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HomeMy WebLinkAbout12-7482UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #44342 STUARI' WINNEG, ESQUIRE - II)#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI 3. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORF, CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 I~ASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. VGASSALL, ESQUIRE - ID#77788 ~' t . ,' AGNES MOIkiBRUN, ESQUIRE - ID#309356 ELANA B. FLEHINGER, ESQUIRE - ID#209197 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 NICHOLAS GAUNCE, ESQUIRE - ID#206228 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 _856-669-5400 pieadin~*s@udren.com __ HSBC Bank USA, N.A., as Indenture Trustee~, COURT 01' COMMON PLEAS for theRegist6red Noteholders of Renaissance i CIVIL, DIVISION Home Equit}~ Loan Trust 2006-3 CUMBERLAND County CJO Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 '~ ~ ~a ~~~ ~ West Palm Beach, FL 33409 ~ NO. ~ o~ - Plaintiff v. CATH'Y' ANN PEIFFER X79 HILLCREST DRIVE CARLISLE, PA I7H~-4333 Defendant(sl COMPLAINT IN MORTGAGE FORECLOSURE C ~' --3 ~ ~- ~, o rn ~~: n ~- _ ~~ ~~~~ ~~ ~ ~'~ .c YOL? 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 attorne}~ and filing in writing with the Court youur 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. YOC:' 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 N O FEE. ~~~~.,,~~ l~ Q~~~ 1t~? `7SPs1 n ~ ~~ ~oB~ ~ ~~ ~~uau3 NOTICE Theamount 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 ~~ith 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 211 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 Iv7ortgage 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 Fidelity Mortgage a division of Delta Funding Corporation, its successors and assigns Assignee: HSBC Bank USA, N.A., as Indenture Trustee for the registered Noteholders of Renaissance Home Equity Loan Trust 2006-3 Date of Assignment: 09/26/2006 .__ Recorded Date: 07/09/2009 Bookllnstrument #: Instrument No :200923813 Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: Cathy Ann Peiffer (hereinafter "Defendants"), are the owners of property located at 579 Hill Crest Drive, Carlisle, PA 17013 , by virtue of Deed dated 09/20!1985 and recorded 09/23/19$5 in Official Records Book M31 at Page 588 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 07/20/2006 ,Defendant(s) and/or their predecessor: CATHY ANN PEIFFER promised to pay to the order of Fidelity Mortgage a Division of Delta > unding Corporation ,the principal sum of $101,500.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 07/20/2006 ,Defendant(s) and/or their predecessor: CATHY ANN PEIFFER to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Tne. as nominee for Fidelity Mortgage a division of Delta Funding Corporation , the Property which is the subject of this action. The Mortgage was recorded on 07/28!2006 in Official Records Book 1960 at Page 0312. Said Mortgage is incorporated herein by referenced in accordance with. Pa.R.C.P 1019(8). 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 05/01/2012, 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; (bj 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 $105,557.68 Accumulated Interest $2,060.60 Accumulated Late Charges $86.60 Escrow Deficit/(Reserve} $5,718.94 Title Report $300.00 Attorney Fees $1,650.00 Property Inspection Fee $21.0Q Property Valuation Fee - BPO $292.00 Grand Total $115,686.82 The above figures are calculated as of 10/03/2012: 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 3.87000 %, The per .diem. interest accruing - ~ - ..: on this debt is $11.29 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 ~.nortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $21.65. 7. Breach letters have been. sent to Defendants} in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1.974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1.983. 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 S1i5,686.82 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged -°- - premises. UDREN LAW OFFICES, P.C. KASSIA FIALKOFF, F_.~QU~~t PA ID 31053Q VERIFICATION The undersigned states that he/~'" is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and. correct to the best of the information and belief of the undersigned. .. .: The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. r Date: (~('C~'/n~~E~r ~ ~ ~ ~~~ ~ ~-~t' - ~, Name: Regina Peragine Title: Company: Ocwen Loan Servicing LLC as attorney in fact for HSBC Bank USA, N.A., as Indenture Trustee far the Registered Noteholders of Renaissance Home Equity Loan Trust 2006-3 NIJU #: 101.00373 CASE #: 1010037;;-3 "Ocwen loan servicing, LLC" .~~ . L{aC82ilZT ~,~." LSCFAL I)SSCRTPTI'JAT .rl that certa_n tract of land with the i~sprovements thereon erected, sit~:ate in South Middleton Township, Cuttttiexland County, Pennsylvania, bou.