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Home My WebLink About13-1726 Supreme CqWfiAlf ennsylvania COUr,t of Cow mo* Pleas For Prothonotary Use Only: Civil tov Sleet Docket No: CUMBERLAND County The information collected on this form is used solely for court administration puThoses. This form does not supplement or replace the fling and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S [H] Complaint D Writ of Summons El Petition Q Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff s Name: Lead Defendant's Name: T HSBC Bank USA, National Association,... Mohamed Mowjood Mohamed Idroos; Izzathul Mowjood Dollar Amount Requested: r1within arbitration limits Are money damages requested? D Yes No 0 (check one) outside arbitration limits N Is this a Class Action Suit? ❑ Yes El No Is this an MDJAppeal? 0 Yes [E No A Name of Plaintiff /Appellant's Attorney: k.. J 1A 0&'E� C ,SQ U (` E El Check here if you have no attorney- (are a Self - Represented [Prof SeJ Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution © Debt Collection: Credit Card Board of Assessment 0 Motor Vehicle Debt Collection: Other Board of Elections E] Nuisance ❑ Dept. of Transportation Premises Liability © Statutory Appeal: Other S ® Product Liability (does not include E mass tort) ® Employment Dispute: Slander/Libel/ Defamation Discrimination C Other: Employment Dispute: Other © Zoning Board T Other: I Other: o MASS TORT 0 Asbestos N ❑ Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS © Toxic Waste Other: 1:1 Ejectment 0 Common Law /Statutory Arbitration B rl Eminent Domain /Condemnation Declaratory Judgment (� Ground Rent Mandamus Landlord/Tenant Dispute Non - Domestic Relations n Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY El Mortgage Foreclosure: Commercial ® Quo Warranto Dental © Partition 0 Replevin © Legal ❑ Quiet Title © Other: Medical © Other: n Other Professional: Updated 1/1/2011 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 M =' SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675� ='; SALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLINO, ESQUIRE - ID #309091 HARRY B. REESE, ESQUIRE - ID #310501 KASSIA FIALKOFF, ESQUIRE - ID#310530 _ ELIZABETH L. WASSALL, ESQUIRE - ID#77788 KATHERINE E. KNOWLTON, ESQUIRE - ID#311713 NICHOLAS GAUNCE, ESQUIRE - ID#206228 JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 - 5400 pleadings @udren.com HSBC Bank USA, National Association as Trustee on COURT OF COMMON PLEAS behalf of SG Mortgage Securities Trust 2007 AHL1 CIVIL DIVISION Asset Backed Certificates, Series 2007 AHL1 CUMBERLAND County C/O Ocwen Loan Servicing, LLC 1661 Worthington Road j Suite 100 NO. / (/ West Palm Beach, FL 33409 Plaintiff V. MOHAMED MOWJOOD MOHAMED IDROOS 50 TORY CIRCLE ENOLA, PA 17025 IZZATHUL MOWJOOD 50 TORY CIRCLE ENOLA, PA 17025 Defendant(s) 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. 4s Q,rul S10f. s LN �7�sa YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades a otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 I . Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Accredited Home Lenders, Inc Assignee: HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Date of Assignment: 01/04/2013 Recorded Date: 01/28/2013 Book/Instrument #: Instrument Number: 201302968 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Mohamed Mowjood Mohamed Idroos & Izzathul Mowjood (hereinafter "Defendants "), are the owners of property located at 50 Tory Circle, East Pennsboro Township, PA 17025, by virtue of Deed dated 05/25/2007 and recorded 06/05/2007 in Official Records Book 280 at Page 1530 of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property "). 3. On 05/25/2007, Defendant(s) and /or their predecessor: MOHAMED MOWJOOD MOHAMED IDROOS promised to pay to the order of Accredited Home Lenders, Inc., a California Corporation, the principal sum of $ 127,800.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 05/25/2007 , Defendant(s) and/or their predecessor: MOHAMED MOWJOOD MOHAMED IDROOS AND IZZATHUL MOWJOOD to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., as nominee for Accredited Home Lenders, Inc., a California Corporation, the Property which is the subject of this action. The Mortgage was recorded on 06/05/2007 in Official Records Book 1994 at Page 4085. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(8). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 09/01/2012, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (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 $132,428.97 Accumulated Interest $3,066.72 Accumulated Late Charges $410.08 Escrow Deficit /(Reserve) $3,126.85 Other Suspense Balance $ -73.83 Title Report $300.00 Attorney Fees $1,650.00 Property Inspection Fee $21.00 Property Valuation Fee - BPO $584.00 Grand Total $141,513.79 The above figures are calculated as of 01/25/2013: 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 4.71000 %. The per diem interest accruing on this debt is $17.3300 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 $37.34. 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 $ 141,513.79 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire PA ID 04302 VERIFICATION The undersigned states that heo 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: _ l 9 1 " 1 Z �i �) v e Name: Regina Peragine Title: Contract MenagerMIM C=dkWW Company: Ocwen Loan Servicing LLC as attorney in fact for HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 MJU #: 12120140 CASE #: 12120140 -1 Ocwen loan servicing, LLC Mi MEDULE A ALL THAT CERTAIN PIBCH OR PAACEI, OF LAND SITUATE IN ME TOWNSM OF EAST pM* SBORO COUNTY OF CUWMRLAND AND COMMONWEALTH OF PENNSYLVANIA, HOUNDED AND DESK AS POU„OWS, TO WIC: BHGMING AT A POINT ON THE WESTERN LEGAL RIGHT-OF-WAY LINE OF HAL LANE AT THE NORTHWEST CORNER OF ]LOT NO. 114 ON THE BERE iAFM DESSCRMED FINAL SUBDiVi 'ON PLAN. THENCE ALONG THE NORTHERN L114E OF SAID LOT NO. 114 SOUTH 61 ASS 53 MDRITE3 00 SECONDS WEST A DISTANCE OF 25-00 FEET TO A POINT; THENCE CONTINUING ALONG THE SAME SOUTH 71 DBGWX S 34 MMCTTIi& 00 SECONDS WEST A DISTANCE OF $4.89 PELT TO A POINT AT THE EASTERN LEGAL RRHIT- OF•WAY LINE OF TORY CA= THENCE ALONG THE EASTERN LEGAL RMiHT-0F WAY LINE OF TORY CIRCLE NORTH 18 DEGREES 26 M>r1 m 00 SECONDS WEST A DISTANCE OF 24-00 PEST TO A POINT AT THE SOUTHWEST CORNER OF LOT No. 112 ON THE HEREINAFTER D8&{RE3ED FINAL SUBDIVISION PLAN, THENCE ALONG THE SOUTHERN LINE OF SAID LOT NO. 112 NORTH 71 DEGREES 34 M MT1'ES 00 SECONDS EAST A DISTANCE OF 103,79 FEET TO A POINT ON THE WEffMN LBOAL RIGITT -OF -WAY LINE OF HAL LANE; THENCE ALONG THE WESTERN LBUAL RIGHT-OF -WAY OF HAL LAW BY A CURVE TO THE LEFT HAVIKG A RADIUS OF 16000 FEET AN ARC LENGTH OF 20.63 FEET TO A POINT AT THE NOIL11 A.ST CORNER OF LOT NO.114 ON THE BERINAFIBR DESCRIBER FINAL SUBDIVISION PLAN, THE POINT AND PLACE OF BEGINNING, CONTAINING 2,515.65 SQUARE FEET, MORE OR LESS. BEING LOT NO. 113 ON THE FINAL SUBDIVISION PLAN OF LAUREL HIUS NORTH LOTS 3 AND 4, SECTION 5, DATED JUNE 1,1991.,' REVUM AUGUST 5, 1992 AND RBOORDBD IN THE OFFICE OF THE RECORDgit OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA IN PLAN BOOK 65, PAGE 39, BEING IMPROVED WITH A DWELLING KNOWN AS 50 TORY CMCI.,E. December 21, 2012 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling_ Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, You may call the Pennsylvania Housing Finance Agenev 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 local bar assoc,.