HomeMy WebLinkAbout12-2341?1 J f ?.?f? 77.. _
12 AF5 i 41u? J' L E
1'i' B-ER .AND COUNTY
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
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 Pleadin2s(&udren.com
OneWest Bank, FSB
C/O OneWest Bank, FSB
888 East Walnut Street
Pasadena, CA 91101
Plaintiff
V.
TAWNA M. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
WILLIAM S. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
No. i - a 3?! t 6-VO
a
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 S
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qti- a-7 3533
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(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 provisiones de esta demanda. Usted
puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
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: Mortgage Electronic Registration Systems, Inc.
Assignee: OneWest Bank, FSB
Date of Assignment: 09/20/2010
Recorded Date: 10/18/2010
Book/Instrument #: Instrument # 201029667
Page: n/a
2. Upon information and belief Defendant(s) and/or their predecessor:
William S. Clipp and Tawna M. Clipp
(hereinafter "Defendants"), are the owners of property located at 483 Pine Grove Road,
(Dickinson Township), Gardners, PA 17324, by virtue of Deed dated 11/30/2006 and
recorded 12/21/2006 in Official Records Book 278 at Page 416 of the Public Records of
Cumberland County, Pennsylvania (hereinafter the "Property")
3. On 11/13/2007, Defendant(s) and/or their predecessor:
TAWNA M. CLIPP
promised to pay to the order of Primelending, a Plainscapital Company, the
principal sum of $ 305,200.00 payable with interest thereon provided in the Note.
4. By Mortgage dated 11/13/2007, Defendant(s) and/or their predecessor:
WILLIAM S. CLIPP AND TAWNA M. CLIPP
to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc.,
acting solely as a nominee for Primelending, a Plainscapital Company, the
Property which is the subject of this action. The Mortgage was recorded on
11/26/2007 in Official Records Book Instrument # 200743944 at Page n/a . 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 08/01/2011, 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 $358,213.33
Accumulated Interest $4,218.40
Accumulated Late Charges $231.96
Escrow Deficit/(Reserve) $-687.58
Recoverable Balance Payments $-1,845.00
Foreclosure Fees/Costs $930.00
Property Inspection $100.00
Grand Total $361,161.11
The above figures are calculated as of 02/03/2012:
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 2.00000 %. The per diem interest accruing
on this debt is $19.63 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 $57.99.
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 $361,161.11 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
L
B
Stuart Winneg, Esquire
PA ID 45362
OneWest Hanky FSB
C/O OneWest 13a"Icy FSS
SSS East Walnut Street
Pasadenay CA 91101
Plaintiff
v.
TAWNA M_ CIJIPP
4S3 PINE GROVE ROAD
GARDNERS, PA 17324
WILLIAM S_ CLZPP
483 PINE GROVE ROAD
GARDNERSy PA 17324
Defondant(s)
VERIFICATION
3ames Gonzales
The undersigned is of OneWest Bank on behalf of
-rle /1fJ, "0It,,7?'F and as such is familiar with the business records maintained
by OneWest Bank for the purpose of servicing mortgage loans. These records (which include
data compilations, electronically imaged documents, and others) are made at or near the time by,
or from other information provided by, persons with knowledge of the activity and transactions
reflected in such records, and are kept in the course of business activity conducted regularly by
OneWest Bank. I am authorized to make this verification on behalf of Plaintiff and hereby
verify that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are true and
correct to the best of my knowledge, information, and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsification to authorities.
OneWest Bank on behalf of
Date: APR A 9 2012
Name:
Title: Anus Gonzales
Company: Assistant Secretary
Q,,,? W"-/ F, , , V- , SSG?