~d.sd era - descrilzed ae fa.lcws _ ~eainning at a point, the northeastern interse~etian of Hi11cr4st Drive and NJOCdlawn Lane; thence by the eastern side of Hillcreat Drive, Nartn 7.p° 12' 2rs== WAst, 25;,.7 feet to a point; thence by the dividing line between Lots I3oa. a and 9 on tra hereinafter mert?aned Plar. of Lots, North ~5° 19' EaS~-, 2oa.15 fe~°t tQ a poirr_; thence by the f~iviCi112C,~ line f7eLweEri Lets Fdas. E and 3 on said Plan cf icts, South J4° ?1t past, 15o feet ts~ a saint ar. thw northern side ox ~oodl.av~*n. Lane; thence uy the narthexn side of +taodlaWn Lane, South 85° 29' West`~S-~.S6 f°et to the place of beginning. 3e.na ,met No. 3 of Section ? on the Plan cf Lets known as ~oxge Raad Acres, as recorded irz the Office of the t~ecorder o€ Leeds €or Cu~aerland County in Plan: nook 2`1, Page 4. Subject, i3awever to the restrictions -& conditions as recorded in I~7isc. So0?t ? 66 , page 512, exce~+t as €t3].lowe ar:y d'rrellang ho:xae cozstructad on said lot sha;il havA :z~~t less t:~an ~1rU square feet Of luring area. 2. The exterior dimensions of any ranch type dwel:.i*~g :House constructed on sated lot shall be not.. less Lfian 25 feet b~= #4 ~aet, exclud,inr~ the garar~e yr ca rt~ort . 3. A gaxage cr carport at least ?4 feet wide shall be erected ~Nith env dJae=.ii:ZC house. Parcel Ive. 40-24~75U-C34 :~ ~~'C~ ` { } ~h ~~ ' i S i ~LE'1:.~5 October 4, 2012 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is._an official notice that the mortgage on vour home is in default and the lender intends to foreclose. Specific information about the nature of the default is urovided iin the attached pages. T_ he HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP~ may be able to help to save vour home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the CounseLne Agency -.:,;: The name, address and phone number of Consumer Credit Counseling Aeencies servuma your County are listed at the end of this Notice. If you have any uuestions, you may call the Pennsylvania Housing Finance Agency toll free at 1-840-342-2397 (Persons with impaired hearin.a can call (717} 784-18b9). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in ,your area. The local bar association may be able to help you find a lawyer. LA NOTTFICACION EN AD~UNTO ES DE SUMA IMPORTANCIA, DUES AFECT A ST.i DER.ECHO A CONTINUAR VIVIENDO. EN SU CAS.~i. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAIVIENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL I'ROGRAMA LLAMADO "HOMEOWNER'S EMERGENCI' MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SL' IIIPOTEC.4. Exhibit A '/ I30MEOWN~R'S NAME(S): Cathy Ann Peiffer PROPERTY ADDRESS: 579 HiIT Crest Dr. Carliste, PA 17013 LOAN ACCT. NO.: 103153227 ORIGINAL LENDER: Fidelity MartgaDe a division of Delta Fanding Ca oration CLFRRENT LENDER: HSBC Bank US.4, N.A., as Indenture Trustee fc~r the registered Noteholders of Renaissance Home Equity Loan Trust 200(-3 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU 1VIAY BE ELIGIBLE I+OR FINANCI_A.L ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS II< YOI COMPLY WTI`H THE PRO~'1SIONS OF TI3F; HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT l3AS BEEN CAUSED BY CIItCUMSTANCES BEYOND YOL"R CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YO'LrR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY TIIE PENNSYZVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you. are entitled to a temporary stay of foreclosure on your mortgage far thirty (>0} days from the date of this Notice (plus three t3} days for mailing}. During that time you must arrange and attend. a "face-to-face" meeting with one of the aons~uner credit counseling ag~,~cies listed at the end of this Notice. THIS MEETING ~VIUST OCCUR V4TITHIN THHtTY-THREE (33) DAYS OF THE DATE OF THIS ~vn~rrrF. r~ vnr r n~ u~T Appl.v FnR EMERGENCY MORTGAGE ASSrSTANCE. YOC? MiIfiT BRING POUR MORTGAGE LTP TO DATE. THE PART OF THIS NOTICE CALLED "HOB' TO CURE YOUR MORTGAGE DEFAULT" E~'LA1NS HOW 'r0 BRiNG YOL`I~ MORTG.!~GE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet. with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30} days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies far the county in which the t~ropem~ is located are set forth. at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your fonder immediately of your intentions. APPLICATION FOR MORTGAGJv ASSISTANCE -- Four mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from frizng a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face--ta-lace meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETI?VG 'WITH A C01LrNSELING AGENCY WTTHLN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 34 DAYS OF THA3' MEEfiING, THEN THE' LENDER WILL BE TEMPORARILY PRESENTED FROM STARTING A FORECLOSURE AG.ALNSfi YOUR PROPERTY, AS EXPLA~IED ABOVE, IN THE SUCTION CALLED "TElVIPORARY STAI' OF FORECLOSURE". YOU"' HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTIlVG A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT r1IVY TIME BEFORE A SHERIFF'S SALE, TRI; FORECLOSURE WILL BE STOPPED. - AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the P.gency under the eligibility criteria established by the Act- The Pennsylvania Housing Finance Agency has sixty {60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be: notified directly by tine Pennsylvania housing Finance Agency of its decision on your application NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTC'Y', THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED A5 AN .