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HomeMy WebLinkAbout12-5653 _ -Tn, j"-r, ~~-y ~ SEA 12 tG: i ~ C~~mERLAt~J COUNTY F~ c PdA~S YLVAtdI, UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. U iREN, ESQUIRE - ID #04302 STUART W ,ESQUIRE - ID#45362 LORRAINE GA ZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRA N5TEIN, ESQUIRE - ID#90675 SALVATORE CROLLO, ESQUIRE - ID#311050 PAIGE M. BEL O, ESQUIRE - ID#309091 HARRY B. RE E, ESQUIRE - ID#310501 KASSIA FIALK FF, ESQUIRE - ID#310530 ELIZABETH L. ~!WASSALL, ESQUIRE - Il?#77788 AGNES MOMBUN, ESQUIRE - ID#309356 ELANA B. FLE LAGER, ESQUIRE - ID#209197 KATHERINE E~ KNOWLTON, ESQUIRE - ID#311713 WOODCREST CORPORATE CENTER 111 WOODCRE~T ROAD, SUITE 200 CHERRY HILLY NJ 08003-3620 856-669-5400 ple~din~s@udren.com Residential Crej~it Solutions, Inc. COURT OF COMMON PLEAS GO Residential' Credit Solutions CIVIL DIVISION 4282 N. Freeway CUMBERLAND County Fort Worth, TIC 76137 c Plainti~'f NO. ' p~ ~ S(o 5~ 1 ?f.~ v. DENNIS ING J~ 2200 N D AND1A PKWY SPARKS, NV 8.34 DENNIS JONA~'HAN ING, JR. A/K/A DENNIS J. ING' JR. 2200 NORTH D~,ANDREA PARKWAY # 2121 SPARKS, NV 891434 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 3 y 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 enuring 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 wazned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court with~ut 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 nghts important to you. ' YOU SHOUL~KE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LA ~ R GO TO OR TELEPHONE THE OFFICE SET FORTEi BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT MIRING A LAWYER. IF OU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO ROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER L GAL SERVICES TO ELIGIBLE PERSONS AT A REDUC»D FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 99(1-9108 AVISO Le han demandadp a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas sig~ientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. I'Hace falta ascentaz una compazencia escrita o en persona o con un abogado y entregaz a la cort~ ~n forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avi~ado que si usted no se dafiende, la cone tomaza medidas y puede continuaz la demanda en cont~ suya sin previo aviso o notificacion. Ademas, la cone puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinelro o sus propiedades u otros derechos importantes paza usted. LLEVE ESTA EMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN P ~tSONA O LLAME POR TELEFONO A LA OFICI~iA CUYA DIRECCION S ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEIGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 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., acting solely as a nominee for Profolio Home Mortgage corporation Assignee: Residenltial Credit Solutions, Inc. Date of Assignmenit: 07/10/2012 Recorded Date: BooldInstrument Page: 2. Upon infdrmation and belief Defendant(s) and/or their predecessor: Dennis Jonathan Ing, Jr. a/k/a Dennis J. Ing, Jr. (hereinafter "Defendants"), are the owners of property located at 706 North Pitt Street, Carlisjle, PA 17013 , by virtue of Deed dated 09/05/2006 and recorded 09/13/2006 in Official Records Book 276 at Page 3198 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 09/052006 ,Defendant(s) and/or their predecessor: DENNIS JONATHAN ING, JR. A/K/A DENNIS J. ING, JR. promised to pay to the order of Profolio Home Mortgage ,the principal sum of $ 10,405.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 09/05/2006 ,Defendant(s) and/or their predecessor: DENNIS JONATHAN ING, JR. A/K/A DENNIS J. ING, JR. _ --TI"~ _ _ _ _ _ to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., acting solely as a nominee for Profolio Home Mortgage Corporation , the Property which is the subject of this action. The Mortgage was recorded on 09/>~'3/2006 in Official Records Book 1965 at Page 4126. 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 11/01/2011, and all subsequent paymehts 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) Byffailing 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 follovwing amounts are due on the said Mortgage or modification agreement as of the dale stated below Unpaid ~xincipal Balance $169,507.77 Accumulated Interest $8,813.66 Accumulated Late Charges $373.80 Bscrow Deficit/(Reserve) $983.54 Title Report $325.00 Attorney Fees $1,650.00 Grand Total $181,653.77 The above figures are calculated as of 06/15/2012: 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 7.37500 010. The per diem interest accruing on this debt is $3.25 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 - _ _ ~n, 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 $62.30. 