HomeMy WebLinkAbout11-8531RICHARD F. STERN, ESQUIRE (03315)
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
THOMAS E. SHEA, ESQUIRE (64384)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
_ FILE -OFFICL
F THE PROTHONOTARY,
2011 NOV 14 PM 2: 4 3
PENN YLVAN A TY
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
v.
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
Defendant(s)
Civil Action Number:
// - ``353
a 10 t. ? '*-7&P-r1
COMPLAINT IN
MORTGAGE FORECLOSURE
CIVIL ACTION - MORTGAGE FORECLOSURE
This is an attempt to collect a debt and any information obtained will be used for that purpose.
NOTICE
You have been sued in Court. If you wish to defend the claims set forth in the following pages, you
must take action within twenty (20) days after this Civil Action and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil Action or
for any other claim or relief requested by the plaintiff. You may lose money or property of other rights
important to you. 492 0
PL444y
J:\Altisource\Complaini.s\Kraber Complaint PA 10.20.201 Ldocx 1:-? P [+ L Q
YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\Altisource\Complaints\Kraber Complaint PA 10.20.2011.docx
RICHARD F. STERN, ESQUIRE (03315)
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
THOMAS E. SHEA, ESQUIRE (64384)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
v.
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
Defendant(s)
Civil Action Number:
COMPLAINT IN
MORTGAGE FORECLOSURE
CIVIL ACTION - MORTGAGE FORECLOSURE
This is an attempt to collect a debt and any information obtained will be used for that purpose.
NOTICE
NOTICE
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
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 asentar una comparencia escrita o en
persona o con un abogado y entrel?ar a la
J:\Altisource\Complaints\Kraber Complaint PA 10.20.2011.docx
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 A
LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, OR CANNOT AFFORD ONE, GO
TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP. 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.
corte en forma escrita sus defensas o sus
objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se
defiende, 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 a otros
derechos importantes para usted.
Lleva esta demanda a un abogado
inmediatamente. 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.
Lawyer Referral and Information Service
(Asociacion de Licenciados
Servicio de Referencia e Informacion Legal)
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
J:\Altisource\ComplaintsXraber Complaint PA 10.20.2011.docx
NOTICE
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ.,
YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU
DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN
VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL
CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT
WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN
ADMISSION OF LIABILITY BY YOU.
IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE
COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE
OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE
MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION
OF THIS DEBT.
THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT
TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
J:\Altisource\Complaints\Kraber Complaint PA 10.20.2011.docx
RICHARD F. STERN, ESQUIRE (03315)
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
THOMAS E. SHEA, ESQUIRE (64384)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
v.
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
Defendant(s)
Civil Action Number:
COMPLAINT IN
MORTGAGE FORECLOSURE
COMPLAINT
CIVIL ACTION - MORTGAGE FORECLOSURE
1. Plaintiff is HSBC Bank USA, N.A., as Indenture Trustee for the registered Noteholders of
Renaissance Home Equity Loan Trust 2007-2, by its attorney infact, Ocwen Loan
Servicing, LLC. (hereinafter referred to as "HSBC Bank USA, N.A., as Indenture, by its
attorney infact, Ocwen Loan Servicing, LLC")with offices located at 1661 Worthington
Road, Suite 100 , West Palm Beach, FL 33409.
2. Defendant(s) are Craig Kraber and Maija Kraber, adult individuals with a last-known
address of 2193 Bradford Drive, Mechanicsburg, PA 17055-5799 and 328 E Meadow Dr,
Mechanicsburg, PA 17055-5187.
J:\Altisource\Complaints\Kraber Complaint PA 10.20.2011.docx
3. Under date of 03/27/2007, defendants executed and delivered to MERS, Inc. as nominee
for Fidelity Mortgage a division of Delta Funding Corporation a mortgage upon the
property 2193 Bradford Drive, Mechanicsburg, PA (the "Property")to secure the payment
of the sum of $234,500.00. The said mortgage is recorded in the Office for the Recording
of Deeds in and for Cumberland County on 04/09/2007 at Book No: 1988 & Page No:
0204 and is incorporated herein by reference as though set forth at length herein. A copy
of the mortgage and legal description of the Property is attached hereto and made a part
hereof as Exhibit "A".
4. An assignment dated June 26, 2007 transferring the mortgage originally with MERS, Inc.
as nominee for Fidelity Mortgage a division of Delta Funding Corporation (Originating
Lender) to HSBC Bank USA, N.A., as Indenture Trustee for the registered Noteholders of
Renaissance Home Equity Loan Trust 2007-2, was duly recorded on 07/15/2010 at Inst
No: '201019068 in the Office of the Recorder of Deeds of Cumberland County,
Pennsylvania.
5. Said Defendant(s) are the real owners of Property 2193 Bradford Drive, Mechanicsburg,
PA 17055.
6. In accordance with Act 91 of 1983, as amended, a combined notice providing the
information required by §403 of Act No. 6 of 1974, and Act 91, aforesaid, was sent to the
defendants and no response was made in the appropriate period of time. A true and
correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit
«B",
7. The said loan is in default as a result of the failure to pay the monthly installments of
$1,759.14 due on July 1, 2011 and on the same day of each month thereafter.
8. The following is due on the loan:
PRINCIPAL BALANCE .......................................................$249,356.26
INTEREST accrued thru 10/20/2011 of ...............................$5,067.38
Interest after 10/20/2011 shall accrue at the per diem
rate of $36.40.)
LATE CHARGES accrued thru 10/20/2011 of .....................$253.80
Late charges after 10/20/2011 shall accrue at the monthly
rate of $63.45.)
ESCROW ADVANCES ........................................................$1,859.49
FEES BILLED .......................................................................$35.50
COSTS ................................................................................... $300.00
ATTORNEY'S FEE .............................................................. $7,000.00
TOTAL .................................................................................. $263,872.43
J:\Altisource\Complaints\Kraber Complaint PA 10.20.2011 docx
The attorney fees 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 Sheriffs Sale. If the
mortgage is reinstated prior to Sale, reasonable attorney fees will be charged based on work actually
performed.
J:\Altisource\Complaints\Kraber Complaint PA 10,20.2011.docx
WHEREFORE, Plaintiff, HSBC Bank USA, N.A., as Indenture, by its attorney infact,
Ocwen Loan Servicing, LLC requests this Court to enter judgment for foreclosure of the mortgaged
property for the sum of $249,356.26 plus interest thereon of $5,067.38 plus $36.40 per day from
10/20/2011 until judgment is paid in full, late charges of $253.80, plus late charges of $63.45 per
month from 10/20/2011 until judgment is paid in full,escrow advances of $1,859.49,fees billed of
$35.50,costs of $300.00,attorney's fees of $7,000.00and all other amounts set forth above, less any
suspense as set forth above, together with record costs and any other amounts that accrue over the
course of the instant matter and to which Plaintiff is entitled to recover.
STERN & EISENBERG, PC
s
BY:
RD F. STERN, ESQ. (OF COUNSEL)
T-rVEN K. EISENBERG, ESQUIRE
KEVIN P. DISKIN, ESQUIRE
? THOMAS E. SHEA, ESQUIRE
? JOSEPH K. REJENT, ESQUIRE
Attorney for Plaintiff
Date: October 20, 2011
VERIFICATION
I, the undersigned, an authorized representative on behalf of, HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC. ("Plaintiff'), am authorized to make this verification on behalf of Plaintiff and hereby
certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and
belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business
records regularly created, kept and maintained in the course of Plaintiff s mortgage servicing business conducted on
Plaintiff's behalf.
In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written
statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do not
believe to be true or which I know to be false.
Date: --w 1 1
Name: Meiiette Noonan
Title: on m ?ment Co dkWor
HSBC Bank USA, N.A., as Indenture Trustee for the
registered Noteholders of Renaissance Home Equity Loan
Trust 2007-2, by its attorney infact, Ocwen Loan Servicing,
LLC.
SAResidential ServicingContract ManagementO. Affidavits\Affidavits 10-26-11\Ocwen\AFFPLD\Exhibit\103359436COM.doc
Nr3?F.i P. ZIEr.LER
C; 17 C r
2007 BPR 9 PN 1 16
After Recording Return To:
Fidelity Mortgage SOUTHEAST EQUITY TITLE
1040 W d PO. Sm 2W
Woodbury, N ork 11797
Attention: on Control Dept 3rd floor. &ftMik OW 45331
[Space Above This Line For Recording Datal _
MORTGAGE
LENDER, (Fidelity Mortgage a division of Delta Funding Corporation)
LOAN #: 0103359436
NOMINEE: MERS, MIN Number#:100076600001084130
DEFINITIONS
Words used in multiple sections of this document are defined below and other words are defined
in Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this
document are also provided in Section 15.
(A) "Security Instrument" means this document, which is dated Marcie 27th, 2007 together
with all Riders to this document.
(B) "Borrower" is CRAIG KRABER, MAIdA KRABER. Borrower is the mortgagor
under this Security Instrument. FIuSgF iwtcr
(C) "MERS" is Mortgage Electronic Registration Systems, Inc. MERS is a separate
corporation that is acting solely as a nominee for Lender and Lender's successors and assigns.
MERS is the mortgagee under this Security Instrument. MERS is organized and existing
under the laws of Delaware, and has an address and telephone number of P.O. Box 2026, Flint,
MI 48501-2026, tel. (888) 679-MERS.
(D) "Leader" is Fidelity Mortgage a division of Delta Funding Corporation. Lender is a
corporation or association organized and existing under the laws of New York. Lender's address
is 1000 Woodbury Road , Woodbury, New York 11797.
(E) "Note" means the promissory note signed by Borrower and dated March 27th, 2007. The
Note states that Borrower owes Lender two hundred thirty-four thousand five hundred Dollars
(U.S.S234,500.00) plus interest. Borrower has promised to pay this debt in regular Periodic
Payments and to pay the debt in full not later than May 1st, 2028.
(F) "Property" means the property that is described below under the heading "Transfer of
Rights in the Property."
PENNSYLVANIA-single Famiy-Fasidc M*dFrv&k Mac UNMRM O rrtuMErrr Form M" 1101 (per r ¦j16
pdw-) (M its)
81(I 988P60204
(G) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and
late charges due under the Note, and all sums due under this Security Instrument, plus interest.
(H) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The
following Riders are to be executed by Borrower [check box as applicable]:
? Adjustable Rate Rider ? Condominium Rider
El Balloon Rider ? Planned Unit Development Rider ? other Home Rider
other( s) [spec?
? 1-4 Family Rider ? Biweekly Payment Rider
(1) "Applicable Law" means all controlling applicable federal, state and local statutes,
regulations, ordinances and administrative rules and orders (that have the effect of law) as well
as all applicable final, non-appealable judicial opinions.
W "Community Association Dues, Fees, and Assessments" means all dues, fees,
assessments and other charges that are imposed on Borrower or the Property by a condominium
association, homeowners association or similar organization.
(K) "Electronic Funds Transfer" means any transfer of funds, other than a transaction
originated by check, draft, or similar paper instrument, which is initiated through an electronic
terminal, telephonic instrument, computer, or magnetic tape so as to order, instruct, or authorize
a financial institution to debit or credit an account. Such term includes, but is not limited to,
point-of-sale transfers, automated teller machine transactions, transfers initiated by telephone,
wire transfers, and automated clearinghouse transfers.