Mar-03-2010 01:23pm From-
is
Exhibit A
0
T-255 P.018/018 F-861
ALL THAT CERTAIN LOT OF LAND SITUATE IN THE DICKINSON TOWNSHIP
CUMBERLAND COUNTY PENNSYLVANIA BEING MORE PARTICULARLY
DESCRIBED AS LOT NO 72 ON A FINAL SUBDIVISION PLAN FOR, DICKINSON
TOWNSHIP JOINT VENTURE DATED NOVEMBER 4, 1983 REVISED FEBRUARY
18 1984 AND APPROVED BY THE SUPERVISORS OF DICKINSON TOWNSHIP
ON FEBRUARY 2Q, 1984 WHICH; SAID PLAN WAS DULY ENTERED OF
RECORD ON MARCH 1, 1984 AND APPEARING OF RECORD IN THE OFFICE OF
THE RECORDER OF DEEDS EV AND FOR CUMBERLAND COUNTY
PENNSYLVANIA IN PLANT BOOK 45 PAGE 32 UNDER AND SUBJECT TO ALL
LE GAL TAIGHWAYS BASEMENTS RIGHT OF WAY AND RESTRICTIONS Of
RECORD
CO."Imonly "CIOWn 0 183 Dine Grove Road GhAduuLN, PA 17324
However, by slowing this address no additional coverage is provided.
0310312010 11:56:51 AM CUMB5RI_AND COUNTY Inst.# 200743544 - Page 17 of 18
Home Loan Servicing
6900 Beatrice Drive
Kalamazoo, MI 49009
12/09/2011
TAWNA CLIPP
483 PINE GROVE RD
GARDNERS, PA 17324-8818
RE: Loan Number:
Legal Description of Property:
NOTICE OF INTENTION TO FORECLOSE
Sent Via Certified Mail
7196 9006 9295 6467 9274
The mortgage held by IndyMac Mortgage Services, a Division of OneWest Bank (herein we, us or our) on your
property located at the above-referenced address is in SERIOUS DEFAULT, because you have not made the
monthly payments that follow:
Next Payment Due Date:
Current Monthly Payment:
Total Monthly Payments Due:
Late Charges:
Other Charges:
1010786117
483 PINE GROVE RD
GARDNERS, PA 17324
Uncollected NSF Fees:
Other Fees:
Partial Payment Balance:
TOTAL YOU MUST PAY TO CURE DEFAULT:
08/01/2011
$1,559.58
$7,753.82
$231.96
$0.00
$0.00
- 0.00
$7,985.78
You may cure this default within THIRTY-TWO (32) DAYS from the date of this letter, by paying to us the
above amount of $7,985.78, plus any additional monthly payments and late charges which may fall due during
this period Such payment should be made in the form of certified check, cashier's check, or money order. If
you do not cure this within THIRTY-TWO (32) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage in monthly installments. If the full
payment of the amount of default is not made within THIRTY-TWO (32) DAYS, we also intend to start a
lawsuit to foreclose on your mortgaged property.
M-51-C
OnOWOst Bank,!
EXHIBIT u
7196 9006 9295 6467 9274
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt.
If you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable
attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to
whatever you owe us, which may also include our reasonable casts. If you cure this default with the
THIRTY-TWO (32) DAY period, you will not be required to pay the attorney's fees. You have the right to
reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or
any other defense you may have to acceleration and foreclosure.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the THIRTY-TWO (32) 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 Sheriffs foreclosure sale.
You may do so by paying the total due, as well as the reasonable attorney's fees and costs incurred in
connection with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated
that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the
date of this notice. A notice of the 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 will be by calling us. This payment must be in CERTIFIED FUNDS, payable to
IndyMac Mortgage Services, a Division of OneWest Bank, and sent to IndyMac Mortgage Services, a
Division of OneWest Bank, PO Box 78826, Phoenix, AZ 85062-8826.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict
you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL
THE PROPERTY TO OBTAIN THE MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT (YOU
MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT,
PROVIDING 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
UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT
CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If you cure this default, the mortgage will be restored to the same position as if no default had occurred.
However, you are not entitled to this right to cure your default more than three (3) times in any calendar year.
Time is of the essence? Should you have any questions concerning this notice, please contact IndyMac
Mortgage Services, a Division of OneWest Bank, Loan Resolution immediately at 1-877-908-4357.
Additionally, you may also contact a HUD-approved housing counseling agency toll-free at 1-800-569-4287 or
TDD 1-800-877-8339 for the housing counseling agency nearest you. These services are usually free of charge.
Sincerely,
IndyMac Mortgage Services, a Division of OneWest Bank, FSB
Loan Resolution
Please
1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank
2) Do not staple your payment to your billing statement
3) Write your loan number on your check or money order
4) Do not include correspondence
5) Do not send cash
6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank
PO Box 78826
Phoenix, AZ 85062-8826
This company is a debt collector and any information obtained will be used for that purpose. However, if you
have filed a bankruptcy petition and there is either an "automatic stay" in effect in your bankruptcy case, or
your debt has been discharged pursuant to the bankruptcy laws of the United States, this communication is
intended solely for informational purposes.