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, tltie Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $181,653.'7 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LA CES, P.C. B ~M1~IO 311©3fl VERIFICATION 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 relaying to unsworn falsification to authorities. Date: ~ 1"~ Name: Romeo G Lasam, Jr Title: Assistant Vice President Company: Residential Credit Solutions, Inc. MJU 12020296 CASE 12020296-1 II'I _ Feb 10 2012 12:16am P011/015 ' . 02-09-'12 12:06 FROM-Premier Abstracts 8005456163 T-905 P00~.110015 F-731 ALL that ~'~n bi of ground, situate in the Borough of Cadists, Gurnbedand Gounty, Pennsylvania, bounded anpl deacnbed as foMowe: - On the by lot now or fom'usaly of Samue! SDMe; on the Eaet by North Pit# Street: on the Sash by lot rbw of of Ma~'Oaret F. Kutz; and on the West by a 18 foot eNey. Containing in front on said North Pitt Street 'feet and extending bads an even width to the said 16 foot alley, 179 feet. BEINGy~~ed With a dwelling house and with the address of 7~ North Pitt Street, Gadisle, Penns 17D13. BEING Lot f~MOS_ 23 and 24, in Block No.1g of the C3eneral Plan of Lob ws ktid out by the Cariiele Land and fmprovemelit Company, as recorded in Cumberland County Mlsoeilaneous book t 1, Page 572. ' BEING TH SAME PREMISES which John C. WaNers, Jr., by his deed to be recorded siniultaneoualy herewith !n a OffiGe of the Recorder of deeds of Cumberland County, granted and conveyed unto Dennis J. Ing, Jr. a Shannon A, Ing. SUBJECT tc all easements, reservations, restrictions, caxlitions, and rights of way of record. I Certify i, ' wC rc;cordcd Yn Currbe ,,,-;:i C`.c~ti my IxA ..!1 rai...~.4..+ ' . f ~ D4~ _ Tm ~IDREN LA W OFFICES, P. C. WOODCREST CORPORATE CENTER MARX J. UDREN, ESQuIR1E 111 WOODCREST ROAD NJ MANAGING ATTORNEY SUl'TE 200 CHERRY HILL, NEW JERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH FAX: 856. 669. 5399 OFFICE AAAlIN/STRA7YIR FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSE April 17, 2012 CERTIFIED MAIL RETURN RECEIPT REQUESTED ARTICLE #7011 2970 0004 1347 3889 Edwin Ortiz 545 S. Lime Street Lancaster, PA 17602 RE: Mortgage Laan dated July 28, 1999 NOTLCE OF INTENTION TO FORECLOSE Dear Mortgagor: The Mortgage serviced by Ocwen Loan Servicing and held by Goldman Sachs Company (hereinafter we, us or ours) an your property located at 545 S. Linlre Street, Lancaster, PA 17602 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $939.72 for the months of Nav~ember 2, 2010 through April 2, 2012. The last assessed late charge on this account was $30.51 at a late charge rate o!~ 5~ for each delinquent payment (s) . As of today, late charges have ,accrued to the total amount of $488.16. Other charges including Property Inspection fees and Property Valuation Fee/BPO have accrued !at the total amount of $302.50. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $17,705.62. You may cure this default within THIRTY (30) DAYS of the date of this letter,'by paying to us the above amount of $I 7,705.62 plus any additional monthly payments and Late charges which may fall due during this ;period. Such payment must be made either by cash, cashier's chick, certified check or money order, and made to IIDRFN LAW OFFICES, P.G. 21100 OCODCRESTO ROAD,T SUITET 200 EX~llblt A _ _ - rn CHERRY HILL, NEW JERSEY 08003-3620 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise the .lender's right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lase the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY {30) DAYS, the lender also intends to instruct our firm to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff or other similar official 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 ovex' $50.00. Any attorney's fees will be added to whatever you dwe the lender, which may also include our reasonable costs. If yoke cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. The lender many also sue you personally far the unpaid principal balance and a~.l other sums due under the mortgage. If you have nqt cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's or other similar official foreclosure sale. You may do sb by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale and perfq~rm any other requirements under the