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Home My WebLink About13-0090UDREN LAW OFFICES, P.C. 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 KAS5IA 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinys~,udren.com Ocwen Loan Servicing, LLC C/O Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Plaintiff v. ALEXANDRA M. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 MICHAEL J. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 Defendant(s) ATTORNEY FOR PLAINTIFF r:t ....~ -~• r~ ~ .~-yy ~ ~~y ~~ b ~ wM1~. ` I ~ , ~~ ~ _ .., -< ~ -. - ~o ~,. s , ~,- - o -- ,.o c ~ ~ COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. i~, ~D COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A s ~1G~ .~5~ a C~ ~~ ul~ 3 ~ ~~ag~gy3 LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) Bias de plazo al partir de la fecha de la demands y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demands en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your-part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems, Inc. (HERS) Assignee: Ocwen Loan Servicing, LLC Date of Assignment: 07/28/2011 Recorded Date: 08/23/2011 Book/Instrument #: Instrument #201123362 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Alexandra M. Greenfield & Michael J. Greenfield (hereinafter "Defendants"), are the owners of property located at 236 Walton Street, Lemoyne, PA 17043, by virtue of Deed dated 04/26/2005 and recorded 05/12/2005 in Official Records Book 268 at Page 4159 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 08/03/2007, Defendant(s) and/or their predecessor: MICHAEL J. GREENFIELD promised to pay to the order of Taylor, Bean & Whitaker Mortgage Corp., the principal sum of $105,950.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/03/2007, Defendant(s) and/or their predecessor: ALEXANDRA M. GREENFIELD & MICHAEL J. GREENFIELD to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc. as nominee for Taylor, Bean & Whitaker Mortgage Corp., the Property which is the subject of this action. The Mortgage was recorded on 08/10/2007 in Official Records Book Document No. 200731376 at Page N/A. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 12/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $99,334.60 Accumulated Interest $6,591.31 Accumulated Late Charges $165.25 Escrow Deficit/(Reserve) $3,282.32 Property Inspections $125.50 Title Report $325.00 Attorney Fees $1,650.00 Grand Total $111,473.98 The above figures are calculated as of 11/19/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.37500 %. The per diem interest accruing on this debt is $17.02 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $33.05. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $111,473.98 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OF~~ KASSIA FIALKOFF, ESQUIRE PA ID 3J0530 VERIFICATION The undersigned states that h she]is authorized to make this verification on behalf of the Plaintiff, and that the facts set forth in the foregoing pleading are true and correct to the best of the information and belief of the undersigned. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date ~ ~ ~ sZ~ JoAnne R. Patterson Name: Contract Management Title: Coordinator Company: Ocwen Loan Servicing, LLC MJU #: 11030777 CASE #: 11030777-2 p,~~r -`+~" r ~ >, ~ ~ ~~ ~~~~~~°~""f;} W~I~.}F' I~ i}~ ',~ I 1I,:~, ""'~ `FG~+~~~'Y.~.~fi pry Y~ ~~ ~' ~ ,. ,,1 ~ ~~,~+~~/ ~~,~~. ~...i.~~~ +~LL THAW .'•G'Tt'f'AI'N le~ni'~round. ~t'Cllh'i'~ in the Etiarooi~ii itf'Lt~1t~:~ttt, 3:U~t~bQY1811!~ ~'t~i1t-~'. P4ttttsYkvmrk, mart >}0~~~~Uy~I~Iv ~+ttnriwd s~nsi iicc~firifu+t~ t'~4~n~s; crr wit; ~E~l1~N1I"dt"rt ~~ ~ :rQn pm un iht ~Ui1~[t~t >:IdC o~ ~ tlr„~, ~4sr~e,~ r~# tisr$ rividtn line bttt+rtrr ~ r~~r ~i~ dr xnt7 +#'1 tiri iks~ 11tC8~thl~t+~t' II1ott~ton.d p~ ot''Lua, :rts! point 4~rid~, d~} f~# a+it~ ~,aa,.+trer[ Y-+~stww~dfb t~~m ~ titcsl~~+'~+t ~ t11t ft-~SC~CKI~irti t}C Wi~lnuc ~~~~ ~nri ~ ~ix.~t, [Isance ~lc~n~ soi+.i ~~+4~ Idttt~: 14n~. fit~utkt 3ti ~ ~~6G~ # t~~t#114`~ ~~'~ ~ ~'.$G fn# ~ ~n n~tiM ptt}; theiic ~~f~ r~e~rsax 1A~c#t a clii~te~ns:~ ~~ l+ci ~ an inin ~Ylt; ~tanre l+la~t#h ~~ dE,~r+~s wlo~ ~ rJrmnnce ut 1! ~.~~ ft:et tc~ n pant. ±~It th±' ~nuthans rich ~~C~~Ix ~»at~ i~sttc¢ tlortk tltr s~vtMth~!1'i'i ~idr ¢`W'nl1~n ~iRt, t4astt~ ~4 deKrtc~ E~~t ~ t~iit~i,~,N ,;Af A~ feet tai n polnt, tht~ pine of h~llutt October 1S, 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 provided in the attached Wages. ' The HOMEQWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP} may be able to help to save vour home. This Notice explains how the program works rvt~ AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NO' this Notice with you when you meet with the Counseling A.genev The name, address and. phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice If you have any questions you may call the Pennsylvama Housing Finance Agency toll free at 1-800-342 2397 (Persons with impaired hearing can call (717) 780.1869). 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 Iocat bar association may be able to help you find a lawyer. _ LA NOTIFICA-LION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO ~EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTiFICACION OSTENGA LTNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO KHOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE I.A PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. EXHIBIT A k HOMEOWNER'S NAME{S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Michael J. Greenfield Alexandra M. Greenfield 236 Walton Street ~~_~~J~"___.._.---.__._.___._..__._.___.____ _ Lemoyne, PA 17043 ____ 71559116 -.Taylor, Bean & WhitakerMortgage_CorPM __..-_.-.:.___---__. Ocwen Loan Servicing, LLC _ _ __ HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE I30MEOWNER'S EMERGENCY MORTGAGE ASSISTANCE. ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: iF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASOI\TABLE PROSPECT OF BEING ABLE TU PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELYGIBII.ITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty {3U) days from the date of this Notice (plus three {3) days for mailing}. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIItTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE 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 {3U) days after the date of this meeting. The names, addresses and telephone numbers of designated con.suxrier credit counseling agencies for the county in which the proi~erty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice {see following pages for specific information. about the nature of your default.) 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 dais 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 ].ender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty {30) days of your face-to-face meeting with. the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FII.E AN APPLICATION WITH PHFA WTTHLN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU RAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIPVIE BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application NOTE: IF YOU ARE CURRENTLY PROTErCTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TffiS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. {If ,you have filed bankruptcy you can still apply far Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it uln to ciatel. NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above ].ender on your property located. at: 236 Walton Street Lemoyne, PA 17043 IS SERIOUSLY I1V DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS far the following months and tihe following amounts are now past due: Monthly Payments of $660.99 for December 1, 2011 through January 1, 2012 = $1,321.98 Monthly Payments of $1,133:22 for February_l, 2012 throu~h_October_l, 2012 =_$10 198.98 ____ ate Charges ,_ $264.40 Other charges (explain/itemize): Property Inspection Fees = $115.50 _ Suspense Balance = -$33.25 ______._._._.._...