--"---n may he able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES S.ER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Exhibit A HOMEOWNER'S NAME(S): Mohamed Mowj000'Mohamed Idroos Izzathul Mow'ood4 PROPERTY ADDRESS: 5WTmi (ircle „ East Pennsboro Township, PA 1702 .. _ LOAN ACCT. NO.: x__08057 — ' �__ _.____. '_.___ ___._.._ ORIGINAL LENDER: Accredited Home Lenders, Inc., A California Corporation -- .. ..... . _._... _._______..__...__._._....... ....... __._..—. ..... _ ---- ...... ..... _...._._.._ .. ... ............ _......._.._.._...._._....._ CURRENT LENDER: HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 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 HOMEOWNER'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 REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY 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 (30) clays 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 THIRTY -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 (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property 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 this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from 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 WITHINT 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 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 HAVE 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 TIME 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 PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. f (If you have tiled bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 50 Tory Circle East Pennsboro Township, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments of $924.28 for September 1, 2012 through December 1, 2012 = $3,697.12 . .......... . Late Charges = $372.74 ....... . ... . ..... . . ...... - -- _... - ------ - . . ..... . . ............ . ... ....... ..... Other charges (explain/itemize): Property Inspection Fees = $10.50 Property Valuation Fees/BPO = $292.00 Suspense Balance =... ..... . . ........ . . ........ ..... ........ .. . ... ... ..... . .. TOTAL AMOUNT PAST DUE: $4298.53 ... .... ....... - .. ......... . ........ ..... . ...... -- . ... .. ........ ......... .. ......... . . ... ........ . . .... . ......... ............. ........... 1------.--, 2 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicabl 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 IS $4,298.53, 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 payable and sent to: Udren Law Offices, P.C. Wooderest Corporate Center 111 Woodcrest 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: o not use if not applicable.): N/A IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its 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 action to foreclose upon your mortgaged property. IF 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 proceedings 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 (30) DAY period, you will not be required to pav attornev'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 any time up to one hour before the Sheriffs Sale, You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attomev's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage Curing your default in 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 - - -- k — 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 LenderlServicer: Ocwen Loan Servicing, LLC Address: 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 . __._._ _. .. _... -__ ___..._.__... Phone Number: 877 -596 -8580 Fax Number: _1_._..' 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 Iive in the property after the Sheriff s Sale, 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. 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 POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated• 08/1712012 11:26 AM Community Action Commission of Capital Region. CCCS of Western PA 1514 Derry Street 2000 Linglestouwn Road Harrisburg, PA 17104 Harrisburg, PA 17102 717 -232 -9757 888 -511 -2227 Maranatha PA interfaith Community Programs Inc 43 Philadelphia Avenue 40 E High Street Waynesboro, PA 17268 Gettysburg, PA 17325 717- 762 -3285 717- 334 -1518 PHFA 211 North Front Street Harrisburg, PA 17110 71.7 -780 -3940 800- 342 -2397 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. UDR.EN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 1.11 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 i UDREN ►_AE's? OFFICES, P.O. � �./OODCRES7 CORPORATE CENTER "`" 11 ENOODCREST ROAD I ya , :.HE=RRY HILL, NJ 08003 $ 05-950 7012 2210 0002 6147 0478 �S p clsTR I �tCxQ,�- SENDER: C04WLI-TE THIS SFCTION ■ Complete items 1, 2, and 3. Also complete A. Signature item 4 if Restricted Delivery is desired. 0 Agent ■ Print your name and address on the reverse X v 0 Addressee 3 so that we can return the card to you. B. Received by ( Printed Name) C M Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: D. is delivery address different from item 1? Dyes If YES, enter delivery address below: 0 No 3. Service iype 7 Cesed Malt f7 Express Mail D Regigistered Rewm Receipt for Merchandise 0 Insured M ail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number 7 012 2 210 000 61, 4 7 0 4 7 8 (Transfer from service Aube() PS Form 3811, February 2004 Domestic Return Receipt 102596.02•M -1540 wJ'- - REST COPPOk-'k - f-Ef� , TER DO i woODCREST ROAO CHERRY HILL, NJ 08003 ,r a $ 05.95� ?012 2210 0002 6147 485 US POSTAGE &-C_�- • Complete items 1, 2, and 3. Also complete A. Signature item 4 if Restricted Delivery is desired. X 0 Agent • Print your name and address on the reverse �, 0 Addr so that we can return the card to you. e. Received by ( Printed Name) C. Date of Delivery • Attach this card to the back of the maiipiece, or on the front if space permits. —, D. is delivery address different from Item 17 0 Yes 1. Article Addressed to: if YES, enter, delivery address below: 0 No W - \0 *CV'O ' v z!' t% A 3. Service Type OCeralled Mail O Express Mail F' 0 Registered M Return Receipt for Merchandise 0 Insured Mail 0 C:O.D. 4. Restricted (delivery? (Extra Fee) 0 Yes 2, Article Number 7 012 2 210 0002 614 7 0485 (Transfer from se labe PS Form 3811, February 2004 Domestic Return Receipt 102595.02- M-1540 FORM I 11` THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff(s) ZL vs. f - -'J JU(4 Defendant(s) 1 kivil NOTICE OF RESIDENTIAL MORTGAGE FORECLOW. 