mortgage. It is estimated than the earliest date that such a Sheriff's or other similar official's sale could be held would be approximately six months from tk~e date of this letter. A notice of the date of the Sheriff's or similar afficial sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the ~:onger you wait . You may find aut at any time exactly what the required payment will be by calling us at the following number: {85~) 569-5400. This payment must be cash, cashier's check, certified check or money order and made payable to us ai:. the address statek~ above. You should realize that a Sheriff's or other similar official 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 Sheriff's or other similar official sale, a lawsuit could be started to ev~,ct you. You shall have the right to assert in the foreclosure proceedings, the non-existence of a default or any other defense that you may have to acceleration ar foreclosure. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. 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, PROVIDED THAT ALL THE OUTSTANDI]NfG 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 RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as xf no default had occurred. However, you are not entitled to tk~is right to cure your default more than three times in any calendar year. UDREN LAW OFFICES, P.C. cc: First Class Mail NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt i~ 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, ar any partioan 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 iIn writing within the 30 day period as stated above, we will cease collection of your debt, ar ahy disputed portion of it, until we obtain the information that is required and mail it to yot1. 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. MARK J. UDREN, ESQUIRE - I:D #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #3457b ALAN M. MINATO, ESQUIRE - ID #75860 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 (856)669-5400 _ _ _ _ _ 1117 UDREN LA W ~fF/CES, P. . WOODCREST CORPORATE CENTER MAR%I UDRB~V, ESQUIRE 111 WOODCREST ROAD NI MANAGI7VGAT7t~RNEY SUlTE200 CHERRYHlL4 NEW ERSEYOIB003-36 856.669.54A0 TINA MARIEIZICII FAX. 856.669.5399 O FF 7 L~' . 9 D M t f MB T R A T 1 ~ R FREDD/EMAC PENN5YL l/AN/A DESJGNATED COUNSEL April 17, 2012 CERTIFIED MAI1L RETURN RECEIPT REQUESTED ARTICLE #7011 2970 0004 1347 3896 Elizabeth Ortiz 545 S. Lime Street Lancaster, PA 17602 RE: Mortgage Loan dated July 28, 1999 NOTICE OF INTENTION TO FORECLOSE Dear Mortgagor: The Mortgage serviced by Ocwen Loan Servicing and held by Goldman Sachs Company (hereinafter we, us or ours) on your property located at 545 S. Lirdte Street, Lancaster, PA 17602 IS IN SERIOUS DEFAULT because you hiave not made the monthly payments of $939.72 for the months of No~rember 2, 2010 through April 2, 2012. The last assessed late charge on this account was $30.51 at a late charge rate of 5~ for each delinquent payment (s} . As of today, late charges have ~.ccrued to the total amount of $488.16. Other charges including Property Inspection fees and Property Valuation Fee/BPO have accrued ~.t the total amount of $302.50. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter is $17,705.62. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $17,705.62 plus any additionajl monthly payments and late charges which may fall due during this period. Such payment must be made either by rash, cashier's check, certified check or money order, and made to UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SQITE 200 i,a CHERRY HILL, NEW JERSEY 08003-3620 If you do not cure the default within THIRTY (30} DAYS, we intend to exercise the lender's right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the o~'iginal mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, the Lender also intends to instruct our firm to staxt a Lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff or other similar official 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 the bender, which may also include our reasonable costs. If you cure t~!le default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. The lender may also sue you personally far the unpaid principal balance and a'll other sums due under the mortgage. If you have nc~t cured the default within the THIRTY (30} DAY period and foreclosurre proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's or other similar official foreclosure sale. You may do so Ly paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fens