HomeMy WebLinkAbout13-2452 Supreme Court.of Pennsylvania
Co u ;` I holm n Pleas
l , ilY
feel For Prothonotary Use Only:
C RLAND,�' COU><lty Docket No:
- -1 � 3 - S
5 l GQ
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiff's Name: Ocwen Loan Servicing, LLC Lead Defendant's Name: Patricia R. Eberts
C
T Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits
I (Check one) x outside arbitration limits
O —
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No
Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC
A ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] 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
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card
El Motor Vehicle El Board of Assessment
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❑ Statutory Appeal: Other
S
El Product Liability (does not include
mass tort) ❑ Employment Dispute:
E ❑ Slander/Libel/Defamation Discrimination
El Other: E3 Employment Dispute: Other
C El Zoning Board
T
El Other:
I MASS TORT El Other:
O El Asbestos
❑ Tobacco
N ❑ Toxic Tort- DES
❑ Toxic Tort- Implant
Toxic Waste REAL PROPERTY MISCELLANEOUS
❑
❑ Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
B ❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
PROFESSIONAL LIABLITY ®Mortgage Foreclosure: Residential Restraining Order
❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
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El Legal El Replevin
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Updated 1/1//2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANA
Mme, -:-
S r I
OCWEN LOAN SERVICING, LLC, CIVIL DIVISION
Plaintiff, NO.: ✓S�
�C:)
VS. C Z' —
TYPE OF PLEADINGS
Patricia R. Eberts; William E. Lovett a /k /a M..I
�
William Lovett; CIVIL ACTION -COMPLAINT w �'•
IN MORTGAGE FORECLOSURE
Defendants.
FILED ON BEHALF OF:
TO: DEFENDANTS Ocwen Loan Servicing, LLC
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE COUNSEL OF RECORD FOR THIS PARTY:
ENTERED AGAINST YOU.
I HEREBY CERTIFY THAT THE ADDRESS ZUCKER, GOLDBERG & ACKERMAN, LLC
OF THE PLAINTIFF IS:
1100 VIRGINIA DRIVE, PO BOX 8300 Scott A. Dietterick, Esquire
FORT WASHINGTON, PA 19034 Pa. I.D. #55650
AND THE DEFENDANT: Kimberly A Bonner, Esquire
600 East Keller Street Pa. I.D. #89705
Mechanicsburg, PA 17055 Joel A. Ackerman, Esquire
Pa I.D. #202729
Ashleigh Levy Marin, Esquire
CERTIFICATE OF LOCATION Pa I.D #306799
1 HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTE2 BY THIS LIEN IS Ralph M. Salvia, Esquire
600 East Keller Str eet , Md PA 17055 Pa I.D. #202946
Municipality: Mecha sb Jaime R. Ackerman, Esquire
Pa I.D. #311032
ATTORNE O P INTIF 200 Sheffield Street, Suite 101
ATTY FIL 'NO.: XFP 173739 Mountainside, NJ 07092
(908) 233 -8500
(908) 233 -1390 FAX
office @zuckergoldberg.com
File No.: XFP- 173739/mme
C, el/
a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
VS. NO..
Patricia R. Eberts; William E. Lovett a /k /a William
Lovett;
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the following pages,
you must take action within twenty (20) days after this complaint and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court without further notice
for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO
YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO !FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990 -9108 Phone (800) 990 -9108
(717) 249 -3166 (717) 249 -3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
VS. NO..
Patricia R. Eberts; William E. Lovett a /k /a William
Lovett;
Defendants.
AVISO
USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en
las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la
notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una
comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a [as demandas
establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe
anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de
dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el
demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o
propiedades u otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN
ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA.SIGUEINTE OFICINA PARA AVERIGUAR
DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990 -9108 Phone (800) 990 -9108
(717) 249 -3166 (717) 249 -3166
o
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
VS. NO..
Patricia R. Eberts; William E. Lovett a /k /a William
Lovett;
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Ocwen Loan Servicing, LLC, by its attorneys, Zucker, Goldberg & Ackerman,
LLC, and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Ocwen Loan Servicing, LLC, (hereinafter "plaintiff') having its principal
place of business at 1100 VIRGINIA DRIVE, PO BOX 8300, FORT WASHINGTON, PA 19034.
2. The Defendant, Patricia R. Eberts, is an individual whose last known address is 600
East Keller Street, Mechanicsburg, PA 17055.
3. The Defendant, William E. Lovett a /k /a William Lovett, is an individual whose last
known address is 600 East Keller Street, Mechanicsburg, PA 17055.
4. Ocwen Loan Servicing, LLC, directly or through an agent, has possession of the
Promissory Note. Ocwen Loan Servicing, LLC is either the original payee of the Promissory Note or
the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is
marked Exhibit A, attached hereto and made a part hereof.
5. On or about November 19, 2009, Patricia R. Eberts, an adult individual and William E.
Lovett, an adult individual made, executed and delivered to Mortgage Electronic Registration
Systems, Inc. as nominee for Fairway Independent Mortgage Corporation a Mortgage in the original
principal amount of $142,809.00 on the premises described in the legal description marked Exhibit B,
attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder
of Deeds of Cumberland County on December 18, 2009, Instrument #200942017. The mortgage is a
matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g),
which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those
documents are of public record.
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
6. By Assignment of Mortgage recorded September 27, 2012, the mortgage was
assigned to GMAC Mortgage, LLC which assignment is recorded in the Office of the Recorder of Deeds
for Cumberland County, Instrument #201229714. The Assignment is a matter of public record and is
incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the
Plaintiff from its obligation to attach documents to pleadings if those documents are of public record.
7. Plaintiff is the current Mortgagee and is in the process of recording an Assignment of
Mortgage.
8. Patricia R. Eberts, an adult individual and William Lovett, an adult individual are
record and real owners of the aforesaid mortgaged premises.
9. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest due June 1, 2012.
10. As of 02/15/2013 the amount due and owing Plaintiff by Defendants) is as follows:
Principal $137,754.83
Interest through 02/15/2013 $6,026.80
Escrow $1,396.80
Late Charges $350.00
Total $145,528.43
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law,
actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow
advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in
the above - captioned action to add such additional sums authorized under the Mortgage and
Pennsylvania Law to the above amount due and owing when incurred.
11. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or
Notice of Default as required by the mortgage document, as applicable, have been sent to the
Defendant(s).
12. This action does not come under Act 91 of 1983 because the mortgage is FHA
insured.
13. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is
not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
a separate legal action if such right exists. If Defendants) have received a discharge of personal
liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount
due of $145,528.43 with interest thereon plus additional costs (including additional escrow
advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged
premises.
ZUCKER, GOLDBE A ,
BY:
Dated: 5 2 Scott A. Diet rick, Esq ire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP- 173739/mme
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
EBERT$. PATRICIA R G
Date: 11127/2009 1 NIT 1111 IT 1114 11411 1 11111111 OR 111111111111111
Multistate NOTE
1 00392499100000932 -L — �
NOVEM R 19, 2009
IDaiel
600 E. 1ZEM SlYan, , PE�]t� MVAM 17055
)Prntxrty Addreu)
1. PARTIES
"Borrower" means each person signing a t The end of this Note, and the person's successors and assigns. "Lender" means
»mY MWE ENDMV CoRpopj Tyr
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises In pay the principal sum of
CHE HMEM M ay Two THOUsi Jar Hammil Nnz s Nci /100
Dollars (U.S. S 142,809.00 ), plus interest, to file order of Lender. Interest will be charged oil unpaid principal,
from the date of disbursement of the loan proceeds by Lender, at The rate of
percent ( 5.25009 %) per year until life full amount of principal has been paid. I:ZVE
3. PROMISE. TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date
as this Note and called the "Security Inslntment." The Security Instrument protects The Lender tom losses which might result if
Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
JMNEMBY Borrower shall make a payment of principal and interest to Lender on the 1ST day of each month beginning on
01, 2010 . Any principal and interest remaining on the 1SP day of ESCEIAM
will be due on that date, which is called the "Maturity Date." 2039,
(B) Place
Payment shall be made at
2445 DAToW p4MO, A 7, T 102, bffi I9M, 11 53704
or at such place as Lender may designate in writing by notice to Burrower.
(C) Amount
Each monthly payment of principal and Interest will be in the amount of U.S. S 788.60 This a
will be par( of a larger monthly payment required by the Security Instrumem, that shall be applied to principal, interes o unt
other items in the order described in the Security Instrument.
(D) Allonge to this Note for payment adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this (Vote, the covenants of
the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of
this Note. lCheck applicabl
Eiradualed Payment Allonge DGrowing Equity Allonge 1 Cher Ispecifyj
441- 9537124 -703 Fn= L72N
iNA MWlrslstc h1tn0 Rac Noto 91011702
VMP it
Wollof{ Kluwer Iina ,ji servrm 10/!15
P R 40R091 00
Imbo15: �y Pago 1 ui 3
WWW.DUCsUIRvc,r,CCrit 11/17/2009 04:56 I'M NEW I.UAN
I
5. BORROWER'S RIGIIT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first
day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on (he amount prepaid for
the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a
partial prepayment, (here will he no changes in the due date or in the amount of the monthly payment unless Lender agrees in
writing to those changes.
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
if Lender has not received the full nton(hly payment required by the Security Instrunnmt, as described in Paragraph
4(C) of this Note, by the end of 15 calendar days after the payment is due. Lender may collect a late charge in the
amount of 1= percent( 4.0000;'0) of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations
of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and
all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent
default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in
full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used
in this Note, "Secretary" means (he Secretary of f lousing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and
expenses including reasonable and customary allorneys' lees for enforcing (his Not(- to the extent not prohibited by applicable
law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. "Presentment" means the right tt► require Lender to demand payment of amounts due. "Notice of dishonor" means the
right to require Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any nolice that must be given to Borrower under this Note will be given
by delivering it or by mailing it by first class mail to Borrower at (he properly address above or at a different address if
Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to lender at the address stated in
Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
if more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made. in
this Note, including (he promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligalet] to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surely
or endorser of this Note, is also obligated to keep all of (he promises made in this Note. Lender may enforce its rights under this
Note against each person individually or against all signatories together. Any one person signing this Note may be required to
pay all of the amounts owed under this Note.
441 - 9537124 -703 mm iam 91011702
F HA M,uRntato Faed Rate Note 10195
VMP •tb MP1R 108091.00
WollMS Kluwt-r Financial Srtrvkoa InrWb: �f �jpc 2 of 3
W`WW.D0CSI►tREC't'.CONt 11/17 /2009 04:56 PM NEW LOAN
BY SIGNING BELOW. Rorrower accepts and agrees to the terms and covenants contained in this Note.
