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Home My WebLink About12-0983FILED-OFFICE 20 12FEE IS AN 10.20 CUMBERLAND COUNTY PENNSYLVANIA UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER ATTORNEY FOR PLAINTIFF 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2sAudren.com U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002-HE1 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 3_? Nt-L V. INGRID LAMMEREE 4265 NANTUCKET DRIVE MECHANICSBURG, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to, you. S of `?? 103.-7 V* d 7/68 1 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO.0 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: North American Mortgage Company Assignee: U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002-HEl Date of Assignment: Recorded Date:: Book/Instrument #: Page: 2. Upon information and belief Defendant(s) and/or their predecessor: Ingrid Lammeree (hereinafter "Defendants"), are the owners of property located at 4265 Nantucket Drive, Mechanicsburg, PA 17055, by virtue of Deed dated 08/06/2001 and recorded 08/28/2001 in Official Records Book 248 at Page 580 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 08/23/2001 , Defendant(s) and/or their predecessor: INGRID LAMMEREE promised to pay to the order of North American Mortgage Company, the principal sum of $ 95,965.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/23/2001 , Defendant(s) and/or their predecessor: INGRID LAMMEREE to secure the Note, mortgaged to North American Mortgage Company, the Property which is the subject of this action. The Mortgage was recorded on 08/28/2001 in Official Records Book 1731 at Page 3889. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 09/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as- follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $107,837.29 Accumulated Interest $3,153.66 Accumulated Late Charges $398.58 Escrow Deficit/(Reserve) $1,789.06 Title Report $300.00 Attorney Fees $1,300.00 Other Suspense Balance $-535.74 Property Inspection $21.00 Property Valuation $292.00 Grand Total $114,555.85 The above figures are calculated as of 01/25/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.06000 %. The per diem interest accruing on this debt: is $18.09 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $30.66. 7. :Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $114,555.85 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. P.C. BY'. PA B 7 NJ IRAR# 1 010 VERIFICATION ANT-)- GLASS, ESQ. Pty BAR # 308367 NJ BAR # 13562010 The undersigned states that he/she is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. )fig 1, d ' Date: Name: Angela Di IWO Title: Cpn ? ?aJla erpe?? C.oo?d;na+z?r Company: Ocwen Loan rvicing, LLC as servicer on behalf of U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through-Certificates, Series 2002-HE1 MJU #: 11121010 CASE #: 11121010-1 ALL THAT CERTAIN lot or piece of land situate in Hampden Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern right-of-way line of Nantucket Drive at the southwest corner of Lot No 33; Ai. THENCE along said right-of-way line b a curve to the left, said curve having a radius of 162.00 feet and an arc distance of 20.41 feet to a point, being the southeast comer of Lot No. 35; THENCE along Lot No 35, North 33 degrees 00 minutes 00 seconds West 126.87 feet to a point on the southern right-of-way line; THENCE by a curve having a radius of 733.94 feet and an arc distance of 20.26 feet to a point, being the northwest corner of Lot No 33; THENCE along Lot No. 33 South 33 degrees 00 minutes 00 seconds East 119.60 feet to a point, being the PLACE OF BEGINNING. CONTAINING 2,461 square feet, more or less. BEING Lot No. 34 on a Plan of Beaumont Square, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 62, Page 51. HAVING THEREON ERECTED a two story dwelling known and numbered as 4265 Nantucket Drive, Mechanicsburg, Pennsylvania 17050. E!t I :: i 5 Ocwen Loan Servicing, LLC P.O. Box 24737 West Palm Beach, Florida 3 O C W E N (Do not send correspondence October 29, 2011 3416-4737 orpayments to the above address) WNk'W.OCWEN.COM VIA First Class Mail VIA Certified Mail (return receipt requested) Certified Number: 71069017515145510383 Reference Code: 1109 Ingrid Lammeree 4265 Nantucket Drive Mechanicsburg, PA 17055-0000 Loan Number: 31043946 Property