Hare Loan Servicing
6900 Beatrice Drive
Kalamazoo, MI 49009
12/09/2011
WILLIAM S CLIPP
483 PINE GROVE RD
GARDNERS, PA 17324-8818
RE: Loan Number:
Legal Description of Property
NOTICE OF INTENTION TO FORECLOSE
Sent Via Certified Mail
7196 9006 9295 6467 9281
The mortgage held by IndyMac Mortgage Services, a Division of OneWest Bank (herein we, us or our) on your
property located at the above-referenced address is in SERIOUS DEFAULT, because you have not made the
monthly payments that follow:
Next Payment Due Date:
Current Monthly Payment:
Total Monthly Payments Due:
Late Charges:
Other Charges:
1010786117
483 PINE GROVE RD
GARDNERS, PA 17324
Uncollected NSF Fees:
Other Fees:
Partial Payment Balance:
TOTAL YOU MUST PAY TO CURE DEFAULT:
08/01/2011
$1,559.58
$7,753.82
$231.96
$0.00
$0.00
A QM
$7,985.78
You may cure this default within THIRTY-TWO (32) DAYS from the date of this letter, by paying to us the
above amount of $7,985.78, plus any additional monthly payments and late charges which may fall due during
this period Such payment should be made in the form of certified check, cashier's check, or money order. If
you do not cure this within THIRTY-TWO (32) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage in monthly installments. If the full
payment of the amount of default is not made within THIRTY-TWO (32) DAYS, we also intend to start a
lawsuit to foreclose on your mortgaged property.
OneWest Bank
ka. 7196 9006 9295 6467 9281
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt.
If you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable
attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to
whatever you owe us, which may also include our reasonable costs. If you cure this default with the
THIRTY-TWO (32) DAY period, you will not be required to pay the attorney's fees. You have the right to
reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or
any other defense you may have to acceleration and foreclosure.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the THIRTY-TWO (32) 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 Sheriffs foreclosure sale.
You may do so by paying the total due, as well as the reasonable attorney's fees and costs incurred in
connection with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated
that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the
date of this notice. A notice of the 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 will be by calling us. This payment must be in CERTIFIED FUNDS, payable to
IndyMac Mortgage Services, a Division of OneWest Bank, and sent to IndyMac Mortgage Services, a
Division of OneWest Bank, PO Box 78826, Phoenix, AZ 85062-8826.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict
you.
You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL
THE PROPERTY TO OBTAIN THE MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT (YOU
MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE
MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT,
PROVIDING 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
UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT
CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
If you cure this default, the mortgage will be restored to the same position as if no default had occurred.
However, you are not entitled to this right to cure your default more than three (3) times in any calendar year.
Time is of the essence? Should you have any questions concerning this notice, please contact IndyMac
Mortgage Services, a Division of OneWest Bank, Loan Resolution immediately at 1-877-9084357.
Additionally, you may also contact a HUD-approved housing counseling agency toll-free at 1-800-569-4287 or
TDD 1-800-877-8339 for the housing counseling agency nearest you. These services are usually free of charge.
Sincerely,
IndyMac Mortgage Services, a Division of OneWest Bank, FSB
Loan Resolution
Please
1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank
2) Do not staple your payment to your billing statement
3) Write your loan number on your check or money order
4) Do not include correspondence
5) Do not send cash
6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank
PO Box 78826
Phoenix, AZ 85062-8826
This company is a debt collector and any information obtained will be used for that purpose. However, if you
have filed a bankruptcy petition and there is either an "automatic stay" in effect in your bankruptcy case, or
your debt has been discharged pursuant to the bankruptcy laws of the United States, this communication is
intended solely for informational purposes.
FORM 1
IN THE COURT OF COMMON PLEAS 0?'
CUMBERLAND COUNTY, PENNSYLVAY
Plaintiff(s) "r
r,
vs.
Defendant(s) a3 Civil
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, you must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Re t e
Y// 3 ?