1
(Sea!) (Seal)
FFJMCD► R. F 3 - Borrower *J+r - Borrower
(Seal) (Seal)
- Borrower - Burrower
(Seal) (Seal)
- Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
/Sign Original Onlyl
441- 9537124 -703 Fnw um 91011702
tHA mdomnta rly" Rate Note 10/95
VMP !q VMPI R 10809).0x+
er
Wolters Ntuw t.nancul Services Pagn 3 r 3
Pay to the order of
ARy► Bank f/k/a GMAC Bank
without recourse
FLAY 3M 2
CCIMKpjawm
Signature: __
Printed Namt:: _Lallr-el -A. Meyer
Title: _ Sr. Vice P reside nt
WWW.D0CSU1tEt 1'.(:00.1 1 u17i2009 04:56 Phl NIiW LOAN
Pay to the order of
GMAC Mortgage, LLC
Without Recourse:
t cn Miller, Assistant Secretary
My Bank DI-la GMAC Back
p $Y to the Or der of
tlluur Rec",:Irs0,
trivi r :�` �.�•:
GM 11v,; 4r� •
G1y�CCnlOrtfi�: , C y rr �iacnt
Mort gage CU r$tk/a
ate
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
ALL TW cmmw MALT CR Ipr OF rm SITU= IN TEE Sol== OF ,
cmeowm C70may, PPi��iS7t1+VAMED►, ZIIG 2406M PRAT LR= BOMMM AMID DF.cCU3= AS
8L4AMM, TO WIT:
1G AT A POINT CH THE SOUTH STDE OF FAST PMZM STiWT AT TEE DIM= I
SA'!mw ZO►1'S MS. 31 AND 32 ON ME PLM CF =8 FM TO , Wm8 sm
POII�P IS ALSO A DIS191 M CV 374.85 MW D yffS^ Y AIM TEE SOUTH SIDE OF
FAST IOMiF1t SIRE" Fun mlwE STREET; AMID z;=ona T88Nm AICNG TAE DIVI=w zma
IM NOS. 31 AMID 32, SOUTH 17 1- 1 a il 8 8 KCNWYZ FAST, A DISTANCE OF 131.83
FEET TO A PatW; EXMMING MENM SOUTH 74 DMaMS 2S MINUTES 30 SWONDS WEST, A
DISTANCE OF 67.66 MW TO A YOnV; FRMIDIIG3 THMM NORTH 28 DWMM 30 MOM
WEST, A DISTMM OF 130.23 1 F14T TO A POINT ON TEE 50018 SIDE OF $AST I=ZM 89REe.T;
EIDII+lC3 TF�10E Axe' T� 51017tH SIDtE OB' EAST IQDTJER STR�*F, NORTH 72 '.S 48
ZMWM FAST, A DISTANCE OF 75.65 PmT TO A POINT, THE KAM Off' WGINNIM.
BL+''= LOT NO. 31, SE=CN "B" ON TEE PLAN OF ffiACMw VIISA=, MMW IN PLAN
BOOEC 7, PX +' 7, CMMR MID COMM FDMW.
TEDC3 DE9QiIPi'IQT IS MM IN AOOMMRNL KM A SURVEY BY ERZII+".ST J. MUM, R.8.E. ,
DATM MPBH 15,1965 AMID OZERICTS TO TEE MCBNN ZNCCNSISTBNT PRIC[t StYtTPTi�ON3.
FAR= MOM 1723- 0563 -076
t
VERIFICATION
, oart"orx -zed - ,kcrner (title), depose and
say subject to the penalties of 18 Pa.C.S.A., sec. 4904 relating to unsworn falsification to authorities that
the facts set forth in the foregoing pleading are true and correct to the best of my information,
knowledge and belief.
By: L a Servicingt
Name: �rattlyr., MCI J \2a
Title
File No: 173739
Borrower Name: Patricia R. Eberts
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
c�
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff, 3 SaCGt/f''m
NO.:
vs.�
U, r"
Patricia R. Eberts; William E. Lovett a /k /a William r
Lovett;
n
2- c:n C✓ "?
Defendants.
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you
may be able to participate in a court - supervised conciliation conference in an effort to resolve this
matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn
Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request
appointment of a legal representative at no charge to you. Once you have been appointed a legal
representative, 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 riust 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.
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
i
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED
BY THIS NOTICE. TIDS PROGRAM IS FREE.
ZUCKER, GOLDBERG & KERMAN, LLC
By:
Dated: May ' , 2013 Scott A. D' ri squire; PA I.D. #55650
Kimberly onner, Esquire; PA I.D. #89705 Joel
A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP- 173739/ns
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
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:
CUSTOM ER/PRI
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):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
CO-BORROWER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL INFORMATION
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:
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1 : Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. Monthly amount:
2. Monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 " Mortgage Utilities
Car Payment(s) Condo /Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other prop. payment
Install. Loan Payment Cable TV
Child Support /Alim. Spending Money
Day /Child Care /Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
Email:
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I /We, , authorize the above named to use /refer this
information to my lender /servicer for the sole purpose of evaluating my financial situation for possible
mortgage options. I /We understand that I /we am /are under no obligation to use the services provided
by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's counsel:
V Proof of Income
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of current utility bill
V Letter explaining reason for delinquency and any supporting documentation (hardship letter)
V Listing agreement (if property is currently on the market)
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC
• CIVIL DIVISION
Plaintiff,
vs. NO..
Patricia R. Eberts; William E. Lovett a /k /a William
Lovett;
Defendants.
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
I. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
1. Defendant lives in the subject real property, which is defendant's primary residence;
2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program" and has taken all of the steps required in that Notice to be eligible to participate in
a court- supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand
that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn
falsification to authorities.
Signature of Defendant's Counsel /Appointed
Legal Representative Date
Signature of Defendant =
Date
Signature of Defendant
Date
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
VS. NO..
Patricia R. Eberts; William E. Lovett a /k /a William
Lovett;
Defendants.
CASE MANAGEMENT ORDER
AND NOW, this day of ,20 ,the defendant /borrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference
verifying that the defendant /borrower has complied with the Administrative Rule requirements for the
scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court - supervised conciliation
Conference on at M. in at the
Cumberland County Courthouse, Carlisle, Pennsylvania.
1. At least twenty -one (21) days prior to the date of the Conciliation Conference, the
defendant /borrower must serve upon the plaintiff /lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet"
(Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties
in writing or at the discretion of the Court, the Conciliation Conference ordered may be
rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be
made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve
the completed Form 2 within the time frame set forth herein or such other date as agreed upon
by the parties in writing or ordered by the Court, the case shall be removed from the
Conciliation Conference schedule and the temporary stay of proceedings shall be terminated.
2. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in
person and an authorized representative of the plaintiff /lender must either attend the
Conciliation Conference in person or be available by telephone during the course of the
Conciliation Conference. The representative of the plaintiff /lender who participates in the
Conciliation Conference must possess the actual authority to reach a mutually acceptable
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the
authorized representative in advance of the Conciliation Conference. If the duly authorized
representative of the plaintiff /lender is not available by telephone during the Conciliation
Conference, the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff /lender at the rescheduled
Conciliation Conference.
3. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and
explore all available resolution options which shall include: bringing the mortgage current
through a reinstatement; paying off the mortgage; proposing a forbearance agreement or
repayment plan to bring the account current over time; agreeing to tender a monetary payment
and to vacate in the near future in exchange for not contesting the matter; offering the lender a
deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the
mortgage default over sixty months; and the institution of bankruptcy proceedings.
4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation
conference.
BY THE COURT,
J.
Zucker, Goldberg & Ackerman, LLC
XFP- 173739
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF
DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD
FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH
THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO
REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30)
DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE
DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE
REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE
CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO
COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE.
IN THI COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
NO.: 13-2452 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
„‹.
c:D
TO THE PROTHONOTARY:
Please mark the Complaint in Mortgage Foreclosure filed at the above-captioned
term and number reinstated.
Dated: April
ZUCKER, GOLDBERG & ACKERMAN, LLC
By: Ari
, 2014 Scott A. Diett ric <, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFP-173739/ns
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
cr,
T'N)
am4. n s atfi
CoLISSL1
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
1x at 4:miabef.T i i'E t aiO}HO 5rl,.,=,,..
Jody S Smith
Chief Deputy 2014 NAY _ I AM 10. 2 0
Richard W Stewart
Solicitor -)g . a ®HE. ,- CUMBERLAND COUNTY
PENNSYLVANIA
Ocwen Loan Servicing, LLC
vs. Case Number
Patricia R. Eberts(et al.) 2013-2452
SHERIFF'S RETURN OF SERVICE
05/10/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Patricia R. Eberts, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 600 E. Keller Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant.
05/10/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: William E. Lovett, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 600 E. Keller Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant.
05/10/2013 07:18 PM -Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: William E. Lovett, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 241
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Per current tenant defendant does
not reside at this address.
05/10/2013 07:18 PM -Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Patricia R. Eberts, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 241
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Per current tenant defendant does
not reside at this address.
05/20/2013 08:55 PM-Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: William E. Lovett, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 243
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. The Mechanicsburg Postmaster
confirms that the defendant is not known at the address provided.
05/20/2013 08:55 PM -Deputy Noah Cline, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit:
Patricia R. Eberts at 243 E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011.
NOAH CLINE, DEPUTY
SHERIFF COST: $105.95 SO ANSWERS,
April 28, 2014 RONR ANDERSON, SHERIFF
(c)CourtySuite Sheriff,Teleosoft.Inc.
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
FILED -OFFICE
OF THE PROTHONOTARY
2U 1+ MAY Ili PH 10
CUMBERLAND COUNTY
PENNSYLVANIA
OFF4CE OF T
IFF
Ocwen Loan Servicing, LLC
vs.
Patricia R. Eberts (et al.)
Case Number
2013-2452
SHERIFF'S RETURN OF SERVICE
04/30/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: William E. Lovett, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within
Complaint in Mortgage Foreclosure according to law.
05/06/2014 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County, the within
named Defendant William E. Lovett, not found. Jack Lotwick, Sheriff, Return of Service attached to and
made part of the within record.
SHERIFF COST: $29.99 SO ANSWERS,
May 08, 2014 RONNS' R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Te!eosoft, Inc.
Shelley Ruhl
Real Estate Deputy
Matthew L. Owens
Solicitor
Commonwealth of Pennsylvania
County of Dauphin
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
ff
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
OCWEN LOAN SERVICING, LLC
VS
WILLIAM E. LOVETT A/K/A WILLIAM
LOVETT
Sheriffs Return
No. 2014-T-1430
OTHER COUNTY NO. 2013-2452
I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that
I made diligent search and inquiry for WILLIAM E. LOVETT A/K/A WILLIAM LOVETT the
DEFENDANT named in the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and
that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND,
MAY 6, 2014.
PER SALLY ANN LOPERT, RESIDENT OF ADDRESS 367 SOUTH 2ND STREET, STEELTON, PA
17113, HER SON'S NAME IS WILLIAM G. LOVETT AND IS CURRENTLY IN CUMBERLAND
COUNTY PRISON. SHE DOES NOT KNOW WHO WILLIAM E. LOVETT IS.
UNABLE TO OBTAIN GOOD ADDRESS THROUGH JNET.
Sworn and subscribed to
before me this 7TH day of May, 2014
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Karen M. Hoffman, Notary Public
City of Harrisburg, Dauphin County
My Commission Expires January 8, 2018
So Answers,
Sheriff of Dhin Coun
By
De Sheriff
Deputy: JEFF TEETER
Sheriffs Costs: $43.25 5/2/2014
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC, CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a William
Lovett;
Defendant(s).
NO.: 13-2452 CIVIL
MOTION FOR ALTERNATE SERVICE ON
DEFENDANT PURSUANT TO
Pa.R.C.P. 430
FILED ON BEHALF OF:
Ocwen Loan Servicing, LLC
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire PA I.D. #55650
Kimberly A. Bonner, Esquire- PA I.D. #89705
Joel A. Ackerman, Esquire- PA I.D. #202729
Ashleigh Levy Marin, Esquire -PA I.D. #306799
Ralph M. Salvia, Esquire- PA I.D. #202946
Jaime R. Ackerman, Esquire- PA I.D. #311032
Jana Fridfinnsdottir, Esquire- PA I.D. #315944
Brian Nicholas, Esquire- PA I.D. #317240
Denise Carlon, Esquire- PA I.D. #317226
Roger Fay, Esquire; PA I.D. #315987
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldberg.com
File No.: XFP- 173739/jbenn
8:I {fid cz inrhi4E
—741
C.)