~TTEMP'T TO COLLECT THE DEBT. (If you have filed bankxuptcy yon can still apply for Emergency Mortgage Assistance.) ~-IGW TO CU1tE YOUR MQRTGAGE DEFAULT (Brim it up to date). NATL"RE OF TH)t% DEFAULT -The MORTGAGE debt. held by the above lender on your property located at: 579 Hill Crest Dr. Carlisle, PA 174]3 1S SERIOL?SLZ' IN DEI'ALTLT because; A. YOU FIAVE NOT MADE MONTHLY MORTGAGE PAY1gIENTS for the following months anti the following amounts are now past due: _Monthl~y P~ments of $742.18 for Mav I _2022 throu~h_October 1, 2012= _$:4,453.08 __.____._...._~._... Late Charges = $86.60 Other charges (explain/itemize}: Property ~~ aluation FeeslBPO = $292.00 Property Inspection Fees $2100 _ TOTAL AMOUNT PAST DL'E: _,--__-_-- __._-- __ _ ~4 8„~52.F8_. B. YOLJ HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do nat. use if not applicable}: NIA IIOW TO CURE THE DEFAULT' --You nay cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING TH.E TOTAL AMOUNT PAST DI3E TO THE LENDER, WHICH IS ~4;852.b$, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (3U) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made navable and sent ta: tidren Law Offices, P.C. Woadcrest Corporate Center 111 Woodcrest Road, S'e 200 ,. ,>_ Cherry Hill. NJ 08003-3620 You can cure any other default by taking the, fallowing action within THIIZ'IY {30) DAYS of the date of this letter: (Do not. use if. not applicable.): NiA IF YOU DO 1SOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Native, the lender intends to-exercise its rights to accelerate the mort4a~e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly uvstallments. If foil payment of t<he total amount past due is not made within THIRTY (30} DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mort~a,~ property. IF TIIE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt, if the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pa}~ the reasonable attorney's fee, that were actually incurred, up to $50.00. However, if legal proceedings v~e started. against you; you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which n~av also include other reasonable casts. If vau cure the default within the THIRTY {30) DAY period, von will not be required to pay attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally .for the. unpaid prizrcipal _. _ balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR T'O SHERIFF'S SALE - If you have not vured the default within the TIIIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to yore the default and event the sale at any time up to one hour before the Sheriff's Sale. You may do so by pavua~the total amount then past due plus any late or other charues then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as spevified in writine by the lender and bv_performin~ any other requirements under the mortea~e. Curing your default in the manner set Earth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE TJATE - It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be seat to you before the sale. Uf course, the amount needed to cure the default wi31. increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CO1V'TACT'I"II~i~it~~~ ~.~~:~. ~.:. _.. __ _ _ ::~~:.... . Name of Lender; Servicer: Ocwen Laan Servicing LLC Address: , __ _ __. 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Phone Number: 877-S9b-8580 Fax Number: 4f17-737-5593 Contact Person: Customer Service E-Mail Address: _ . ,. EFFECT OF SHERIFF'S SALE -You should realize that a Sherifr s Sale will end your ovv~tership of the mortgaged property and your right to occupy it. if you continue to live in the property after t2~~e Sheriff s Sale, a lawsuit,#o remove you and your furnishings and other belonginbs could be started by the lender at anv time. ASSUMPTION OF MORTGAGE -You may have the right to t*~ansfer your home to a buyer ar transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. I+3O'1'fCE The amount of your debt is as stated ixi 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,ss 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 wilt 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 a.nd 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 tiae collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached doculaaent is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREI\7 LAVS~ OFFICES, P.C. /s/ Martz J. lidren, Esquire Woodcrest Corporate Center lyl Woodcrest Road, Suite 200 Cherry Hill, N.I 08003-3620 (856}G69-5400 YOU MAY ALSO HAVE THE RIGHT: TO SELL TI-IE PROPERTY TO OBTAIi~I MONEY TU PAY OFF THE MORTGAGE DE$T OR TO BORRO~J MONEY FROM ANOTHER LENDING LNSTITUTION Tt) PAY OFF THIS DEBT. :_, _ ... • TO HAVE THIS DFFAL'LT CiTRED BY ANY "I'FIIRD PARTY ACTING- O?