1�& " CD DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action.. you may be able to participate in a court - supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 25 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, YOU must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto. the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which Must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date [Signature of Counsel for Plaintiff] Mark 3. Udren, Esquire PA ID 04302 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): Citv: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: Citv: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: S $ Retirement Funds: $ $ Investments: $ Checking: S $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation. (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: J. 1. Additional Income Description (not wages): l . monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Pa yment Cable TV Child Su ort/Alim. Spending Money Day/Child Care /Tuit. Other Ex enses i Amount Available for Monthly Mortgage Payments Based on [ncome & Expenses: Have you been working with a Housing Counseling Agency? I Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 1 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If ves. please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: 1/We, authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements V Proof of any expected income for the last 45 days Copy of a current utility bill l+ .Letter explaining reason for delinquency and any supporting documentation + (hardship letter) V Listing agreement (if property is currently on the market) 3 FORM 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plaimiff(s) vs. Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated .2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies i as follows: 1, Defendant is the owner of the real property which is the subject of this mortgage foreclosure action: ?. Defendant lives in the subject real property, which is defendant's primary residence; �. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion .Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. 1 understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. I Signature of Defendant's Counsel /Appointed Date Legal Representative I 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 SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 L �' ELIZABETH L. WASSALL, ESQUIRE - ID #77788 KATHERINE E. KNOWLTON, ESQUIRE - ID #311713 JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 NICOLE B. LABLETTA, ESQUIRE - ID #202194 2!! C. DAVID NEEREN, ESQUIRE - ID #204252 W ,c JORDAN DAVID, ESQUIRE - ID #311968 WOODCREST CORPORATE CENTER' 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 Pleadings @udren.com HSBC Bank USA, National Association as Trustee COURT OF COMMON PLEAS on behalf of SG Mortgage Securities Trust 2007 CIVIL DIVISION AHLI Asset Backed Certificates, Series 2007 AHL1 CUMBERLAND County 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 Plaintiff NO. �V V. Mohamed Mowjood Mohamed Idroos 50 Tory Circle Enola, PA 17025 Izzathul Mowjood 50 Tory Circle Enola, PA 17025 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; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; Katherine E Knowlton, Esquire, and John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire; Jordan David, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREN LAW OFFICES, P.C. BY: �-- Mark 3. Udren, Esquire PA ID 04302 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff j;� U` i ' era O" THE PROTHONOTAR'( Jody S Smith Chief Deputy ';�0 2013 APR 10: Richard W Stewart Solicitor OFFICEOFTHEVERWr CUMBEKAND COUNT`/ PENNSYLVANIA HSBC Bank USA Case Number vs. Mohamed Mowjood Mohamed Idroos(et al.) 2013-1726 SHERIFF'S RETURN OF SERVICE 04/12/2013 03:23 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Mark Dragan Roommate,who accepted as"Adult Person in Charge"for Mohamed Mowjood Mohamed Idroos at 50 Tory Circle, East Pennsbora .Enola, PA 17025. DENbKS FRY, DEP 04/12/2013 03:23 PM-Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Mark Dragon roommate,who accepted as"Adult Person in Charge"for Izzathul Mowjood at 50 Tory Circle, East Pennsboro Township, Enola, PA 17025. DENN1S FRY, DEPVTY SHERIFF COST: $59.00 SO ANSWERS, April 15, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuito Sheritl,Teleosoit,Inc. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 lep adings@udren.com HSBC Bank USA,National Association as Trustee on behalf COURT OF COMMON PLEAS of SG Mortgage Securities Trust 2007 AHLI Asset Backed CIVIL DIVISION Certificates, Series 2007 AHL1 Cumberland County 1610 E. St.Andrews PI#8150 r Santa Ana, CA 92705 MORTGAGE FORECLOSURE, Plaintiff - o� V. rn � MOHAMED MOWJOOD MOHAMED IDROOS NO. 13-1726 Civil r j 50 TORY CIRCLE ENOLA,PA 17025 IZZATHUL MOWJOOD pw r 50 TORY CIRCLE : ENOLA,PA 17025 Defendant(s) 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),MOHAMED MOWJOOD MOHAMED EDROOS; IZZATHUL MOWJOOD; 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: FROM TO Unpaid Principal Balance $132,428.97 Interest Per Complaint $3,066.72 Additional Interest 01/26/2013 07/30/2013 $3,223.38 Late Charges Per Complaint $410.08 Additional Late Charges 01/26/2013 07/30/2013 $224.04 Escrow Per Complaint $3,126.85 Other Suspense Balance $-73.83 Title Report $300.00 Attorney Fees $1,650.00 Property Inspection Fee $21.00 Property Valuation Fee-BPO $584.00 Grand Total $144,961.21 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. 