and costs connected with the foreclosure sale and perform any other requirements under the mortgage. It is estimated that the earliest date that such a Sheriff's or other similar official's sa~.e could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff's ar similar official 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 many find out at any time exactly what the required payment will be by calling us at the following number: (856) 669-5400. This payment must be cash, cashier's check, certified check or money order and madle payable to us at the address stated above. You should re~lixe that a Sheriff's or other similar official 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 Sheriff's or other similar official sale, a lawsuit could be started to evict you. You shall have the right to assert in the foreclosure proceedings, the non-existence of a default or any other defense that you may have to acceleration or foreclosure. You have additional rights to help protect your interest in the T rm _ _ _ _ _ property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. 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, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR A~' THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE', SATISFIED. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES'THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure tl~e 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 times in any calendar year,. U~REN LAW OFFICES, R.C. _ _ _ rrT 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 3A 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 witthin 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. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #758b0 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 (856} 669-5400 UDREN LAW OFFIGE5, P.C. ~ 1 ~ WOODCREST CORPORATE. CENTER t 19 WOODCREST ROAD CHERRY N1LL, NJ 08003 ~M~ (}1F~H?6: _ ~ o~.t 7[17,7, 2970 0004 1347 3889 y ~ o~~rr~: 7p1,1, 2970 0004 1347 3889 R~tai4eci~ri~m $ ~ ~ US PQS" ~ ~ ~r. r CERTIFIED '~!3 RETURN REC ~ - ~ ~':~1' s ARTICLE #7 iU ~ Edwin Ort i ~ _ ~ 54 5 S . Lim _~..-,~,-Ar ~ } ~t ~ i • j ¦ Complete items t, 2, and 3. Also complete a Signature item 4 tt Restricted Delivery is desired. X ~ ' your name and address on the reverse ? Addressee t ~dnt so that vre qn tetum tie cart? fa you. Received by (Prirrted Name) C. Oaffi of fSetivery ¦ Attach this card to the back of the mailpiece, or on the front if space permits. D. Is delivery address different from kem 7? ? Yea 1. Article Addressed to: tf YES, enter deflvery address below: ? ~ ' t ~.t.tr~ \ i V' ~ ~ ~ ''r`" 3. CertlNed Mall ,,?~~rrE~resa Mali ? Registered ~Retum Receipt for Mendiandiae ' ? Insured Mai{ C.Q.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number ?flyy 297? ~0~4 134? 3889 (transfer tom servk.e , e P5 Form 3811, February 2Q04 Domestic Return Receipt 102'~-M'ts'!O 9 a ~ . _c .n z o ~ ~ 0 5. $ c q ~~g~ Z g m ~¢'~mL° u_as w¦¦¦ ¦ r ¦ i • Complete Rams 1, 2, artd 3. Also ttbrttpleta A. Signature item 41f Restricted Delivery is desired. X p ~t • Print your name and addttsss on the nose p # so that we can return tha cared to you. ~ f ~t+~i Ate} ~ ~ bap~~tfia f~Fprece, s. or on the front if space permits. 1. Article Addressed to: D• ~ deYvery address rent from item 1? O Yes i ; ~ H Yes, enter delivery address below: ? No ~Ll~ 5 f~11'~ ~1~=~ Certified Mefl Express Mall ~ Registered Return Reoeipt for Merr~arrdfae ? Insrsgd Mail O C.O.D. 4. RestricteZ}t]alivaryt (Exhe Fee) ? Yes 2. Article Number f7?ansrer rvrn se,vtce !a 7 D 11 2 9 7 0 D D 0 4 13 4 7 3 8 9 6 PS Form 3$11, February 2004 Dorrrestic Return Receipt tp2b~-o2~M. t640 7r'~Q ~ 2~u~.,~ft~ro~u. N^~ w ¦ ¦ ¦ € ¦ ¦ ¦ • ' e ~ t _ UDREN LAW OFFICES, P.G. ~ ~OpCREST CORPORATE CENTS 11 ~ •,~OpDCREST ROAD ~ Ct-SERRY HiIL. NJ 08003 ~ j '~k1` ~ '•`~'t`' ~1lfiH265'{~a216 7i71,Z 297Q flOfl4 2347 3896 + - 0~'E17l2U12 `Z C'97~ []t3fl4 ti347 3$96 ` ~ ~ tuiailedFrom Qt~00~ ~ 't: $ ~ tJS POSTAGE ~i ' ~i ~ = ~ ~ CERTiF~ ED N (/1 ~ ff3 os RETURN RE''"E ~ rF'"'ICLE #70 i? , Ela.za.r~e`h 54 5 S . Li.m f~. Lancaster . ' i~,1 ~ ~ ~ ~ _ _ PRESORT gin ~ Frst-Class Mail PO Bcoc X93 U. S. Postage and Temecula. CA 92589-9093 Fees Paid wso send Payments to: 7196 9006 9295 6830 6466 Saxon PO Box 54838 Los Angeles, CA 90054-0838 Send Correspondence to: Saxon 4700 Mercantile Drive Fort Worth, TX 76137-3605 2011 ~ 228-~ 34 illll,l,1111,II„L.Ill„I.il~u~~Illllirnrllllllunlinll.,l Dennis J Ing Jr 706 N PITT ST