(L) "Escrow Items" means those items that are described in Section 3.
(1VI) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or
proceeds paid by any third party (other than insurance proceeds paid under the coverages
described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or
other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (iv)
misrepresentations of, or omissions as to, the value and/or condition of the Property.
(N) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or
default on, the Loan.
(O) "Periodic Payment" means the regularly scheduled amount due for (i) principal and
interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument.
(P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. §2601 et seq.) and
its implementing regulation, Regulation X (24 C.F.R Part 3500), as they might be amended
from time to time, or any additional or successor legislation or regulation that governs the same
subject matter. As used in this Security Instrument, "RESPA" refers to all requirements and
restrictions that are imposed in regard to a "federally related mortgage loan" even if the Loan
does not qualify as a "federally related mortgage loan" under RESPA.
(Q) "Successor in. Interest of Borrower" means any party that has taken title to the Property,
whether or not that party has assumed Borrower's obligations under the Note and/or this Security
Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals,
extensions and modifications of the Note; and (ii) the performance of Borrower's covenants and
agreements under this Security Instrument and the Note.
PENNsnVAM A-Single Family-Fanffie MxWFreddk Mac VNIFORM INS7yf[7M NT
Pte)
(HERS) Form 30M 1161 (pale 2 0f 16
Bi l 98V pG020 .
For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as
nominee for Lender and Lender's successors and assigns) and to the successors and assigns of
MERS, the following described property located in the
County
of
See Property Description
which currently has the address of 2193 Bradford Drive
Mechanicsburg Pennsylvania 17055 Property Address):
Section: Block: Lot:
TOGETHER WITH all the improvements now or hereafter erected on the property, and
all easements, appurtenances, and fixtures now or hereafter a part of the property. All
replacements and additions shall also be covered by this Security Instrument. All of the
foregoing is referred to in this Security Instrument as the "Property." Borrower understands and
agrees that MFRS holds only legal title to the interests granted by Borrower in this Security
Instrument, but, if necessary to comply with law or custom, MERS (as nominee for Lender and
Lender's successors and assigns) has the right: to exercise any or all of those interests, including,
but not limited to, the right to foreclose and sell the Property; and to take any action required of
Lender including, but not limited to, releasing and canceling this Security Instrument.
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby
conveyed and has the right to mortgage, grant and convey the Property and that the Property is
unencumbered, except for encumbrances of record. Borrower warrants and will defend
generally the title to the Property against all claims and demands, subject to any encumbrances
of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and
non-uniform covenants with limited variations by jurisdiction to constitute a uniform security
instrument covering real property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late
Charges. Borrower shall pay when due the principal of, and interest on, the debt evidenced by
the Note and any prepayment charges and late charges due under the Note. Borrower shall also
pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this
Security Instrument shall be made in U.S. currency. However, if any check or other instrument
received by Lender as payment under the Note or this Security Instrument is returned to Lender
unpaid, Lender may require that any or all subsequent payments due under the Note and this
Security Instrument be made in one or more of the following forms, as selected by Lender: (a)
cash; (b) money order; (c) certified check, bank check, treasurer's check or cashiers check,
provided any such check is drawn upon an institution whose deposits are insured by a federal
agency, instrumentality, or entity; or (d) Electronic Funds Transfer.
MM"YLVAN[A-.Single Family-Fannie M OFre"k Mw UNMR M D&MUMENT For= 3M 1/01 4Mv 3 afi6
(MFRS)
Bt 1988PG0U .
Payments are deemed received by Lender when received at the location designated in the
Note or at such other location as may be designated by Lender in accordance with the notice
provisions in Section 15. Lender may return any payment or partial payment if the payment or
partial payments are insufficient to bring the Loan current. Lender may accept any payment or
partial payment insufficient to bring the Loan current, without waiver of any rights hereunder or
prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not
obligated to apply such payments at the time such payments are accepted. If each Periodic
Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied
funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan
current. If Borrower does not do so within a reasonable period of time, Lender shall either apply
such funds or return them to Borrower. If not applied earlier, such funds will be applied to the
outstanding principal balance under the Note immediately prior to foreclosure. No offset or
claim which Borrower might have now or in the fixture against Lender shall relieve Borrower
from making payments due under the Note and this Security Instrument or performing the
covenants and agreements secured by this Security Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section
2, all payments accepted and applied by Lender shall be applied in the following order of
priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under
Section 3. Such payments shall be applied to each Periodic Payment in the order in which it
became due. Any remaining amounts shall be applied first to late charges, second to any other
amounts due under this Security Instrument, and then to reduce the principal balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
sufficient amount to pay any late charge due, the payment may be applied to the delinquent
payment and the late charge. If more than one Periodic Payment is outstanding, Lender may
apply any payment received from Borrower to the repayment of the Periodic Payments if, and to
the extent that, each payment can be paid in fWl. To the extent that any excess exists after the
payment is applied to the fill payment of one or more Periodic Payments, such excess may be
applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment
charges and then as described in the Note.
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal
due under the Note shall not extend or postpone the due date, or change the amount, of the
Periodic Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic
Payments are due under the Note, until the Note is paid in full, a sum (the "Funds") to provide
for payment of amounts due for: (a) taxes and assessments and other items which can attain
priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold
payments or ground rents on the Property, if any; (c) premiums for any and all insurance
required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums
payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in
accordance with the provisions of Section 10. These items are called "Escrow Items." At
origination. or at any time during the term of the Loan, Lender may require that Community
Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees
and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all notices
of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow items
unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Items.
PUVNWLVANIA-8m* Family--Faaa4e MftdRreddk Mac UNIFORM INSTRUMENT Form M39 t/01 (pear 4 oj76
(MFRS)
BK198,8PG02071
Lender may waive Borrower`s obligation to pay to Lender Funds for any or all Escrow Items at
any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall
pay directly, when and where payable, the amounts due for any Escrow Items for which payment
of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts
evidencing such payment within such time period as Lender may require. Borrower's obligation
to make such payments and to provide receipts shall for all purposes be deemed to be a covenant
and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is
used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver,
and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights
under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to
repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items
at any time by a notice given in accordance with Section 15 and, upon such revocation,
Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this
Section 3.
Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit
Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the
maximum amount a lender can require under RESPA. Lender shall estimate the amount of
Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow
Items or otherwise in accordance with Applicable Law.
The Funds shall be held in an institution whose deposits are insured by a federal agency,
instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so
insured) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow
Items no later than the time specified under RESPA. Lender shall not charge Borrower for
holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow
Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to
make such a charge. Unless an agreement is made in writing or Applicable Law requires interest
to be paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on
the Funds. Borrower and Lender can agree in writing, however, that interest shall be paid on the
Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as
required by RESPA.
If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall
account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of
Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by
RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in
accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of
Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by
RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in
accordance with RESPA, but in no more than 12 monthly payments.
Upon payment in full of all sums secured by this Security Instrument, Lender shall
promptly refund to Borrower any Funds held by Lender.
4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines, and
impositions attributable to the Property which can attain priority over this Security instrument
leasehold payments or ground rents on the Property, if any, and Community Association Dues,
Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall
pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security
Instrument unless Borrower. (a) agrees in writing to the payment of the obligation secured by the
lien in a manner acceptable to Lender, but only so long as Borrower is performing such
agreement;(b) contests the lien in good faith by, or defends against enforcement of the lien in,
legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while
those proceedings are pending, but only until such proceedings are concluded; or (c) secures
from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this
PENNSYLVANIA-Single Family-Finate MmWreMle Mae UNIFORM INSI RUMNT Form 3634 U81 (psde S of I6
Pam (A RS)
BK 1988PG0208
If Lender determines that any part of the Property is subject to a lien which can attain priority
over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10
days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more
of the actions set forth above in this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification
and/or reporting service used by Lender in connection with this Loan.
5. Property Insurance. Borrower shall keep the improvements now existing or hereafter
erected on the Property insured against loss by fire, hazards included within the term "extended
coverage," and any other hazards including, but not limited to, earthquakes and floods, for which
Lender requires insurance. This insurance shall be maintained in the amounts (including
deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the
preceding sentences can change during the term of the Loan. The insurance carrier providing the
insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice,
which right shall not be exercised unreasonably. Lender may require Borrower to pay, in
connection with this Loan, either: (a) a one-time charge for flood zone determination,
certification and tracking services; or (b) a one-time charge for flood zone determination and
certification services and subsequent charges each time remappings or similar changes occur
which reasonably might affect such determination or certification. Borrower shall also be
responsible for the payment of any fees imposed by the Federal Emergency Management
Agency in connection with the review of any flood zone determination resulting from an
objection by Borrower.
If Borrower fails to maintain any of the coverages described above, Lender may obtain
insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to
purchase any particular type or amount of coverage. Therefore, such coverage shall cover
Lender, but might or might not protect Borrower, Borrower's equity in the Property, or the
contents of the Property, against any risk, hazard or liability and might provide greater or lesser
coverage than was previously in effect. Borrower acknowledges that the cost of the insurance
coverage so obtained might significantly exceed the cost of insurance that Borrower could have
obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of
Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate
from the date of disbursement and shall be payable, with such interest, upon notice from Lender
to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject
to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall
name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold
the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Lender
all receipts. of paid premiums and renewal notices. If Borrower obtains any form of insurance
coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such
policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an
additional loss payee.
FZMSYLVArOA_Sk%1c Family-Fueie MwFre6dle Mae UN FORM {lVMUMEW Furor 30" 1191 b 6 e 16
PM3e1 (MEW +ad? t
OK 1988PG0209
In. the event of loss, Borrower shall give prompt notice to the insurance carrier and
Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and
Borrower otherwise agree in writing, any insurance proceeds, whether or not the underlying
insurance was required by Lender, shall be applied to restoration or repair of the Property, if the
restoration or repair is economically feasible and Lender's security is not lessened. During such
repair and restoration period, Lender shall have the right to hold such insurance proceeds until
Lender has had an opportunity to inspect such Property to ensure the work has been completed
to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may
disburse proceeds for the repairs and restoration in a single payment or in a series of progress
payments as the work is completed. Unless an agreement is made in writing or Applicable Law
requires interest to be paid on such insurance proceeds, Lender shall not be required to pay
Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third
parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole
obligation of Borrower. If the restoration or repair is not economically feasible or Lender's
security would be lessened, the insurance proceeds shall be applied to the sums secured by this
Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such
insurance proceeds shall be applied in the order provided for in Section 2.
If Borrower abandons the Property, Lender may file, negotiate and settle any available
insurance claim and related matters. If Borrower does not respond within 30 days to a notice
from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate
and settle the claim. The 30-day period will begin when the notice is given. In either event, or if
Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender
(a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid
under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the
right to any refund of unearned premiums paid by Borrower) under all insurance policies
covering the Property, insofar as such rights are applicable to the coverage of the Property.
Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts
unpaid under the Note or this Security Instrument, whether or not then due.
b. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's
principal residence within 60 days after the execution of this Security Instrument and shall
continue to occupy the Property as Borrower's principal residence for at least one year after the
date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be
unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's
control.
