HomeMy WebLinkAbout12-3138UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID#45362
LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576
ALAN M. MINATO, ESQUIRE - ID#75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675
SALVATORE CAROLLO, ESQUIRE - ID#311050
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
AGNES MOMBRUN, ESQUIRE - ID#309356
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Ocwen Loan Servicing, LLC
C/O Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Plaintiff
V.
LESLIE G. HOFFER
4520 LINDEN AVENUE
MECHANICSBURG, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
Nit
NO.
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.
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.
1o3.7S?
??a7svo7
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 provisions 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 SUMCIENTE 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
I. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the
legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the
current mortgagee of record, is the legal holder of the Mortgage by virtue of being
successor in interest to the current mortgagee of record, or is the legal holder of the
Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the
Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of
Mortgage, all of which have either been recorded or Plaintiff is in the process of
formalizing the actual Assignment of Mortgage in Plaintiff s favor:
Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Taylor, Bean &
Whitaker Mortgage Corp.
Assignee: Ocwen Loan Servicing, LLC
Date of Assignment: 01/20/2010
Recorded Date: 01/31/2011
Book/Instrument #: Instrument #201103574
Page: n/a
2. Upon information and belief Defendant(s) and/or their predecessor:
Leslie G. Hoffer
(hereinafter 'Defendants"), are the owners of property located at 4520 Linden Avenue,
(Lower Allen Township), Mechanicsburg, PA 17055, by virtue of Deed dated
11/10/2006 and recorded 12111/2006 in Official Records Book 277 at Page 4684 of the
Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property").
3. On 11/17/2006, Defendant(s) and/or their predecessor:
LESLIE G. HOFFER
promised to pay to the order of Taylor, Bean & Whitaker Mortgage Corp., the
principal sum of $101,000.00 payable with interest thereon provided in the Note.
4. By Mortgage dated 1:1117/2006, Defendant(s) and/or their predecessor:
LESLIE G. HOFFER
to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc.,
as nominee for Taylor, Bean & Whitaker Mortgage Corp., the Property which
is the subject of this action. The Mortgage was recorded on 12/11/2006 in Official
Records Book 1975 at Page 3732. 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 10/01/2011, 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 $105,701.49
Accumulated Interest $3,690.41
Accumulated Late Charges $160.92
Escrow Deficit/(Reserve) $1,167.28
Title Report $300.00
Attorney Fees- Estimated $1,300.00
Property Inspections $73.50
Grand Total $112,393.60
The above figures are calculated as of 05/01/2012:
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 5.25000 %. The per diem interest accruing
on this debt is $15.08 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 $26.82.
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 $112,393.60 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDREN LAW OFFICES, P.C.
BY• F. _
R . R ESE, ESQUIRE
PA ID 310501
VERIFICATION
The undersigned states that h 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 unswom falsification to authorities.
Date: (0- I 4i Z
Name: Tanisia A. Spaulding
Contract Management
Title: Coordinator
Company: Ocwen Loan Servicing, LLC
MJU #: 10110718 CASE #: 10110718-2
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O C W E N
November 15, 2011
VIA First Class Mail
VIA Certified Mail (return receipt requested)
Certified Number: 71069017515146801329
Reference Code: 1108
Leslie G. Hoffer
4520 Linden Avenue
Mechanicsburg, PA 17055-0000
Loan Number: 71540751
Property Address: 4520 Linden Avenue , Mechanicsburg, PA 17055-0000
NOTICE OF DEFAULT
AVISO IMPORTANTE PARA PERSONAS DE RABLA HISPAN_A:
Esta notificaci6n es de suma importancia. Puede afectar su derecho a continuar viviendo en su casa. Si no entiende su comenido, obtenga
una traducci6n inmediatamente o contaetenos ya que tenemos representantes que hablan espahol y estan disponibles para asistir.
Dear Borrower (s):
SPECIAL NOTICE IN THE EVENT YOU HAVE FILED BANKRUPTCY
If* you have received a Chapter 7 discharge under the Bankruptcy Code of the United States or if your mortgage is the type which has been
discharged pursuant to a completed Chapter 13 plan, this notice is not intended and does not constitute an attempt to collect a debt against
you personally. If the foregoing applies to you, this notice is sent to you only as a preliminary step to a foreclosure on your mortgage
against the above-referenced property. Provisions may be contained within your mortgage/deed of trust that require notice prior to
foreclosure. As such, this is not an attempt to assert that you have any personal liability for this debt.