CARLISLE, PA 1 701 3-1 951 RG'f 85 _ _ r~, A ~1 X(~ S 4700 Mercantile Drive Fort Worth, TX 76137 Dennis J Ing Jr Sent Via Certified Mail 706 N PITT ST 7196 9DD6 9295 683D 6466 CARLISLE, PA 17013-1951 December 27, 2011 Loan Number: 2000583906 Property Address: 706 N Pitt Street Carlisle, PA 17013 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The MORTGAGE held by Saxon Mortgage Services, Inc. (herein as "Saxon") (hereinafter we, us or ours) on your property located at: 706 N Pitt Street Carlisle, PA 17013 IS IN SERIOUS DEFAULT because you have not made the monthly payment(s) and other charges for the months of November 1, 2011 through December 27, 2011 as follows: Next Payment Due Date : 1 1 /0 11201 1 Total Monthly Payments Due: $3,469.86 @$1,734.93) Late Charges: $124.60 Other Charles: Uncollected NSF Fees: $0.00 Other Fees: $0.00 Corporate Advance Balance: $30.00 Unapplied Balance: 0.00 TOTAL YQU MUST PAY TO CURE DEFAULT: $3,624.46 The total amount naw required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is'$3,624.46. RG165 Page 1 of 3 7196 9006 9295 6830 6466 _ You may cure this default within THIRTY (30} DAYS of the date of this letter, by paying to us the above amount of $3,624.4G, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order. Please include your loan number and property address with your payment and send to: Saxon Mortgage Services, Inc. P.O. Box 54838 Los Angeles, CA 90054-0838 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that 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 full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default befioxe they 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 $50.00. Any attorney's fees will be added to whatever you owe u$, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. 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 day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do sa by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately six (6) months from the date of this notice. A notice of the date of the Sheriff 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 at 888-325-3502. This payment must be in cash, cashier's check, cerpified check or money order and made payable to us at the address stated above. You should realize that a Sheriff's 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 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, 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 UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST. Y4U HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are nat entitled to this right to cure your default more than three times in any calendar year. RG165 Page 2 of 3 ?196 9006 9295 6830 6466 ~ , IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Saxon offers consumer assistance progams designed do help resolve delinquencies and avoid FORECLOSURE. These services are provided without cost to our cj~stomers. You may be eligible for a loan workout plan or other similar alternative. If you would like to learn] more about these progams, you may contact the Loss Mitigation Department at 888-325-3502, Monday through Thursday from 7:00 a.m. to 11:00 p.m CT, Friday from 7:00 a.m. to 7:00 p.m. CT and Saturday from 7:00 a.m. to 2:00 p.m. CT. WE ARE VERY INTERESTED IN ASSISTING YOU. Attention Serviceme hers and dependents: The Federal Servicemembers' Civil Relief Act ("SCRA") and certain state laws provide im rtant protections for you, including prohibiting foreclosure under most circumstances. If you are currently in the milit y service, or have been within the last nine (9) months, AND joined after signing the Note and Security Instrument n w in default, please notify Saxon immediately. When contacting Saxon as to your military service, you must pro aide positive proof as to your military status. If you do not provide this information, it will be assumed that you are of entitled to protecEion under the above-mentioned Act. If you are experienc' g financial difficulty, you should know that there are several options available to you that may help you keep our home. You may contact a government approved housing counseling agency which provides free or 1 w-cost housing counseling. You should consider contacting one of these agencies immediately. These gefficies specialize in helping homeowners who are facing financial difficulty. Housing counselors can hel you assess your financial condition and work with us to explore the possibility of modifying your to establishing an easier