Zucker, Goldberg & Ackerman, LLC
XFP-173739
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
NO.: 13-2452 CIVIL
MOTION FOR ALTERNATE SERVICE PURSUANT TO Pa.R.C.P. 430
AND NOW, comes the Plaintiff, Ocwen Loan Servicing, LLC, by and through its attorneys,
Zucker, Goldberg & Ackerman, LLC, and files the within Motion for Alternate Service pursuant
to Pa.R.C.P. 430 as follows:
1. On or about May 3, 2013, Plaintiff filed its original Complaint in Mortgage
Foreclosure ("Complaint") against the Defendants, Patricia R. Eberts, an adult individual and
William Lovett, an adult individual ("Defendant(s)"), at the above -captioned number and term.
2. Plaintiff has effectuated service upon Defendant, Patricia R. Eberts.
3. Plaintiff directed the Sheriff of Cumberland County to serve Defendant, William
Lovett, with the Complaint in Mortgage Foreclosure at Defendant's last known address being
600 East Keller Street, Mechanicsburg, PA 17055 but service was returned property is vacant. A
true and correct copy of said Return of Service from the Cumberland County Sheriff's Office is
marked Exhibit "A," attached hereto and made a part hereof.
4. A search of the U.S. Postmaster's records for 600 East Keller Street,
Mechanicsburg, PA 17055 replied moved, left no forwarding address. A true and correct copy
of Plaintiff's U.S. Postmaster's Search is marked Exhibit "B," attached hereto and made apart
hereof.
5. Also, Plaintiff attempted service of the defendant by instructing the Sheriff of
Cumberland County to serve Defendant at an alternate address being 243 East Main Street,
Camp Hill, PA 17011, but return of service indicated Defendant not known at address. A copy of
said return is marked Exhibit "A," attached hereto and made a part hereof.
6. A search of the U.S. Postmaster's records for 243 East Main Street, Camp Hill, PA
17011 replied not known at address given. A true and correct copy of Plaintiff's U.S.
Postmaster's Search is marked Exhibit "C," attached hereto and made apart hereof.
7. Also, Plaintiff attempted service of the Defendant by instructing the Sheriff of
Cumberland County to serve Defendant at an alternate address being 241 MAIN ST CAMP HILL,
PA 17011, but return of service indicated not known at address given. A copy of said return is
marked Exhibit "A," attached hereto and made a part hereof.
8. A search of the U.S. Postmaster's records for 241 MAIN ST CAMP HILL, PA 17011
replied not known at address given. A true and correct copy of Plaintiff's U.S. Postmaster's
Search is marked Exhibit "D," attached hereto and made apart hereof.
9. Also, Plaintiff attempted service of the Defendant by instructing the Sheriff of
Dauphin County to serve Defendant at an alternate address being 367 S 2nd Street Steelton, PA
17113-2524, but return of service indicated Defendant does not reside at this address. A copy
of said return is marked Exhibit "E," attached hereto and made a part hereof.
10. A search of the U.S. Postmaster's records for 367 S 2nd Street Steelton, PA
17113-2524 replied no change of address order on file. A true and correct copy of Plaintiff's
U.S. Postmaster's Search is marked Exhibit "F," attached hereto and made apart hereof.
11. An internet person locator search provided no alternative address for Defendant.
12. Plaintiff conducted an investigation to determine the whereabouts of Defendant,
William E. Lovett a/k/a William Lovett, but all sources indicated no alternative address other
than that of the Mortgaged Premises. An affidavit of Plaintiff's counsel regarding the
investigation taken to determine the whereabouts of Defendant is marked Exhibit "G,"
attached hereto and made a part hereof.
13. Plaintiff attempted to obtain concurrence of Defendant William E. Lovett a/k/a
William Lovett with the Motion, but Defendant cannot be located, therefore no concurrence
was obtained.
14. There has been no other motion filed in this case.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court to permit Plaintiff
to serve Defendant, William E. Lovett a/k/a William Lovett, with the Complaint and Notice of
Sale, if necessary, by instructing the Cumberland County Sheriff's Office to POST a copy of same
on the Mortgaged Premises, being 600'East Keller Street, Mechanicsburg PA 17055 and by
mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage
Prepaid to 600 East Keller Street, Mechanicsburg, PA 17055, 243 East Main Street, Camp Hill, PA
17011, 241 MAIN ST CAMP HILL, PA 17011 and to 367 S 2nd Street Steelton, PA 17113-2524,
with said service being valid and complete upon such posting and mailing in accordance with
Pa.R.C.P. 430.
Dated: Vz_\
ZUCKER GOLDBERG & ACKERMAN, LLC
BY:
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh Levy Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Roger Fay, Esquire; PA I.D. #315987
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-173739
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
EXHIBIT "A"
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
�ppot:,
eh{ �Ca Ut�r��lb
OfFICCE C 'i-rE erE�tFF
'LE.D-LJ i I ;
THE PROTHODU r k
2014 MAY - I AM Ii 20
CUMBERLAND COUNTY
PENNSYLVANIA
Ocwen Loan Servicing, LLC Case Number
vs. 2013-2452
Patricia R. Eberts (et al.)
SHERIFF'S RETURN OF SERVICE
05/10/2013 Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Patricia R. Eberts, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 600 E. Keller Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant.
05/10/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: William E. Lovett, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 600 E. Keller Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant.