7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower
shall not destroy, damage or impair the Property, allow the Property to deteriorate or commit
waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall
maintain the Property in order to prevent the Property from deteriorating or decreasing in value
due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not
economically feasible, Borrower shall promptly repair the Property if damaged to avoid further
deterioration or damage. If insurance or condemnation proceeds are paid in connection with
damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring
the Property only if Lender has released proceeds for such purposes. Lender may disburse
proceeds for the repairs and restoration in a single payment or in a series of progress payments
as the work is completed If the insurance or condemnation proceeds are not sufficient to repair
or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of
such repair or restoration.
PENNSYLVANIA-Single Family--F4asle MadFreddle Moe UNIFORM INFMUMLWT Farm 3034 1/01 (peae 7 ojl6
Pte) (MFIM
BK t 988FGQ218
Lender or its agent may make reasonable entries upon and inspections of the Property. If
it has reasonable cause, Lender may inspect the interior of the improvements on the property.
Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying
such reasonable cause.
S. Borrower's Loan Application. Borrower shall be in default if, during the Loan
application process, Borrower or any persons or entities acting at the direction of Borrower or
with Borrower's knowledge or consent gave materially false, misleading, or inaccurate
information or statements to Lender (or failed to provide Lender with material information) in
connection with the Loan. Material representations include, but are not limited to,
representations concerning Borrower's occupancy of the Property as Borrower's principal
residence.
9. Protection of Lender's Interest in the Property and Rights Under this Security
Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this
Security Instrument, (b) there is a legal proceeding that might significantly affect Lender's
interest in the Property and/or rights under this Security Instrument (such as a proceeding in
bankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain
priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has
abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate
to protect Lender's interest in the Property and rights under this Security Instrument, including
protecting and/or assessing the value of the Property, and securing and/or repairing the Property.
Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien which
has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable
attorneys' fees to protect its interest in the Property and/or rights under this Security Instrument,
including its secured position in a bankruptcy proceeding. Securing the Property includes, but is
not limited to, entering the Property to make repairs, change locks, replace or board up doors and
windows, drain water from pipes, eliminate building or other code violations or dangerous
conditions, and have utilities turned on or off. Although Lender may take action under this
Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is
agreed that Lender incurs no liability for not taking any or all actions authorized under this
Section 9.
Any amounts disbursed by Lender under this Section 9 shall become additional debt of
Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate
from the date of disbursement and shall be payable, with such interest, upon notice from Lender
to Borrower requesting payment
If this Security Instrument is on a leasehold, Borrower shall comply with all the
provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee
title shall not merge unless Lender agrees to the merger in writing.
Borrower shall not surrender the leasehold estate and interests herein conveyed or
terminate or cancel the ground lease- Borrower shall not, without the express written consent of
Lender, alter or amend the ground lease.
10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of
making the Loan, Borrower shall pay the premiums required to maintain the Mortgage Insurance
in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be
available from the mortgage insurer that previously provided such insurance and Borrower was
required to make separately designated payments toward the premiums for Mortgage Insurance,
Borrower shall pay the premiums required to obtain coverage substantially equivalent to the
Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to
Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer
selected by Lender.
PENNSYLVANIA-Single Family-Fanale MaaWreddk Mac UNIFORM DMMUMEw Form 3939 1/'91 (vW d #f16
P*9-) (MW
B{ 1 9V V! 6O2 I
If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall
continue to pay to Lender the amount of the separately designated payments that were due when
the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments
as a nonrefundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be
non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall
not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no
longer require loss reserve payments if Mortgage Insurance coverage (in the amount and for the
period that Lender requires) provided by an insurer selected by Lender again becomes available,
is obtained, and Lender requires separately designated payments toward the premiums for
Mortgage Insurance. If Lender required Mortgage Insurance as a condition of malting the Loan
and Borrower was required to make separately designated payments toward the premiums for
Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage Insurance
in effect, or to provide a nonrefundable loss reserve, until Lender's requirement for Mortgage
Insurance ends in accordance with any written agreement between Borrower and Lender
providing for such termination or until termination is required by Applicable Law. Nothing in
this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain
losses it may incur if Borrower does not repay the Loan as agreed Borrower is not a party to the
Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to
time, and may enter into agreements with other parties that share or modify their risk, or reduce
losses. These agreements are on terms and conditions that are satisfactory to the mortgage
insurer and the other party (or parties) to these agreements. These agreements may require the
mortgage insurer to make payments using any source of funds that the mortgage insurer may
have available (which may include funds obtained from Mortgage Insurance premiums).
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any
reinsurer, any other entity, or any affiliate of any of the foregoing, may receive (directly or
indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's
payments for Mortgage Insurance, in exchange for sharing or modifying the mortgage insurer's
risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of
the insurer's risk in exchange for a share of the premiums paid to the insurer, the arrangement is
often termed "captive reinsurance." Further:
(a) Any such agreements will not affect the amounts that Borrower has agreed to
pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not
increase the amount Borrower will owe for Mortgage Insurance, and they will not entitle
Borrower to any refund.
(b) Any such agreements will not affect the rights Borrower has -- if any - with
respect to the Mortgage Insurance under the Homeowners Protection Act of 1998 or any
other law. These rights may include the right to receive certain disclosures, to request and
obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated
automatically, and/or to receive a refund of any Mortgage Insurance premiums that were
unearned at the time of such cancellation or termination.
11. Assignment of Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds
are hereby assigned to and shall be paid to Lender.
PENNSYLVANIA-Single Family-Fasa[e Mae/Freddie Mac UNIFORM UIMMUMENT Form 3039 1081 &"e 9 #f 16
(MERS)
If the Property is damaged, such Miscellaneous proceeds shall be applied to restoration
or repair of the Property, if the restoration or repair is economically feasible and Lender's
security is not lessened. During such repair and restoration period, Lender shall have the right to
hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property
to ensure the work has been completed to Lender`s satisfaction, provided that such inspection
shall be undertaken promptly. Lender may pay for the repairs and restoration in a single
disbursement or in a series of progress payments as the work is completed Unless an agreement
is made in writing or Applicable Law requires interest to be paid on such Miscellaneous
Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such
Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's
security would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by
this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such
Miscellaneous Proceeds shall be applied in the order provided for in Section Z.
In the event of a total taking, destruction, or loss in value of the Property, the
Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument,
whether or not then due, with the excess, if any, paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the
fair market value of the Property immediately before the partial taking, destruction, or loss in
value is equal to or greater than the amount of the sums secured by this Security Instrument
immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender
otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the
amount of the Miscellaneous Proceeds multiplied by the following fraction: (a) the total amount
of the suers secured immediately before the partial taking, destruction, or loss in value divided
by (b) the fair market value of the Property immediately before the partial taking, destruction, or
loss in value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the
fair market value of the Property immediately before the partial taking, destruction, or loss in
value is less than the amount of the sums secured immediately before the partial taking,
destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the
Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument whether
or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that
the Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for
damages, Borrower fails to respond to Lender within 30 days after the date the notice is given,
Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or
repair of the Property or to the sums secured by this Security Instrument, whether or not then
due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the
party against whom Borrower has a right of action in regard to Miscellaneous Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is
begun that., in Lender's judgment, could result in forfeiture of the Property or other material
impairment of Lender's interest in the Property or rights under this Security Instrument.
Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in
Section 19, by causing the action or proceeding to be dismissed with a ruling that, in Lender's
judgment, ;precludes forfeiture of the Property or other material impairment of Lender's interest
in the Property or rights under tlris Security Instrument. The proceeds of any award or claim for
damages that are attributable to the impairment of Lender's interest in the Property are hereby
assigned and shall be paid to Lender.
PM-) SV LYAMA•-SuWk Family-Famde M*&Tre"k Mot UNWORM INSTRUMENT Form" 1181 ONW I i em
(MERS)
OK 1 l V V`t U V G j 3
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property
shall be applied in the order provided for in Section 2.
12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the
time for payment or modification of amortization of the sums secured by this Security
Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not
operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender
shall not be required to commence proceedings against any Successor in Interest of Borrower or
to refuse to extend time for payment or otherwise modify amortization of the sums secured by
this Security Instrument by reason of any demand made by the original Borrower or any
Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or
remedy including, without limitation, Lender's acceptance of payments from third persons,
entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall
not be a waiver of or preclude the exercise of any right or remedy.
13. Joint and Several Liability; Co-sipers; Successors and Assigns Bound.
Borrower covenants and agrees that Borrower's obligations and liability shall be joint and
several. However, any Borrower who co-signs this Security Instrument but does not execute the
Note (a "co-signer"): (a) is co-signing this Security Instrument only to mortgage, grant and
convey the co-signer's interest in the Property under the terms of this Security Instrument; (b) is
not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that
Lender and any other Borrower can agree to extend, modify, forbear or make any
accommodations with regard to the terms of this Security Instrument or the Note without the
co-signer's consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who
assumes Borrower's obligations under this Security Instrument in writing, and is approved by
Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument.
Borrower shall not be released from Borrower's obligations and liability under this Security
Instrument unless Lender agrees to such release in writing. The covenants and agreements of this
Security Instrument shall bind (except as provided in Section 20) and benefit the successors and
assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in
connection with Borrower's default, for the purpose of protecting Lender's interest in the
Property and rights under this Security lnstrument, including, but not limited to, attorneys' fees,
property inspection and valuation fees. In regard to any other fees, the absence of express
authority in this Security Instrument to charge a specific fee to Borrower shall not be construed
as a prohibition on the charging of such fee. Lender may not charge fees that are expressly
prohibited by this Security Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally
interpreted so that the interest or other loan charges collected or to be collected in connection
with the Loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the
amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected
from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may
choose to make this refund by reducing the principal owed under the Note or by making a direct
payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial
prepayment without any prepayment charge (whether or not a prepayment charge is provided for
under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower
will constitute a waiver of any right of action Borrower might have arising out of such
overcharge.
PENNSYLVANIA-S rot Family-Female MaeJFreddie Mae UNIFORM IIV TRUMgNT Farza 30" 1,41 (fie 71 oj76
(MERS)
BKto88PS0214
15. Notices. All notices given by Borrower or Lender in connection with this Security
Instrument must be in writing. Any notice to Borrower in connection with this Security
Instrument shall be deemed to have been given to Borrower when mailed by first class mail or
when actually delivered to Borrower's notice address if sent by other means. Notice to any one
Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires
otherwise. The notice address shall be the Property Address unless Borrower has designated a
substitute notice address by notice to Lender. Borrower shall promptly notify Lender of
Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change
of address, then Borrower shall only report a change of address through that specified procedure.
There may be only one designated notice address under this Security Instrument at any one time.
Any notice to Lender shall be given by delivering it or by mailing it by first class mail to
Lender's address stated herein unless Lender has designated another address by notice to
Borrower. Any notice in connection with this Security Instrument shall not be deemed to have
been given to Lender until actually received by Lender. If any notice required by this Security
Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy
the corresponding requirement under this Security Instrument.
16. Governing Law; Severability; Rules of Construction. This Security Instrument
shall be governed by federal law and the law of the jurisdiction in which the Property is located.