0%A X16'<bz UDREN LA , OFFICES,P.C. l k.1+ 5)9(? ) 7 . o7quo rne Pla nt LIZABETH SSALL, Eb,,WW ,Q DAMAGES ARE( E Y ASSESSED AS INDICATED flPlf,7788 Nou- DATE: V PRA MJU#: 12120140 CASE#: 12120140-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF BY: MARK J.UDREN,ESQUIRE-ID#04302 STUART WINTNEG,ESQUIRE-ID#45362 LORRAINE GAZZARA DOYLE,ESQUIRE-ID#34576 SHERRI J.BRAUNSTEIN,ESQUIRE-ID#90675 SALVATORE CAROLLO,ESQUIRE-ID#311050 PAIGE M.BELLING,ESQUIRE-IDD#309091 HARRY B.REESE,ESQUIRE-ID#310501 C0 KASSIA FIALKOFF,ESQUIRE-ID#310530 ELIZABETH L.WASSALL,ESQUIRE-ID#77788 KATHERINE, E.KNOWLTON,ESQUIRE -ID#311713 NICHOLAS GAUNCE,ESQUIRE-IM06228 JOHN ERIC KISHBAUGH,ESQUIRE -ID#33078 WOODCREST CORPORATE CENTER III WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udrg�n.com HSBC Bank USA,National Association as Trustee on COURT OF COMMON PLEAS behalf of SG Mortgage Securities Trust 2007 AHLI CIVIL DIVISION Asset Backed Certificates,Series 2007 AHLI CUMBERLAND County C/O Ocwen Loan Servicing,LLC 1661 Worthington Road Suite 100 ' NO. C4 West Palm Beach,FL 33409 Plaintiff V. MOHAMED MOWJOOD MOHAMED h)ROOS 50 TORY CIRCLE ENOLA,PA 17025 IZZATHUL MOWJOOD 50 TORY CIRCLE ENOLA,PA 17025 Defendant(s) 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. o Verbal Confirmation of Service of Complaint Date: Apri1.23, 2013 Spoke with: Nicole @Cumberland County Sheriffs Office Defendant(s): Mohamed Mowiood Mohamed Idroos Q Served: 4/12/13 at: 50 Tory Circle, Enola, PA 17025 Notes: Service accepted by the Adult in Charge-Roommate Mark Dragon Defendant(s): Izzathul Mowiood Q Served: 4/12/13 at: 50 Tory Circle, Enola, PA 17025 Notes: Service accepted by the Adult in Charge-Roommate Mark Dragon Are there any additional fees due? No If so, how much? $ i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ` Richard W Stewart Solicitor HSBC Bank USA Case Number vs. 2013-1726 Mohamed Mowjood Mohamed Idroos(et al.) SHERIFF'S RETURN OF SERVICE 04/12/2013 03:23 PM- Deputy Dennis Fry,being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Mark Dragan Roommate,who accepted as"Adult Person in Charge"for Mohamed Mowjood Mohamed Idroos at 50 Tory Circle, East Pennsboro Enola, PA 17025_ DEN S FRY, OEP. � 04/12/2013 03:23 PM-Deputy Dennis Fry, being duly sworn according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Mark Dragon roommate,who accepted as"Adult Person in Charge"for izzathul Mowjood at 50 Tory Circle, East Pennsboro Township, Enola, PA 17025. DENN%r8 FRY, DEPIJ �- SHERIFF COST: $59.00 SO ANSWERS, April 15, 2013 RbNW R ANDERSON,SHERIFF I i ic)Cotjn"&Re Sheriff,TdeosoR.Inc. UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage Securities CIVIL.DIVISION Trust 2007 AHLI Asset Backed Certificates, Cumberland County Series 2007 AHL1 Plaintiff ; MORTGAGE FORECLOSURE V. Mohamed Mowjood Mohamed Idroos, NO. 13-1726 Civil Izzathul Mowjood Defendant(s) TO: Mohamed Mowjood Mohamed Idroos 50 Tory Circle Enola,PA 17025 Date of Notice: June 12,2013 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 EVIPORTANTE 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(I0)DIAS DE ESTA NOTIFICACION,EL TRIBUNAL PODRA,SIN NECESMAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS, ROORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO MVIEDIATAMENTE SI USTED NO TIENE ABOGADO,O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTR.A 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. BY: omey for Plaintiff J.Eric Wshbaugh, Esquire PA ID 33078 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 i Cherry Hill,New Jersey 08003-3620 i MJU#: 12120140 CASE#: 12120140-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage Securities CIVIL DIVISION Trust 2007 AHL1 Asset Backed Certificates, Cumberland County Series 2007 AHLI Plaintiff MORTGAGE FORECLOSURE V. Mohamed Mowjood Mohamed Idroos, NO. 13-1726 Civil Izzathul Mowjood Defendant(-) TO: Izzathul Mowjood 50 Tory Circle Enola,PA 17025 Date of Notice: June 12,2013 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 ACCJON 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 COMPARA.RECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS DERECHOS,RvIPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO,VAYA EN PERSONA O 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. BY: Attomey for Plaintiff J.Eric IQshbaugh, Esquire PA ID 33078 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill,New Jersey 08003-3620 MJU#: 12120140 CASE#: 12120140-1 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udreift.com HSBC Bank USA,National Association as Trustee on COURT OF COMMON PLEAS behalf of SG Mortgage Securities Trust 2007 AHLI CIVIL DIVISION Asset Backed Certificates,Series 2007 AHLI Cumberland County Plaintiff V. MORTGAGE FORECLOSURE MOHAMED MOWJOOD MOHAMED IDROOS IZZATHUL MOWJOOD NO. 13-1726 Civil Defendant(s) 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),the Defendant,MOHAMED MOWJOOD MOHAMED IDROOS,who is over 18 years of age is 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 Defendant, IZZATHUL MOWJOOD is in active military service because Plaintiff cannot provide date of birth and/or Social Security number for said Defendant, who is not a borrower on the loan, to enable a search. . This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. L !A BALL, EwSQ Dated: PA 1D7��88 Attorney for Plaintiff MJU#: 12120140 CASE#: 12120140-1 Department of Defense Manpower Data Center Results as of:Jut-30-2013 08:01:61 SCRA 3.0 Status Report F" Pursuant to Serv%cemembem Civil Relief Act. Last Name: MOHAMED IDROOS First Name: MOHAMED Middle Name: MOWJOOD Active Duty Status As Of: Jul-30-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA This response reflects the mtiM"duals'active duty status based on the Active Duty Status Date Lett Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date tt Status Service Component NA NA ''yr rt4; Y t -�-'NO S- y NA t _ -` This response reflects where the Individual left active duty status within 367 days preceding the,Active'Duty Status Date 1 :4 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 `.NA,�'. �� r.'. 1 ^,r•No ♦ r� NA This response reflects whether the Individual'®r hislhe nit has received earty notification to report for active duty 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 Uniformed Services(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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Aaj A. 4A4,,A� Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 i The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility 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 at 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:hftp://www.defenselink.mil/faq/pis/PCOgSLDR.