payment plan for you, or even working out a period of loan forbearance. For y ' r benefit and assistance, there are government approved homeownership counseling agencies designed !help homeowners avoid losing their homes. To obtain a list of approved counseling agencies, please call X800) 569-4287 or visit http://www.hudgov/offices/hssz/sfh/hcc/hcs.cfin. You may be eligibl for assistance from the Homeownership Preservation Foundation or other foreclosure counseling agency. ou may call the following toll-free number to request assistance from the Homeownership Preservation Founds. ion: (888) 995-HOPE. If you wish, you may also contact us directly at 888-325-3502 and ask to discuss possi 1e options. This matter is very important. Please give it your immediate attention. Sincerely, I, Saxon 47W Mercantile Dri}?e Fort W orth, Texas 7 137 888-325-3502 ~ Saxon Mortgage Services, I . is a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. If your loan is currently in bankruptcy, this notice is being sent for informational purposes only. This notice is not intended as an attempt to collect, assess, or claim against or demand payment marry person who is protected by the U.S. Bankruptcy Code. If you have recently been discharged of your personal liability on this debt due to your C er 7 bankruptcy, we are not seeking to collect, recover or offset the debt as a personal liability. We intend only to enforce and crollect the debt against the c (lateral as permitted by applicable state law. This communication is only for the purpose of protecting our right to enforcement of the lien on the collateral. Visit us on the web at www.saxononline.com. RG165 Page 3 of 3 7196 9006 9295 6830 6466 ~ ' FaxM i {~~'Si~ e~, ~C'4~ G,~PdC'~ : rnl THE COURT OF COMMON PLEAS OF ( t T CUMBERLAND COUNTI', PENNSYLVAMarf Plaintiff(s) cry r~i-~°'~ Defendan s Civil cc ` NOTICE OF ~ESDENTIAL MORTGAGE FO?RECLOS~R~ DIVERSION PROGRAM You have been s~rved with. a foreclosure complaint that could cause you to lose your home. If you own and Ihve in the residential property which is the subject of this foreclosure action, you may be able to participate in ~ court-supervised conciliation conference in an effort to resolve this matter with your lender. If yon do not h e a Lawyer, you must take the fotiowiag steps to be eligiibie for a conciliation conference. First, withi twenty (20} days of your receipt of this notice, you must contact MidPenn Legal Services at (7l 7) 243-9 00 extension 2510 or (800) 822-5288 extension 2510 and request. appointment of a legal representative at n 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 prov de the legal representative with all requested financial information so that a loan resolution proposal can ' e prepared on your behalf. If you and your Iega1 representative complete a financial worksheet in the forma attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the C which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complai t. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet wi 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 rep , ented by alawyer, yon and your lawyer must take the following stel?s to be etigibfe for a con ' ' pn .c~on#'erence. )t is not necessary for you to corrtact MidPenn Legal Service for the appointment of a legal. 'presentative. However, you must provide your lawyer with all requested financial information so that a I sn resolution proposal can be prepared on your behalf. If you. and your lawyer complete a financial worksheet i ahe format attached hereto, your lawyer will prepare and. file a Request for Conciliation Conference with the C 'urt, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure compl imt. if you do so and a conciliation conference is scheduled, you will have an opportunity to meet w' h a representative of your lender in an attempt to work out reasonable arrangements with your lender befor~ the mortgage foreclosure suit proceeds forward. ff YOU WIS TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED Y THIS NOTICE. THIS PROGRAM IS FREE. Respectfully sub ed: ~~-Zz-1 Date ignature of Counsel for Pla%ntiffJ SAWATORE GROLIA, NQW!!E r~? rra s~i©sc? ' FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Prob am Financial Worttsheet Date Cumberland Coutlty Court of Common Pleas Docket # BORROWER R VEST FOR HARDSHIP ASSISTANCE To complete your;request for hardship assistance, your lender must consider your circumstances to etermine possible options while working with your Please provide th 'following information to the best of your knowledge: Borrower name(s~: Property Address: City: ' State: Zip: Is the property fo~ sale? ~'es ? No ? Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occup ed? Yes ? No ? Mailing Address~(if different): City: State: Zip: Phone Numbers:) Home: Office: Celi: Other: Email: # of people in hdusehold: How long? Mailing Address: City: State: Zip: Phone Numbers" Home: Office: Cell: Other: Email: # of people in h~usehold: How long? First Mortgage .ender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgae Lender: Type of Loan: i; Loan Number: Total Mortgag Payments Amount: $ Included Taxes & Insurance: Date of Last P~yment: Primary Reasoh far Defautt: Is the loan in ~iankruptcy? Yes ? No ? ~ _ I ' If yes, pro~•Zde names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Chec>aing: $ $ Sati~ings: $ $ Other: $ $ Automobile #1: i~'Iodel: Year: Amount owed: Value: Automobile #2: 1~Iodel: Year: ' Amount awed: ! Value: Other ttansporta 'pn (automobiles. boats, motorcycles): Model: Year: Amount owed: Value Motrthly Iacom Name of Emplo, rs: 3. Additional Inco e Description (not waves): 1. monthly amount: 2 monthly amount: Borrower Pay D ys: Co-Borrower Pay Days: Monthiy Er:Aed$es: (Please only include expenses you are currently paying) EXPENSE " AMOUNT EXPENSE AMOUNT Mort a Food 2° Mort e ! Utilities CarPavment(s) Ctindo/Nei h. Fees Auto Insurance ~ Med. (not covered) Auto fuel/re airs Other ro a ent Install. Loan Fa • ent Cable TV i Child Su ort~Alim. S endin. Money Da /Child Care uit. Other Ex eases i Amount. Availab~e for Monthiy 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 Ag~ncv: Counselor; Phone (Office) Fax: J 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 v~nth 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 thy. follawing information, if know, regarding your lender or lender's loan servicing company: Lender's Contact) (Name): Phone: Servicing Compalny (Name): Contact: ' Phone: I/We ,authorize the above named to use/refer this information to my lender!servicer for the sole purpose of eval ting my financial situation for possible mortgage options. L•'We understand that. !we am,'are under no obligation to use the services provided by the above named Barrower Signature Date Co-Borrower Si ature Date Please forward Ithis document. along with the following information to lender anal lender's couns~~: Proof o~ income ~f Past 2 !Wank statements ~__Y(( Proof off' a~~ expected income for the last 45 days ~_V! Copy o~' a current utilitl7 bill ~V Letter tt~plaining reason far delinquency and any supporting docume~ation (hardsl~~p letter) ~1 Listing~ereement (if property is currently on the market} FORM 3 •PSI~d end`, qtr : IN THE COURT OF COMMON PLEAS OF ~~~`f S~lu~/~[ ~~~C MBERLAND COUNTY, PENI~rSYI.,VANiA Plaintiff(s) ~'s• Defendants} CIVIL REQ(TEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated .2012 governing the Cumberland Count<r Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies i as follows: 1. Diefendant is the ovtmer of the real property which is the subject of this mortgage foreclosure action; Defendant lives in the subject real property, which is defendant's primary residence; 3. 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 acourt-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 1.8 Pa. C.S. X4904 relating to unsworn falsification to authorities. Signature of Iae~fendant's Counsel/Appointed Date Legal Represehtative Signature of Defendant Date Signature of Iefendant Date i ~ UDREN LAW FFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. REN, ESQUIRE - ID #04302 ~ ~ STUART WI EG, ESQUIRE - ID#45362 LORRAINE G ZARA DOYLE, ESQUIRE - ID#34576-~-~ ~ SHERRI J. B UNSTEIN, ESQUIRE - ID#90675 ~ SALVATORE AROLLO, ESQUIRE - ID#311050 PAIGE M. BE INO, ESQUIRE - ID#309091 HARRY B. RE SE, ESQUIRE - ID#310501 ca KASSIA FIAL OFF, ESQUIRE - ID#310530 ELIZABETH WASSALL, ESQUIRE - ID#77788 AGNES MO RUN, ESQUIRE - ID#309356 ELANA B. FL ~IINGER, ESQUIRE - ID#209197 KATHERINE . KNOWLTON, ESQUIRE - ID#311713 WOODCREST (CORPORATE CENTER 111 WOODC ST ROAD, SUITE 200 CHERRY HIL ' , NJ 08003-3620 856-669-5400 adin s udren.com Residential C edit Solutions, Inc. COURT OF COMMON PLEAS 4282 N. Freew' y, Fort Worth, TX 76137 CIVIL DIVISION Plain 'ff ~I CUMBERLAND County . v. n (~VC NO. ~a• SUl~~ DENNIS JON "THAN ING, JR A/K/A DENNIS J. IN , JR. 2200 NORTH ANDREA PARKWAY # 2121 SPARKS, NV 8 34 Defenjdant(s) ENTRY OF APPEARANCE TO THE PROT$IONOTARY: Kindly