05/10/2013 07:18 PM - Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search
and inquiry for the within named Defendant to wit: William E. Lovett, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore retums the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 241
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Per current tenant defendant does
not reside at this address.
05/10/2013 07:18 PM - Ronny. R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Patricia R. Eberts, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 241
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Per current tenant defendant does
not reside at this address.
05/20/2013 08:55 PM - Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search
and inquiry for the within named Defendant to wit: William E. Lovett, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 243
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. The Mechanicsburg Postmaster
confirms that the defendant is not known at the address provided.
05/20/2013 08:55 PM - Deputy Noah Cline, being duly swom according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit:
Patricia R. Eberts at 243 E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011.
NOAH CLINE, DEPUTY
SHERIFF COST: $105.95 SO ANSWERS,
April 28, 2014
(c) CountySuite Sheriff, Teleosoft, Inc.
RONNY ANDERSON, SHERIFF
EXHIBIT "B"
June 11, 2014
Attn: PA Service Team
Postmaster of Mechanicsburg, PA 17055
XFP-173739
C_173739PD021X1_C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: William E. Lovett a/k/a William Lovett
Address: 600 East Keller Street,Mechanicsburg, PA 17055
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d}(5)(ii). There is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting pro se must cite statute): Not Applicable.
3. The names of all known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricia R. Eberts, et al.
4. The court In which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or b must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity in which this individual is to be served (e.g., defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
Isl Scoff Vrarerieli
Signature
SCOTT A. DIETTERICK
Printed Name
No Change of Address order on file.
Moved, left no forwarding address.
No such address.
c/o Zucker Goldberg & Ackerman, ILC
200 Sheffield Street, Suite 101
Address:
Mountainside, NJ 07092
City, State, ZIP Code
POST OFFICE USE ONLY
NEW ADDRESS OR BOXHOLDER'S NAME AND
STREET ADDRESS
EXHIBIT
June 11, 2014
Attn: PA Service Team
Postmaster of Camp Hill, PA 17011
XFP-173739
C_173739PD022X1_C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:.
Name: William E. Lovett a/k/a William Lovett
Address: 243 East Main Street, Camp Hill, PA 17011
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(5}(ii). There is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting pro se must cite statute): Not Applicable.
3. The names of all known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricia R. Eberts, et al.
4. The court in which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or b must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity in which this individual is to be served (e.g., defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
is/Sear/it Diettoted
c/o Zucker Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Signature Address:
SCOTT A. DIETTERICK Mountainside, Ni 07092
Printed Name
No Change of Address order on file.
Moved, left no forwarding address.
No such address.
r F. k,A'w'P A� ctaibec.,5
City, State, ZIP Code
POST OFFICE USE ONLY
NEW ADDRESS OR BOXHOLDER'S NAME AND
STREET ADDRESS
EXHIBIT"D"
June 11, 2014
Attn: PA Service Team
Postmaster of PA 17011
XFP-173739
C_173739PD023X1_C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: William E. Lovett a/k/a William Lovett
Address: 241 MAIN ST CAMP HILL, PA 17011
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d}(5)(ii). There is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting pro se must cite statute): Not Applicable.
3. The names of all known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricia R. Eberts, et al.
4. The court in which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or b must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity in which this individual is to be served (e.g., defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
Scot Dimpled
ed
c/o Zucker Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Signature Address:
SCOTT A. DIETTERICK Mountainside, NJ 07092
Printed Name City, State, ZIP Code
No Change of Address order on file.
Moved, left no forwarding address.
No such address.
POST OFFICE USE ONLY
NEW ADDRESS OR BOXHOLDER'S NAME AND
STREET ADDRESS
itt Of- ILo1-(9ttJ ) ¢ "d 4 ess so
` / POST MARIG '
1.}i �'` 1` )s)
/,,,
EXHIBIT "E
Shelley Ruhl
Real Estale Deputy
Matthew L. Owens
Solicitor
Commonwealth of Pennsylvania
County of Dauphin
lite e of :ale t 1?-eri, .
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
ti 51 '69
OCWEN LOAN SERVICING, LLC
VS
WILLIAM E. LOVETT A/K/A WILLIAM
LOVETT
Sheriffs Return
No. 2014-T-1430
OTHER COUNTY NO. 2013-2452
I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that
I made diligent search and inquiry for WILLIAM E. LOVETT A/K/A WILLIAM LOVETT the
DEFENDANT named in the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and
that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND,
MAY 6, 2014.
PER SALLY ANN LOPERT, RESIDENT OF ADDRESS 367 SOUTH 2ND STREET, S 1'hELTON, PA
17113, HER SON'S NAME IS WILLIAM G. LOVETT AND IS CURRENTLY IN CUMBERLAND
COUNTY PRISON. SHE DOES NOT KNOW WHO WILLIAM E. LOVETT IS.
UNABLE TO OBTAIN GOOD ADDRESS THROUGH JNET.
Sworn and subscribed to
before me this 7TH day of May, 2014
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Karen M. Hoffman, Notary Public
City of Harrisburg, Dauphin County
My Commission Expires January 8, 2018
So Answers,nsA B
Sheriff of D hin Count
By
Dei > y 'heriff
Deputy: JEFF TEETER
Sheriffs Costs: $43.25 5/2/2014
Ronny RAnderson
Sheriff
Jody S Smith
Chief Depu
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND AND COK 8NTY
01, al CORI
Ocwea Loan Servicing, LLC
vs.
PatriciaR. Eberts (et al.)
Case Number
2013-2452
SHERIFF'S RETURN OF SERVICE
04/30X2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: William E. Lovott, but was unable to Iocate the Defendant in the
Sheriffs bailiwick. The Sheriff thnefodeputizes thSheriff of Dauphiri, Pennsylvania to serve the within
Complaint iri Mortgage Foreclosure according to law.