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 an 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(0 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: J37CJD9EQ036X30 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 j2leadingsQudren.Co'n1 HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage CIVIL DIVISION Securities Trust 2007 AHLI Asset Backed Cumberland County Certificates, Series 2007 AHLI Plaintiff MORTGAGE FORECLOSURE V. Cn Mohamed Mowjood Mohamed Idroos NO. 13-1726 Civil Izzathul Mowjood Defendant(s) C-- PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 144961.21 Interest From 7/31/2013 $ 2,200.91 to Date of Sale December 4,2013 Ongoing Per Diem of$17.33 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN:7FICES,P.C. auk BY: Attorne or Plaintiff 0 ELIZABETH L WASSALL, ESQ PA ID 77788 MJU#: 12120140 CASE#: 12120140-1 0? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@ydren.com HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage CIVIL DIVISION Securities Trust 2007 AHL1 Asset Backed Cumberland County Certificates, Series 2007 AHL1 c_- Plaintiff MORTGAGE FORECLOSURE V. rn Mohamed Mowjood Mohamed Idroos I NO. 13-1726 Civil C::� Izzathul Mowjood Defendant(s) _4 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 n 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 LAW OFFICES, P.C. BY: Attorney for Plaintiff ,t-t)A'L WhSSALk,,ESQ 1D 77788 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER III WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadinus(i�udren.com HSBC Bank USA,National Association as COURT OF COMMON PLEAS -a Trustee on behalf of SG Mortgage CIVIL DIVISION Securities Trust 2007 AHLI Asset Backed Cumberland County Certificates, Series 2007 AHLI :-r--n Plaintiff MORTGAGE FORECLOSURE C:) V. C-) Mohamed Mowjood Mohamed ldroos Xr Izzathul Mowjood NO. 13-1726 Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 HSBC Bank USA,National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHLI Asset Backed Certificates, Series 2007 AHLI,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: ,50 Tory Circle,East Pennsboro Township,PA 17025 1.Name and address of Owner(s) or reputed Owner(s): Mohamed Mowjood Mohamed ldroos 50 Tory Circle Enola,PA 17025 Izzathul Mowjood 50 Tory Circle Enola, PA 17025 2.Name and address of Defendant(s) in the judgment: Mohamed Mowjood Mohamed ldroos 50 Tory Circle Enola,PA 17025 Izzathul Mowjood 50 Tory Circle Enola,PA 17025 3.Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Midland Funding LLC 8875 Aero Drive Suite 200 San Diego, CA 92123 Portfolio Recovery Associates LLC 140 Corporate Blvd. Norfolk,VA 23502 Capital One Bank(USA) c/o Edwin A. Abrahamsen Assoc. 120 North Keyser Ave. Scranton,PA 18504 t 4. Name and address of the last recorded holder of every mortgage of record: HSBC Bank USA,National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHLI 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders -None Jr Mortgage Holders -None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders-None 6.Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County 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 50 Tory Circle East Pennsboro Township, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDREN LAW OFFICES, P.C. BY: Attorne y for flETH L WASSAIL, ESQ PA ID 77788 MJU#: 12120140 CASE#: 12120140-1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 12leadings@,udren.6om HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage CIVIL DIVISION Securities Trust 2007 AHL1 Asset Backed Cumberland County Certificates, Series 2007 AHL1 Plaintiff MORTGAGE FORECLOSURE ; V. M -: mm r r- MOHAMED MOWJOOD MOHAMED NO. 13-1726 Civil C a C? IDROOS, IZZATHUL MOWJOOD r"M ---4 3 Defendant(s) � =C:) : CD NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mohamed Mowjood Mohamed Idroos 50 Tory Circle Enola, PA 17025 Your house (real estate) at 50 Tory Circle,East Pennsboro Township, PA 17025 is scheduled to be sold at the Sheriffs Sale on December 4, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$144,961.21, 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. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadings& dren.com HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage CIVIL DIVISION > Securities Trust 2007 AHL1 Asset Backed Cumberland County _ ,� .-a Certificates, Series.2007 AHL1 r � r' t Plaintiff MORTGAGE FORECLOSURE , V. co zp a MOHAMED MOWJOOD MOHAMED NO. 13-1726 Civil =-, IDROOS, IZZATHUL MOWJOOD ? T`' Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Izzathul Mowjood 50 Tory Circle Enola,PA 17025 Your house (real estate) at 50 Tory Circle,East Pennsboro Township,PA 17025 is scheduled to be sold at the Sheriffs Sale on December 4,2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$144,961.21, 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.) i i 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 i Carlisle,PA 17013 (800)990-9108 i i i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-1726 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC BANK USA,NATIONAL ASSOCIATION AS TRUSTEE ON BEHALF OF SG MORTGAGE SECURITIES TRUST 2007 AHL1 ASSET BACKED CERTIFICATES,SERIES 2007 AHL1 Plaintiff(s) From MOHAMED MOWJOOD MOHAMED IDROOS,IZZATHUL MOWJOOD (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) if property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $144,961.21 L.L.: $.50 Interest FROM 7/31/2013 TO DATE OF SALE DECEMBER 4,2013-ONGOING PER DIEM OF $17.33 TO ACTUAL DATE OF DALE INCLUDING IF SALE IS HELD AT A LATER DATE- $2,200.91 Atty's Comm: Due Prothy: $2.25 Atty Paid: $207.75 Other Costs: Plaintiff Paid: Date: August 20,2013 David D.Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: ELIZABETH L.WASSALL,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. 77788 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com HSBC Bank USA,National Association as COURT OF COMMON PLEAS G � C Trustee on behalf of SG Mortgage Securities cd CIVIL DIVISION Trust 2007 AHL1 Asset Backed Certificates, Cumberland County Series 2007 AHL1 V Plaintiff MORTGAGE FORECLOSURE L p rr. NO. 13-1726 Civil MOHAMED MOWJOOD MOHAMED ; IDROOS, IZZATHUL MOWJOOD, Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff,by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale,a true and correct copy of which is attached hereto as Exhibit"A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution,on the date(s)appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s)on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto,then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit"B". 4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as Exhibit"B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. 