All rights and obligations contained in this Security Instrument are subject to any requirements
and limitations of Applicable Law. Applicable Law might explicitly or implicitly allow the
parties to agree by contract or it might be silent, but such silence shall not be construed as a
prohibition against agreement by contract. In the event that any provision or clause of this
Security Instrument or the Note conflicts with Applicable Law, such conflict shall not affect
other provisions of this Security Instrument or the Note which can be given effect without the
conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and
include corresponding neuter words or words of the feminine gender; (b) words in the singular
shall mean and include the plural and vice versa; and (c) the word "may" gives sole discretion
without any obligation to take any action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security
Instrument.
18. Transfer of the Property or a Beneficial Interest In Borrower. As used in this
Section 18, "Interest in the Property" means any legal or beneficial interest in the Property,
including, but not limited to, those beneficial interests transferred in a bond for deed, contract for
deed, installment sales contract or escrow agreement, the intent of which is the transfer of title
by Borrower at a future date to a purchaser.
If all. or any part of the Property or any Interest in the Property is sold or transferred (or if
Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred)
without Lender's prior written consent, Lender may require immediate payment in full of all
sums secured by this Security Instrument. However, this option shall not be exercised by Lender
if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shalt give Borrower notice of acceleration. The
notice shall provide a period of not less than 30 days from the date the notice is given in
accordance with Section 15 within which Borrower must pay all sums secured by this Security
Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may
invoke any remedies permitted by this Security Instrument without further notice or demand on
Borrower.
PENNSYLVANIA-Single Family-Faank Mew7reddk Mw UNWOBM TNg=UMEW Fwm 3035 1/$1 owr JI oj76
P"-) (MRS)
B{ 1988K0215
19. Borrower's Right to Reinstate After Acceleration If Borrower meets certain
conditions, Borrower shall have the right to have enforcement of this Security Instrument
discontinued at any time prior to the earliest of. (a) five days before sale of the Property pursuant
to any power of sale contained in this Security Instrument; (b) such other period as Applicable
Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment
enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums
which then would be due under this Security Instrument and the Note as if no acceleration had
occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses
incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys'
fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting
Lender's interest in the Property and rights under this Security Instrument; and (d) takes such
action as Lender may reasonably require to assure that Leader's interest in the Property and
rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this
Security Instrument, shall continue unchanged. Lender may require that Borrower pay such
reinstatement sums and expenses in one or more of the following forms, as selected by Lender:
(a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check,
provided any such check is drawn upon an institution whose deposits are insured by a federal
agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by
Borrower, this Security Instrument and obligations secured hereby shall remain fully effective as
if no acceleration had occurred. However, this right to reinstate shall not apply in the case of
acceleration under Section 18.
20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial
interest in the Note (together with this Security Instrument) can be sold one or more times
without prior notice to Borrower. A sale might result in a change in the entity (known as the
"Loan Servicer") that collects Periodic Payments due under the Note and this Security
Instrument and performs other mortgage loan servicing obligations under the Note, this Security
Instrument, and Applicable Law. There also might be one or more changes of the Loan Servicer
unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given
written notice of the change which will state the name and address of the new Loan Servicer, the
address to which payments should be made and any other information RESPA requires in
connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is
serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing
obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan
Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note
purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as
either an individual litigant or the member of a class) that arises from the other party's actions
pursuant to this Security Instrument or that alleges that the other party has breached any
provision of, or any duty owed by reason of, this Security Instrument, until such Borrower or
Lender has notified the other party (with such notice given in compliance with the requirements
of Section 15) of such alleged breach and afforded the other party hereto a reasonable period
after the giving of such notice to take corrective action. If Applicable Law provides a time period
which must elapse before certain action can be taken, that time period will be deemed to be
reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure
given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower
pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective
action provisions of this Section 20.
?NSVLVANM-Single Fmnily--Famde MaaWr"Wh Mae UNIMRM INSMUMEW Form" JAI 6vW M of16
BX 198 8 PS Q 216
21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are
those substances defined as toxic or hazardous substances, pollutants, or wastes by
Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic
petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing
asbestos or formaldehyde, and radioactive materials; (b) "Environmental Law" means federal
laws and laws of the jurisdiction where the Property is located that relate to health, safety or
environmental protection; (c) "Environmental Cleanup" includes any response action, remedial
action, or removal action, as defined in Environmental Law; and (d) an "Environmental
Condition" means a condition that can cause, contribute to, or otherwise trigger an
Environmental Cleanup.
Borrower shall not cause or permit the presence, use, disposal, storage, or release of any
Hazardous Substances, or threaten to release any Hazardous Substances, on or in the property.
Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a) that is in
violation of any Environmental Law, (b) which creates an Environmental Condition, or (c)
which, due to the presence, use, or release of a Hazardous Substance, creates a condition that
adversely affects the value of the Property. The preceding two sentences shall not apply to the
presence, use, or storage on the Property of small quantities of Hazardous substances that are
generally recognized to be appropriate to normal residential uses and to maintenance of the
Property (including, but not limited to, hazardous substances in consumer products).
Borrower shall promptly give Lender written notice of (a) any investigation, claim,
demand, lawsuit or other action by any governmental or regulatory agency or private party
g perry and any Hazardous Substance or Environmental Law of which Borrower
has actual knowledge, (b) any Environmental Condition, including but not limited to, any
spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any
condition caused by the presence, use or release of a Hazardous Substance which adversely
affects the value of the Property. If Borrower learns, or is notified by any governmental or
regulatory authority, or any private party, that any removal or other remediation of any
Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all
necessary remedial actions in accordance with Environmental Law. Nothing herein shall create
any obligation on Lender for an Environmental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender finther covenant and agree as
follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to
acceleration following Borrower's breach of any covenant or agreement in this Security
Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides
otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the
action required to cure the default; (c) when the default must be cured; and (d) that failure
to cure the default as specified may result in acceleration of the sums secured by this
Security Instrument, foreclosure by judicial proceeding and sale of the Property, shall further inform Borrower of the the Lender
right to reinstate after acceleration and the right to
assert in the foreclosure proceeding the non-existence of a default or any other defense of
Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at
its option may require immediate payment in full of all sums secured by this Security
Instrument without further demand and may foreclose this Security Instrument by
judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the
remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs
of title evidence to the extent permitted by Applicable Law.
PENNWLVANIA- Single Family-Fanmie MoelFreddk Mae UN[FORM INMUMENT Form 30M! U61
P'e3? (peat 14 ofl6
BX ! 988PG0217
23. Release. Upon payment of all sums secured by this Security Instrument, this Security
Instrument and the estate conveyed shall terminate and become void After such occurrence,
Lender shall discharge and satisfy this Security Instrument. Borrower shall pay any recordation
costs- Lender may charge Borrower a fee for releasing this Security Instrument, but only if the
fee is paid to a third party for services rendered and the charging of the fee is permitted under
Applicable Law.
24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases
any error or defects in proceedings to enforce this Security Instrument, and hereby waives the
benefit of any present or future laws providing for stay of execution, extension of time,
exemption from attachment, levy and sale, and homestead exemption.
25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall
extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale
pursuant to this Security Instrument.
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is
lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase
money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a
judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable
from time to time under the Note.
28. I certify that address of mortgagee is 1000 Woodbury Rd., P.Q. Box 9009 Woodbury,
NY 11797
PENMYLVAi4TA-Single Family-Fannk MWFreddje Mae UNIFORM E4STRUMENT For," 3034 Uil (PW is efm
pas-)
1188PG0218
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in
this Security Instrument and in any Rider executed by Borrower and recorded with it.
Witnesses:
CRAIG
MAIJA
Seal
-Borrower
Seal
-Borrower
Seal
-Borrower
Seal
-Borrower
[Space Below This Line For Acknowledgement]
STATE OF PENNSYLVANIA, 6,?,& ?er?i of County ss :
On this 27th day of March, 2007 , before me, the undersigned, a Notary Public in and for said
County, personally appeared CRAIG KRABER, MAIJA KRABER and acknowledged the
execution of the foregoing instrument. ?tv?uZ ? w t[r
WITNESS my hand and official seal.
My commission Expires: 41a/0$
lL U ?...
Notary Public
PENNSYLVANU-Singk Family-Fuide MaeffreMe Mac UNI POM INSTRUMENT
PAV-) (MFRS)
NOVAK sm
MALWA A RICNARDNON
Notary Pubic
NORM NEWON IM,, CUMMIRLAND COUNTY
My Con niwlon ftl6 Aug 2. zoos
F- 363! 1/01 (me 16 of l6
OK 1-988P602 19
EXHIBIT "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN piece, parcel or lot of land situate in UpperAllen Township, Cumberland
County, Pennsylvania, bound and described as folk ws:
BEGINNING at a point located on the northern right of way line of Bradford Drive (50.00 feet
wide), said point being located at the southeastern comer of Lot No. 101; thence along the
eastern boundary lineof Lot No. 101 and passing through a 25.00 foot drainage easement North
01 degrees 25 minutes 55 seconds West for a distance of 125.00 feet, to a point located at the
northeastern comer of lot No. 101; thence along the northern boundaryline of Lot No. 100 and
along said 25.00 foot drainage easement North 88 degrees 34 minutes 05 seconds East for a
distance of 83.00 feet to a point located in the northwestern comer of Lot No. 99; thence along the
western boundary One of Lot No. 99 and passing through said 25.00 foot drainageeasement
South 01 degree 25 minutes 55 seconds East for a distance of 125.00 feet to a point located on
the Northern right of wayof Bradford Drive (50.00 feet wide) said point being located at the
southwestem comer of Lot No. 99; thence along the northern rightof way line of Bradford Drive
South 88 degrees 34 minutes 06 seconds West for a distance of 83.00 feet, to a point and the
place of BEGINNING.
Parcel No. 42-29-2458-102
I I'" 220
The attached Mortgage covets real property principally improved by a one to four family dwelting.
Premises commonly known as:
2193 Bradford Drive Mechanicsburg, PA 17055
DISTRICT SECTION BLOCK LOT
CRAIG
t 'citify t?lis to l:c recorded
`:1 Cumberland County PA
Recorder of Deeds
C2"W
4
CERTIFICATE OF RESIDENCE
I, ?4CV_1 x{Pt , do hereby certify that the correct address of the
within-named Mortgagee is
681 Andersen Drive, Bldg 6 / Suite 600, Pittsburgh, PA 15220,
Witness my hand this ZZ' day of , 2007.