05/06/2014 The requested Complaint in Mortgage Foreclosure retumed by the Sheriff of Dauphin County, the within
named Deferidant William E. Lovett, not found. Jack Lotwick, Sheriff, Return of Service attached to and
made part of the within record.
SHERIFF COST: $29.99
SO ANSWERS,
May 08, 2014
�DN R ANDERSON, SHERIFF
fl273
-�~'
EXHIBIT "F"
Zucker, Goldberg & Ackerman, LLC
«Field2»-«Fieldl»
June 11, 2014
Attn: PA Service Team
Postmaster of Steelton, PA 17113-2524
XFP-173739
C 173739PD024X1 C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: William E. Lovett a/k/a William Lovett
Address: 367 S 2nd Street Steelton, PA 17113-2524
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(5}(ii). There is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting pro se must cite statute): Not Applicable.
3. The names of all known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricia R. Eberts, et al.
4. The court in which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or b must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity In which this individual is to be served (e.g., defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
/S/ Scar Dtctaarte4
c/o Zucker Goldberg & Ackerman, LLC.
200 Sheffield. Street, Suite 101
Signature Address:
SCOTT A. DIETTERICK Mountainside, NJ 07092
Printed Name City, State, ZIP Code
No Change of Address order on file.
Moved, left no forwarding address.
No such address.
POST OFFICE USE ONLY
NEW ADDRESS OR BOXHOLDER'S NAME AND
STREET ADDRESS
POST MARK
EXHIBIT "G"
Zucker, Goldberg & Ackerman, LLC
«Field2»-«Fieldl»
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF DAUPHIN
NO.: 13-2452 CIVIL
AFFIDAVIT
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Ralph M. Salvia, Esquire, attorney for and authorized
representative of Plaintiff, who being duly sworn according to law, deposes and says that
Plaintiff, or counsel for Plaintiff, conducted an investigation to determine the whereabouts of
Defendant, which included, but was not limited to searches of the following records:
(X) Records of the U.S. Postmaster with results of same attached to the foregoing
Motion.
(X) Internet Person Locator Records
(X) Credit Report Agency.
(X) Telephone Directory
(X) Records of the County Recorder of Deeds and Prothonotary
Finally, Affidavit deposes and says that if Defendant is not located at the address
uncovered by this investigation, the whereabouts of Defendant is unknown to Plaintiff.
Dated:
By:
Sworn to and subscribed before me this
ld10lday of (ijy ,2014.
YI?61Le24;x2. yl&
Noltary Public
My Commission Expires:
ZUCKE'. O.LDBER
& ACKERMAN, LLC
•�'
Ral.h M. Salvia, Esq` A. ID#202946
Atty File No.: XFP-173739
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
Email: Office@zuckergoldberg.com
(908) 233-8500; (908) 233-1390 FAX
COM .ONWEALTH OF PENNSYLVANIA
'NOTARIAL SEAL.
KATHERINE N MILLER
Notary Public
• UPPER ALIEN.TWR. CUMBERLAND COUNTY
My Commission•Expires May 7.2017
Person Search
Person Search Results
Search Terms Used - SSN: 195-6411111.0
All
Full Name
SSN
Address
Phone
Page 1 of 7
Records: 1 to 17 of 17
Next Steps
1.
WILLIAM LOVETT 195-64.1110 600 E KELLER ST
EBERTS LexID: 1553347303 MECHANICSBURG PA 17055-
WILLAIM G LOVETT 3425
WILLIAM LOVETT Oct 2008 - Mar 2014
WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM GENE
LOVETT
WILLIAM PORTER
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM LOVETT
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-5)
Setup Alert
717-795-6240 - EDT
Oct 08 - Jan 13
Possible non DA
WILLIAM LOVETT
We Also Found:
❑ Property Records
❑ Email Address
2. WILLIAM G LOVETT
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
Setup Alert
195.64 N PIKE ST
LexID: 1553347303 BARRACKVILLE WV 26559
Aug 2013
3, WILLIAM LOVETT
WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM PORTER
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
WILLIAM G
PORTERLOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-4)
13 Setup Alert
195-64 _ 367 S 2ND ST
LexID: 1553347303 STEELTON PA 17113-2524
Jan 1995 -Aug 2013
761-0784
Oct 13 - Apr 14
https://secure.accurint.com/app/bps/misc
4/23/2014
Person Search
Page 2 of 7
4, WILLIAM E LOVETT
WILLIAM PORTER
LOVETT
WILLIAM G PORTER
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-2)
13 Setup Alert
195-6411111111 11 RICHLAND LN APT 102
LexID: 1553347303 CAMP HILL PA 17011-2498
Jul 2013
5.
WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM PORTER
LOVETT
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-2)
1' Setup Alert
195-64L PO BOX 461
LexID: 1553347303 BARRACKVILLE WV 26559-0461
Oct 2012 - Mar 2013
6. WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
Setup Alert
195-64_f 243 E MAIN ST APT
LexID: 1553347303 CAMP HILL PA 17011-6315
Jun 2012 - Oct 2012
7, WILLIAM E LOVETT 198.84.1.1111 224 REDWOOD ST
WILLIAM G LOVETT LexID: 1553347303 HARRISBURG PA 171094713
WILLIAM PORTER Sep 2006 - Apr 2009
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM LOVETT
PORTER
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
**View Sources (-4)
k Setup Alert
8. WILLIAM E LOVETT
WILLIAM G LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
195-64600 241 E MAIN ST FL 1
LexID: 1553347303 CAMP HILL PA 17011-6315
Sep 2008
https://secure.accurint.com/app/bps/misc
4/23/2014
Person Search
*View Sources (-2)
40 Setup Alert
Page 3 of 7
9. WILLIAM E LOVETT 195-644gme 29 SUSSEX RD 761-0784
WILLIAM G LOVETT LexID: 1553347303 CAMP HILL PA 17011-6649
WILLIAM GENE Feb 1989 - Aug 2008
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM LOVETT
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
WILLIAM G
PORTERLOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-4)
c
Setup Alert
10. WILLIAM E LOVETT 195-64411111111 1280 N FRONTAGE RD W UNIT 761-0784
WILLIAM G LOVETT LexID: 1553347303 M17
LOVETT WILLIAM VAIL CO 81657-4034
PORTER Apr 1988 - May 2008
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM PORTER
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-3)
la Setup Alert
11.