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: 0 UDREN LAW OFFICES,P.C. BY: AttomeyA for Plaintiff !Nicole LaBlefla, Esquire. MN#: 12120140 CASE#: 12120140-1 PA ID 202104 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage CIVIL DIVISION Securities Trust 2007 AHL1 Asset Backed Cumberland County Certificates, Series 2007 AHL1 Plaintiff MORTGAGE FORECLOSURE V. Mohamed Mowjood Mohamed Idroos NO. 13-1726 Civil Izzathul Mowjood Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 HSBC Bank USA,National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1, 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: 50 Tory Circle,East Pennsboro Township, PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Mohamed Mowjood Mohamed Idroos 4004 Golfview Drive Mechanicsburg, PA 17055 Izzathul Mowjood 4004 Golfview Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Mohamed Mowjood Mohamed Idroos 4004 Golfview Drive Mechanicsburg,PA 17055 Izzathul Mowjood 4004 Golfview Drive Mechanicsburg, PA 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Midland Funding LLC 8875 Aero Drive Suite 200 San Diego, CA 92123 Midland Funding LLC c/o Burton Neil& Associates, PC 1006 Andrew Drive, Suite 120 West Chester, PA 19380 Portfolio Recovery Associates LLC 140 Corporate Blvd. Norfolk,VA 23502 Capital One Bank(USA) c/o Edwin A. Abrahamsen& Assoc. 120 North Keyser Ave. Scranton, PA 18504 4. Name and address of the last recorded holder of every mortgage of record: HSBC Bank USA, National.Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 1661 Worthington Road-Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County 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 50 Tory Circle East Pennsboro Township, PA 17025 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: ( )o a �� UDREN LAW OFFICES, P.C. BY: 4) 1 A 44 Y/'28V�L Attorney:for.Plaintiff MJU#: 12120140 CASE#: 12120140-1 Nicole LaBMaj ,° PA !D 202194 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 -Bank HSBC National Association as COURT OF COMMON PLEAS Trustee on behalf of f Mortgage SG Mortgage Securities Trust 2007 AHL1 Asset Backed CIVIL DIVISION Certificates,Series 2007 AHL1 Cumberland County Plaintiff V. MORTGAGE FORECLOSURE MOHAMED MOWJOOD MOHAMED IZA f1R NO. 13-1726 Civil IZZATH�JL MOWJOOD; Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): MOHAMED MOWJOOD MOHAMED IDROOS; IZZATHUL MOWJOOD; PROPERTY: 50 Tory Circle, East Pennsboro Township, PA 17025 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/04/2013 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 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O g x .R o C❑C C❑� x w c 1 w �j RX m I. , U.S.POSTAGE>>PITNEY BOWES y o fD 4;l o 9 O w. o w00 �{ 02 0003 $ 001.20° '� o °n o �Cb' 0001387090 SEP. 24. 2013. C 5 0 md'wb° / d 5�� tip f V It ob , o 0 rn g c(o d yey oq y. CD o to 5rn�vx A em oB 6 w B g 9 T 9 a. v�cmHv c m ^ W Cl `�o • Oct. 18. 2013 11 :42AM Cumberland County Sherrif No. 7807 P. 4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �o��r�p of Itr;uhbrrrA�ip Jody S Smith r Chief Deputy Richard W Stewart ' :.. Solicitor OFFICE OF TkE SHERIFF HSBC Bank USA vs. Case Number Mohamed Mowjood Mohamed Idroos let al.) 2013-1726 SHERIFF'S RETURN OF SERVICE 09/27/2013 04:10 PM-Deputy Stephen Bender, 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 50 Tory Circle, Enola, PA 17025,Cumberland County. 10107/2013 Ronny R.Anderson,Sheriff, being duly sworn according to law,states that he made a diligent search and inquiry for the within named Defendant,to wit: Izzathui Mowjood, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Deal Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 50 Tory Circle, Enola,PA 17025,defendant no longer resides at address stated, house is being rented, left forwarding addresse of,4004 Golfview Drive, Mechanicsburg, PA 17055 with Post Office. 10/07/2013 Ronny R.Anderson, Sheriff,being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant,to wit: Mohamed Mowjood Mohamed Idroos, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action,as"Not Found"at 50 Tory Circle, Enola,PA 17025, defendant no longer resides at address stated,house is being rented, left forwarding addresse of,4004 Golfview Drive, Mechanicsburg,PA 17055 with Post Office. 10/10/2013 07:21 PM-Deputy Dawn Kell, being duly sworn according to taw,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: Mohamed Mowjood Mohamed Idroos at 4004 Golfview Dr, Hamden Twp, Mechanicsburg, PA 17055, Cumberland County. 10/10/2013 07:21 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 Mohamed Mowjood, Husband, j who accepted as"Adult Person in Charge"for Izzathul Mowjood at 4004 Golfvlew Dr, Hampden Twp, Mechanicsburg,PA 17055, Cumberland County. SHERIFF COST: $991.16 SO ANSWERS, October 18, 2013 RON R ANDERSON, SHERIFF �a� Q ;c)CountyS"ile SnerM.Tele mk Inc. DOREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com HSBC Bank USA, National • Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Plaintiff v. . Mohamed Mowjood Mohamed Idroos Izzathul Mowjood Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13-1726 Civil PETITION FOR POSTPONEMENT 0' SHE wr's SALE Plaintiff, by its counsel, petitions the Court for a 1 (one) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1: A Sheriff's sale of the mortgaged property involved herein, located at 50 Tory Circle, East Pennsboro Township, PA 17025 was originally scheduled for December 4, 2013, then postponed to January 8, 2014, due to pending loan modification review, then postponed to March 12, 2014. 2. The Plaintiff seeks the postponement of the Sheriff's sale 1 (one) month to allow Plaintiff time to assess the possibility of a loan modification. 3. Pursuant to local rule the defendant(s) is unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail. 4. No Judge has been assigned to this matter. WHERE 'ORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property ,be postponed to the April 9, 2029 Sheriff's sale. Na . an C. Wol al Counsel BY: Respectfully submitted,- UDREN LAW OFFICES, P.C. orney for Pl. miff HARRY B, REESE, • UIRE PA ID 310 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 - CHERRY SILL, Na 08003-3620 856-669-5400, pleadings@udren.com HSBC Bank USA, National COURT OF COMMON PLEAS Association as Trustee on behalf CIVIL DIVISION of SG Mortgage Securities Trust iCumberland County 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Plaintiff 1NO. 13-1726 Civil v. Mohamed Mowjood Mohamed Idroos ATTORNEY TOR PLAINTIFF Izzathul Mowjood Defendant(s) PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows for the postponement of a Sheriff's sale. In the present matter, the sale has been previously postponed. Plaintiff now seeks an additional postponement to allow time to assess the possibility of a loan modification. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 50 Tory Circle, East Pennsboro Township, PA 17025, to the April 9, 2014 Sheriff's sale as set forth in the Motion. N han C. 1 Counsel qu e BY: Respectfully submitted, UDREN LAW OFFICES, P.C. orney aintiff HARRY B. REESE, SQUIRE PA ID 310501 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 NOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400, pleadings@udren.com HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Plaintiff v. Mohamed Mowjood Mohamed Idroos Izzathul Mowjood Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13,-1726 Civil CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached PetitiOn for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: X)pCX Regular First Class Mail Certified mail Other Date Served: March 10, 2014 TO: Mohamed Mowjood Mohamed Idroos 4004 Golfview Drive Mechanicsburg, PA 17055 .Izzathul Mowjood 4004 Golfview Drive Mechanicsburg, PA 17055 an C. Wol o al Counsel re BY: UDREN LAW OFFICES, P.0 A torney for laintiff HARRY B. REES ESQUIRF PA ID n' IN THE COURT OF COMMON PLEAS 0? CUNBERLOAND COUNTY, CIVIL DIVISION HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Plaintiff v. Mohamed Mowjood Mohamed Idroos Izzathul Mowjood Defendant (S) ORDER NO. 13-1726 Civil AND NOW this/pa, day of March, 2014, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 50 Tory Circle, East PennsbOro Township, PA 17025, it is hereby ORDERED that the said Sale currently scheduled for March 12, 2014, is extended 1 (one) month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for April 9, 2014. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the March 12, 2014, Sheriff's Sale. BY THE COURT: TOZamed Mowjood Mohamed Idroos 4004 Golfview Drive Mechanicsburg, PA 17055 Mowjood 4004 Golfview Drive Mechanicsburg, PA 17055 Sheriff of Cumberland County One Courthouse Square Carlisle, PA 17013-3387 Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 Attn: Sale Department '14"441 LA) Cop CE,s, /72..V.1 LEL 2/1/04, J. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856 - 669 -5400, pleadings @udren.com HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHLI Plaintiff v. Mohamed Mowjood Mohamed Idroos Izzathul Mowjood Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13 -1726 Civil PETITION FOR POSTPONEMENT OF SHERIFF'S SALE Plaintiff, by its counsel, petitions the Court for a 3 (three) month postponement of the Sheriff's sale scheduled in the above captioned matter and in support thereof avers the following: 1. A Sheriff's sale of the mortgaged property involved herein, located at 50 Tory Circle,'East Pennsboro Township, PA 17025 was originally scheduled for December 4, 2013, then postponed to January B, 2014, due to pending loan modification review, then postponed to March 12, 2014, then postponed to April 9, 2014 2. The Plaintiff seeks the postponement of the Sheriff's sale 3 (three) month to allow Plaintiff time to assess the possibility of a loan modification. 3. Pursuant to local rule the defendant(s) is unrepresented by counsel and plaintiff has no manner in which to seek concurrence except by mail.. 4. The Honorable Christylee Peck, was assigned to this matter and granted Plaintiff's prior petition to postpone sheriff sale:. WHEREFORE, Plaintiff respectfully prays and requests that the Sheriff's sale of the mortgaged property be postponed to the July 2, 2014 Sheriff's sale- Respectfully submitted, UDREN LAW OFFICES, P.C. BY: Nathan WWolf, Esquire to 'hey for P intiff HARRY B. REESE, UIRE PA ID 31O Local Counsel UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003 -3620 856 -669 -5400, pleadings @udren.aom HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Plaintiff v. Mohamed Mowjood Mohamed Idroos ,Izzathul Mowjood Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13 -1726 Civil PLAINTIFF'S MEMORANDUM OF LAW Pennsylvania R.C.P. 3129.3(b) allows a Sheriff's sale. In the present matter, for the postponement of the sale has been previously postponed. Plaintiff now seeks an additional postponement to allow time to assess the . possibility of a loan modification. Therefore, in order for the Plaintiff to be able to properly conduct itself at the Sheriff's sale, a postponement of the sale is necessary. Pa.R.C.P. 3129.3(a) allows the postponement of the sale more than once, and without new notice, by Special Order of Court. Accordingly, for the reasons hereinabove stated, and as more particularly set forth in the Motion, Plaintiff respectfully requests continuance of the Sheriff's Sale of the mortgaged premises, located at 50 Tory Circle, East Pennsboro Township, PA 17025, to the July 2, 2014 Sheriff's sale as set forth in the Motion. BY: Respectfully submitted, UDREN LAW OFFICES, P.C.. Nathan C. W Esquire A rney forraintff Local Counsel HARRY 8. REESE, ESQUIRE PA ID 310501 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856-669-5400, pleadings @udren.com HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Plaintiff v. Mohamed Mowjood Mohamed Idroos Izzathul Mowjood Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 13 -1726 Civil CERTIFICATE OF SERVICE The undersigned certifies that true and correct copies of the attached Petition for Postponement of Sheriff's Sale was served upon the following person(s) named herein at their last known address or their attorney of record by: Regular First Class Mail Certified Mail Other Date Served: April 4, 2014 TO: Mohamed Mowjood Mohamed Idroos 4004 Golfview Drive Mechanicsburg, PA 17055 Izzathul Mowjood 4004 Golfview Drive Mechanicsburg, PA 17055 Na . Wolf, Esquire Loca .ounsel UDREN LAW OFFICES, P.C., BY••1 p`rt'torney for laintiff HARRY B. REESE,;'ESQUIRE PA ID 3105n1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL DIVISION HSBC Bank USA, National Association as Trustee on behalf of SG Mortgage Securities Trust 2007 AHL1 Asset Backed Certificates, Series 2007 AHL1 Plaintiff v Mohamed Mowjood Mohamed Idroos Izzathul Mowjood Defendant (s) O R D E R `.0 a ---9 m. 01 10 r zy .a.. y 1 —17 r NO. 13 -1726 Civil o?� ;sc., co S' 1 - -; 0.1 AND NOW, this Oz day of April, 2014, after consideration of Plaintiff's Petition for Postponement of Sheriff's Sale of the mortgaged property located at 50 Tory Circle, East Pennsboro Township, PA 17025, it is hereby ORDERED that the said Sale currently scheduled for April 9, 2014, is extended 3 (three) month(s) to the regularly scheduled Cumberland County Sheriff's Sale scheduled for July 2, 2014. No further advertising or additional notice to lienholders or Defendant(s) is required provided the postponement is announced at the April 9, 2014, Sheriff's Sale. TO* ohamed Mowjood Mohamed Idroos 4004 Golfview Drive Mechanicsburg, PA 17055 zathul Mowjood 4004 Golfview Drive Mechanicsburg, PA 17055 Sheriff of Cumberland County One Courthouse Square Carlisle, PA 17013 -3387 dren Law Offices, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 i. Attn: Sale Depart ent Veil BY THE COURT: // • SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE O?