*I" Y"OUR BEHALF. TO HAVE THE R+IORTGAGE RESTORED TO TI3B SAME POSITION AS IF NO DEFt1LiLT HAD GCCUItRED, IF Y'OU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT' 1'O CURE YOUR. DEFAUL"f MORE THAN THREE TL'vIF,S IN ANY CALENDAR I~AR. j TO ASSERT THE NOIv~ISTFNCE OF A DEFAL~I.T LN ANY FORECLOSL,`RF, PROCEEDiIvG OR ANY OTHER LAWSUIT INSTffU'fED UNDER 1'HE MORTGAGE DOCUMENTS, .. . _ _. TO ASSERT ANY OTHER DET~'ENSE YOU BELIEVE ~'OU MAY H,4VE TO SUCH: ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BAIv'KRUPTCY L.A.W. CONSUMER CREDIT CC?UNSELING AGENCIES SERVING YC?UR COI.iNT~' CUMBERLAND COUNTY ~EN~:Ak' C~nsum~r- C~~d~t Co~ns~iing ~g.en~ies .___ Ct1'V~BERLAi'~T~ County Report lastupdrted ORIi',t2U12 i t:2G A;v1 Community Action Commission of Capital Region. 1514 Derry Street Harrisburg, PA i 7104 717-232-9757 CCCS of R%estern PA 2000 Lingiestovtm Road i-ia.*risburg, PA 17101 888-SII-2227 Maranatha 43 Philadelphia Avenue RTavnesbora. PA ':7258 711-752-3285 PA Interfaith Community Programs Inc 40 E High Street Cxettysburg, PA 1?325 7I7-~34-1118 PHPA 211 Noz"~i] Pram Street iarrisburg, PA I? 1 ? Q 7i%-780-3940 800-342-2397 _.... t ~ ~fUC1LlGh'~~"!'CQRr,:~,~±~ ~,r~r-dT~R . 111 trdOQDC~2~ST i~Us~l.1 C~!wRRY HILL: NJ 08003 7E]],2 Z64C1 Ud~Q 578 1~76fi ~. ~-'2'K-.~ Irv ~S P~ti ~=e~j'-~ x. ~: 01fiN2fib19Lf6 ~}~.~~~ 10/04/2G12 R9aifeH Frnm (}Q003 4 ~ t ~a~~ ~-'~ F~c_'i f }, ^ Complete items 1, 2, end 3. AI$o compiete A. t3tgnature , item 4 if Restricted Delivery is desired. Q Agent ~ X ^ Print your name and address on the reverse ^ Addressee . ' so that we can return the oard fo you. g. Received by (PrL7#ed Name) C. pate of Clalivary ^ Attach this oard to the back of the maltpieca, ar on the front It space permfts. D. is deivery address different ir¢m Item 12 fl Yes 1. Article Addressed to: tf YES, enter delivery address below: ^ No // ~`~-~ N i~ ttz~~a~ . `- ~ +~+_/-~ ~ P / j (~ d I ~ 3. Service Type + 'Certified Mal ^ Lx teas Mao ' 2. Article Number (7Yarwter from service labe+ L _ C pS Form 3811, February P d Pegisterad ~RPRaturn Recelt7t for Merchandise .Q 17~surad Mail ©C.O.D. 4. Restricted Delivery? {Extra Fae) ... [~ Yes 717~~ 3,64Q Q[lCl~^ 5078. ~7bq __.~ pomest(c ReWrn Receipt 702595-0&h1-i6a0 i, .-.-,~ 1 l ~~1.~ ~~111~ IJ~SH y /1~ ~~ Plaintiffs j vs. G~fi~-y ~n~ ~e'~ ~~tc- Defendant(s) FORM 1 h' THE COURT OF COMMON PLEAS OF ,~, CUMBERLAND COUNTY, PENNSYL~'ANTgq~ N 't'i ~ -~ Y"" -~ r~ w c'~ nn rr~~ ~Q{•~y~OlCivil .~~ ~. ~ ~ -- _... C? r., MORTGAGE FORECLO~'CJ~~E~ NOTICE OF RESIDENTIAL DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your borne. If you own and live in the residential property which is the subject of this foreclosure action, you may he able to participate in a court-supen~ised 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 (7l 7) 2~3-9400 extension 2~ IO or (800) 522-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, yc~u 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 sa 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 sixt}' (60) days of the service upon you of the foreclasure 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 mortUage 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. ti 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 youu and your lawver complete a financial worksheet in the format attached hereto, your lawyer will prepare and. file a Request for Conciliation Conference with the Court, which most. be filed with the Court within sixty (60) days of the sen~ice upon you of the foreclasure 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 REQUIKED BY THIS NOTICE;. THIS PROGRAM IS FREE. Respectfully submitted: Date [Signature of Counsel for Plaintiff] KASSIA FIALKOFF, ESQU?<.'= FORM 2 Cumberland Coun y Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # tiuKKC)WER 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 follo~~ing information to the best of your kno~~lledge: Borrower name(sj: Property Address: City-: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different) Cit` Phone Numbers: Email: of people in household: Maiiing Address: Cit~•; Phone Numbers: Email: # of people in household: First Mortgage Lender: Type of Loan: Loar. Number: Second Mortgage Lender; Type. of Loan: Loan Number: Total Mortgage Payments Amount: S Included Taxes & Insurance: Date of Last Payment: PrimarS- Reason far Default• State: 7_.ip: Yes ^ No ^ Listing date: Price: $_ Realtor Phone:_ Yes ^ No ^ Home: Cell: Zip: Hour long? Home: Cell: State: Office: Other: Office: Other: State: lip: How long? Date You Closed Your Loan: 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: S $ Retirement Funds: $ _ $ Investments: $ g Checking: S $ Savings: _ $ _ $ Other: $ $ Automobile #1: Model: Amount owed: _ Value: Automobile #2: Model: Amount owed; _ Value: Other transportation (automobiles boats motorcyclesl• Model: Year: Amount owed: Value Monthlv Income ', Name of Employers: 1. Year: Year: ., -- -, --- ~. Additional Income Description (n.ot wages): l ._ monthly amount: monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthlv Expenses: (Please only include expenses you are currently paying] EXPENSE AMOUNT EXPENSE AMOUI~TT Mort~ave Food 2" lviort ~a«e Utilities Car Payment(s) Cando/Nei h. Fees ~ Auto Insurance Med. (not covered) ~ 'Auto fiielire airs Other ro a ment ~ }nstall. Loan Payment Cable TV Child Su ort/Alim• S endin Money Dav/Child Care~Tuit. Other Ex enses ~ 4mount .Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agenc}~? Yes ^ No ^ If yes, please proti~ide the following information: Counseling .Agency: CounselorV Phone (Office): Ea3;: -, Email: Have you made application for Homeowners Emergency Mortgage lssistance Program (HEM.AP) assistance? `~ ~'es ^ No ^ If yes. please indicate the status of the application: Have you bad any prior negotiations ~ti°ith your ]ender or lender's loan servicing company to resolve your delinquency? ~'es ^ No ^ If yes. please indicate the status of those negotiations: Please provide the follm~~ing information, if know, regarding your lender or lender's loan servicing companw~: Lender's Contact (frame): Sen~icinp Company (Name): Contact: Phone: Phone: I/We, authorize the above named to use/refer this information to my lender,~sen~icer for the sole purpose of evaluating my financial situation for possible mortgage options. L!We understand that I!we am,'are under no obligation to use the sei~~ices provided by the. above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lend_e1r's counsel: V Proof of income V Past 2 bank statements Proof of any expected income for the last 45 daS-s r ~ Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) ti~ Listing agreement (if propec-t3~ is currenth• on the market) FORM 3 N s ~G ~~~ r~ ~~, N ~a Plainii:ff{s) vs. ~~~H y I~~ Pe.~ F~~~ Dcfendatrt(s} IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYI,VANI.A CIV1L., 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 follo~~~s: 1. Defendant is the owner of the real property «rhich is the subject of this mortgage foreclosure action; ?. Defendant lives in the subject real property, which is defendant's primar}' residence; _;. Defendant has been sensed 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 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel!Appointed Date Legal Representative Si~,nature of Defendant Date Signature of Defendant Date LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 {800)-990-9108 AVISO Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas - en las paginas siguientes, usted time veinte {20) dias de plazo al partir de la fecha de la demanda y la notification: Hate falta ascentar una comparencia escrita o en persona o eon un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a Ias demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la den~anda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas l.as provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE F,STA DEMANDA A UN ABOGADO IIViMEDIATAMENTE, 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 PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, FA 17013 (800) 990-9148 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 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 AGNES MOMBRUN, ESQUIRE - ID#309356 ELANA B. FLEHINGER, ESQUIRE - ID#209197 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 NICHOLAS GAUNCE, ESQUIRE - ID#206228 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(~udren.com_ _ _ __ _ ___ HSBC Bank USA, N.A., as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Loan Trust 2006-3 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Plaintiff ~~ c~ ~, .w. ~. a ~~~ ~., .... ~,~, w 3 ~'"' ~~ ,~- c» .:c COURT OF COMMON PLEAS CIVIL DNISION CUMBERLAND County ~a ~vi ~ 'NO. )a ~y v. CATHY ANN PEIFFER 579 HILLCREST DRIVE, CARLISLE, PA 17015-4333 Defendant(s) ~~ ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Kassia Fialkoff, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassail, Esquire; Agnes Mombrun, Esquire; Elana B. Flehinger, Esquire; Katherine E Knowlton, Esquire; Nicholas Gaunce, Esquire, and John Eric Kishbaugh, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN LAW OFFICES, P.C. ~ _,~- ~_~ BY:__~ _ KASSIA FIALKOFF, ESQUIRE 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 HSBC Bank USA,N.A.,as Indenture Trustee COURT OF COMMON PLEAS for the Registered Noteholders of Renaissance. CIVIL DIVISION Home Equity Loan Trust 2006-3 Cumberland County ' Plaintiff - V. MORTGAGE FORECLOSURE rn . � . CATHY ANN PEIFFER, NO. 12-7482-CIVIL Defendant(s) o > C:) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 ;� Plaintiff,by its/his/her Attorney hereby verifies-that: -- - 1. A copy of the Notice of Sheriffs Sale,a true and correct copy of which is attached hereto as Exhibit"A",was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution,on the date(s)appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date appearing on the attached Return Receipt,which was signed for by Defendant(s)on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit"B". 