___.._.._ _._.._.____._._.._._.___..._. TOTAL AMOUNT PAST DUE: $11,867.61 B. YOU HAVE FAII.ED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): N/A HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30} DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH LS $11,867.61, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check certified check. or money order made a able and sent to: Udren Law Offices, P.C. Woodcrest Corporate Center 111 Wooderest Road Suite 200 Cherry Hill, NJ 08003-3620 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable: N/A IF YOU DO NOT CURE THE DEFAULT -- If you do pat cure the default within THIRTY (30} DAYS of the date of this Notice, the lender intends to exercise itc rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may Lose the chance to pay the mortgage in monthly installments. If full payment ~of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal actian to foreclose upon your mortgaged property lF THE 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 praceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY {30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30} DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at env time up to one hour before the Sheriff's Sale You may do so by payins the total amount then past due plus env late or other charges then due reasonable attorney s fees and costs connected. with the foreclosure sale and an other costs connected with the Sheriffs Sale as specified in writine by the lender and by performing any oilier requirements under the mortgage. Curing your default m the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - 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 Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender/Servicer: Ocwen Loan Servicin~___._.._..__.__...._._...______.___..._.__....._..........._._........_. _. _._..__... Address: - -- 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Phone Number: 877-596-8580 Fax Number: 407-737-5693 Contact Person: Customer Service E-Mail Address: EFFECT OF SHERIFF'S SALE -- You should realize that a. Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Saie, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may have the right to transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document, Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a capy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to yau. 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. is/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry HiII, NJ 08003-3620 (SS6) 669-5400 YOU MAY ALSO 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. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSTI'ION AS IF NO DEFAL=L,T HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANA" CALENDAR. YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT .IN ANY FORECLOSURE PROCEEDING OR AIv'Y OTHER LAWSUIT II~'STITUTED UI~TDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVF, YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • """ TO SEEK PROTECTION `UNI3ER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Cumberland County ~iEMAP Consumer Credit Counseiin~~encies CUMBERLAND County Report last updated; 08/1 12012 3 3:26 AM Community Action Commission of Capital Region. 1514 Derry Street Hamsburg, PA 17104 717-232-9757 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA I7I02 888-511-2227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 7I7-762-3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA i 7325 717-3 34-15 l 8 PHFA 211 North Frant Street Hamsburg, PA I7I I0 717-780-3940 800-342-2397 ,, 1 f } ~ : ... tE ~ ~~ s ~._~ ~,~ b _ i , ~ °~ i - 1 I .. i i i ~n~~ ~o1a ona^ 965tJ ~11~ 7[]b2 ],a1n R~tpn 965q ~],~~7 ~ = m -+ ~~ ~A ~o ~3 ~M' ~~ ~ .. ~ m ryryT ~ ['pi1 f1T~ ~ ~ tC C tD N ufi O ~ . . .... ~ j ~ N~E ~::; .<.. z ° ;: ,:: m 3 :~ zf F 5 R.., #,', i~~~ ~ ~,~ `~ ~i i. E,~~.:.t ._ .~.g (iii ~ ~~h#t~~y SCi ~~.~~~() 1ci i ~,• 2 U !'~ ~! Complete items 1, 2, and 3. Aiso complete Item 4 if Restricted Delivery is desired. ^ Prfnt your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mallp(ece, or on the front if space permits. 7. Article Addressed to: ~-~ r c:VY.~~I -z~~ UJ~°~F~,r, .s, ~,~e.-,~-- ~~S`J~~~t .~~~~3 2. ArtlcleNumber -_~ ee) D Yes (Transfer fromservlcelabet) _~~~L,' ~~1^ pOQp 965p 3],~,~ PS Form 3811, February 2pp4 ~ Domestic Return Receipt -- -- t02595-OZ•M-1¢40 ~ + G~ ~ y ~ Q> B C ~ St ~ lr a ? U w~ OH ` .~ ~ `. +~ ~ ~ w . V C,.U N t~ ~ ~ j 0 ;1 ~ 7 V ~; ~ ,-'3 'r CG .~ a CU `~ +C C C .^~i, :u'O O" L ~ c c3 ~; v Q o C,3 r~ a ~ ~ i~ ~ w: r~ ~ . ,~ ~ e. ----- A. Signature X ^ Agent ^ Addressee R. Received by (Printed Name C. Date of Delivery , D., Is delivery address different fiom Item 1 ? D Yes If YES, enter delivery address below: D No ~I 3. Service Type ~Cerflf'ied Mail D Express Mall ' Registered Return Receipt for Merchandise D Insured Mail CJ,G.O_D. 4. Restricted Delivary7 (Extra F ~ tl~ll,il~1~' ~t1~e~, , V~ ~ t ? x- ~i ~~~=i~! ~ i 'I ~ .. '-.}.} 7D12 1D],D DDDD 965D 31DD 7D1,2 ti01D DDDD 965D 31DD __.~q: o c^c^~ a mx m o ~ ~ ~ m gN ~ D ~ ~ m .~ M . ]si -li ~ ' ' tii ~ o~ m ~ S ? ~ ~ „, ~ ~~ ' ~i ~ i~ ~ ~~ 37 fpSn ~ ~,~ CO '~ m Yt r a m -i o f" .: ~ m ~ 0 fl . ,x ~ ~ ~ . , ~ ~: . . ,~ i ~ ,,., -r :: rn. 9 9 J "~ 4~ ~ dSf .., ~'~~ ~ t ~ v .~:: '-'r~.' 1C~ ~i20'i2 o!~ ~=~ t~ l ATat` ^ Complete Items 1, 2, and 3. Also complete item 4 It Restricted Delivery is desired. ^ 'Print your name and address an the reverse so that we can return the card to you. ^ Attach this card to the back of the malipiece, or on the front if space permits. 1. Article Addressed to: (QY7~tc:>~ , ~`t~~ f l'ul-sly A. Signatwe x D Agent ^ Addressee B. Received by [ Printed Name) G. Date of pelivery D, Is delivery address different from item t? ~ Yas IF YES, enter delivery address below: O No 3. Service Type Certified Mali • ^ Express Mall O Registered ~ Return Receipt for Merchandise ^ insured Mali ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ^ Yes 2. Article Number ~Qy~ ~O~o o00a 9650 31,g0 (T)ansfer from service labeR f PS Form 3811, February 2004 Domestic Return Receipt t0259b-D2-M-f54U ~v ~ - - ~ o.c ... _. - ~~ V +J cJ L: r RC V m ~j w u` r J r1i ~~ 0 _ u: ~' ~ ,c m ~~ u~ e . ' ~ , _e ~~ ;~ k ~ Q H- ., E X 1 . +. ,~ W ~ ` ;~ .~ x . :~ _ ~ , v _ ~ ~ w. LL c.a a u ~, E a s a cr ~, e ~ T~ FORM 1 J r.~ -, ~ IN THE COURT OF COMMON PLEAS C+~ ~= -.-. CUMBERLAND COUNTY, PENNSYL~IA ~ ~';-1~? Plaintiff(s) .• r --i a Defendant(s) ~ DCivil ~G `~ ~'~'~ ~' ~ , y ~ NOTICE OF RESIDENTIAL MORTGAGE FORECLOS~LTRE .