In addition. if you have recently filed a petition under the Bankruptcy Code, this notice has been sent to you because OCWEN has not
been notified of your bankruptcy case. If the foregoing applies to you, it is IMPORTANT that you or your bankruptcy attorney contact us
immediately and provide us with the following information: date and jurisdiction of your filing- your case number and the bankruptcy
chapter number under which you have filed.
If you have not recently filed bankruptcy or received a bankruptcy discharge, you are hereby notified that this letter is an attempt to
collect a debt. All information obtained will be used for that purpose. The debt is owed to OCWEN as the owner or servicer of your
home loan and mortgage.
Unless you dispute the validity of the debt, or any portion thereof, within thirty (30) days after receipt of this letter, the debt will be
assumed to be valid by OCWEN. If you notify OCWEN in writing within thirty (30) days that the debt or a portion of the debt is
disputed, OCWEN will send you verification of the debt. If you would like such verification, please make your request in writing to the
Loan Resolution Consultant within thirty (30) days. The failure to dispute the validity of the debt may not be construed by any court as
an admission of liability by you.
Your mortgage payments are past due, which puts you in default of your loan agreement. As of November 15, 2011, you owe the
tol)owing.
Principal and Interest.
Interest Arrearage.....
Escrow ..................................................
Late Charges ...........................................
Insufficient Funds Charges ...........................
Fees / Expenses ........................................
Suspense Balance (CREDIT) ........................
Interest Reserve Balance (CREDIT) ................
TOTAL DUE ..........................................
$ 1.072.70
$ 0.00
$ 288.20
$ 26.82
$ 0.00
$ 0.00
$ 0.00
$ 0.00
EXHI6If 10.48
DEMANDPA.24
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 bankruptcv 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
O C W E N
On or before December 15, 2011, you must submit payment by Money Gram, Bank Check, Money Order or Certified Funds for the entire
total due amount stated above to the appropriate address listed at the bottom of page two of this notice. Any payment(s) that come due in
the interim must also be included.
Failure to bring your account current may result in our election to exercise our right to foreclose on your property. Upon acceleration,
your total obligation will be immediately due and payable without further demand. In foreclosure proceedings, we are entitled to collect
your total arrearage in addition to any expenses of foreclosure, including but not limited to reasonable attorney's fees and costs. If your
loan has already been accelerated and foreclosure proceedings already begun, we will continue the foreclosure action (if possible). You
have the right to assert in court the non-existence of a default or any other defense to acceleration and foreclosure.
OCWEN will work with bankruptcy lawyers, foreclosure defense lawyers, housing counselors, and other authorized representatives of our
customers. We will only release information once your written authorization is obtained, as required by law.
After acceleration of the debt, but prior to foreclosure. you may have the right to reinstate the mortgage loan, depending on the terms of
the note and mortgage. We encourage you to review the provisions of the note and mortgage. Please be aware that. after acceleration of
the debt, there may be expenses and attorney's fees and costs incurred by OCWEN to enforce the mortgage in addition to the overdue
amount on the mortgage. Any payment to reinstate the mortgage loan after acceleration must therefore include an amount sufficient to
cover such expenses and fees incurred. Payments received that are less than the amount required to reinstate the mortgage loan will be
returned and will not stop any foreclosure proceedings that have begun. PRIOR TO SUBMITTING PAYMENT, YOU MAY WISH
TO CALL US TO VERIFY THE EXACT AMOUNT DUE.
A HUD counseling agency may be able to provide you with assistance. To locate the HUD approved counseling agency in your area, call
the HUD Housing Counseling Service at (800) 569-4287 or consult HUD's website at www.HUD.gov.
I1'you are unable to bring your account current, I urge you to call us immediately to discuss possible alternatives to foreclosure.
If you have the desire to remedy this situation we want to assist you in trying to reach that goal. OCWEN would like to present you with
some of the alternatives that may be available regarding your delinquent mortgage loan. While our primary objective is the collection of
past due amounts on your loan, we want to work with you to find the best available alternative for you to bring your mortgage loan
obligation current.