3. If a Return Receipt is not attached hereto,then service was by personal service on the date specified on the attached Return of Service,attached hereto as Exhibit'B". 4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as Exhibit'B". All Notices were served within the time limits set,forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ` UDREN LAW 'OFFICES,P.C. BY: ��� -Ztt'p Attorne for Plaintiff Esquire NICOIe LaBlefta, PA 1D 202194 MJU#: 10100373 CASE#: 10100373-3 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 S Ban A, .A., as ndenture COURT OF COMMON PLEAS Trustee for the Registered Noteholders of CIVIL DIVISION Renaissance Home Equity Loan Trust 2006-3 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE CATHY ANN PEIFFER; Defendant(s) NO. 12-7482-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): CATHY ANN PEIFFER; PROPERTY: 579 Hill Crest Drive, Carlisle,PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 06/05/2013 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 10100373 CASE#: 10100373-3 Name and Address Henrietta Crommarty 1-1 Registered E]Return Receipt for Check appropriate block for p Affix stamp here if issued as of Sender UDREN LAW OFFICES,P.C. ❑Insured Merchandise Registered Mail: certificate of mailing or for 111 Woodcrest Road,Suite 200 0 COD Int'l Recorded Del. ❑With Postal Insurance additional copies of this bill. Cherry Hill,NJ 08003 Certified �Express Mail �W ithout postal Insurance Posnnark and Date of Receipt Article Handling Act.Value Insured Due R.R. S.D. S.H. Rst.Del.Fee Line Number Name of Addressee,Street,and Post Office Address Postage Fee Charge (If Regis:) If COD Value Sender Fee Fee Fee Remarks ] Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle,PA 17013 2 Cumberland County Domestic Relations Section *00 13 North Hanover Street Carlisle,PA 17013 3 Commonwealth of PA,Department of Revenue t Bureau of Compliance 0 ?� PO Box 281230 w A m 'IV Harrisburg,PA 17128-1230 cN 01 n,, Z 4 Tenants/Occupants �- 0 o 579 Hill Crest Drive (� n o rQ 5 Carlisle,PA l70t3 a 5 12-7482 n 0 0 CS � M k Q 7 06/05/2013 as/SpM �e us 8 9 N 10 UJ 11 12 13 14 15 Total number of Pieces Total Number of feces Postmaster,Per Name of'Receiving Employee) The full declaration of value is required on all domestic and international registered mail.The maximum indemnity payable for the Listed by Sender Received Po Office _ reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is$50,000 per piece subject to a limit of $500,000 per occurrence.The maximum indemnity payable on Express Mail merchandise is$500.The maximum indemnity payable is $25,000 for registered mail,sent with optional postal insurance.See Domestic Mail Manual R900,5913,and 5921 for limitations of 4 coverage on insured and COD mail.See International Mail Manual for limitations of coverage on international mail.Special handling char es a I out to third and forth class arcels. PS Form 3877,February 1994 Form Must be Completed bye ewriter,Ink.or Ball Point Pen Cathy Ann Peiffer-MJU# 10100373-3 (Cumberland County) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE cr I&E c�SRIFF HSBC Bank USA, N.A. Case Number vs. 2012-7482 Cathy Ann Peiffer SHERIFF'S RETURN OF SERVICE 04/01/2013 02:32 PM -Deputy Jason Kinsler, 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 579 Hillcrest Drive, South Middleton Township, Carlisle, PA 17015, Cumberland County. 04/03/2013;01:25 PM :Deputy Noah Cline, being duly sworn according to law-, served the requested Real Estate'' Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Cathy Ann Peiffer at 579 Hillcrest Drive, South Middleton Township, Carlisle, PA 17015, Cumberland County. SHERIFF COST: $899.21 SO ANSWERS, April 09, 2013 RbNW R ANDERSON, SHERIFF G �lJ LU {c}CountvSuite Shenf, eteosoft..inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _ _r, Sheriff �q��r�t� �t �� Jody S Smith 14 Chief Deputy 4t: f-1, Y 22 d Richard W Stewart Solicitor �, ,tE IF ,LA?q Co—, y PENHSYLVANIjA HSBC Bank USA, N.A. Case Number vs. Cathy Ann Peiffer 2012-7482 SHERIFF'S RETURN OF SERVICE 04/01/2013 02:32 PM -Deputy Jason Kinsler, 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 579 Hillcrest Drive, South Middleton Township, Carlisle, PA 17015, Cumberland County. 04/03/2013 01:25 PM -Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Cathy Ann Peiffer at 579 Hillcrest Drive, South Middleton Township, Carlisle, PA 17015, Cumberland County. 