~t DIVERSION PROGRAM You have been. served with. a foreclosure complaint that could cause you to lose your home. if you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with vour lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twent<~ (20} days of your receipt of this notice, you must contact MidPenn Legal Sen~ices at (717) 243-9400 extension 2~ 10 or (800) 822-5288 extension 2510 a.nd request appointment of a legal representative at no charge to you.. Once you have been appointed a legal representative. you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so.that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court. which must be filed with the Court within sixty (b0) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled. you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to he e[igi.ble for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared an your behalf. If you and your lativyer complete a financial worksheet in the format attached hereto, vour lawyer wilt prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. if you do so and a conciliation conference is scheduled. you will have an opportunity iG nleci Witn a representative of your iei~'uer „~ air ..~.empt tv i~'Cr;: „'.;; rya ^•~+!° with vour lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOL? MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. 3 Date Respectfully submitted: LSignature of Counsel for Plaintiff? KASSIA FIALKOFF, ESQUIRE PA ID 310530 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Doekei # Borrower name(s): Property Address: City: is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different) Citv: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender: _ Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Stater Zip: Yes ^ No ^ Listing date: Price: Realtor Phone: Yes ^ No ^ Home: Cell: State: Zip: Office: Other: How long? Home: Cell: State: Zip: Office: Other: How long? Date You Closed Your Loan: Total Mortgage Payments Amount: $ lncluded Taxes & Insurance: Date of Last Payment: Priman~ Reason for Default• Is the loan in Bankruptcy? Yes ^ No ^ BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please protiride the following information to the best of your knowledge: If yes, prop-~ide names. location of court; case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ - $ Retirement Funds: $ ~ Lnvestments: $ ~ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Amount awed: _ Value: Automobile #2: Model: Amount awed: Value: Other transportation (automobiles boats motorcycles~• Model: fear: Amount owed: Value Year: Year: Monthly Income Name of Employers: 1. ~. Additional Lncome Description (not wages): I. monthly amount: monthly amount: Borrower Pay Days: _ Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT MortQave Food 2" Mort axle Utilities Car Payment(s) C~ndo/Nei h. Fees Auto Insurance Med. (not covered) Auto fiielire airs Uther ro a ment Install. Loan Pa_ •ment Cable Tti' i j ~."l1}.~. ~~4pnnr•f;'A:~rr~ S endln ~~ PJlnn ~~; • D /ya' Child CareiTuit. Other Expenses i -1 Amount Available for Monthly Mortgage Payments Based on income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email Have you made application for Homeowners Emergency Mortgage Assistance Program (HEM.~P} assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations writh your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If ves, please indicate the status of those negotiations: Please provide the follov<ring information, if know, regarding your lender or lender's loan servicing company: Lender" s Contact (1~Tame): Servicing Company (Name): Contact: Phone: Phone: UWe ,authorize the above named to use/refer this information to my lender!servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I!We understand that I/we am,~are under no obligation to use the services provided by the above named Borrower Signature `O'BOiTO ~/e1" S.`c;lature TJate Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements 1~ Proof of any expected income for the last 45 days ~ Copy of a current utilit~~ bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if properh~ is currently on the market) Date J FOKM 3 IN THE COURT OF COMMON PLEAS C)F CUMBERLAND COUNTY. PENNSYI,V.AN1A Plaintiff(s) : vs. Defendant(s) C'IV.I.I. REQUEST FUR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated . ?012. governing the Cumberland Count<~ Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as :follows: 1 • Defendant is the owner of the real property which is the subject o:f~ this moJ-tgage foreclosure. action; ?. Defendam Lives in the subject real property, which is defendant's primar} residence; ~. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program'' and has talen all of the steps required in that Notice to be eligible to participate in acourt-supervised conciliation conference. The undersigned verities that the statements made herein are true acid 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 De_fendant's Counsel,-Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date 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 rat ~- ---_ SALVATORE CAROLLO, ESQUIRE - ID#311050 ~~~'.. ~ `~ PAIGE M. BELLING, ESQUIRE - ID#309091 ..~~ -..~ ,,,,;$ ~; HARRY B. REESE, ESQUIRE - ID#310501 ~~ ,,. ~°..~:; KASSIA FIALKOFF, ESQUIRE - ID#310530 , ~ y ~ ~= 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 leadin~s a,udren com ____ Ocwen Loan Servicing, LLC '~ COURT OF 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 Plaintiff ,COMMON P LEAS v. CIVIL DIVISION ALEXANDRA M. GREENFIELD CUMBERLA ND 236 WALTON STREET, LEMOYNE, PA 17043 'County MICHAEL J. GREENFIELD / 236 WALTON STREET, LEMOYNE PA 17043 NO• ~ ~- ~ ~ i V; l~ , 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~ F~"~'~?~;r PA ID 3105aU s Ocwen Loan Servicing, LLC c/o Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. Alexandra M. Greenfield and Michael J. Greenfield 236 Walton Street Lemoyne, PA 17043 Defendants Docket No. 13-90 CIVIL ACTION- MORTGAGE FORECLOSURE CASE MANAGEMENT ORDER AND NOW, this 90 day of I2613, the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on QQ 13 at d in C,?tQir?p_ at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial a Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made and may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 with the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendantiborrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, z' I ?Ix DISTRIBUTION: vl Jaime M. Haley, Esquire MidPenn Legal Services 401 E. Louther Street, Ste 103 Carlisle, PA 17013 For the Defendant Mark J. Udren, Esq. Kassia Fialkoff, Esq. Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 For the Plaintiff ( I'll cf' e s n'a. I."j ?/1)0//? J. 1.. 1 ,ellC OCWEN LOAN SERVICING, IN THE COURT OF COMMON PLEAS OF LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION—LAW VS. : NO. 13-4090 CIVIL ALEXANDRA M. GREENFIELD and MICHAEL J. GREENFIELD, Defendants MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held June 14, 2013,were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley, Esquire, attorney for the homeowners. It appears that the servicing entity for the plaintiff has changed and that this foreclosure has been assigned to NationStar Mortgage LLC. NationStar is requesting a release from the defendants so that they will be able to correspond and otherwise communicate with counsel. Unfortunately, it may be that the submissions made are now outdated. NationStar has requested a continuance of the conciliation for a period of thirty(30).days. ORDER AND NOW,this /y+ day of June, 2013, continued conciliation conference is set for Friday, July 12,2013, at 3:00 p.m. in the Chambers of the undersigned. BY THE COURT, 1 Kevi . Hess, P. J. Nathan Wolf, Esquire ' --� For the Plaintiff n: x Y .-. w Jame Haley,Esquire r- For the Defendants b -� �: CD-n �z C . ?