Address: 4265 Nantucket Drive , Mechanicsburg, PA 17055-0000 PLEASE SEE THE ENCLOSED DOCUMENT 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 XHIBITA Ocwen Loan Servicing, LLC P.O. Box 24737 O C W1.00 EN West Palm Beach' Florida 33416-473 7 (Do not send correspondence or payments to the above address) WNW \A .OC WEN.CQM October 29, 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, pecific information about the nature of the default i provided in the attached pages The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) m1y be able to help to save your home This Notice explains how the program works. To see if HEMAP can helwou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY (30) DAYS OF THE DATE OF THIS NOTI F Take this Notice with you when you meet with the_ Counseling Agency. The name address and phone number of Consumer Credit oun a in_gAgencies 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 ]8691 This Notice contains important legal information If you have any questions. representative 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 1_ne_al 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): Ingrid Lammeree PROPERTY ADDRESS: 4265 Nantucket Drive Mechanicsburg, PA 17055-0000 LOAN ACCT. NO.: 31043946 ORIGINAL LENDER: NORTH AMERICAN MORTGAGE COMPANY CURRENT LENDER/SERVICER: 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 orpayments to the above address) 1- N " .OCA'EN.CQM HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN AVE 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. TE MPO RAR Y STAY O F FORECLO SURE -Und er the Act yo u are entit led to a te mpora ry stay of f oreclosure o„ you r mo rtgage for thirty _ (30 &yc_ fro m the date of this No tice- D uring that t im e you m ust arr ange and at tend a "face- to-f ace" meeti ng with one of the consu mer credit co unselin g agen cies li sted at t he end o f this THI Notice S MTFTING MU ST O CCU R WITHI N THE NEX T (30) DAYS . IF Y OU DO NO T AP PL Y FOR EME . RGENCY MORTGAGE ASS ISTA NCE . YOU M UST BRIN G YOUR M ORTGA GE UP T O D AT E, THE PAR T OF TH IS NOTI F CA LLE D"HO W TO CU RE YOUR M ORTGAGE DEFAU LT". EXPL AINS H OW TO BRIN G 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 propejy 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 (Bring 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 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 0 - C ..... WE _ West Palm Beach, Florida 33416-4737 O N (Do not send correspondence orpayments to the above address) lVxA V17.0C"`Eh` ('0M NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 4265 Nantucket 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 $ 1,000.97 from September 01. 2011 through October 29. 2011 DETAIL Principal and Interest ............................ Interest Arrearage ................................ Escrow ............................................. Late Charges ...................................... Insufficient Funds Charges ..................... Fees / Expenses ................................... Suspense Balance (CREDIT) .................. Interest Reserve Balance (CREDIT).......... TOTAL DUE ..................................... $ 1,226.46 $ 0.00 $ 775.48 $ 367.92 $ 25.00 $ 711.50 $ 535.74 $ 0.00 $ 2,570.62 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 $2,570.62, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be mad either by Money Gram Cashier's heck, 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 intend 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 ON - 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 ND R REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the ehe^t* s Sale You may do so by payjugthe 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 Sole a specified in writing b 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 Ocwen Loan Set vicing, 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 C)CWEN COM 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. 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; an), 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 J"'UF F IC' UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAIP?`I PROTz 10N0TA ',' BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 , 2 FES 15 AM l?? 19 LORRAINE DOYLE, ESQUIRE - ID #34576 ''UMBERLAND COUNTY ALAN M. MINATO, ESQUIRE - ID #75860 PENNSYLVANIA SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinj!s(a)udren.com U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage I COURT OF COMMON Pass-Through Certificates, Series 2002-HE1 PLEAS 1661 Worthington Road #100, West Palm Beach, FL 33409 CIVIL DIVISION Plaintiff CUMBERLAND County INGRID LAMMEREE n NO. 23 4265 NANTUCKET DRIVE MECHANICSBURG, PA 17055 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein., Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Elizabeth L. Wassall, Esquire; on behalf of the Plaintiff, in the above-captioned matter. UDFXN-LAW B 611 l Abky CYL SS, ESQ. PA # 308367 NJ BAR # 13862010 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor US Bank NA vs. Ingrid Lammeree r!d Ci c- F- '19 12 ?j a 16 CUMSI ERLA,401 COW-iTY PENNSYLVAI?d6A Case Number 2012-983 SHERIFF'S RETURN OF SERVICE 03/12/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Ingrid Lammeree, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Ingrid Lammeree. Request for service at 4265 Nantucket Drive, Mechanicsburg, Pennsylvania 17055 the Defendant was not found. Deputies were advised by a neighbor the residence is vacant. However, The Mechanicsburg Postmaster is still delivering her mail to this address. SHERIFF COST: $43.00 March 12, 2012 SO ANSWERS, 6Z ??2x? RON R ANDERSON, SHERIFF s U.S. Bank N.A.,in its capacity as Trustee COURT OF COMMON PLEAS for CSFB Mortgage Pass-Through CIVIL DIVISION Certificates, Series 2002-HE1 CUMBERLAND County Plaintiff V. INGRID LAMMEREE Defendant(s) NO. 2012-983 ORDER AND NOW, this6?oW day of 2012, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of 11 the Complaint in Mortgage Foreclosure on Defendant(s), INGRID LAMMEREE, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 4265 Nantucket Drive Mechanicsburg, PA 17055 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: INGRID LAMMEREE 4265 NANTUCKET DRIVE MECHANICSBURG, PA 17055 BY THE COURT: L J. - ?.., r r Lj 10! 5 'cPy rna -1 "d 413%a UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 204 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank N.A.,in its capacity as Trustee COURT OF COMMON PLEAS for CSFB Mortgage Pass-Through CIVIL DIVISION Certificates, Series 2002-HE1 Cumberland County Plaintiff V. NO. 2012-983 INGRID LAMMEREE r=te _? ... ?. Defendant(s) 1 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: ?I UDREI?W OFFICES, P.C. AGNES W MBRUN,'M PA ID 509356 Uyu,} 411. ?S?d 07 gr?'? ??- a?43aa SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4? of ciljll;t"j4'7G r PR Jody S Smith Chief Deputy Richard W Stewart Solicitor 2012 MAY -4 PM 3: 21 CUMBERLAND CUU '? Y PENNSYLVANIA: US Bank NA vs. Ingrid Lammeree Case Number 2012-983 SHERIFF'S RETURN OF SERVICE 05/01/2012 06:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 1, 2012 at 1823 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Ingrid Lammeree, pursuant to order of court by posting the premises located at 4265 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 with a true and correct copy according to law. SHERIFF COST: $44.00 May 02, 2012 RYAN BURGETT, DEP T?- SO ANSWERS, RON R ANDERSON, SHERIFF "i Gou ard?Sre 't 7-aecs >i?. lr_.:. V, UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank N.A., in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002-HEl 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff V. Ingrid Lammeree 4265 Nantucket Drive Mechanicsburg, PA 17055 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County rn _-x a: ate,,. rn .._. cn r >c NO. 2012-983 ?= cn > VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter a true and correct copy of the Complaint in Mortgage Foreclosure was mailed to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant (s) as follows: DATE MAILED : 6/-7//Z Ingrid Lammeree 4265 Nantucket Drive Mechanicsburg, PA 17055 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: / UDR W?OFFICES, 1 I BY: Attorney for Plaintiff pMCSE M. BELUNO, ESQUIRL PA ID 309091 N r i -3 L5? ;y 1 it - ,i N f/1 ? C ? N : Q Q O ? Z ti ! U 'T I CO CC) rq r-q Ev ru ?. En L n ----- --- m m CO CO -ostage -0 -0 Certified Fee 0 0 C3 E3 Return Receipt Fee w? C3 p (Endorsement Required) C3 E3 Restricted Delivery Fee Q O (Endorsement Required) m m cE) cCj Total Postage & Fees r-q r -I . . fi 'D I i ?! ru Here m ;- 1 l1 EU 4 Ln M m r 0 o m o . o a) M r r I] 0 r- I I c Z m to U N n E f? O C N °r a T i CO O a ?: 1 1 `-?" ? ' ?.: ? .9 S J, ?