Dar [ o ounsel for Plaintifff
Stuart Winneg, Esquire
PA ID 45362
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City.
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
C ity:
Phone Numbers:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
First Mortgage Lender: _
Type of Loan:
Loan Number:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Date You Closed Your Loan:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
State: Zip:
Yes ? No F-1 Listing date: Price: $_
Realtor Phone:_
Yes ? No ?
State: Zip:
Home: Office:
Cell: Other:
How long?
State: Zip:
Home:
Cell:
Office:
Other:
How long?
Is the loan in Bankruptcy? Yes ? No ?
f
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $
Retirement Funds: $ _ $
Investments: $ _ $
Checking: $ _ $
SaNings: $ _ $
Other: $ $
Automobile #1: Model:
Amount owed: _ Value:
Automobile 42: Model:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1.
Year:
Year:
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2"' Mort ue Utilities
Car Payment(s) Condo/Nei h. Fees
Auto Insurance Med. (not covered)
Auto fuel/re airs Other prop. payment
Install. Loan Pa yment Cable TV
Child Support/Alim. Spending Money
Day/Child Care/Tuit. _
?- Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No ?
If yes, please provide the following information:
Counseling Agency: _
Counselor:
Phone (Office): Fax:_
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ? No ?
If yes. please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact:
Phone:
I/We, , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that I/we amlare under no obligation to use the services provided by the above
named
Borrower Signature
Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
V Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
V! Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
V Listing agreement (if property is currently on the market)
Plaintiff(s)
nA ti
Qw?? / Vt , II/'? J
Defendant(s)
CIVIL
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated .2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
>. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. 54904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed
Legal Representative
Signature of Defendant
Signature of Defendant
FORM 3
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYI..VANIA
Date
Date
Date
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF''
BY: MARK J. UDREN, ESQUIRE - ID #04302 4. t ,{4
16
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576 ; a f1.RL COUNTY
'
ALAN M. MINATO, ESQUIRE - ID #75860 1A
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 pleadings(a,udrenxom
OneWest Bank, FSB COURT OF COMMON PLEAS
888 East Walnut Street, Pasadena, CA 91101 CIVIL DIVISION
Plaintiff CUMBERLAND County
TAWNA M. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
WILLIAM S. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
Defendant(s)
TO THE PROTHONOTARY:
NO. 1;) -a3'/
ENTRY OF APPEARANCE
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.
UDREN I" OAS, P.C.
BY:
Stuart Winneg, Esquire
PA ID 45362
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Onewest Bank FSB
vs.
Tawna M. Clipp (et al.)
01?.
1.012MAY, -I PAM 2:4Q
PENNSYLVANIA
SHERIFF'S RETURN OF SERVICE
04/19/2012 05:31 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
19, 2012 at 1731 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice
of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: William
S. Clipp, by making known unto Tawna Clipp, Wife of Defendant at 483 ffi i Gro Road, Gardners,
Cumberland County, Pennsylvania 17324 its contents and at the same ary it to her personally the
said true and correct copy of the same. ?
HARRISON, DEPUTY
04/19/2012 05:31 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
19, 2012 at 1731 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice
of Residential Mortgage Foreclosure Diversion Program, upon the within name defendant, to wit: Tawna
M. Clipp, by making known unto herself personally, at 483 Pine Grove Road, a ners, Cumberland
County, Pennsylvania 17324 its contents and at the same time handinj7 h f pe onally the said true and
correct copy of the same.
WN
SHERIFF COST: $55.00
April 26, 2012
SO ANSWERS,
Case Number
2012-2341
SON, DEPUTY
- 02,
RON R ANDERSON, SHERIFF
I
f`
Rob Bleecher, Esquire
Attorney I.D. No. 32594
Pecht & Associates, PC
1205 Manor Drive, Suite 200
Mechanicsburg, PA 17055
(717) 691-6809
0 TA
id 01 i% i
211211 Y 16 P I ::", 7
-UMBERLAND COUNT"l
PENINSY1 VANIA
OneWest Bank, FSB
C/O OneWest Bank, FSB
888 East Walnut Street
Pasadena, CA 91101
Plaintiff
V.
TAWNA M. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
WILLIAM S. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 2012-2341 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, William S. and Tawna M. Clipp, Defendants, to proceed in forma ap uperis.