05/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed", per letter of instruction from Attorney. SHERIFF COST: $1,319.35 SO ANSWERS, May 21,2013 RON R ANDERSON, SHERIFF 71) UDREN VAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODi2REST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ,08003-3620 856-669-5400 pleadinas(kudren.com HSBC Bank USA,N.A., as Indenture COURT OF COMMON PLEAS Trustee for the Registered Noteholders of CIVIL DIVISION Renaissance Home Equity Loan Trust Cumberland County 2006-3 Plaintiff MORTGAGE FORECLOSURE V. Cathy Ann Peiffer Defendant(s) NO. 12-7482-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 HSBC Bank USA,N.A., as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Loan Trust 2006-3,Plaintiff in the above action,by its undersigned attorney,upon information and belief,Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 579 Hill Crest Drive,Carlisle,PA 17013 1.Name and address of Owner(s) or reputed Owner(s): Cathy Ann Peiffer 579 Hillcrest Drive Carlisle, PA 17015-4333 2.Name and address of Defendants) in the judgment: Cathy Ann Peiffer 579 Hillcrest Drive Carlisle, PA 170154333 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4.Name and address of the last recorded holder of every mortgage of record: HSBC Bank USA,N.A., as Indenture Trustee for the Registered Noteholders of Renaissance Home Equity Loan Trust 2006-3 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders-None Jr Mortgage Holders-None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders-None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by'the sale: Cumberland County.Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tag Department 1 Courthouse Square Carlisle,PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Bog 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 579 Hill Crest Drive Carlisle,PA 17013 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDREN LAW OFFICES, P.C. 13 Att "L�6ntifr- HARRY B. REESE, ESQUIRE MJU#: 10100373 CASE#: 10100373-3 PA ID 310501 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCRE8T CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY BILL,NJ 08003-3620 856-669-5400 leadin saudren.com HSBC Bank USA,N.A., as Indenture COURT OF COMMON PLEAS Trustee for the Registered Noteholders of CIVIL DIVISION Renaissance Home Equity Loan Trust ; Cumberland County 2006-3 Plaintiff MORTGAGE FORECLOSURE v. CATHY ANN PEIFFER NO. I2-7482-CIVIL Defendants) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Cathy Ann Peiffer 579 Hillcrest Drive Carlisle,PA 170154333 Your house(real estate) at 579 Hill Crest Drive, Carlisle,PA 17013 is scheduled to be sold at the Sheriff's Sale on June 5,2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013,to enforce the court judgment of$117,173.38, obtained by Plaintiff above(the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDA.DOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ..... ........ .. . ALL THAT CERTAIN TRACT OF LAND•WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT, THE NORTHEASTERN INTERSECTION OF HILLCREST DRIVE AND WOODLAWN LANE; THENCE BY THE EASTERN SIDE OF HILLCREST DRIVE, NORTH 10 ° 12' 30" WEST, 150.7 FEET TO A POINT; THENCE BY THE DIVIDING LINE BETWEEN LOTS NOS. 3 AND 4 ON THE HEREINAFTER MENTIONED PLAN OF LOTS,NORTH 85° 19' EAST, 108.18 FEET TO A POINT; THENCE BY THE DIVIDING LINE BETWEEN LOTS NOS. 2 AND 3 ON SAID PLAN OF LOTS, SOUTH 040 41' EAST, 150 FEET TO A POINT ON THE NORTHERN SIDE OF WOODLAWN LANE; THENCE BY THE NORTHERN SIDE OF WOODLAWN LANE, SOUTH 85° 19' WEST 93.68 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 3 OF SECTION F ON THE PLAN OF LOTS KNOWN AS FORGE ROAD ACRES,AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 20, PAGE 4. SUBJECT,HOWEVER TO THE RESTRICTIONS & CONDITIONS AS RECORDED IN MISC. BOOK 166,PAGE 512, EXCEPT AS FOLLOWS: 1. ANY DWELLING HOUSE CONSTRUCTED ON SAID LOT SHALL HAVE NOT LESS THAN 1100 SQUARE FEET OF LIVING AREA. 2. THE EXTERIOR DIMENSIONS OF ANY RANCH TYPE DWELLING HOUSE CONSTRUCTED ON SAID LOT SHALL BE NOT LESS THAN 26 FEET BY 44 FEET, EXCLUDING THE GARAGE OF CARPORT. 3. A GARAGE OR CARPORT AT LEAST 14 FEET WIDE SHALL BE ERECTED WITH ANY DWELLING HOUSE. PARCEL NO. 40-24-0758-034 BEING KNOWN AS: 579 HILL CREST DRIVE, CARLISLE,PA 17013 PROPERTY ID NO.: 40-24-0758-034 TITLE TO SAID PREMISES IS VESTED IN CATHY ANN PEIFFER BY DEED FROM YONG KI PAEK AND CHUM L. PAEK, HIS WIFE DATED 09/20/1985 RECORDED 09/23/1985 IN DEED BOOK M31 PAGE 588 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7482 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due HSBC BANK USA,N.A.,AS INDENTURE TRUSTEE FOR THE REGISTERED NOTEHOLDERS OF RENAISSANCE HOME EQUITY LOAN TRUST 2006-3 Plaintiff(s) From CATHY ANN PEIFFER (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $117,173.38 L.L.:$.50 Interest FROM 2/5/2013 TO DATE OF SALE JUNE 5,2013-ONGOING PER DIEM OF$11.29 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE-$1,366.09 Atty's Comm: Due Prothy:$2.25 Arty Paid: $182.75 Other Costs: Plaintiff Paid: Date:2/11/2013 David D.Buell,Prothonotary (Seal) 1 :�-i .