is the attorney for the Plaintiff, 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 Plaintiffs 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 OF C.
BY:.-EN
- .?
DanieI S. Sied!mGn, EsgLii,c!
PA ID J06 '1- 34
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860 c?
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 o
DANIEL S. SIEDMAN, ESQUIRE - ID #306534 rMco =-n
rn-
HEATHER RILOFF
, ESQUIRE - ID #309906 c -?, r-
SHERNESE V. WOODBINE, ESQUIRE - ID#91209
r
o ern
C:°
PAIGE M. PRONOVOST, ESQUIRE - ID#309091 . ?°
LEE SCHOTTENFELD, ESQUIRE - ID#91654
WOODCREST CORPORATE CENTER
u `d` i
111 WOODCREST ROAD, SUITE 200 + r?
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings(&..udren.com
Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS
1661 Worthington Road #100, West Palm CIVIL DIVISION
Beach, FL 33409 CUMBERLAND County
Plaintiff
v.
NO.// 6 3yo 6-wl /C t m
ALEXANDRA M. GREENFIELD
236 WALTON STREET
LEMOYNE, PA 17043
MICHAEL J. GREENFIELD
236 WALTON STREET
LEMOYNE, PA 17043
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, Sherri J.
Braunstein, Esquire; Daniel S. Siedman, Esquire; Heather Riloff, Esquire, Shernese V.
Woodbine, Esquire; Paige M. Pronovost, Esquire; Lee Schottenfeld, Esquire; on behalf of
the Plaintiff, in the above-captioned matter.
UDREN LAW OFFICE ,
BY: L t?
T _ ?mn, Esquire
PA ICS 300-534
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILED-OFFICE
Sheriff OF THE PROTHONOTARY
???tittr ntu+nye?r
Jody S Smith
Chief Deputy s 2011 AUG 23 PM 3: 36
Richard W Stewart CUMBERLAND COUNTY
Solicitor OFPLa, '-E $-ERiFF PENNSYLVANIA
Ocwen Loan Servicing, LLC Case Number
vs.
Alexandra Greenfield (et al.) 2011-6340
SHERIFF'S RETURN OF SERVICE
08/18/2011 03:39 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August
18, 2011 at 1539 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Alexandra Greenfield, by making known unto Michael Greenfield,
Husband of Defendant at 236 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043 its
contents and at the same time handing to him personally the said true and co a opy of the same.
ffl?_F!P_BARRICK, DE TY
08/18/2011 03:39 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August
18, 2011 at 1539 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Michael Greenfield, by making known unto himself personally, at 236
Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time
handing to him personally the said true and correct copy of the same.
MICHAEL BARRIC , DEPUTY
SHERIFF COST: $60.00
August 19, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
;c) CxmtySuite Shentf, Te'eosa`t, inc-
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
Ocwen Loan Servicing, LLC : COURT OF COMMON PLEAS
1661 Worthington Road # 100 : CIVIL DIVISION
West Palm Beach, FL 33409 : Cumberland County -?
Plaintiff -
V. : NO. 11-6340-Civil Term ='-" _,1r
Alexandra M. Greenfield
Michael J. Greenfield .? o' -4c:;
236 Walton Street :-
Lemoyne, PA 17043
Defendant (s) =C
_
ms
-
iI
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE s
. F
S "
TO THE PROTHONOTARY:
Kindly mark the above DISCONTINUED WITHOUT PREJUDICE,
upon payment of your costs only.
DATED: September 19, 2011
Attorney for Plai
11030777-1