I, Rob Bleecher, attorney for the party proceeding in forma ap uperis, certify that I believe
the party is unable to pay the costs and that I am providing free legal services to the party.
Respectfully sjibmi
& ACIATES, PC
Dated: May Z' 2012
Rob $W*??, squire
Attorney I.D. No. 32594
Pecht & Associates, PC
1205 Manor Drive, Suite 200
Mechanicsburg, PA 17055-4917
(717) 691-9809
Attorneys for Defendants
CERTIFICATE OF SERVICE
I, Rob Bleecher, Esquire, the attorney for Plaintiff, hereby certify that I have served the
foregoing document this date by depositing a true and correct copy of the same in the United
States mail, first-class postage prepaid, addressed as follows:
Salvatore Carollo, Esquire
Udren Law Offices, P.C.
Woodcrest Corporate Center
11 I Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Dated: May /-7 , 2012
Rob Bleecher, Esquire
Attorney I.D. No. 32594
Pecht & Associates, PC
1205 Manor Drive, Suite 200
Mechanicsburg, PA 17055
(717) 691-6809
OneWest Bank, FSB
C/O OneWest Bank, FSB
888 East Walnut Street
Pasadena, CA 91101
Plaintiff
V.
TAWNA M. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
WILLIAM S. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
Defendants
i
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I 4 '... r- r ppy- } (nt'? tf
- ..? L 1 \ l- 1?'?i 1 N 'J W ? V 1 3 ? . ? .
?'gc?tif ! in IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 2012-2341
CIVIL TERM
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendants are the owner of the real property which is the subject of this
mortgage foreclosure action;
2. Defendants live in the subject real property, which is Defendants' primary
residence;
3. Defendants have been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and have taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn fatsi fi
'?atign to authorities.
Roux Ble cher, squire Date
William S. Clipp Date
f
Tawna M. Clipp Date
CERTIFICATE OF SERVICE
I, Rob Bleecher, Esquire, the attorney for Plaintiff, hereby certify that I have served the
foregoing document this date by depositing a true and correct copy of the same in the United
States mail, first-class postage prepaid, addressed as follows:
Salvatore Carollo, Esquire
Udren Law Offices, P.C.
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
Dated: June 1, 2012
ONE WEST BANK, FSB IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 12-2341 CIVIL
TAWNA M. CLIPP and
WILLIAM S. CLIPP,
Defendants
CASE MANAGEMENT ORDER
AND NOW, this F ' day of June, 2012, the defendant/borrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendant/borrower has complied with the Administrative Rule
requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND
DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
Conciliation Conference on Tuesday, July 24, 2012, at 10:30 a.m. in the Chambers of
the undersigned at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form 2 within the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lender must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
Conciliation Conference.
BY THE COURT,
Hess, P. J.
? Salvatore Carollo, Esquire
For the Plaintiff
? Rob Bleecher, Esquire
For the Defendants
Am '.e6 m&ded f
-V
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--:
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--
Rob Bleecher, Esquire
Attorney I.D. No. 32594
Pecht & Associates, PC
1205 Manor Drive, Suite 200
Mechanicsburg, PA 17055
(717) 691-6809
P IL D-t FFICE
JY THE PROTHOROTAR`i
1112 JUL -3 AM 11: 24
Cl% &RILAND COUNTY
SYLVANtA
OneWest Bank, FSB
C/O OneWest Bank, FSB
888 East Walnut Street
Pasadena, CA 91101
Plaintiff
V.
TAWNA M. CLIPP
WILLIAM S. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 2012-2341 CIVIL TERM
CERTIFICATE OF SERVICE
I, Rob Bleecher, Esquire, the attorney for Defendants, hereby certify that I have served the
Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet (Form 2)
this date, by email and by depositing a true and correct copy of the same in the United States mail, first-
class postage prepaid, addressed as follows:
Salvatore Carollo, Esquire
Udren Law Offices, P.C.