4-)
-or ortgagee
RK1908X-0.222
Ocwen Loan Servicing, LLC
P.O. Box 24737
West Palm Beach, Florida 33416-4737
--O C W W E N N
(Do not send correspondence orpayments to the above address.) WWW.OCWEN.COM
August 30, 2011
VIA First Class Mail
VIA Certified Mail (return receipt requested)
Certified Number: 71069017515143840291
Reference Code: 1108
Maija Kraber
328 E MEADOW DR
MECHANICSBURG, PA 17055-5187
Loan Number: 103359436
Property Address: 2193 Bradford Drive, Mechanicsburg, PA 17055-0000
PLEASE SEE THE ENCLOSED DOCUMENT
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
NMLS # 1852
Ocwen Loan Servicing, LLC
P.O. Boa- 24737
.... W E N West Palm Beach, Florida 33416-4737
(Do not send correspondence orpayments to the above address.) WW\,k%.0CWEN.C0N1
August 30, 2011
APPENDIX A
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 if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN
THIRTY (30) 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 County are listed at the
end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance AQt ency toll free at
(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 NOTIFICA.CION 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 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.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CORPORATION
CURRENT LENDER/SERVICER:
Maija Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-0000
103359436
FIDELITY MORTGAGE A DIVISION OF DELTA FUNDING
OCWEN
DACT91.21
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
NMLS # 1852
Ocwen Loan Servicing, LLC
I P.O. Box 24737
- West Palm Beach, Florida 33416-4737
O C W E N
(Do not send correspondence or payments to the above address.) C- Vlrv'W.OCWEN.C0M
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH AN 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 mort a e for thirty (30) days from 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 WITHIN THE 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
UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names, 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 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 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 (Bringit up to date).
DACT91.21
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
NMLS # 1852
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.) WWW.0CWEN.C0N1
NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 2193
Bradford Drive , Mechanicsburg, PA 17055-0000
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
2 payments in the amount of $ 1,759.14 from July 01, 2011 through August 30. 2011
DETAIL SUMMARY :
Principal and Interest .................................
Interest Arrearage .....................................
Escrow ..................................................
Late Charges ...........................................
Insufficient Funds Charges ...........................
Fees / Expenses ........................................
Suspense Balance (CREDIT) ........................
Interest Reserve Balance (CREDIT) ................
TOTAL DUE ..........................................
$ 2,538.04
$ 0.00
$ 980.24
$ 190.35
$ 0.00
$ 0.00
$ 0.00
$ 0.00
$ 3,708.63
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 $3,708.63, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by Money Gram. Cashier's Check, Certified Check or Money Order made
payable and sent to:
OCWEN
P.O. BOX 6440
CAROL STREAM, IL 60197-6440
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 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 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 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 ALE - 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 herifl's ale 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 ale a 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.
DACT9121
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
NMLS # 1852
0 Ocwen Loan Servicing, LLC
P.O. Box 24737
--- - West Palm Beach, Florida 33416-4737
O C W E N
(Do not send correspondence orpayments to the above address.) WWW.nCWE COO
EARLIEST POSSIBLE SHERIFF'S SALE DATE - 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 334164737
Phone Number: 800-310-9229
Fax Number: 407-737-6300
Contact: Early Intervention Dept
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 or X may not (CHECK ONE) sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
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 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
DACT91.21
This communication is fi om 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
NMLS # 1852
Ociven,. Loan Servicing, LLC
August 30, 201 1
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) WWW.OCWEN.COtiI
VIA First Class Mail
VIA Certified Mail (return receipt requested)
Certified Number: 71069017515143840284
Reference Code: 1108
Craig Kraber
2193 bradford drive
MECHANICSBURG, PA 17055-0000
Loan Number: 103359436
Property Address: 2193 Bradford Drive, Mechanicsburg, PA 17055-0000
PLEASE SEE THE ENCLOSED DOCUMENT
DACT91.21
1 his 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
NMLS # 1852
Ocwen Loan Servicing, LLC
August 30, 201 1
P.O. Box 24737
O?L; W E N West Palm Beach, Florida 33416-4737
(Do not send correspoazdence orpayments to the above address) WWW.QCWEN.COM
APPENDIX A
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 pecific
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 if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN
THIRTY (30) 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 County are listed at the
end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at
(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 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 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.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CORPORATION
CURRENT LENDER/SERVICER:
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-0000
103359436
FIDELITY MORTGAGE A DIVISION OF DELTA FUNDING
OCWEN
DACT91.21
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
NMLS # 1852
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)
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 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 THE NEXT (30) DAY 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 agency
listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this
meeting. The names 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 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 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 ring it up to datel
DACT91.21
This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that
pu7pose. 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
WWW.OCWEN.COM
NMLS # 1852
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) «'WW.0CWLN.C0M
NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 2193
Bradford Drive , Mechanicsburg, PA 17055-0000
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following
amounts are now past due:
2 payments in the amount of $ 1,759.14 from July 01. 2011 through August 30, 2011
DETAIL SUMMARY :
Principal and Interest ................................. $ 2,538.04
Interest Anearage ..................................... $ 0.00
Escrow .................................................. $ 980.24
Late Charges ........................................... $ 190.35
Insufficient Funds Charges ........................... $ 0.00
Fees / Expenses ........................................ $ 0.00
Suspense Balance (CREDIT) ........................ $ 0.00
Interest Reserve Balance (CREDIT) ................ $ 0.00
TOTAL DUE .......................................... $ 3,708.63
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 $3,708.63, PLUS ANY
MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY
PERIOD. Payments must be made either by Money Gram, Cashier's Check, Certified Check or Money Order made
payable and sent to.
OCWEN
P.O. BOX 6440
CAROL STREAM, IL 60197-6440
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 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 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 properly.
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 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 ALE - 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 ale 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 le 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.
DACT91.21
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
NMLS # 1852
Ociven Loan Servicing, LLC
P.O. Box 24737
' O -- f: -._ W E . E N West Palm Beach, Florida 33416-4737
(Do not send correspondence or payments to the above address) WW\-V.0 WE .QQN4
EARLIEST POSSIBLE SHERIFF'S SALE DATE - 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 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 servicer.
HOW TO CONTACT THE SERVICER:
Name of ServiceL. OCWEN
Address: P.O. BOX 24737
WEST PALM BEACH, FL 334164737
Phone Number: 800-310-9229
Fax Number: 407-737-6300
Contact: Early Intervention Dept
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 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 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 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
DACT91.21
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
NMLS # 1852
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
lLc.??EJt• ?? I?
;l. THE FR0THe
2012 JAN I7 Ati11? 1?
CUMBBLAO COUNTY
HSBC Bank USA, N.A. Case Number
vs.
Craig L. Kraber (et al.) 2011-8531
SHERIFF'S RETURN OF SERVICE
11/21/2011 08:52 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on
November 21, 2011 at 2052 hours, he served a true copy of the within Complaint in Mortgage
Foreclosure, upon the within named defendant, to wit: Maija Kraber, Wbakoi known unt o herself
personally, at 328 E. Meadow Drive, Mechanicsburg, Cumberland Csyvania 17055 its
contents and at the same time handing to her personally the said tru ct copy of the same.
DEPUTY
12/01/2011 07:40 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December
1, 2011 at 1940 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Craig L. Kraber, by making known unto himself personally, at 2193
Bradford Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same
time handing to him personally the said true and correct copy of the same.
SHERIFF COST. $64.00
December 05, 2011
RYAN BURGETT, DEP
SO ANSWERS,
RON R ANDERSON, SHERIFF
!C CCUl' yStAO Sher ft, Teleos,tt. It*;
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JOSEPH K. RE.IENT, ESQUIRE (59621)
f 4
"
STERN & EISENBERG, PC r t
THE PAVILION
261 OLD YORK ROAD, SUITE 410 - .•° N ?r__''
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111 -?`
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF) -?
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Civil Action Number: 11-8531
Craig Kraber and
Maija Kraber
Defendant(s)
MORTGAGE FORECLOSURE
PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Enter judgment in favor of Plaintiff and against Defendant(s), Craig Kraber Maija Kraber, for
failure of said Defendant(s) to file a responsive pleading to the Complaint within twenty (20)
days of service thereof.
PRINCIPAL BALANCE ....................................................................$249,356.26
INTEREST accrued thru 10/20/2011 of ...........................................$5,067.38
Interest after 10/20/2011 shall accrue at the per diem
rate of $36.40.)
LATE. CHARGES accrued thru 10/20/2011 of .................................$253.80
Late charges after 10/20/2011 shall accrue at the monthly
rate of $63.45.)
ESCROW ADVANCES ....................................................................$1,859.49
FEES BILLED ...................................................................................$35.50 *11.0.!50 pt AT7-l
easy is
,A , 7o 584
W ve Oa i cl
LEGAL COSTS .................................................................................$300.00
ATTORNEY'S FEE ..........................................................................$7,000.00
Sub-Total Through Date of Complaint ........................................$263,872.43
ACCRUED INTEREST after 10/20/2011 shall accrue
at the per diem
rate of $36.40 to January 26, 2012 .....................................................$3,567.20
ACCRUED LATE CHARGES Late charges
after 10/20/2011 accruing at the monthly rate
of $63.45 through January 26, 2012 ..................................................$190.35
TOTAL DUE THROUGH DATE OF REQUEST
FOR JUDGMENT .............................................................................$267,629.98
QUIRE
? JOSEPH K. REJENT, ESQUIRE
Attorney for Plaintiff
STERN & EISENBERG, PC
BY:
STEVEN K. EISENBERG, ES
KEVIN P. DISKTN, ESQUIRE
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JOSEPH K. REJENC, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Craig Kraber
Maija Kraber
Defendant(s)
Civil Action: 11-8531
,71
,,,j
M p .-...
17 I
MORTGAGE FORECLOSURE
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF MONTGOMERY
I, the undersigned, being duly sworn according to law, deposes and says, to the best of his
knowledge, information and belief, Defendants':
1. Last-known address is
Craig Kraber, 2193 Bradford DriveMechanicsburg, PA 17055-5799
Maija Kraber, 328 E Meadow DrMechanicsburg, PA 17055-5187
2. Is over the age of twenty-one.
3. Is not now nor has been within the last six (6) months in the Armed Services of the
United States as defined in the Soldiers' Civil Relief Act of 1940, as amended.
STERN & EISENBERG, PC
BY: ?-
EVEN K. EISENBERG, ESQUIRE
VEVIN P. DISKIN, ESQUIRE
? JOSEPH K. REJENT, ESQUIRE
Attorney for Plaintiff
Sworn to and subsc ' ed before me
this Day of , 2012.
1
LC,?
Notary Public
COMMONWEALTH OF PENNSYLVAMA
NOTARIAL SEAL
HELEN CAPASSO, Notary
JwWntown Boro.. Montgomery
Commission Expires October 21,2012
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
vuamw
N4W
Jan-26-2012 12:49:13
Last First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
Name
Based on the information you have furnished, the DMDC does not possess
KRABER CRAIG any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
Y)ta, & L,.j. *r
let , rA??
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http•//www.defenselink.mil/fag/pis/PC09SLDR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Jan-26-2012 12:49:41
'._ Last
N
First/Middle
Begin Date
Active Duty Status
Active Duty End Date Service
S
ame Agency
KRABER MAIJA Based on the information you have furnished, the DMDC does not possess
any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
4WY, 14- A??_
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington., VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://www.defenselink.mil/fag/pis/PC09SLDR.htm1. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JosEPH K. RESENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
26101 D YORK ROAD
SUITE 410
,
JENKINTOWN, PENNSYLVANIA 19046 MM 'Ti °-?