el~ter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, squire; Lorraine Doyle, Esquire; Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Kassia Fialkoff, Esquire; Salvatore Carollo, Esquire; Elizab~th L. Wassail, Esquire; Agnes Mombrun, Esquire; Elana B. Flehinger, Esquire; Kathe~ine E. Knowlton, Esquire; on behalf of the Plaintiff, in the above- captioned matte#. ' UDREN LAW OF S, P.C. BY: ~12~ UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL:,, NJ 08003-3b20 856-669-540() Residential Credit Solutions, Inc. Plaintiff ~~. DENNIS JONATHAN ING, JR. A/K/A DENNIS J. ING, JR.; et al Defendant(s) ATTORNEY' FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-5653-CIVIL PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: UDREN LAW OFFICES, P.C. BY: ~~ -- Attorney for Plaintiff ELIZABETH L WASSALL,-ESQ PA ID 77788 F ~. -,' ~ ~ ru ~,~, _, ~ -~-: ~~ ~ o~ ~~ <~ C~ ~ ~~. 2 _.-t C! '' Service of i'roce5s by Residential Credit Solutions, Ync., et. al., ]C'taintit~s) va. lleanis Jonathan Ing, Jr. aku Dennis J, In;, Jr„ ct. nl., Uefendaul(s) APS 1N'rbRNA'rtONAL APS Ynternatiunal, Ltd. 1-•800-328-7171 AI'S lutcruatioual Ylucu 7800 Glcnruy Rd. i~linncupulis, hl~ 5~39.312~ APS Tile #: 116973-000l AFFYDA~VIT OF Slal2~`1C~: -- Yndivrdual r ___..._ _ ------------~----•-__ ._ Servacu of Process on: UAREN LAW OFFICES --Dcuuis Jonathan lag, Jr., alco llennis~J. lug, Jr. Court Case No. Cumberland Co 12-4653 Civil NIb. Cuurhtey 1~fyers ' 11I V4'uodcrCSt R.d., Ste. ~00 ~ Cherry Hill, r`I,I 08003-3630 I~ State ot': N L V A ll~~ ) ss. County of: WASHUE ) I\ame. of Server: DA h' A R ~HITT, A ,undersigned, bring duly sworn, clcooses and says that at the lime ot'service, s/he v,'as of legal aae and was not a party to this action; Date/Timc of Service„ that ou the 1 ~ day of OCTOBER , ?p 12 , at ~ ~ 50 o'clock ~ M Place ut' Service: &t ZZOO i`iorth D'Andrea Purkwt-y, t~1?t1 # 22 13 > in Spurlcs, Ny 8943:1 ~______ Documents Served; the undersil;ri~d served the documents dds~Cribed as: Complaint in Mortgage Foreclosure Service of Process on: A true and Correct copy of the aforesaid document{s}was served on: Dennis Jouatltdp Ing, Jt•., alca Dennis J« Iug, Jr« Porsou Served, and Method of Service: ~ ~Y Personally delivering them into tho hands of the person to f~i; served. [~ Dy delivering diem into the hands of MA1trA iviARTINF% , a Aersoti of suitable age, who verified, or who upon questioning stilted, that he/she resides With Ucnltis Jonathan lug, Jr„ eke llennis J. lag, Jr, atthe p{ac+; of service, and ~a'hose rulatioflsllip to the person is; ADULT CO--RESID.ENT Description of Person The person receiving; documents is dnseribEd fls follows: Receiving lloeutnents: Sex F Slcin Color WHITE ;Hair Color RED facial 1-lair_ yUNl; Approx, Age z5 Appro~:. Hei6ltt S' S" ;Approx. Weight ~ 70 LX To the best of my knowledge and belief, said person ~wd5 net engaged is the US I~lilitary at the time of service. Signature of Sorver: undersigned declares under per7alty of pt:rjuty Subscc'ibc~d and st~1orn to UePoru me this that t foreboing is true and correct. 1 ~, ~ day Of , 20 Signatute of Served I~olaty 1'vblic (Commission I/xpires) APS International, l~tci. r .._.S..PRPKA.,...,.........w._ z Notary PubNc - ~~ of Nevada APPo+etoient Recordotl in Wpm County "' No: 07ti37tA•2 ...... ..............r,...„,.,~,~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnde on F j ED-OFFIC " Sheriff " THE PFOTNONT ' ct ia�t�barl ' Jody S Smith �' � Chief Deputy '' i:4 2013 � 2' Richard W Stewart CUMBERLAND CO UN y SolicitorF 'cE°F "E ss'Fr PENNSYLVANIA i a Residential Credit Solutions, Inc. Case Number i` vs. 2012-5653 Dennis Jonathan Ing, Jr. SHERIFF'S RETURN OF SERVICE 01/02/2013 09:53 AM-Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 706 North FP ft Street, Carlisle, PA 17013, Cumberland County. 02/06/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed", per letter of instruction from Attorney. i SHERIFF COST: $3,817.68 SO ANSWERS, March 18, 2013 RbNIV R ANDERSON, SHERIFF i I` (c)CountySude Sheriff,Teleosoft,Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Residential Credit Solutions, Inc. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County c DENNIS JONATHAN ING,JR.A/K/A MORTGAGE FORECLOSURE rnca DENNIS J.ING,JR.; et al Defendant(s) tn�" �. 3> CD NO. 12-5653-CIVIL ' PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: (41 --t?pnl l UDREN LAW OFFICES, P.C. BY: Att rney for Plainti Katherine E. Knowlton, Esq MJU#: 12020296 CASE#: 12020296-1 PA 1D 311723 0IM4 q C�v oi cI dos"