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
scarollo@udren.com
Respectfully
Dated: July 2, 2012
PC
Attorney I.D. No. 32594
Pecht & Associates, PC
1205 Manor Drive, Suite 200
Mechanicsburg, PA 17055-4917
(717) 691-9809
Attorneys for Defendants
ONE WEST BANK, FSB, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW -Urn Ca
vs. NO. 12-2341 CIVIL
TAWNA M. CLIPP and WILLIAM rr
S. CLIPP, c `
2-. r
IN RE: CONCILIATION CONFERENCE
MEMORADUM AND ORDER
C-
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Present at a conciliation conference held this date were Nathan Wolf, Esquire, attorney
for the plaintiff; Rob Bleecher, Esquire, attorney for the defendants; and the homeowners, T
M. Clipp and William S. Clipp. Participating by telephone was Paige Bellino, Esquire.
After some discussion it was determined that counsel for the plaintiff will furnish to
counsel for the defendant at his request a new blank HAMP application form. A completed
HAMP application will be forwarded to counsel for the plaintiff not later than the close of
business on Thursday, August 9, 2012. Continued conciliation conference is set by order of
date herewith.
ORDER
AND NOW, this .2 Y' day of July, 2012, further conciliation conference in this
matter is set for Wednesday, October 3, 2012, at 1:30 p.m. in Chambers of the undersigned.
BY THE COURT,
Kevin ess, P. J.
71r
CD
il Nathan Wolf, Esquire
j/ Paige Bellino, Esquire
For the Plaintiff
? Rob Bleecher, Esquire
For the Defendants
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ca
CIVIL ACTION -LAW rn~
NO. 12-2341 CIVIL
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IN RE: CONCILIATION CONFERENCE .
MEMORADUM AND ORDER
rte,,,
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Present at a conciliation conference held this date were Nathan Wolf, Esquire, attorney
ONE WEST BANK, FSB,
Plaintiff
V S.
TAWNA M. CLIPP and WILLIAM
S. CLIPP,
Defendants
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for the plaintiff; Rob Bleecher, Esquire, attorney for the defendants; and the homeowners, Tawna
M. Clipp and William S. Clipp. Towards the end of the conference, Paige Bellino, Esquire,
participated by telephone.
The process of the submission of necessary documents in this case has been nothing short
of excruciating. After much discussion, the Court emphasized the importance of an end date to
the process of submission of documents for review. Counsel for the plaintiff assured the Court
that once the package was complete, the bank would conduct its review with the documents then
and there available and would not interrupt the review process to obtain updated documents,
thereby delaying the review process. Based on that assurance and other discussion, the Court
enters the following order.
ORDER
AND NOW, this 30 ~ day of November, 2012, counsel for the plaintiff are ordered
and directed to submit to counsel for the homeowners, on or before the close of business on
December 7, 2012, a complete list of any documents which are required by the bank for its
review and any and all documents which would expire on or before December 20, 2012. The
homeowners, through counsel, will submit the documents necessary to complete the review
package on or before the close of business on December 14, 2012. Thereafter, a new
conciliation conference can be rescheduled by either party.
BY THE COURT,
.~~
~ Nathan Wolf, Esquire
For the Plaintiff
~Elana B. Flehinger, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
~ob Bleecher, Esquire
For the Defendants
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P
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Kevin QCHess, P. J.
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Rob Bleecher,Esquire
Attorney I.D.No.32594 '
Pecht&Associates,P.C.
650 North Twelfth Street,Suite 100 �
Lemoyne,PA 17043
717 691-6809x1 P�AND CflUdT
OneWest Bank, FSB. IN T bF COMMON PLEAS OF
C/O OneWest Bank, FSB CUMBERLAND COUNTY PENNSYLVANIA
888 East Walnut Street
Pasadena, CA 91101
Plaintiff
V. NO. 2012-2341 CIVIL TERM
TAWNA M. CLIPP
483 PINE GROVE ROAD
GARDNERS, PA 17324
WILLIAM S. CLIPP
483 PINE GROVE ROAD
GARDNERS,PA 17324
Defendants
PRAECIPE FOR CHANGE OF ADDRESS
TO: Stephen E. Farina, Prothonotary
Please mark the record to indicate the change of address for counsel for Defendants as follows:
Rob Bleecher,Esquire
PAID No.: 32594
650 North Twelfth Street, Suite 100
Lemoyne,PA 17043
Telephone: (717) 691-9809
Facsimile: (717) 695-6550
E-mail: rbleecher@pechtlaw.com
Respectfully submitted,
PECHgASS AT ES, P.C.