TELEPHONE: (215) 572-8111 ter,
FACSIMILE: (215) 572-5025 ? ?-
(COUNSEL FOR PLAINTIFF)
mac., C
?
l
r
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
':---` r
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Craig Kraber
Maija Kraber
Defendant(s)
Civil Action: 11-8531
MORTGAGE FORECLOSURE
CERTIFICATION UNDER RULE 237.1
I, the undersigned attorney on the writ and attorney for Plaintiff, hereby certify that a ten-day
notice of intention to enter judgment by default was sent to Defendants in accordance with Pa.
R.C.P. No. 237. 1., a true and correct copy of which is attached hereto.
STERN & EISENBERG PC
BY- _
TEVEN K. EISENBERG
IRININ P. DISKIN
Attorney for Plaintiff
STERN & EISENBERG PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANLA,
CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for the
registered Noteholders of Renaissance Home Equity
Loan Trust 2007-2, by its attorney infact, Ocwen Loan
Servicing, LLC.
(Plaintiff)
V.
Docket #: 11-8531
TEN DAY NOTICE
Craig Kraber
Maija Kraber
NOTICE PURSUANT TO Pa.R.C.P. 237.1
TO:
Craig Kraber Maija Kraber
2193 Bradford Drive 328 E Meadow Dr
Mechanicsburg, PA 17055-5799 Mechanicsburg, PA 17055-5187
Date of Notice: Monday, January 9, 2012
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 (10) 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU
CAN GET LEGAL HELP:
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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
STERN ,& EJSENBERG, PC ,
By:
for Plaintiff
J:\Amanda\Ten Days\Cumb:!rlwid\Ocwen.Kraber.01.12.docx
STEVEN K. EISENBERG, ESQUIRE (75736) - -?
KEVIN P. DISKIN, ESQUIRE (86727) rv
ESQUIRE (59621)
JOSEPH K. RESENT
J r"1 e.r.:
,
STERN & EISENBERG, PC ,?
THE PAVILION
= [ -'
261 OLD YORK ROAD, SUITE 410 -
' ?r
JENKINTOWN, PENNSYLVAN[A 19046
7 Q -- '
TELEPHONE: (215) 572-8111 _
FACSIMILE: (215) 572-5025 = -t
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Craig Kraber
Maija Kraber
Defendant(s)
Civil Action: 11-8531
MORTGAGE FORECLOSURE
CERTIFICATE UNDER ACT 91 OF 1983
It is hereby certified that the Sheriffs Sale scheduled in the above-captioned matter is not
protected under the Homeowner's Emergency Assistance And Mortgage Foreclosure Act, P.L.
1688, No. 621 because notice, as required, was sent to Defendants and no timely response was
made.
ESQUIRE
DIRE
? JOSEPH K. REJENT, ESQUIRE
Attorney for Plaintiff
STERN & EISENBERG, PC
BY:
STEVEN K. EISENBERG
VIN P. DISKIN, ESQ
STEVEN K. EISENBERG, ESQUIRE (75736) ,
KEVIN P. DISKIN, ESQUIRE (86727)
" --,
I
.
JOSEPH K. REJEN"I', ESQUIRE (59621.) t
ri .
STERN & EISENBERG, PC „
Y
THE PAVILION < I
iV _
+
261 OLD YORK ROAD, SUITE 410 `r
JENKINI'OWN, PENNSYLVANIA 19046 ?.'
TELEPHONE: (215) 572-81 11 ° C7
FACSIMILE: (215) 572-5025
e
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Craig Kraber
Maija Kraber
Defendant(s)
Civil Action: 11-8531
MORTGAGE FORECLOSURE
CERTIFICATION OF ADDRESS
It is hereby certified that the last known addresses of the parties are as follows:
HSBC Bank USA, N.A., as Indenture, by
its attorney infact, Ocwen Loan Servicing, LLC
1661 Worthington Road, Suite 100
West Palm Beach, FL 33409
(Plaintiff)
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
(Defendant(s))
STERN & EISENBERG, PC
ENBERG, ESQUIRE
C?KEVIN P. DISKIN, ESQUIRE
? JOSEPH K. REJENT, ESQUIRE
Attorney for Plaintiff
BY:
STEVEN K. EIS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
HSBC Bank USA, N.A.
Plaintiff
E] Confessed Judgment
? Other
vs.
Craig and Maija Kraber
Defendant
Address:
2193 Bradford Drive, Mechanicsburg, PA 17055
328 E. Meadow Drive, Mechanicsburg, PA 17055
TO THE PROTHONOTARY OF THE SAID COURT:
File No. 11-8531
Amount Due $267,629.98
from 1/27/12 at the perdiem rate of $36.40
Interest iint_il_judamentpa; rt in f„l l
Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale,
contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original
proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as
amended.
Cumberland
Issue writ of execution in the above matter to the Sheriff of
r-n
County, for debt, interest and costs, upon the following described property of the defendant (s) ,T, c..7
cnr
see full legal description attached
PRAECIPE FOR ATTACHMENT EXECUTION °"!
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest
and costs, as above, directing attachment against the above-named garnishee(s) for the following property
(if real estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date 1/30/12 Signature: _
O _
Print Name: vin P. Diskin
?a8.6o PO ATTY
CQF
(Q q. 00
Address: 261 Old York Rd
q 9. oo The Pavilion, Ste 410
l (°' so u
#J of Attorney for: Jenkintown, PA 19046
it 50 ?'?? at-? Telephone: 215-572-8111
Supreme Court ID No: 86727
so w
?#?srala?s9o .
RE Ori
_..?
TI
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Civil Action: 11-8531
Craig Kraber
Maija Kraber
7 r..?
r T-1
.?
cf) r
r,
rC-- t'
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the Praecipe
for the Writ of Execution was filed, the following information concerning the real property
located at 2193 Bradford Drive, Mechanicsburg, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
2. Name and address of Defendant(s) in the judgment:
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Mai j a Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
3. Name and last known address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
NIA
4. Name and address of the last recorded holder of every mortgage of record:
N/A
5. Name and address of every other person who has any record lien on the property:
N/A
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:
PA Department of Revenue
Bureau of Compliance
Box 2,81230
Harrisburg, Pennsylvania 171.28
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:
Domestic Relations
Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Tax Claim Bureau
Cumberland County Courthouse
One Courthouse Street
Carlisle, PA 17013
Tenant(s)/Occupant(s)
2193 Bradford Drive,
Mechanicsburg, PA, 17055.
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
Date: January 26, 2012
,OMMONVVEALTH OF PENNSYLYANI Y:
NOTARIAL SEAL
LIEN CAPASSO, Notary POk
iwAvdown Bora, Montgomery Courtly
ynKrusswn Expires October 21,2012
Lit
STERN &EISENBERG Pc
J_
EVEN K. EISENBERG
CHARD F. STERN
X&VIN P. DISKIN
Attorney for Plaintiff
Swo to and subsc be before me
this Day of 44-1 , 2012.
Notary Public
STEVEN K. EISENBERG, ESQUIRE (75736)
EsQuu; E (86727)
KEVIN P. DISKiN rri M - n
,
JOSEPII K. REJENT, ESQUIRE (59621) - -'
STERN & EISENBERG, PC I )
THE PAVILION ?7'
26101,1) YORK ROAD, SUITE 410 ` -
JENKINTOWN, PENNSYLVANIA 19046 . -
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025 C-D
(COUNSEL FOR PLAINTIFF) '`.D
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Craig Kraber
Maija Kraber
Defendant(s)
Civil Action: 11-8531
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
Your real estate at 2193 Bradford Drive, Mechanicsburg, PA is scheduled to be sold at
Sheriffs Sale on Wednesday, June 6, 2012 at 10 A.M., at Sheriff s Office, Cumberland County
Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $267,629.98
obtained by HSBC Bank USA, N.A., as Indenture, by its attorney infact, Ocwen Loan Servicing,
LLC against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern & Eisenberg, PC the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may
call Stern & Eisenberg PC, telephone (215) 572-8111.
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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling Stern & Eisenberg PC, telephone (215) 572-8111.
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 Stern & Eisenberg PC, telephone (215) 572-8111.
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 a 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 on a date specified by
the Sheriff no later than 30 days after the sale date. 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 the date of filing of said schedule. You should check with the Sheriffs Office by
calling (717) 240-6390 to determine the actual date of filing of said schedule.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for the
registered Noteholders of Renaissance Home Equity Loan
Trust 2007-2, by its attorney infact, Ocwen Loan Servicing,
LLC.
V.
Craig Kraber
Maija Kraber
Defendant(s)
Civil Action: 11-8531
MORTGAGE FORECLOSURE-
RE: PREMISES: 2193 Bradford Drive, Mechanicsburg, PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result of
a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of
Cumberland County on Wednesday, June 6, 2012 at 10 A.M. at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (subject to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $267,629.98 together with interest, costs (and
such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named
Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or
interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you
have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff=s Sale upon
your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after
the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto
within ten (10) days thereafter.
January 26, 2012 STERN & EISENBERG PC
ISENBERG
STERN
.-ICEVIN P. DISKIN
Attorney for Plaintiff
BY:
STEVEN K. E
RICHARD F.
ALL THAT CERTAIN piece, parcel or lot of land situate in Upper Allen Township, Cumberland
County, Pennsylvania, bound and described as follows:
BEGINNING at a point located on the northern right-of-way line of Bradford Drive (50.00 feet wide),
said point being located at the southeastern corner of Lot No. 101; thence along the eastern boundary line
of Lot No. 101 and passing through a 25.00 foot drainage easement North 01 degrees 25 minutes 55
seconds West for a distance of 125.00 feet, to a point located at the northeastern corner of Lot No. 101;
thence along the northern boundary line of Lot No. 100 and along said 25.00 foot drainage easement
North 88 degrees 34 minutes 05 seconds East for a distance of 83.00 feet to a point located at the
northwestern corner of Lot No. 99; thence along the western boundary line of Lot No. 99 and passing
through said 25.00 foot drainage easement South 01 degree 25 minutes 55 seconds Fast for a distance of
125.00 feet to a point located on the Northern right-of-way of Bradford Drive (50.00 feet wide) said point
being located at the southwestern corner of Lot No. 99; thence along the northern right-of-way line of
Bradford Drive South 88 degrees 34 minutes 05 seconds West for a distance of 83.00 feet, to a point and
the place of BEGINNING.
CONTAINING 10, 375 square feet, more or less.
BEING Lot No. 100 on the Final Subdivision Plan for Canterbury Estates, Phase N, which is recorded in
the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book 71, Page 142.
BEING the same premises which Craig Kraber, by Deed dated July 19, 2004 and recorded July 19, 2004
in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 264 Page 1165,
granted and conveyed unto Craig Kraber and Maija Kraber, his wife.