- , OCWEN LOAN SERVICING, IN THE COURT OF COMMON PLEAS OF LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION—LAW VS. NO. 13-0090 CIVIL ALEXANDRA M. GREENFIELD and MICHAEL J. GREENFIELD, Defendants MORTGAGE FORECLOSURE ORDER AND NOW,this day of July, 2013, at the request of counsel, the conciliation conference set for July 12, 2013, is continued to Friday, August 30, 2013, at 10:00 a.m. in the Chambers of the undersigned. BY THE COURT, Kevin .'Hess, P. J. Nathan Wolf, Esquire For the Plaintiff ,--�Jaime Haley, Esquire For the Defendants :rlm I DES •Cs�t J f { OCWEN LOAN SERVICING, IN THE COURT OF COMMON PLEAS OF LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION-LAW VS. NO. 13-0090 CIVIL ALEXANDRA M. GREENFIELD and MICHAEL J. GREENFIELD, Defendants MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held August 30, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley, Esquire, attorney for the homeowners. Mr. Wolf will provide Ms. Haley with a list of the few submissions which remain outstanding. The homeowners will have fourteen (14) days within which to submit these final documents. The conference will be continued, again,to give the plaintiff the opportunity to evaluate the situation. ORDER AND NOW,this 30' day of August, 2013, continued conciliation conference is set for Thursday, October 24, 2013, 2:30 p.m. in the Chambers of the undersigned. BY THE COURT, Kevin . Hess, P. J. .s athan Wolf, Esquire cD 3:-M = pt S r-= ,.A For the Plaintiff cnr-- W ' may, C:) , aime Haley, Esquire For the Defendants, =c> Am .. $ 3v ! 3 OCWEN LOAN SERVICING, • IN THE COURT OF COMMON PLEAS OF LLC, • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • CIVIL ACTION—LAW vs. : NO. 13-0090 CIVIL -i- -D ALEXANDRA M. GREENFIELD v;; fl� ; and MICHAEL J. GREENFIELD, = - - _ Defendants • MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held October 24, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley, Esquire, attorney for the homeowners. Submissions to the bank are now complete. Presumably, the plaintiff has this matter under review. The conference will be continued to afford the plaintiff the opportunity to complete its evaluation ORDER AND NOW, this 2 Y' day of October, 2013, continued conciliation conference is set for Monday, December 16, 2013, 1:30 p.m. in the Chambers of the undersigned. BY THE COURT, Kevin ess, P. J. ✓ Nathan Wolf, Esquire For the Plaintiff /.l acme Haley, Esquire For the Defendants :rim CC3p I'ELS yrzatic.;‘, /op.r//3 OCWEN LOAN SERVICING, : IN THE COURT OF COMMON PLEAS OF LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION—LAW vs. : NO. 13-0090 CIVIL ALEXANDRA M. GREENFIELD : and MICHAEL J. GREENFIELD, : Defendants : MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held December 16, 2013, were Nathan Wolf, Esquire, local counsel for the plaintiff, and Jaime Haley, Esquire, attorney for the homeowners. A change in servicing entity has once again occasioned a delay in this matter. Documents continue to be required and will be submitted by the defendants within seven(7) days. A continued conference will be set by order of even date herewith. ORDER AND NOW, this /�' day of December, 2013, continued conciliation conference is set for Friday, January 24, 2014, 2:15 p.m. in the Chambers of the undersigned. BY THE COURT, At" Kevin '1. Hess, P. J. ✓ Nathan Wolf, Esquire For the Plaintiff '= Jaime Haley, Esquire x ; For the Defendants c)n r CO's t ES t lick, tr- OCWEN LOAN SERVICING, IN THE COURT OF COMMON PLEAS OF LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION—LAW VS. NO. 13-0090 CIVIL ALEXANDRA M. GREENFIELD and MICHAEL J. GREENFIELD, Defendants MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this Z Y' day of January, 2014, following conciliation conference, it appearing that there are still documents outstanding in this case, a continued conciliation conference is set for Monday, February 10, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevi . Hess, P. J. Nathan Wolf, Esquire For the Plaintiff ZJaime Haley, Esquire For the Defendants Arn ` Ces fry., ;)� •s Zr N L; _ ;-0 OCWEN LOAN SERVICING, : IN THE COURT OF COMMON PLEAS OF LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION—LAW vs. : NO. 13-0090 CIVIL ALEXANDRA M. GREENFIELD : and MICHAEL J. GREENFIELD, : Defendants : MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this !O• day of February, 2014, following conciliation conference, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this case is VACATED. The plaintiff is authorized to proceed with the foreclosure action. BY THE COURT, 4AL Kevi• . Hess, P. J. ✓ Nathan Wolf, Esquire For the Plaintiff /ime Haley, Esquire For the Defendants :rlm Copt'es IYLIALQL CD cp_pgiq xtz`f rt7 /11 b —' X cp LP? DC x -r' UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin • s ' udren.com ATTORNEY FOR PLAINTIFF Ocwen Loan Servicing, LLC COURT OF COMMON PLEAS CIVIL DIVISION v. Plaintiff ALEXANDRA M. GREENFIELD MICHAEL J. GREENFIELD Defendant CUMBERLAND COUNTY NO. 13 -0090 PRAECIPE TO SUBSTITUTE SUCCESSOR IN INTEREST AS PLAINTIFF PURSUANT TO Pa.R.C.P. 2352(a) TO THE PROTHONOTARY: Kindly substitute Nationstar Mortgage LLC as the successor Plaintiff in the pending action, by virtue of an Assignment of Mortgage recorded on June 3, 2013 in the Cumberland County Recorder of Deeds Office as Instrument Number 201318204. A true and correct copy of the Assignment of Mortgage is attached hereto as Exhibit "A ". UDREN LAW OFFICES, P.C. B A edfor Plaintiff J. Eric Kishbaugh, Esquire PA ID 33078 aM-I 4q.s6pd a #i etli,?-77(/ %38(03 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin • s 1 udren.com Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. ALEXANDRA M. GREEN FIELD MICHAEL J. GREENFIELD Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 13 -0090 CERTIFICATE OF SERVICE The undersigned attorney, hereby certifies that I have served or caused to be served true and correct copies of the Praecipe to Substitute Successor in Interest as Party Plaintiff Pursuant to Pa.R.C.P. 2352(a) upon the following person(s) named herein at their last known address or their attorney of record by: xxxxx Date Served: April], , 2014 TO: Regular First Class Mail ALEXANDRA M. GREENFIELD C/O JAIME M HALEY, ESQ. 401 E. LOUTHER STREET SUITE 103 CARLISLE, PA 17013 MICHAEL J. GREENFIELD C/O JAIME M HALEY, ESQ. 401 E. LOUTHER STREET SUITE 103 CARLISLE, PA 17013 UDREN LAW OFFICES, P.C. BY: A TO ' EY FOR PLAINTIFF J EricKishbaugh, Esquire PA tp 33078_ Inst. # 201318204 - Page 1 of 4 Prepared By / Return To: E.Lance/NTC, 2100 Alt. 19 North, Palm Harbor, FL 34683 (800)346 -9152 Loan #: 463581067 Effective Date 05/16/2013 Tax Code/PIN/UPI #: 12 -22- 0820 -065 CERTIFIED PROPERTY IDENTIFICATION NUMBERS 12 -22- 0820 -065 - LEMOYNE BORO CCGIS REGISTRY 06/03/2013 BY TB ASSIGNMENT OF MORTGAGE FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the undersigned, OCWEN LOAN SERVICING, LLC, WHOSE ADDRESS IS 1661 Worthington Road S'1'E 100, West Palm Beach, FL, 33409, (ASSIGNOR) by these presents does convey, grant, assign, transfer and set over the described Mortgage therein together with all interest secured thereby, all hens, and any rights due or to become due thereon to NATIONSTAR MORTGAGE LLC, WHOSE ADDRESS IS 350 HIGHLAND DRIVE, LEWISVILLE, TX 75067 (469)549 -2000, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE). Said Mortgage dated 08/03/2007, in the amount of $105,950.00 made by MICHAEL J GREENFIELD AND ALEXANDRA M GREENFIELD to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP. recorded on , in the Office of the Recorder of Deeds of CUMBERLAND County, in the State of Pennsylvania, in Book , Page and/or Document # 200731376. Property is more commonly known as: 236 WALTON ST BOROUGH OF LEMOYNE, LEMOYNE, PA 17043. See Exhibit attached for Assignments, Modifications etc. Dated this 31st day of May in the