�7R P PPr�/l11 �~ Deputy REQUESTING PARTY: Name: HARRY B. REESE, ESQUIRE Address: UDREN LAW OFFICES,P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for: PLAINTIFF TII.IE C631'Y FROM RECORD Telephone: 856-669-5400 in Testitnony whereof, I here unto set my hand Supreme Court ID No.310501 and the seal of said Cou �+C Aisle, Pa. This it day of—, Q ,20 f -���, Prothonotary On March 8, 2013 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as 579 Hillcrest Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 8, 2013 By: Real Estate Coordinator C� cJ-I U CUMBERLAND LAW JOURNAL Writ No.2012-7482 Civil TITLE TO SAID PREMISES IS VESTED IN Cathy Ann Peiffer by HSBC BANK USA,N.A. deed from Yong Ki Paek and Chom V& L. Paek, his wife dated 09/20/1985 CATHY ANN PEIFFER recorded 09/23/1985 in Deed Book M31 Page 588. Atty.: Mark Udren ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEGINNING at a point,the north- eastern intersection of Hillcrest Drive and Woodlawn Lane; thence by the eastern side of Hillcrest Drive,North 10 ° 12' 30" West, 150.7 feet to a point; thence by the dividing line between Lots Nos. 3 and 4 on the hereinafter mentioned Plan of Lots, North 85° 19' East, 108.18 feet to a point; thence by the dividing line between Lots Nos. 2 and 3 on said Plan of Lots, South 04° 41' East, 150 feet to a point on the northern side of Woodlawn Lane; thence by the northern side of Woodlawn Lane, South 85° 19'West 93.68 feet to the place of BEGINNING. BEING Lot No. 3 of section f on the Plan of Lots known as Forge Road Acres,as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 20,Page 4. SUBJECT,however to the restric- tions & conditions as recorded in Misc. Book 166, Page 512, except as follows:1. any dwelling house constructed on said Lot shall have not less than 1100 square feet of liv- ing area.2. The exterior dimensions of any ranch type dwelling house constructed on said Lot shall be not less than 26 feet by 44 feet, exclud- ing the garage of carport.3.A garage or carport at least 14 feet wide shall be erected with any dwelling house. PARCEL NO.40-24-0758-034. BEING KNOWN AS:579 Hill Crest Drive, Carlisle,PA 17013. PROPERTY ID NO.: 40-24-0758- 034. 61 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 12, April 19 and April 26, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. r-- �TCO a Marie Coyne, Ed' or SWO AND SUBSCRIBED before me this 26 da y of April, 2013 Notary NOTARIAL SEAL DEBOi,AH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 23,2014 The Patriot-News Co. 20`20 Technology Pkwy the atr1*otwXews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries- 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. t PUBLICATION COPY, This ad ran on the date(s)shown below: 04/16/13 04/23/13 c_- -, 04/30/13 . . .. Sworn to and subscribed before me this 3 day of May, 2013 A.D. ota u lic COMMONVWEAL.TH OFD ANIA Notarial seal Public Holly Lynn Warfel,Notary Dauphin County Washington TWP Tres Dec.12,2016 My Commission Exp MEMBER,PENNS(LVANIA ASSOCIATION ARIES OF NOT I 2012-7482 CWII F1*6C BANK U81►,14X ANN KOM C A Mark Udren THAT CEI .TRACT OF ALL TfI'TIIE IN LAND T EON E D TO S TOWNSHIP, Soum MID ERLAN?) ED AND PENNSYLVANIA, DESCRIBED A YOM THE BEGINNING AT INTWFCr ON NOT DRIVE AND OF � F'8 THENCE- BY LANE; D� SIDE OF IIII�CREST DRIVE, NOM 10 ° 12' 30" CET' 150.1 FEET TO A POIlB`E EE LOTS ,�DMDINGLIl`TE ASR NOS.3 AND 4 ON I QF WORTH MENTIONED PLAN TOAPOINT, 85°19'EAS Y— DWIDING LINE T CE BY 2 AND 3o ON SAID P�pF IA 15 ON THE EAST,,150 FEET DI AVJN NOI 311E HORN SID OF WGODLAWN LANE,som THE 85° 19, WEST .68 B iG LOT NO. 3 OF SEMON F AS ON THE PLAN OF LOTS TCNOORDED FORGE A ' °�RECORDER IN THE OFFICE OF DEEDS�UN.I.Y IN pLATI gpOK 2dAAERI AND HOWE� THIN CI'IONS 8L.CONDITIONS AS RECORDED ST IN MISC.BOOK166+PAGE APT A$ FOLLO�UCTED D2WEG HOUSE CO ON SAID LOT SHALL HAVE NOT OF LESS THAN 1]00 SQUARE FELT'OR LIVING AREA-2' IDCYpE THE DIMENSIONS OF ANY RANCH DWELIdNG HODS S AkjL BE OT ON �. LOT LESS THAN , FEET GARAGE INGGEORCARPOIXt C��RT314 FEET WIDE SHALL BE RECD WITH ANY DWELLING HOUSE. CREST 1,ARCELN0.40 579 BEING KNOWN AS.579 HILL DRIVE CARLISLE,YA 170158-034 PROP�I TO�REM�IS VESTED IN CATHY ANN PEWMR BY DEED AND iZHOM FROM Y TED og�20119€.3 L.FAMI'US VM` IN DEO RECORDED 0'9123 BOOKM31 PAGE 588 s i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 - r leadin s udren.com HSBC Bank USA,N.A., as Indenture COURT OF COMMON PLEAS Trustee for the Registered Noteholders of CIVIL DIVISION Renaissance Home Equity Loan Trust Cumberland County 2006-3 Plaintiff MORTGAGE FORECLOSURE V. ,... C= ' a CATHY ANN PUFFER; et al NO. 12-7482-CIVIL -v ZZ ZZ CO rn Defendant(s) CD PRAECIPE TO WITHDRAW JUDGMENT r AND DISCONTINUE WITHOUT PREJUDICE =c' ;Z TO THE PROTHONOTARY: Kindly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE,upon payment of your costs only. DATED: �"�� ��l UDREN LAW OFFICES, P.C. BY: Attorn for Plaintiff MJU#: 10100373 CASE#: 10100373-3 Nicole LaBlefta, Esquire PA ID 202104 �9 C#-530 -33 �ag33s