•m { RIFF F ;+,_. D -CE �- IC's Tc RO V,101.10,. 4'~� 2Tilt JUL —3 Ft\ 3: 53 CUMBERLAND COUNT'( PENNSYLVANIA; HSBC Bank USA Case Number vs. Mohamed Mowjood Mohamed Idroos (et al.) 2013-1726 SHERIFF'S RETURN OF SERVICE 09/27/2013 04:10 PM - Deputy Stephen Bender, 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 50 Tory Circle, Enola, PA 17025, Cumberland County. 10/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Izzathul Mowjood, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 50 Tory Circle, Enola, PA 17025, defendant no longer resides at address stated, house is being rented, left forwarding addresse of, 4004 Golfview Drive, Mechanicsburg, PA 17055 with Post Office. 10/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Mohamed Mowjood Mohamed Idroos, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 50 Tory Circle, Enola, PA 17025, defendant no longer resides at address stated, house is being rented, left forwarding addresse of, 4004 Golfview Drive, Mechanicsburg, PA 17055 with Post Office. 10/10/2013 07:21 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: Mohamed Mowjood Mohamed Idroos at 4004 Golfview Dr, Hamden Twp,. Mechanicsburg, PA 17055, Cumberland County. 10/10/2013 07:21 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 Mohamed Mowjood, Husband, who accepted as "Adult Person in Charge" for Izzathul Mowjood at 4004 Golfview Dr, Hampden Twp, Mechanicsburg, PA 17055, Cumberland County. 11/27/2013 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/8/2014 01/06/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/12/2014 03/11/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/9/2014 04/08/2014 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/2/2014 06/30/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,179.32 July 01, 2014 (c) CountySuite Sheriff, leleosoft. €nc SO ANSWERS, RONRANDERSON, SHERIFF R-'a".'*5.0PLI ' (,1,Lg70 �-� On August 22, 2013 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as, 50 Tory Circle, Enola, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 22, 2013 By: (at -C. (fL6 Real Estate Coordinator LS :b V ZZ SMJ E151 LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013-1726 Civil Term HSBC BANK USA vs. MOHAMED MOWJOOD MOHAMED IDROOS, Izzathul Mowjood Atty.: Mark Udren ALL THAT CERTAIN piece or par- cel of land situate in the Township of East Pennsboro County of Cumber- land and Commonwealth of Penn- sylvania, bounded and described as follows, to wit: BEGINNING at a point on the western legal right-of-way line of Hal Lane at the northwest corner of Lot No. 114 on the hereinafter described Final Subdivision Plan: thence along the northern line of said Lot No. 114 South 61 degrees 53 minutes 00 seconds West a distance of 25.00 feet to a pont; thence continuing along the same South 71 degrees 34 minutes 00 seconds West a distance of 84.89 feet to a pont at the eastern legal right-of-way line of Tory Circle; thence along the eastern legal right- of-way line of Tory Circle North 18 degrees 26 minutes 00 seconds West a distance of 24.00 feet to a point at the southwest corner of Lot No. 112 on the hereinafter described Final Subdivision Plan; thence along the southern line of said Lot No. 112 North 71 degrees 34 minutes 00 sec- onds East a distance of 103.79 feet to a point on the western legal right- of-way line of Hal Lane; thence along the western legal right-of-way of Hal Lane by a curve to the left having a radius of 160.00 feet an arc length of 20.63 feet to a point at the northeast corner of Lot No. 114 on the hereinaf- ter described Final Subdivision Plan, the point and place of BEGINNING. CONTAINING 2,515.65 square feet, more or less. BEING Lot No. 113 on the Final Subdivision Plan of Laurel Hills North Lot 3 and 4 Section 5, dated June 1, 1992, revised August 5, 1992 and re- corded in the Office of the Recorder of 66 Deeds of Cumberland County, Penn- sylvania in Plan Book 65, Page 39. BEING improved with a dwelling known as 50 Tory Circle. BEING KNOWN AS: 50 Tory Circle, East Pennsboro Township, PA 17025 Property ID No.: 09-14- 0835-104. TITLE TO SAD PREMISES IS VESTED IN Mohamed Mowjood Mo- hamed Idroos and Izzathul Mowjood, husband and wife, as tenants by the entirety by deed from Mowjood Idroos a/k/a Mohamed Mowjood Mohamed Idroos and Izzathul Mowjood, hus- band and wife dated 05/25/2007 recorded 06/05/2007 in Deed Book 280 Page 1530. 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: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. n sa Male Coyne, ditor SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 he Patriot -News Co. 2020 Techriology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Iie patriot*Xews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2013-1726 CMI Term . HSBC BANK USA • vs. MOHAMED MOWJOOD, MOHAMEDIDROOS r4'; Izzathul Mowjood • Atty: Mark Udren ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF EAST PENNSBORO COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE WESTERN LEGAL RIGHT-OF- WAY LINE OF HAL LANE AT THE NORTHWEST CORNER OF LOT NO.114 ON THE HEREINAr1 ER DESCRIBED FINAL SUBDIVISION PLAN: THENCE ALONG THE NORTHERN LINE OF SAID LOT NO.114 SOUTH 61 DEGREES 53 MINUTES 00 SECONDS WEST A DISTANCE OF 25.00 FEET TO A PONT; THENCE CONTINUING ALONG THE SAME SONAI 71 ;DEGRF.FS 34 MINUTES 00 SECONDS WEST A DISTANCE OF 84.89 FEET TO A PONT AT THE FASTFRIgiar°1 oT,_trrnr. This ad ran on the date(s) shown below: 10/13/13 10/20/13 10/27/13 Swor d subscribed before th.. 11 day of November, 2013 A.D. ublic COMMONW Ii OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Rleadings@udren.com HSBC Bank USA,National Association as COURT OF COMMON PLEAS Trustee on behalf of SG Mortgage CIVIL DIVISION Securities Trust 2007 AHL1 Asset Backed Cumberland County Certificates, Series 2007 AHL1 Plaintiff MORTGAGE FORECLOSURE --c1",---) 9 — -, v. c: N MOHAMED MOWJOOD MOHAMED NO. 13-1726 Civil IDROOS IZZATHUL MOWJOOD Defendant(s) - PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: 9' 111 UDR W OFFICES, P.C. BY: , At • • aintiff Davi : l eeren, Esquii.tj MJU#: 12120140 CASE#: 12120140-1 PA ID 204252 0),.0 q �