year 2013 OCWEN LOAN SERVICING, LLC By: NADINE HOMAN AUTHORIZED SIGNATORY All Authorized Signatories whose signatures appear above are employed by NTC and have reviewed this document and supporting documentation prior to signing. FHLNA 20171304 -- N1 DOCR T3113053014 [C] EFRMPA1 1111111 11111 11111 11111 111111111111111111111111 liii 11111111111911111111111111111111111111191 Inst. # 201318204 - Page 2 of 4 Loan #: 463581067 Effective Date 05/16/2013 STATE OF FLORIDA COUNTY OF PINELLAS The foregoing instrument was acknowledged before me on this 31st day of May in the year 2013, by Nadine Homan as AUTHORIZED SIGNATORY for OCWEN LOAN SERVICING, LLC, who, as such AUTHORIZED SIGNATORY being authorized to do so, executed the foregoing instrument for the purposes therein contained. He /she /they is (are) personally known to me. Ja4,1„ NICOLE BALDWIN - NOTARY PUBLIC COMM EXPIRES: 08/05/2016 Nicole Baldwin Notary Public State of Florida My Commission # EE 222285 Expires August 5, 2016 Assignment of Mortgage from: OCWEN LOAN SERVICING, LLC, WHOSE ADDRESS IS 1661 Worthington Road STE 100, West Palm Beach, FL, 33409, (ASSIGNOR), to: NATIONSTAR MORTGAGE LLC, WHOSE ADDRESS IS 350 HIGHLAND DRIVE, LEWISVILLE, TX 75067 (469)549 -2000, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE) Mortgagor: MICHAEL J GREENFIELD AND ALEXANDRA M GREENFIELD When Recorded Return To: Federal Home Loan Mortgage Corporat C/O NTC 2100 Alt. 19 North Palm Harbor, FL 34683 All that certain lot or piece of ground situated in Mortgage Premise: 236 WALTON ST BOROUGH OF LEMOYNE LEMOYNE, PA 17043 CUMBERLAND (Borough or Township, if stated), Commonwealth of Pennsylvania. Being more particularly described in said Mortgage. Certificate of Residence I, Nadine Homan, do certify that the precise address of the within named Assignee is: NATIONSTAR MORTGAGE LLC, WHOSE ADDRESS IS 350 HIGHLAND DRIVE, LEWISVILLE, TX 75067 (469)549 -2000, as SUCCESSORS OR ASSIGNS, (ASSIGNEE) NADINE HOMAN AUTHORIZED SIGNATORY All Authorized Signatories whose signatures appear above are employed by NTC and have reviewed this document and supporting documentation prior to signing. *20171304* FHLNA 20171304 -- Ni DOCR T3113053014 [C] EFRMPA1 1111111111111111111111111111111111111 11111 liii liii 1111111 liii 111111110 11111 HIll 11111 liii 1111111111111111111 tIll EXHIBIT .i . Loan No: 463581067 Inst. # 201318204 - Page 3 of 4 'EXHIBIT A' Assignments, Modifications, Consolidations Exhibit Assignment: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP. TO OCWEN LOAN SERVICING, LLC DATED 07 -28 -2011. REC: 08 -23 -2011 INSTR# 201123362 1111111 I11I1111111tIIiI11111lNlll 1111101 11111191r11111111111111111111 Inst. # 201318204 - Page 4 of 4 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717 - 240 -6370 Instrument Number - 201318204 Recorded On 6/3/2013 At 9:54:59 AM * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 138407 User ID - MBL * Mortgagor - GREENFIELD, ALEXANDRA M a Mortgagee - NATIONSTAR MORTGAGE LLC *Customer - SIMPLIFILE LC E- RECORDING FEES STATE WRIT TAX STATE JCS /ACCESS TO JUSTICE RECORDING FEES — RECORDER OF DEEDS PARCEL CERTIFICATION FEES COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $23.50 $11.50 $15.00 $2.00 $3.00 $55.50 " Total Pages - 4 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER OF DEEDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. „tX fflB1T UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsaxdren.com Nationstar Mortgage LLC Plaintiff V. Alexandra M. Greenfield Michael J. Greenfield Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 04/23/2014 to Date of Sale 09/03/2014 Ongoing Per Diem of $17.02 to actual date of sale including i sale is held at a later date. (Costs to be added) MJU#: 11030777 CASE#: 11030777-2 ?. SO/XI a (fiu poi t-k4- 1,, U $ 120,869.21 $ 2280.68 UDREN L W 0 ICES, P.C. BY: Attorney for Plaintiff AMANDA L. RAUER, ESQUiRE PA. ioD, # 307028 4c)c7,Ps I ra.os 0110k Lot-IPYD g-4-2bLictdo 15-ori UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin' s ' udren.com Nationstar Mortgage LLC Plaintiff v. Alexandra M. Greenfield Michael J. Greenfield Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above - captioned matter: Act 91 procedures have been fulfilled 11 Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LA FFICES, P.C. BY: Attorney for AMANDA L. RAUER, ESQUIRE PA. B.D. # 307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(&,udren.corn Nationstar Mortgage LLC Plaintiff V. Alexandra M. Greenfield Michael J. Greenfield Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: ALEXANDRA M. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 ALEXANDRA M. GREENFIELD C/O JAIME M HALEY, ESQ. 401 E. LOUTHER STREET SUITE 103 CARLISLE, PA 17013 MICHAEL J. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 MICHAEL J. GREENFIELD C/O JAIME M HALEY, ESQ. 401 E. LOUTHER STREET SUITE 103 CARLISLE, PA 17013 CLJ rn co IT, < CD XI> This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. UD N OF CES, P.C. AMA1'ta L. rFliikf liEfR, ESQUIRE PA. LR #307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(&,udren.com Nationstar Mortgage LLC Plaintiff V. Alexandra M. Greenfield Michael J. Greenfield Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Nationstar Mortgage LLC, 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: 236 Walton Street, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s): Alexandra M. Greenfield 236 Walton Street Lemoyne, PA 17043 Alexandra M. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 Michael J. Greenfield 236 Walton Street Lemoyne, PA 17043 Michael J. Greenfield do Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Alexandra M. Greenfield 236 Walton Street Lemoyne, PA 17043 Alexandra M. Greenfield do Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 C) Michael J. Greenfield 236 Walton Street Lemoyne, PA 17043 Michael J. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 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: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 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 Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128 -1230 Tenants /Occupants 236 Walton Street Lemoyne, PA 17043 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: toqiq MJU#: 11030777 CASE#: 11030777-2 UDREN FIC S, P.C. • BY: Attorney for Plamti AMANDA L. RAUER, ESQUIRE PA. W. # 307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin s ' udren.com Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Alexandra M. Greenfield 236 Walton Street Lemoyne, PA 17043 N 7.747 C? N: cr; Your house (real estate) at 236 Walton Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriffs Sale on 09/03/2014 at 10:00AM at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $120,869.21, 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 fmd 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 fmd out if this has happened, you may call 856- 669 -5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin s udren.com Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Greenfield 236 Walton Street Lemoyne, PA 17043 C, ice.