Sincerely, ADDRESS WRITTEN CORRESPONDENCE TO:
Research Department
Ocwen Loan Servicing, LLC
Ocwen Loan Servicing, LLC P.O. Box 24736
Toll Free Phone: 800-310-9229 West Palm Beach, FL 33416-4736
PAYMENT REMITTANCE INFORMATION (always include Loan # 71540751 with your payment)
Money Gram Overnight Address VIA Regular Mail
Receive Code: 2355 Ocwen Loan Servicing, LLC Ocwen Loan Servicing, LLC
City: Orlando 1661 Worthington Road Suite 100 P.O. Box 6440
St: FL West Palm Beach, Florida 33409 Carol Stream, IL 60197-6440
Loan # 71540751 Attention: Cashiering Department
DEMANDPA.24
This communication is from a debt collector attempting to collect a debt; any information obtained will be used for that
purpose. However il' 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
O C W E N
Dear Customer.
There is help available if you are having difficulty making your mortgage loan payments. You may be eligible for the Home
Affordable Modification program, part of the initiative announced by President Obama to help homeowners.
As your mortgage loan servicer, we will work with you in an effort to try to make your mortgage payment affordable.
You will not pay any fees to take advantage of this opportunity to modify your mortgage loan payment and keep your
home. Now is the time to act. We are ready to help you.
HERE IS HOW IT WORKS
• We will first determine if you are eligible based on your situation
• If you are eligible, we will look at your monthly income and housing costs, including any past due payments, and then
determine an affordable mortgage payment
• At first, you will make new, affordable monthly payments on your mortgage loan during a trial period
• If you make those payments successfully and fulfill all trial period conditions, we will permanently modify your mortgage loan
HOW THIS MAY CHANGE YOUR MORTGAGE
The modification may involve some or all of the following changes to your mortgage loan;
• Bringing your account current;
• Reducing the interest rate on your loan;
• Extending the term of the loan, and/or
• Delaying your repayment of a portion of the mortgage principal until the end of the loan term
HOW TO `START THE PROCESS
You can obtain the application via our website or if you do not have access to the web you can call us.
• Download the application via the web at tx t??tci _con:
o Click on the a'a sidfeni's Foreriosu.; i;ntion Priam, link
c Once you confirm that you meet the requirements, you can download the package directly from the web
• Call us for an application package at 1-800-74-OCWEN (1-800-746-2936)
C Hours of Operation -
¦ 24 hrs a day Monday - Thursday
¦ Friday 12:00am - 7:00pm ET
¦ Saturday 9:00am - 4:00pm ET
A complete application will be required and must also include a request for modification and affidavit form, a 4506T or 4506T-EZ, and
evidence of income.
WHAT IF I DO NOT QUALIFY FOR THE PROGRAM?
There may be other options available to you such as;
e Ocwen's alternative modification programs
o HAFA (Home Affordable Foreclosure Alternatives) program
o Ocwen's Deed In Lieu of Foreclosure
o Ocwen's Short Sale program - Selling your home and payoff your mortgage at an approved discounted payoff
amount
We want to make the resolution of your situation as easy as possible and helping homeowners is what we do!
Sincerely,
Ocwen Loan Servicing
1661 Worthington Rd. Ste. 100
West Palm Beach, FL 33409
DEMANDPA.Z4
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
...................
:....................
O W E 1
ti'p' fv.€. ?111
We want to help you avoid foreclosure scams.'
FINANCIAL COUNSELING SERVICES
When you are experiencing a financial hardship, counseling may be a way to help you manage your finances. We urge you to
contact HUD approved agencies to obtain assistance in keeping your home. This assistance is available at no charge. For
specific guidance on this notice or information related to the Home Affordable Modification Program, ask the counselor for
MHA HELP.
HUD Approved Housing Counseling: 1-800-569-4287 N, z ?
HOPE Hotline Number: 1-888-995-4673
_ DEMANDPAZ4
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
FORM 1
ctweA-N 4:)enjic; 00 1 l,Lk-
Plaintiff(s)
Defendant(s)
IN THE COURT OF COMMON PLEAS O f
CUMBERLAND COUNTY. PENNSYLV?s
J
civil r,
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,
-r
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, youu 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 representarive. 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
apportunirv 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 SAFE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE TI4E
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
1????