- ? -.?` UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002-HE1 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff V. INGRID LAMMEREE 4265 NANTUCKET DRIVE MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF .. Pas I i?• 4a,?: COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-983 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: k'J} L®Ud'j E Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), INGRID LAMMEREE; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Title Report Attorney Fees Other Suspense Balance Property Inspection Property Valuation Grand Total FROM 01/26/2012 01/26/2012 TO 06/21/2012 06/21/2012 I hereby certify that (1) the addresses of the Plaintiff and Defendant given in accordance with Rule 237. 1, a copy of which is attached here $107,837.29 $3,153.66 $2,677.32 $398.58 $153.30 $1,789.06 $300.00 $1,300.00 $-535.74 $21.00 $292.00 $117,386.47 shown above, and (2) that notice has P.C. AGNES MOMBRUN, ESQUIRE -___2 ID -"356 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PI MJU#: 11121010 CASE#: 11121010-1 l??P , qs MI%VV D (A(oed PROTHONd-TApy ????F?? f 5 ?? fOt ? '?UMBERLAND COUNTY PENINsYLVANIA UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID ##45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinas(a-?udren.com U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002-HEI C/O Oewen Loan Servicing, LLC 1661 Worthington Road #100 West Palm Beach, FL 33409 Plaintiff V. INGRID LAMMEREE 4265 NANTUCKET DRIVE MECHANNICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 0Dla-Q 8-3 0101 COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. f( 1A 9 1 f l r. t ?? ' i?_ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF T4S S?rrZiFr US Bank NA vs. Case Number . Ingrid Lammeree 2012-983 SHERIFF'S RETURN OF SERVICE 05/01/2012 06:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 1, 2012 at 1823 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Ingrid Lammeree, pursuant to order of court by posting the premises located at 4265 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 with a true and correct copy according to law. SHERIFF COST: $44,00 May 02, 2012 RYAN BURGETT, DEP 'f -= SO ANSWERS,/ RON R ANDERSON, SHERIFF Mi ? OW-ItySWO SherrH. Teleosoti_ L•ic UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank N.A.,in its capacity as Trustee COURT OF COMMON PLEAS for CSFB Mortgage Pass-Through CIVIL DIVISION Certificates, Series 2002-HEI Cumberland County Plaintiff NT. MORTGAGE FORECLOSURE INGRID LAMMEREE NO. 2012-983 Defendant(s) TO: INGRID LAMMEREE 4265 NANTUCKET DRIVE MECHANICSBURG, PA 17055 Date of Notice: May 30, 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER. TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DE:NTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA., SIN NECESIDAD DE COMPA.RA.RECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, LISTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O ST NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA. CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. LA OFFICES, PC. q rney fo Plaintiff AG.MUM8RU E PA ID 309356 Wooderest Corporate Center 111 Wooderest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 11121010 CASE#: 11121010-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 lp eadingsa*udren.com U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002-HE1 Plaintiff V. Ingrid Lammeree Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-983 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), INGRID LAMMEREE, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of falsification to authorities. MJU#: 11121010 CASE#: 11121010-1 AGNES MOMBRUN 1 PA ID 309356 Department of Defense Manpower Data Center Status RCPWI Pursuant to Servicernembers Civil Relief Aci Last Name: LAMMEREE First Name: INGRID Active Duty Status As Of: Jun-21-2012 Results as of : Jun-21-2012 06:55:45 SCRA 2.2.1 Active Duty Start Date Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Data Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received eady notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Awt Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) 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 Servicemembers Civil Relief Act (50 USC App. § 501 at 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 only 