PARCEL NO. 42-29-2458-102
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8531 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HSBC BANK USA, N.A., Plaintiff (s)
From CRAIG and MAIJA KRABER
(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: $267,629.98 L.L.: $.50
Interest from 1/27/12 at the per diem rate of $36.40 until judgment paid in full
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $203.50 Other Costs:
Plaintiff Paid:
Date: 2,12/12
David D. Buell, Prothonotary
(Seal) 44 r
Deputy
REQUESTING PARTY:
Name: KEVIN P. DISKIN, ESQUIRE
Address: STERN & EISENBERG, PC
THE PAVILION, SUITE 410
JENKINSTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111
Supreme Court ID No. 86727
Xic
COURT OF COMMON PLEAS OF CUMBERLAND C 6if ^ n E PPI (. 7
CIVIL ACTION-LAW D Ct?UPr f
KEVIN P. DISKIN, ESQUIRE
STERN AND EISENBERG, PC
The Pavilion
261 Old York Road, Suite 410
Jenkintown, PA 19046
(215) 572-8111
I.D. #86727
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V. Civil Action Number: 11-8531
Craig Kraber and
Maija Kraber
MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
I, KEVIN P. DISKIN, ESQ., attorney for the within Plaintiff, hereby certify that notice of
the Sheriff's Sale was mailed to the Defendants by certified mail, return receipt requested and
regular mail on April 4, 2012.
I further certify that notice of the Sheriff s Sale was mailed to each lienholder by regular,
first-class, postage prepaid mail on April 4, 2012 as evidenced by copy of certificates of mailing
attached.
4/5/12
STERN AND EISENBERG PC
BY-
VIN P. DISKIN
Attorney for Plaintiff
(Domestic Maii Only: No Insurance Coverage ProvOed)
CU information
F
d
li usps
(-Oln
visit our website at www
or
e
very
OFFI .
.
CIAL
m
O Postage a U
m Certified Fee
0
°
Return Receipt Fee
(Endorsement Required)
?.
, Postmark ,
Q Here
%< O
R - 42032
°
° Restricted.Dellvery Fee
(Endorsement Required) -4
C /
C%-
Q' ;I,
Total Postage & Fees
?,
• .-
/
US PC
ru i
Sent To 13A?._ r-----------
C3 -
or PO Box No.
--
----•---
- -----•--
r -----------
- --- ----- ----------
------ •------ -
II
tate
ta'h4 S, ZIP+4M /
--7v% I-7 .t r?-
rrI
r0 For delivery information visit our website at www.usps.com
m
r Postage $ J??t-? O 1Sj \
Certified Fee
O Return Receipt Fee X 114TUe 1032 O
O (Endorsement OeAuired) ® ae 4 /
Restricted Delivery Fee
° (Endorsement Required)
I' Total Postage & Fees
ru
nt To
o n--- a?I `i- Kromer---- --------------------------- ----------
or PO Box No. I
76,,- siaie, P+4-a ------ ------------ -------------- I --n!?:,V -------
PS Form
0
v
c
0
a
WHv
zr S
CnNti
fi
'b L
CO y b
80?
?aaw
z - o
U.S. POSTAGE>> PITNEY BOWES
ZIP 1
046 $ 002
52'
.
0
2 1 YV
0001371685APR 04 2012
no
0 11
?
V
l? !
V)
O V)
O
00
N
°
a
O
U O o
q-4
p
Q'
bA bA
a 0
> 0 py a
kr)
0
kr
°
U i
a?
u )
o
Q Q o o a? a
o o U x C? o
\
? O N
°
o
?W
bAW
0
U ?U
oo
QN
v?
o
PQ c ?a
8
°>
z X00
cq C00
C14
U
U O o oZ
M
C:? O??a?ri
E-+ w >
m M QI W •
+ N H
U
N
7
a? z o T
u-0
- y
N M V v'i o° o. N M :1 z y
G
. a
SHERIFF.'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson -`
Sheriff _
y r
Jody S Smith ?,? Frd
E
Chief Deputy ? ? (? ?Jt ? 6 t!" I',::
Richard W Stewart .? SolicitorGt>[RL fa rev
PENNSYLV.=. „
HSBC Bank USA, N.A.
vs. Case Number
Craig L. Kraber (et al.) 2011-8531
SHERIFF'S RETURN OF SERVICE
03/21/2012 08:38 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled actin ,
upon the property located at 2193 Bradford Drive, Upper Allen Township, Mechanicsburg, PA 17055,
Cumberland County.
03/21/2012 08:38 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Es ate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same ime
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Crai L.
Kraber at 2193 Bradford Drive, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland Count .
03/24/2012 09:50 AM - Deputy Mark Conklin, being duly sworn according to law, served the requested Real Estat
Writ, Notice and Description, in the above titled action, by making known its contents and at the same ime
personally handing a true copy to a person representing themselves to be WALT NEVKER-BOYFRIE D,
who accepted as "Adult Person in Charge" for Maija Kraber at 328 E MEADOW DRIVE, Upper Allen
Township, Mechanicsburg, PA 17055, Cumberland County.
06/06/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on June 06, 2012 at 10:00
AM. He sold the same for the sum of $1.00 to Attorney Kevin Diskin, on behalf of HSBC Bank USA, N. A.,
being the buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $995.44 SO ANSWERS,
il-, I
, onp
July 12, 2012 RON R ANDERSON, SHERIFF
ccul
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISK IN, ESQUIRE (86727)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Craig Kraber
Maij a Kraber
S
Civil Action: 11-8531
MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
I, the undersigned attorney for Plaintiff in the above caption, sets forth as of the date the
for the Writ of Execution was filed, the following information concerning the real
located at 2193 Bradford Drive, Mechanicsburg, PA.
1. Name and address of Owner(s) or Reputed Owner(s):
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
2. Name and address of Defendant(s) in the judgment:
Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maij a Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
3. Name and last known address of every judgment creditor whose judgment is a record lien bn
the real property to be sold:
N/A
4. Name and address of the last recorded holder of every mortgage of record:
N/A
5. Name and address of every other person who has any record lien on the property:
N/A
6. Name and address of every other person who has any record interest in the property
whose interest may be affected by the sale:
PA Department of Revenue
Bureau of Compliance
Box 281230
Harrisburg, Pennsylvania 17128
7. Name and address of every other person of whom the plaintiff has knowledge who has
interest in the property which may be affected by the sale:
Domestic Relations
Cumberland County
13 North Hanover Street
Carlisle, PA 17013
Tax Claim Bureau
Cumberland County Courthouse
One Courthouse Street
Carlisle, PA 17013
Tenant(s)/Occupant(s)
2193 Bradford Drive ,
Mechanicsburg, PA, 17055.
I verify that the statements made in this affidavit are true and correct to the best of my perso
knowledge or information and belief. I understand that false statements herein are made subj
to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities.
Date: January 26, 2012
COMMONWEALTH OF PENNSYLVANIA Y:
Np RIAL SEAL
HELEN CAPASSO, Notary PubNc
jw*&ttown Boro., Montgomery County
commission Expires October 21, 2012
STERN & EISENBERG Pc
EVEN K. EISENBERG
"RICHARD F. STERN
KEVIN P. DISKIN
Attorney for Plaintiff
Swo to and subsc 'bed before me
this 7 Day of 2012.
Notary Public
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EiSENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINfOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Civil Action: 11-8531
Craig Kraber
Maija Kraber
Defendant(s)
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Craig Kraber Maija Kraber
2193 Bradford Drive 328 E Meadow Dr
Mechanicsburg, PA 17055-5799 Mechanicsburg, PA 1.7055-5187
Your real estate at 2193 Bradford Drive, Mechanicsburg, PA is scheduled to be sold
Sheriffs Sale on Wednesday, June 6, 2012 at 10 A.M., at Sheriffs Office, Cumberland Cow
Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $267,629.
obtained by HSBC Bank USA, N.A., as Indenture, by its attorney infact, Ocwen Loan Servicii
LLC against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be canceled if you pay to Stern & Eisenberg, PC the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay, you
call Stern & Eisenberg PC, telephone (215) 572-8111.
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
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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You ma
find out the price bid by calling Stern & Eisenberg PC, telephone (215) 572-8111.
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. T
find out if this has happened you may call Stern & Eisenberg PC, telephone (215) 572-8111.
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 a right to remain in the property until the full amount due is paid to the Sheriff
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 on a date specified by
the Sheriff no later than 30 days after the sale date. 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 tei
(10) days after the date of filing of said schedule. You should check with the Sheriffs Office b,
calling (717) 240-6390 to determine the actual date of filing of said schedule.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N_A., as Indenture Trustee for the
registered Noteholders of Renaissance Home Equity Loan
Trust 2007-2, by its attorney infact, Ocwen Loan Servicing,
LLC.
Civil Action: 11-8531
Craig Kraber
Maija Kraber
Defendant(s)
MORTGAGE FORECLOSURE
RE: PREMISES: 2193 Bradford Drive, Mechanicsburg, PA
Dear Sir or Madam:
Please be advised that I represent the above creditor that has a judgment against the above Defendant. As a result
a default, the above referenced premises, also described on the attached sheet, will be sold by the Sheriff of
Cumberland County on Wednesday, June 6, 2012 at 10 A.M. at Sheriffs Office, Cumberland County Courthouse,
Carlisle, PA 17013 (subject to change without further notice).
The sale is being conducted pursuant to the judgment in the amount of $267,629.98 together with interest, costs (a
such other allowed amounts) thereon entered in the above matter in favor of Plaintiff against the above-named
Defendant(s) who is/are also the real owner of said premises. I have discovered that you may have a lien and/or
interest in the premises to be sold. This notice is given so that you can protect your interest, if any, in the lien you
have on the premises. If you have any questions regarding the type of lien or the effect of the Sheriff=s Sale upon
your lien, we urge you to CONTACT YOUR ATTORNEY, as we are not permitted to give you legal advice.
A Schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after
the sale date and the distribution will be made in accordance with the schedule unless exceptions are filed thereto
within ten (10) days thereafter.
January 26, 2012 STERN & EISENBERG PC
BY:
STEVEN K. EISENBERG
RICHARD F. STERN
--KtVIN P. DISKIN
Attorney for Plaintiff
ALL THAT CERTAIN piece, parcel or lot of land situate in Upper Allen Township, Cumber
County, Pennsylvania, bound and described as follows:
BEGINNING at a point located on the northern right-of-way line of Bradford Drive (50.00 feet wide),
said point being located at the southeastern corner of Lot No. 101; thence along the eastern boundary li e
of Lot No_ 101 and passing through a 25.00 foot drainage easement North Ol degrees 25 minutes 5
seconds West for a distance of 125.00 feet, to a point located at the northeastern corner of Lot No. 1 1;
thence along the northern boundary line of Lot No. 100 and along said 25.00 foot drainage easement
North 88 degrees 34 minutes 05 seconds East for a distance of 83.00 feet to a point located at the
northwestern corner of Lot No. 99; thence along the western boundary line of Lot No. 99 and passing
through said 25.00 foot drainage easement South 01 degree 25 minutes 55 seconds East for a distance of
125.00 feet to a point located on the Northern right-of-way of Bradford Drive (50.00 feet wide) said point
being located at the southwestern comer of Lot No. 99; thence along the northern right-of=way line f
Bradford Drive South 88 degrees 34 minutes 05 seconds West for a distance of 83.00 feet, to a point and
the place of BEGINNING.
CONTAINING 10, 375 square feet, more or less.
BEING Lot No. 100 on the Final Subdivision Plan for Canterbury Estates, Phase W, which is recorded
the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book 71, Page 142.
BEING the same premises which Craig Kraber, by Deed dated July 19, 2004 and recorded July 19, 21
in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 264 Page 11
granted and conveyed unto Craig Kraber and Maija Kraber, his wife.