`. c..re Your house (real estate) at 236 Walton Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriffs Sale on 09/03/2014 at 10:00AM at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $120,869.21, 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 LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin ' s ' udren.com Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Alexandra M. Greenfield do Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 Your house (real estate) at 236 Walton Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriffs Sale on 09/03/2014 at 10:00AM at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $120,869.21, 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 LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin udren.com Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael J. Greenfield do Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 r .) Your house (real estate) at 236 Walton Street, Lemoyne, PA 17043 is scheduled to be sold at the Sheriffs Sale on 09/03/2014 at 10:00AM at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $120,869.21, 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 fmd out if this has happened, you may call 856- 669 -5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net NATIONSTAR MORTGAGE LLC Vs. NO 13 -90 Civil Term CIVIL ACTION — LAW ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $120,869.21 L.L.: $.50 Interest FROM 4/23/2014 TO DATE OF SALE 9/3/2014 - ONGOING PER DIEM OF $17.02 TO 0,22,80.4,8 ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE Atty's Comm: Atty Paid: $218.25 Plaintiff Paid: Dater 4/24(14 , 5J (Seal) REQUESTING PARTY: Nan e: AMANDA L. RAUER, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 Attorney for: PLAINTIFF Telephone: 856- 669 -5400 Supreme Court ID No. 307028 Due Prothy: $2.25 Other Costs: . 1ZL David D. Buell, Prothonotary By: Deputy UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleading,s@udren.com Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 Plaintiff v. JAIME M HALEY 401 E. LOUTHER STREET, SUITE 103 CARLISLE, PA 17013 ALEXANDRA M. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 MICHAEL J. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), ALEXANDRA M. GREENFIELD; MICHAEL J. GREENFIELD; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Property Inspections Title Report Attorney Fees Grand Total Clwt-1 \1wpd atELI FROM TO 11/20/2012 04/22/2014 11/20/2012 04/22/2014 Ck��y t2_a 30 $99,334.60 $6,591.31 $8,833.38 $165.25 $561.85 $3,282.32 $125.50 $325.00 $1,650.00 $120,869.21 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES DATE: BY ASSESSED AS INDICATED MJU#: 11030777 CASE#: 11030777-2 OCWEN LOAN SERVICfNG, : IN THE COURT OF COMMON PLEAS OF LLC, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff' : CIV1L ACTION — LAW vs. : NO. 13-0090 CIVIL ALEXANDRA M. GREENFIELD and MICHAEL J. GREENFIELD, : Defendants : MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 69 day of February, 2014, following conciliation conference, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this case is VACATED. The plaintiff is authorized to proceed with the foreclosure action, Nathan Wolf, Esquire For the Plaintiff Jaime Haley, Esquire For the Defendants :rim BY THE COURT, .4— rn -- rn r- CO 4-•rii a) I ...a s —4C -21 CO UDREN LAW OFFICES, P.C. 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. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 'CASSIA 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 pleadings udren.com Ocwen Loan Servicing, LLC C/O Ocwen Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Plaintiff v. ALEXANDRA M. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 MICHAEL J. GREENFIELD 236 WALTON STREET LEMOYNE, PA 17043 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A a a O! -11(431 t2_� 9849y3 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �a�tt? a{ trantatirrlfi 00f iCt OF Ttie t -iitFf Ocwen Loan Servicing, LLC vs. Alexandra Greenfield (et al.) Case Number 2013 -90 SHERIFF'S RETURN OF SERVICE 01/14/2013 06:30 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person represen ing themselves to be the Defendant, to wit: Alexandra Greenfield at 236 Walton Street, Lemoyne Be. • , Lemoyne, PA 17043. 1f //i ce M LI , DEPUTY 01/14/2013 06:30 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Alexandra Greenfield, Wife, who accepted as "Adult Person in Charge" for Michael Greenfiel at 236 Walton Street, Lemoyne Borough, Lemoyne, PA 17043. ILL AM CLINE, DEPUTY SHERIFF COST: $60.00 SO ANSWERS, January 17, 2013 {c! Cout ySuits Shoriff, TeIecsoft, arx. RONNY R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 Nationstar Mortgage LLC Plaintiff v. Alexandra M. Greenfield, Michael J. Greenfield Defendant(s) TO: Alexandra M. Greenfield 236 Walton Street Lemoyne, PA 17043 Date of Notice: April 10, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIM, (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IlVIMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAV.7...OFFICES, PC. BY: "/ `Attorney for Plaint] ELIZABETH L WASEALL, E,SQ. PA ID 77788 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003 -3620 MJU #: 11030777 CASE #: 11030777 -2 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 -669 -5400 Nationstar Mortgage LLC Plaintiff v. Alexandra M. Greenfield, Michael J. Greenfield Defendant(s) TO: Alexandra M. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 Date of Notice: April 10, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMLNO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA,0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE: PURSUANT TO '11:11; FAIR DEBT COLLEC1'1ON PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN,N AW OFFICES, BY: Attorney for Plaintiff ELIZABETH L WASSALL, ESC PA ID 77788 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003 -3620 MJU #: 11030777 CASE #: 1,1030777 -2 UDREN LAW MINCES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 Nationstar Mortgage LLC Plaintiff v. Alexandra M. Greenfield, Michael J. Greenfield Defendant(s) TO: Michael J. Greenfield 236 Walton Street Lemoyne, PA 17043 Date of Notice: April 10, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER. IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTIFICACION JMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC..._........ T ..� BY: Attorney for Plaintiff ELIZABETH L WASSk.LL, PA ID 77788 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003 -3620 MJU #: 11030777 CASE #: 11030777 -2 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400 Nationstar Mortgage LLC Plaintiff v. Alexandra M. Greenfield, Michael J. Greenfield Defendant(s) TO: Michael J. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 Date of Notice: April 10, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DWISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NO'I'IknCACION LMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO 1MMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRTTA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE: PURSUANT TO 'I'UJ FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND 'IHfS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. BY. Attorney for Plaintiff ELIZABETH L WASSSALL, c , PA ID 77788 Wooderest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003 -3620 MJU #: 11030777 CASE#: 11030777 -2 Pennsylvania Office 100 W. 3rd Ave. Suite 200 Conshohocken, PA 19428 (PH) 215-568-9500 Mark'. Udren, Esq. Licensed' P4, NJ, FL UDREN LAW OFFICES, P. C. New Jersey Office Woodcrest Corporate Center 111 Woodcrest Rd. Suite 200 Cherry Hill, NJ 08003 (PH) 856 -669 -5400 (FX) 856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Re: Nationstar Mortgage LLC vs. Florida Office 2101 W. Commercial Blvd Suite 5100 Fort Lauderdale, FL 33309 (PH) 954 - 378 -1757 (FX) 954 - 378 -1758 JAIME M HALEY, ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD, Cumberland County C.C.P. No. 13 -0090 MJU #: 11030777 CASE #: 11030777 -2 Dear Sir or Madam: Enclosed please find Affidavit of Non - Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non - Military Service to be time stamped and returned in the enclosed self - addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Kevin Kerr Foreclosure Specialist MJU/ Enclosures MJU #: 11030777 CASE #: 11030777 -2 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin s ' udren.com Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -0090 AFFIDAVIT OF NON - MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), MICHAEL J. GREENFIELD, who /each of whom is over 18 years of age is /are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is /are attached hereto as Exhibit "A ". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search: ALEXANDRA M. GREENFIELD. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Dated: April 22, 2014 MJU #: 11030777 CASE #: 11030777 -2 4 t o ey or Pla' 'ti AMANIAT ��-AUER, f ESQUIRE RA. 1.D. # 307028 SCRA 3.0 Status Report Pursuant to Serviceffil 's Oiyil Relief Act Last Name: GREENFIELD First Name: MICHAEL Middle Name: J. Active Duty Status As Of: Apr -22 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NACU 4i /'.--, . i_A_':. -. .14o' NA ! r,! I, -++' a .r -r ,. r-, a .-, u ns 1 V. . / �'» --.# • 1.V... This response reflects the individuals',active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA tf 7 I!'T : ;IttNA .' .5..tL_ t` t 66 1___'.._ .1ir+y- LY''NO . Viitals1!�U NA This response reflects where the individual left acts a duty status within 367 days preceding the Aetrve Duty Status Date The Member or His /Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA 1'NA' E f,t J ' ,+NNo 4S /,l NA +'� ---'a .- .; .rte' •,,rr This response reflects whether.the individual or his/her -unit has received earty notificatiori'to report for active duty .7 Upon searching the data banks of the Department of Defense Manpower Data Center; based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Unifo d.Sery es (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink.mil /faq /pis /PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: Z92223C1 N061 U00 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin l s s udren.com Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County c> ,.., rn MORTGAGE FORECLOSUREcn CD i —r) NO. 13-0090�'� AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 r —i n 77, 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. 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: 7#// MJU#: 11030777 CASE#: 11030777-2 UDREN ' OFFICES, P.C.._ ... B : Attorneys for Plaintiff ELIZABETH L WASSALL, C a PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com Nationstar Mortgage LLC Plaintiff v. Alexandra M. Greenfield Michael J. Greenfield Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Nationstar Mortgage LLC, 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: 236 Walton Street, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s): Alexandra M. Greenfield 236 Walton Street Lemoyne, PA 17043 Alexandra M. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 Michael J. Greenfield 236 Walton Street Lemoyne, PA 17043 Michael J. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street Suite 103 Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Alexandra M. Greenfield 236 Walton Street Lemoyne, PA 17043 Alexandra M. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street, Suite 103 Carlisle, PA 17013 Michael J. Greenfield 236 Walton Street Lemoyne, PA 17043 Michael J. Greenfield c/o Jaime M Haley, Esq. 401 E. Louther Street, Suite 103 Carlisle, PA 17013 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: Nationstar Mortgage LLC 350 Highland Drive Lewisville, TX 75067 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Borough of Lemoyne 510 Herman Avenue Lemoyne, PA 17043 Borough of Lemoyne c/o Michael J. Cassidy, Esquire 301 Market Street Lemoyne, PA 17043 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 Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 236 Walton Street Lemoyne, PA 17043 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: 7-/6.-/ MJU#: 11030777 CASE#: 11030777-2 UDREN LA • FFICES BY: Attorney for Plaintiff ELIZABETH L WASSALL, ESQ PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD; MICHAEL J. GREENFIELD; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): ALEXANDRA M. GREENFIELD AND MICHAEL J. GREENFIELD; PROPERTY: 236 Walton Street, Lemoyne, PA 17043 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 09/03/2014 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#: 11030777 CASE#: 11030777-2 Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑ Registered ❑ insured ❑ COD ❑ Certified ❑ Merchandise ❑ ❑ Return Receipt for Int'l Recorded Del. Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurance ❑ Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 illre ■■■ CN 171/4 --■■■ ■ '� 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 3 Commonwealth of PA, Department of Revenue Bureau of CompliancePO Box 281230 Harrisbur•, PA 17128-1230 4 13-0090 Tenants/Occupants cets 236 Walton Street Lemoyne, PA 17043 ( OS(AGE*prTNEY B 4.95 •;f H t 02 08003 p3 $ 00 • by -• 0p01387pg0 JUL, 02 20 1 l 1 ■■■ ■❑� 5 Jaime M Haley, Esq. 401 E. Louther Street, Suite 103, Carlisle, PA 17013 6 09/03/2014 Borough of Lemoyne c/o Michael J. Cassidy, Esquire 301 Market Street, Lemoyne, PA 17043 .� 7 Bor510 Her of ianLemoyneAvenue, 510 Herman AveLemoyne, PA 17043 8 9 is es 10 11 ■■■ 1213 14 15 Total number of Pieces Listed by Sender 7 Total Number of Pieces Received ffice 1 Postmaster, Per (Name of Receiving Employee) The full declaration of value is required on all domestic and reconstruction of nonnego iable documents under Express Mail $500,000 per occurrence. The maximum indemnity payable on $25,000 for registered mail, sent with optional postal insurance. coverage on insured and COD mail. See International Mail Manual charges apply only international registered mail. The maximum indemnity payable for the document reconstruction insurance is $50,000 per piece subject to a limit of Express Mail merchandise is $500. The maximum indemnity payable is See Domestic Mail Manual 11900, 5913, and S921 for limitations of for limitations of coverage on international mail. Special handling to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Alexandra M. Greenfield - MJU# 11030777-2 (Cumberland County) Michael J. Greenfield - MJU# 11030777-2 (Cumberland County) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF TIKE SRERIFF Ocwen Loan Servicing, LLC vs. Alexandra Greenfield (et al.) Case Number 2013-90 SHERIFF'S RETURN OF SERVICE 06/17/2014 07:02 PM - Deputy Dawn Kell, 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 236 Walton Street, Lemoyne, PA 17043, Cumberland County. 06/17/2014 07:02 PM - Deputy Dawn Kell, 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: Alexandra Greenfield at 236 Walton Street, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County. 