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 was on active duty for the active duty status date, 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: hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: KSVGCUNDQ4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-983 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK N.A., IN IT'S CAPACITY AS TRUSTEE FOR CSFB MORTGAGE PASS--THROUGH CERTIFICATES, SERIES 2002-HE1 Plaintiff (s) From INGRID LAMMEREE (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: $117,386.47 L. L.: $.50 Interest from 6/22/12 to Date of Sale December 5, 2012 - ongoing per diem of $18.09 to actual date of sale including if sale is held at a later date - $3,021.03 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $250.00 Other Costs: Plaintiff Paid: Date: 6/26/12 (Seal) REQUESTING PARTY: Name: AGNES MOMBRUN, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 309356 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 PleadingsQ)udren.com U.S. Bank N.A.,in its capacity as Trustee COURT OF COMMON PLEAS for CSFB Mortgage Pass-Through CIVIL DIVISION Certificates, Series 2002-HE1 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE Ingrid Lammeree NO. 2012-983 Defendant(s) PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 6/22/2012 to Date of Sale December 5, 2012 Ongoing Per Diem of $18.09 to actual date of sale including if sale is held at a later date (Costs to be added) U?'S FF. 0.c)C 4y. oo ?? tt IDS. 7< 11 • is u It MJU#: 11121010 CASE#: 11121010-1 1U. S& 11 K U << a CA ?aSD. 19 4a* a6 ,„SUS cq'ff ,?I o &9 1) Ll a,-«96 $.117,386.47 $ 3,021.03 wj it 4 M1-C T3socj PA ID 309356 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 11 =5 t CHERRY HILL, NJ 08003-3620 856-669-5400 3 ?; t S Y 1. 1 sA`. pleadings@a udren.com U.S. Bank N.A.,in its capacity as Trustee COURT OF COMMON PLEAS for CSFB Mortgage Pass-Through CIVIL DIVISION Certificates, Series 2002-HE1 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE Ingrid Lammeree Defendant(s) NO. 2012-983 CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: M Act 91 procedures have been fulfilled n Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. OF.FIWS, P.C. BY: P AGNES MOMBRUN, 0 PA ID 309356 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinss(&udren.com ATTORNEY FOR PLAINTIFF U.S. Bank N.A.,in its capacity as Trustee COURT OF COMMON PLEAS for CSFB Mortgage Pass-Through CIVIL DIVISION Certificates, Series 2002-HE1 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE Ingrid Lammeree Defendant(s) NO. 2012-983 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002- HE1, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 4265 Nantucket Drive, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Ingrid Lammeree 4265 Nantucket Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Ingrid Lammeree 4265 Nantucket Drive Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: U.S. Bank N.A.,in its capacity as Trustee for CSFB Mortgage Pass-Through Certificates, Series 2002-HE1 1661 Worthington Road #100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 4265 Nantucket Drive Mechanicsburg, PA 17055 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: Federal Tax Lien Holders - None Beaumont Square Homeowners Association Address to Follow I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: li _a MJU#: 11121010 CASE#: 11121010-1 jog UDREN LAW OFFICES, P.C. "'Ar>'TORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 4 p { " 856-669-5400 R r c? ?+? 4' ?i 1 i`, pleadinma)udren.com U.S. Bank N.A.,in its capacity as Trustee COURT OF COMMON PLEAS for CSFB Mortgage Pass-Through CIVIL DIVISION Certificates, Series 2002-HE1 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE INGRID LAMMEREE Defendant(s) NO. 2012-983 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ingrid Lammeree 4265 Nantucket Drive Mechanicsburg, PA 17055 Your house (real estate) at 4265 Nantucket Drive, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriffs Sale on December 5, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $117.386.47, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 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. 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.) J4 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 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108