PARCEL NO. 42-29-2458-102
STEVEN K. EISENBERG, ESQUIRE (75736)
KEVIN P. DISKIN, ESQUIRE (86727)
JOSEPH K. REJENT, ESQUIRE (59621)
STERN & EISENBERG, PC
THE PAVILION
261 OLD YORK ROAD, SUITE 410
JENKINTOWN, PENNSYLVANIA 19046
TELEPHONE: (215) 572-8111
FACSIMILE: (215) 572-5025
(COUNSEL FOR PLAINTIFF)
IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA
FOR CUMBERLAND COUNTY
HSBC Bank USA, N.A., as Indenture Trustee for
the registered Noteholders of Renaissance Home
Equity Loan Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC.
V.
Craig Kraber
Maija Kraber
Defendant(s)
Civil Action: 11-8531
MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Craig Kraber
2193 Bradford Drive
Mechanicsburg, PA 17055-5799
Maija Kraber
328 E Meadow Dr
Mechanicsburg, PA 17055-5187
Your real estate at 2193 Bradford Drive, Mechanicsburg, PA is scheduled to be sold
Sheriffs Sale on Wednesday, June 6, 2012 at 10 A.M., at Sheriffs Office, Cumberland Coui
Courthouse, Carlisle, PA 17013 (location of sale) to enforce the court judgment of $267,629.
obtained by IISBC Bank USA, N.A., as Indenture, by its attorney infact, Ocwen Loan Servicii
LLC against you.
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 canceled if you pay to Stern & Eisenberg, PC the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay, you
call Stern & Eisenberg PC, telephone (215) 572-8111.
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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You ma}
find out the price bid by calling Stern & Eisenberg PC, telephone (215) 572-8111.
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. T
find out if this has happened you may call Stern & Eisenberg PC, telephone (215) 572-8111.
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 a right to remain in the property until the full amount due is paid to the Sheriff anc
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 on a date specified by
the Sheriff no later than 30 days after the sale date. 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 tei
(10) days after the date of filing of said schedule. You should check with the Sheriffs Office b
calling (717) 240-6390 to determine the actual date of filing of said schedule.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
800-990-9108
717-249-3166
ALL THAT CERTAIN piece, parcel or lot of land situate in Upper Allen Township, Cumberland
County, Pennsylvania, bound and described as follows:
BEGINNING at a point located on the northern right-of-way line of Bradford Drive (50.00 feet wide),
said point being located at the southeastern corner of Lot No. 101; thence along the eastern boundary lin
of Lot No. 101 and passing through a 25.00 foot drainage easement North 01 degrees 25 minutes 5
seconds West for a distance of 125.00 feet, to a point located at the northeastern corner of Lot No. 101;
thence along the northern boundary line of Lot No. 100 and along said 25.00 foot drainage easeme
North 88 degrees 34 minutes 05 seconds East for a distance of 83.00 feet to a point located at th .
northwestern corner of Lot No. 99; thence along the western boundary line of Lot No. 99 and passin
through said 25.00 foot drainage easement South 01 degree 25 minutes 55 seconds East for a distance of
125.00 feet to a point located on the Northern right-of-way of Bradford Drive (50.00 feet wide) said po' I
being located at the southwestern comer of Lot No. 99; thence along the northern right-of-way line 1
Bradford Drive South 88 degrees 34 minutes 05 seconds West for a distance of 83.00 feet, to a point an
the place of BEGINNING.
CONTAINING 10, 375 square feet, more or less.
BEING Lot No. 100 on the Final Subdivision Plan for Canterbury Estates, Phase IV, which is recorded i
the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book 71, Page 142.
BEING the same premises which Craig Kraber, by Deed dated July 19, 2004 and recorded July 19, 200
in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 264 Page 116
granted and conveyed unto Craig Kraber and Maija Kraber, his wife.
PARCEL NO. 42-29-2458-102
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8531 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HSBC BANK USA, N.A., Plaintiff (s)
From CRAIG and MAIJA KRABER
(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: $267,629.98 L.L.: $.50
Interest from 1/27/12 at the per diem rate of $36.40 until judgment paid in full
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $203.50 Other Costs:
Plaintiff Paid:
Date: 2/2/12
(Seal)
REQUESTING PARTY:
Name: KEVIN P. DISKIN, ESQUIRE
Address: STERN & EISENBERG, PC
THE PAVILION, SUITE 410
JENKINSTOWN, PA 19046
Attorney for: PLAINTIFF
Telephone: 215-572-8111
Supreme Court ID No. 86727
Ja.'f ?-J. ??f L
David D.
Deputy
TRUE COPY FROM RECORD
In Testimony whereof, l here unto set y hand
and Me segi of said at Carlisle, Pa.
Tlwa.? of AL-
L Pronotary
On February 3, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Upper Allen Township, Cumberland County, PA, known
and numbered as 2193 Bradford Drive, Mechanicsburg,
PA 17055, more fully described on Exhibit"A" filed with
this writ and by this reference incorporated herein.
Date: February 3, 2012
By: (?_
For Claudia Brewbaker, Real Estate Coordinator
The Patriot-News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
Notary Public
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, i
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 1 E
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nc
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted sev
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recordi
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
UBLICATION COPY
This ad ran on the date(s) shown
Sworn to and
Patti ot-
Now y0i
of May, 2012 A.D.
`?, ?•
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L. Owens, Notary Public
Lower Paxton Twp., Dauphin County
Commission rec Nov. 26 2015
MEM MANIA QATION OF NOTARIES
dews
know
if the
i the
"he Sunday
:ate
th, 1949,
heir regular
r said
tatement as
latement on
:rally by the
ig of Deeds
Al:
04/27/12
05/04/12
05/11/12
CUMBERLAND LAW JOURNAL
Writ No. 2011-8531 Civil Term
HSBC Bank USA, N.A., as
Indenture Trustee for The
registered Noteholders of
Renaissance Home Equity Loan
Trust 2007-2, by its attorney infact,
Ocwen Loan Servicing, LLC
vs.
Craig Kraber,
Maija Kraber
Atty.: Kevin P. Diskin
ALL THAT CERTAIN piece, parcel
or lot of land situate in Upper Allen
Township, Cumberland County,
Pennsylvania, bound and described
as follows:
BEGINNING at a point located
on the northern right-of-way line of
Bradford Drive (50.00 feet wide), said
point being located at the southeast-
ern corner of Lot No. 101; thence
along the eastern boundary line of Lot
No. 101 and passing through a 25.00
foot drainage easement North 01 de-
grees 25 minutes 55 seconds West for
a distance of 125.00 feet, to a point
located at the northeastern corner of
Lot No. 101; thence along the north-
ern boundary line of Lot No. 100 and
along said 25.00 foot drainage ease-
ment North 88 degrees 34 minutes 05
seconds East for a distance of 83.00
feet to a point located at the north-
western comer of Lot No. 99; thence
along the western boundary line of
Lot No. 99 and passing through said
25.00 foot drainage easement South
01 degree 25 minutes 55 seconds
East for a distance of 125.00 feet to
a point located on the Northern right-
of-way of Bradford Drive (50.00 feet
wide) said point being located at the
southwestern corner of Lot No. 99;
thence along the northern right-of-
way line of Bradford Drive South 88
degrees 34 minutes 05 seconds West
for a distance of 83.00 feet, to a point
and the place of BEGINNING.
CONTAINING 10, 375 square feet,
more or less.
BEING Lot No. 100 on the Final
Subdivision Plan for Canterbury Es-
tates, Phase IV, which is recorded in
the Office of the Recorder of Deeds of
Cumberland County, Pennsylvania,
in Plan Book 71, Page 142.
BEING the same premises which
Craig Kraber, by Deed dated July 19,
2004 and recorded July 19, 2004 in
the Office of the Recorder of Deeds
in and for Cumberland County in
Deed Book 264 Page 1165, granted
and conveyed unto Craig Kraber and
Maija Kraber, his wife.
PARCEL NO. 42-29-2458-102.
78
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County an
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La
Journal, a legal periodical published in the Borough of Carlisle in the County and State afores,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularl
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
April 27, May 4, and
11, 2012
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subjec
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
'-? ??' C
4
Li a arie Coyne, Editor
SWORN TO AND SUBSCRIBED before me this
11 day of May, 2012
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH. CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify
the Sheriff's Deed in which HSBC Bank USA
of Renaissance Home Equity Loan Trust 2007-2 is the grantee the same having been sold to said
on the 6 day of June A.D., 2012, under and by virtue of a writ Execution issued on the 2 day of
February, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number
8531, at the suit of HSBC Bank USA N.A. as Indenture Trustee for the Registered Noteholders of
Renaissance Home Equity Loan Trust 2007-2 against Craig Kraber and Maija Kraber is duly recor?ed as
Instrument Number 201221093.
IN TESTIMONY WHEREOF, I have ereunto set m hand
and eal of said office this d y of
A.D. 4
A66M4Fdf mberland County, Carlisle,
My Commission es the Fast Monday of Jan.
2011-8531 Chill Term
HS6C Bank USA, N.A., as
Indenture Trustee for
The registered Noteholders of
Renaissance Home
Equity Loan Trust 2007.2, by Its
attorney Infect,
Ocvven Loan Servicing, LLC
VS
Craig Kraber
Malta Kraber
Atty; Kevin R Dlskin
ALL THAT CERTAIN piece, parcel or lot
of land situate in Upper Allen Township,
Cumberland County, Pennsylvania, bound
and desm&d as follows:
BEGINNING at a point located on the
northern right-of-way line of Bradford
Drive (50.00 feet wide), said point being
located at the southeastern comer of
Lot No. 101; thence along the eastern
boundary line of Lot No. 101 and passing
through a 25.00 foot drainage easement
North 01 degrees 25 minutes 55 seconds
West for a distance of 125.00 feet, to a
point located at the northeastern comer
of Lot No. 101; thence along the northern
bo mdary line of Lot No. 100 and along
s? 125.00 foot drainage easement North
8' legrees 34 minutes 05 seconds East for
a stance of 83.00 feet to a point located
at ie northwestern corner of Lot No. 99;
th ice along the western boundary line of
Lot No. 99 and passing through said 25.00
f„.). drainage easement South 01 degree
?5, minutes 55 seconds East for a distance
25.00 feet to a point located on the
rthem right-of-way of Bradford Drive
X 00 feet wide) said point being located
at the southwestern comer of Lot No. 99;
thence along the northern right-of-way
line of Bradford Drive South 88 degrees
34 minutes 05 seconds West for a distance
of 83.00 feet, to a point and the place of
BEGINNING.
CONTAINING 10, 375 square feet, more
or less.
BEING Lot No. 100 on the Final
Subdivision Plan for Canterbury Estates,
Phase IV, which is recorded in the Office
of the Recorder of Deeds of Cumberland
County, Pennsylvania, in Plan Book 71.
Page 142.
BEING the same premises which Craig
Kraber, by Deed dated July 19, 2004 and
recorded July 19, 2004 in the Office of the
Recorder of Deeds in and for Cumberland
County in Deed Book 264 Page 1165,
granted and conveyed unto Craig Kraber
and Maija Kraber, his wife.
PARCEL NO. 42-29-2458-102