Date T gnature of Counsel for Plaintiff]
HARRY B. REESE, ESQUIRE
PA ID 310501
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date _
Cumberland County Cour: 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)
City:
Phone Numbers
Email:
# of people in household:
Mailing, Address:
City:
Phone Numbers:
Email:
# of people in household:
Office:
Other:
State: Zip:
How long?
First Mortgage Lender: _
"hype of Loan:
Loan Number: Date You Closed Your Loan: _
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $
Date of Last Payment: _
Primary Reason for Default:
State: Zip:
Yes ? No ? Listing date: Price: S_
Realtor Phone:_
Yes ? No ?
Home:
Cell:
How long?
State:_ Zip:
Office:
Other:
Home:
Cell:
Included Taxes & Insurance:
Is the loan in Bankruptcy`? Yes ? No ?
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $_ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount: owed: Value
Monthly Income
Name of Employers:
1.
3.
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
r
Mortgage
Food
2" Mortgage
Car Payment(s) Utilities
Cnndo/Nei h. Fees
_
Auto Insurance Med. (not covered)
Auto fuel/re airs Other prop. payment
Install. Loan Payment Cable TV
C:niid Support/Ahm. Spending Money
Day/Child Care/Tuft . Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ? No F
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):
Servicing Company (Name):
Contact: Phone:
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 am,/are under no obligation to use the services provided by the above
named
Borrower Signature
Date
Co-Borrc-.ver Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
Past 2 bank statements
of Proof of any expected income for the last 45 days
V Copy of a current utilih7 bill
Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the market)
J
FORM 3
i
Ir)cLkx.r\ Loar\ v; c ALL
Plaintiff(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
V'?Q r
Defendant(s)
CIVIL.
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated 2012 governing the Cumberland
Counts Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property -which is the subject oaf this mortgage
foreclosure action;
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. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel,/Appointed
Legal Representative
Signature of Defendant
Signature of Defendant
Date
Date
Date
h
Ui ?r
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID#45362
LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576
ALAN M. MINATO, ESQUIRE - ID#75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675
SALVATORE CAROLLO, ESQUIRE - ID#311050
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
AGNES MOMBRUN, ESQUIRE - ID#309356
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadinas(tiudren.com
Ocwen Loan Servicing, LLC
1661 Worthington Road #100
West Palm Beach, FL 33409
Plaintiff
V.
LESLIE G. HOFFER
4520 LINDEN AVENUE
MECHANICSBURG, PA. 17055
Defendant(s)
TO THE PROTHONOTARY:
t e ?J
E T ,'?ba': C%if s
r+ 4.?
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
NO.
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; Salvatore Carollo, Esquire; Elizabeth L. Wassall,
Esquire; Agnes Mombrun, Esquire; on behalf of the Plaintiff, in the above-captioned
matter.
UDREN LAW OFFICES, P.C.
BY:
Y 6. BEES , E UIRE
PA ID 310501
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
r?
J1'1_VANIA
Ocwen Loan Servicing, LLC
vs. Case Number
Leslie G. Hoffer 2012-3138
SHERIFF'S RETURN OF SERVICE
05/21/2012 06:04 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 21,
2012 at 1804 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: Leslie G.
Hoffer, by making known unto herself personally, at 4520 Linden Avenue, Mechanicsburg, Cumberland
County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and
correct copy of the same.
SHERIFF COST: $38.00
May 22, 2012
RYAN BURGETT, D
SO ANSWERS,
RON R ANDERSON, SHERIFF
C l our-.i s:. a. L:;;
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400
pleadings~a udren.com
ATTORNEY FOR PLAINTIFF
Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
~• ~~ Cumberland County
LESLIE G. HOFFER; et al MORTGAGE FORECLOSUR E ~-= ~~>
Defendant(s) ' --~:. ~= ~ `~
,
o
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NO. 12-3138-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: 11 ~ ~i • ~ i
MJU#: 10110718 CASE#: 10110718-2
UDREN LAW~O,F'FICES, P.C.
~~
Attorney for Plaintiff
SAtvAi'pRE CIWWCW+
PA ID 311050