Dated: June 21, 2013 By:
Rob Q er, Esquire
Attorney I.D. No. 32594
650 North Twelfth Street, Suite 100
Lemoyne, PA 17043
Telephone: (717) 691-9809
Facsimile: (717) 695-6550
E-mail: rbleecher @pechtlaw.com
CERTIFICATE OF SERVICE
I, Rob Bleecher, Esquire, the attorney for Defendants, hereby certify that I have served the
foregoing document this date by depositing a true and correct copy of the same in the United States
mail, first-class postage prepaid, addressed as follows:
Sherri J. Braunstein, Esquire
Udren Law Offices, P.C.
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill,NJ 08003-3620
Nathan C. Wolf, Esquire
Wolf& Wolf, Attorneys at Law
10 West High Street
Carlisle, PA 17013-2922
Dated: June 21, 2013 / �9
b Becher, Esquire
10030011-5
UDREN LAW OFFICES, P.C.
SHERI J. BRAUNSTEIN, ESQUIRE ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadings @udren.com
One West Bank, FSB COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff
Cumberland County c �
_-0:K ,
MCU CA
MORTGAGE FORECLOSURE ='M r*l
=� -0
Tawna M. Clipp cn'— no ='
NO. 2012-2341 -<r" o•
William S. Clipp
='C p
Defendant
NOTICE OF INTENT TO PROCEED
TO THE PROTHONOTARY:
Kindly file this as Plaintiffs Statement of Intention to Proceed in the above-referenced
matter.
Respectfully submitted,
UDREN LAW OFFICES, P.C.
B �
S errs 2raunst6iR/. Esquire
Attorney for Plaintiff
10030011-5
UDREN LAW OFFICES, P.C.
SHERI J. BRAUNSTEIN, ESQUIRE ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadings @udren.com
One West Bank, FSB COURT OF COMMON PLEAS
Plaintiff ; CIVIL DIVISION
Cumberland County
v ; MORTGAGE FORECLOSURE
Tawna M. Clipp NO. 2012-2341
William S. Clipp
Defendant
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of Plaintiff s Notice of
Intent to Proceed and this Certificate of Service was served upon the following person named
herein at their last known address or their attorney of record.
xxxxxx Regular First Class Mail
Certified Mail
Other(certificate of mailing)
Date Served: September 25, 2013
TO:
Rob Bleecher, Esquire Tawna M. Clipp William S. Clipp
650 North Twelfth Street, Suite 100 483 Pine Grove Rd 483 Pine Grove Rd
Lemoyne, PA 17043 Gardners, PA 17324 Gardners, PA 17324
Attorney for Defendant
UDR CES, P.C.
BY:
Bra n quire
Attorney or aintiff
ONE WEST BANK, FSB, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
vs. : NO. 12-2341 CIVIL
TAWNA M. CLIPP and WILLIAM :
S. CLIPP,
Defendants •
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 2.0 • day of January, 2014, a conciliation conference in the above
matter is set for Friday, February 21, 2014, at 2:00 p.m. in Chambers of the undersigned.
BY THE COURT,
Key' A. Hess, P. J.
Sherri J. Braunstein, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill,NJ 08003-3620
✓Rob Bleecher, Esquire
For the Defendants
:rim
COPE QS 11? ticC —4 c■
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ONE WEST BANK, FSB, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
vs. : NO. 12-2341 CIVIL
TAWNA M. CLIPP and WILLIAM :
S. CLIPP,
Defendants •
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this Z ' s day of February, 2014, it appearing that a loan modification
is being entered into in this case, the conciliation conference is continued generally.
BY THE COURT,
*4--
Kevin A. ess, P. J.
✓ Sherri J. Braunstein, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill,NJ 08003-3620
./Rob Bleecher, Esquire
For the Defendants + �
rn
:rlm C<_ r=' `'
ILL C231.6g fi&t
CC?
ailic( .
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings@udren.com
One West Bank, FSB
Plaintiff
V.
TAWNA M. CLIPP; WILLIAM S. CLIPP; et
al
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
1^-.)
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NO. 12-2341-CIVIL
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PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of
your costs only.
DATED: 3111)M
MJU#: 10030011 CASE#: 10030011-2
UDREN LAW OFFICES, P.C.
BY:
Attorney