06/17/2014 07:02 PM - Deputy Dawn Kell, 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: Michael Greenfield at 236 Walton Street, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County. SHERIFF COST: $965.24 SO ANSWERS, NY July 02, 2014 RONR ANDERSON, SHERIFF EighilYM f� (c) CountySuite Sheriff, Teleosoft, Inc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pl eadin gs (&,,udren. com Nationstar Mortgage LLC Plaintiff v. Alexandra M. Greenfield Michael J. Greenfield Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 CERTIFICATE OF SERVICE The undersigned hereby certifies that true and correct copies of the Notice of Sale were served upon the following Defendant(s) named herein by: ® Regular First Class Mail ® Certified Mail Date Served: July 2, 2014 TO: Alexandra M. Greenfield Michael J. Greenfield c/o Jaime M. Haley, Esquire 401 E. Louther Street, Suite 103 Carlisle, PA 17013 MJU#: 11030777 CASE#: 11030777-2 Effdi��;�f: 73) UDREN LAW__O FICES, P.C. BY: Attorney for Plaintiff ELIZABETH L Vv .: `' ._L., PA ID 77788 Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) #11030777-2 Mt IIlIIIII 11 91 7199 9991 7033 2442 0393 MICHAEL J. GREENFIELD C/O JAMIE M. HALEY, ESQUIRE 401 E, LOUTHER STREET, SUITE 103 CARLISLE, PA 17013 Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) #11030777-2 11 11 11 111 1 11 17$ 1 11 91 7199 9991 7 033 2 442 0909 ALEXANDRA M. GREENFIELD C/O JAIME M. HALEY, ESQUIRE 401 E, LOUTHER STREET, SUITE 103 CARLISLE, PA 17013 U.S. POMO E PrrNEr BOWES ZIP 0800.3 $ 005.630 021r 0001387090 JUL 02. 2014. U.S. POSTAGE* PITNEY BOWES rraa,==1 ZIP 08003 $ 005.63 02 111 • 0001387090 JUL 02. 2014. Name andAddress of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 Registered• ❑ Insured 11 COD Certified Merchandise Return Receipt for Int'I Recorded Del. Express Mail Check appropriate block for Registered Mail: With Postal Insurance Without postal Insurance Affix stanlp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Alexandra M. Greenfield c/o Jaime M. Haley, Esquire 401 E, Louther Street, Suite 103 Carlisle, PA 17013 2 Michael J. Greenfield c/o Jaime M. Haley, Esquire 401 E, Louther Street, Suite 103 Carlisle, PA 17013 _ — 1)('N 1 3 �f "1,b d CC 4 13-0090 .eU s 0.65 N 1 ' "•� �+��41oof1` ■!� 4:26 09/03/2014 a>3- II MEM W r o�� U9 0.N0 K.) ' ioo 10 �r 11 y ..4 „i #t3., "71. A: t ti 12 13 14 15 Total number of Pieces Listed by Sender 2 Total Nu Pieces Received t PO Office Po .c Per (Name ofReceiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnego iable 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, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen parcels. Alexandra M. Greenfield - MJU# 11030777-2 (Cumberland County) Michael J. Greenfield - MJU# 11030777-2 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Nationstar Mortgage LLC Plaintiff V. ALEXANDRA M. GREENFIELD MICHAEL J. GREENFIELD Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for September 3, 2014 at 10:00 AM in the above -captioned matter has been continued until November 5, 2014 at 10:00 AM. Date: MJU#: 11030777 CASE#: 11030777-2 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Nationstar Mortgage LLC Plaintiff v. ALEXANDRA M. GREENFIELD MICHAEL J. GREENFIELD Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-0090 NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for November 5, 2014 at 10:00 AM in the above -captioned matter has been continued until January 7, 2015 at 10:00 AM. Date: ` 31 A MJU#: 11030777 CASE#: 11030777-2 BY: Atto ANDA L. ~,AUER, ESQUIRE PRRIE L/Pttr,tr qt4 S, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 (856) 669-5400 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY oF v7 THE IFF f, Ea1 3 12, r L iL A N PEN`SYLVANIA Ocwen Loan Servicing, LLC vs. Alexandra Greenfield (et al.) Case Number 2013-90 SHERIFF'S RETURN OF SERVICE 06/17/2014 07:02 PM - Deputy Dawn Kell, 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 236 Walton Street, Lemoyne, PA 17043, Cumberland County. 06/17/2014 07:02 PM - Deputy Dawn Kell, 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: Alexandra Greenfield at 236 Walton Street, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County. 06/17/2014 07:02 PM - Deputy Dawn Kell, 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: Michael Greenfield at 236 Walton Street, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County. 09/02/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/5/2014 11/03/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/7/2015 01/06/2015 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: $988.26 SO ANSWERS, January 13, 2015 RONNTV R ANDERSON, SHERIFF a-0 frtP 3 /5 6 y.3 (ci ; ounfySu;;e Sierift. Teleoscft, Inc THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net NATIONSTAR MORTGAGE LLC Vs. NO 13-90 Civil Term CIVIL ACTION — LAW ALEXANDRA M. GREENFIELD, MICHAEL J. GREENFIELD WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $120,869.21 L.L.: 5.50 Interest FROM 4/23/2014 TO DATE OF SALE 9/3/2014 - ONGOING PER DIEM OF $17.02 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE — -9i2-2116•108 Atty's Comm: Atty Paid: $218.25 Plaintiff Paid: Date: 4/24/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonota By: REQUESTING PARTY: Name: AMANDA L. RAUER, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 307028 Deputy TRUE COPYFROM RECORD In Testimony whereof, I -here unto set my hand and the, e,al of said CourtFst‘Ciariisle, Pa. 2O H Prothonotary This LI day of LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-90 Civil OCWEN LOAN SERVICING, LLC vs. ALEXANDRA GREENFIELD Michael Greenfield Atty.: Mark Udren ALL THAT CERTAIN lot of ground. situate in the Borough of Lemoyne, Cumberland County, Pennsylvania, more particularly bounded and de- scribed as follows, to wit: beginning at an iron pin on the southern side of Walton Street at the dividing line between Lots Nos. 46 and 47 on the hereinafter mentioned Plan of Lots, said point being 400 feet when meas- ured westwardly from a monument at the intersection of Walnut Street and Warren Street; thence along said dividing line South 36 degrees East, a distance of 217.80 feet to an iron pin; thence South 54 degrees West a distance of 45 feet to an iron pin; thence North 36 degrees West a distance of 217.80 feet to a point on the southern side of Walton Street; thence along the southern side of Walton Street, North 54 degrees East a distance of 45 feet to a point, the place of BEGINNING. BEING KNOWN AS: 236 Walton Street, Lemoyne, PA 17043. PROPERTY ID NO.: 12-22-0820- 065. TITLE TO SAID PREMISES IS VESTED IN Alexandra M. Greenfield and Michael J. Greenfield, Husband and Wife by Deed from PNC Bank, N.A., Executor of the Estate of the Last Will and Testament of Miriam M. Martz, and Alexandra M. Greenfield, Administratrix of the Estate of Bar- bara L. Crossland dated 04/26/2005 Recorded 05/12/2005 in Deed Book 268 Page 4159. 47 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: July 11, July 18 and July 25, 2014 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. SWORN TO AND SUBSCRIBED before me this 5 day of July, 2014 Notary COMMONWEALTH Of PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE My Commission Expires 2 s Apr 28.018 T--'_-^ '--''_-__-. 1900 Patriot Drive Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE youCUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 patriogews �� Now ....~~~. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof Publication Under Aot No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Amy Kotula, beinduly 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 1900 Patriot Drive, 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. L, i 2013-90 Civl Term WEN LOAN LLC vs. ALEXANDRA GREENFIELD Michael Greenfield Ally: Mark Udren ALL THAT CERTAIN LOT OF GROUND. SITUATE IN THE BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT AN IRON PIN ON THE SOUTHERN , SIDE OF WALTON STREET AT THE DIVIDING LINE BETWEEN HEREINAFTER MENTIONED Sworn to This ad ran on the shown below: 07/13/14 07/20/14 07/27/14 bscribed before me this 20 day of August, 2014 A.D. COM ON ALTH OF PENNSYLVANIA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 NEWBER, PENNSYLVANIA ASSOCIATION OF NOTARIES