WILLIAM LOVETT
WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM GENE
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-3)
c
Setup Alert
195-64engi PO BOX 4906
LexID: 1553347303 VAIL CO 816584906
Nov 1999 - Jul 2000
12. LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
Setup Alert
195-64�
LexID :1553
10 YORK MECHANICSBURGPA 761-0784
7303 MECHANICSBURG PA 17055
Nov 1999
https://secure.accurint.com/app/bps/misc
4/23/2014
c
Person Search
Page 4 of 7
13. WILLIAM E LOVETT
WILLIAM G LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM LOVETT
PORTER
WILLIAM G PORTER-
LOVETT
WILLIAM L PORTER-
LOVETT
WILLIAM G
PORTERLOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-3)
Setup Alert
195-64600.11 6625 CARLISLE PIKE
LexID: 1553347303 MECHANICSBURG PA 17050-
1707
Jul 1993 -Jan 1999
14. WILLIAM G PORTER
WILLIAM GENE
PORTER
DOB: 12/1969
Age: 44
Gender: Male
*View Sources (-1)
7l Setup Alert
195-640fra 6625 CARLISLE PI
LexID: 1553347303 BERRYSBURG PA 17005
May 1995
0
761-0784
15. WILLIAM G PORTER
WILLIAM GENE
PORTER
DOB: 12/1969
Age: 44
Gender: Male
*View Sources (-1)
Setup Alert
195-64411111.1 10 YORK CIR
LexID: 1553347303 MECHANICSBURG PA 17050-
2751
Apr 1988
761-0784
16. WILLIAM G LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
ti Setup Alert
195-6 600 E KELLER STREEET
LexID: 53347303 MECHANICSBURG PA 17055
17. JENNIFER STOUT
Gender: Female
*View Sources (-1)
Setup Alert
195-641.... 500 BLUE RIDGE RD
LexID: 2447029759 BLACK MOUNTAIN NC 28711-
8724
Dec 2013 - Mar 2014
w1 Probable current address
828-357-5216 -
EDT
Mar 13 -Apr 14
V' Active Phone
STOUT JENNIFER
828-447-5720 -
EDT
Sep 10 - Jan 11
Possible Cell
Phone
JENNIFER STOUT
Records: 1 to 17 of 17
Your DPPA Permissible Use: Civil, Criminal, Administrative or Arbitral Proceedings
Your GLBA Permissible Use: Legal Compliance
https://secure.accurint.com/app/bps/misc
4/23/2014
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
NO.: 13-2452 CIVIL
ORDER OF COURT
AND NOW, this 28 day of 4 , 2014, upon consideration of
Plaintiff's Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that
Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on
Defendant William E. Lovett a/k/a William Lovett, by instructing the Sheriff of Cumberland
County to POST a copy of same on the Mortgaged Premises, being 600 East Keller Street,
Mechanicsburg PA 17055, and by mailing a copy, via Certified Mail, no signature required and
First Class U.S. Mail, Postage Prepaid to 600 East Keller Street, Mechanicsburg, PA 17055, 243
East Main Street, Camp Hill, PA 17011, 241 MAIN ST CAMP HILL, PA 17011 and to 367 S 2nd
Street Steelton, PA 17113-2524, with said service being valid and complete upon such posting
and mailing in accordance with Pa.R.C.P. 430.
.
Vol aft Y
Zucker, Goldberg & Ackerman, LLC
XFP-173739
ti
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
NO.: 13-2452 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
`::
G mow^:
t�T► Tie
-o r1
C) oQ
r
Qf 3 -n
T7C.)7-1",
- ,
TO THE PROTHONOTARY:
Please mark the Complaint in Mortgage Foreclosure filed at the above -captioned term and
number reinstated.
Dated: tultq
By:
OL l) ERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Roger Fay, Esquire; PA I.D. #315987
Attorneys for Plaintiff
XFP-173739/jfa/MSS
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
� 1yiO
%cA SR
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson THE
J_Or f iC
OFI Hi,_ Pf OTHONO FAO.
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
`FFI(;Ci or THE F,:NERIFF
21014 liUC 19 MI 10: 20
CUMBERLAND COUNTY
PENNSYLVANIA
Ocwen Loan Servicing, LLC
vs.
Patricia R. Eberts (et al.)
Case Number
2013-2452
SHERIFF'S RETURN OF SERVICE
08/12/2014 04:27 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 upon the
within named Defendant, to wit: William E. Lovett, pursuant to Order of Court by "Posting" the premises
located at 600 E. Keller Street, Mechanicsburg Borough, Mechanicsburg, PA 17055 with a true and
correct copy according to law.
SHERIFF COST: $45.30
August 14, 2014
(c) CountySuite Sheriff, Teleoseft, Inc.
DEN S FRY, DEPUTY
SO ANSWERS,
RONR ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC ISSUE NO.: 13-2452 CIVIL
Plaintiff
TYPE OF PLEADING —9
VS.
Patricia R. Eberts;William E. Lovett a/k/a William AFFIDAVIT OF SERVICE OF
Lovett COMPLAINT PURSUANT TO
Pa.R.C.P.,430 SPECIAL ORDER
Defendants OF COURT r�
CODE:
FILED ON BEHALF OF:
Ocwen Loan Servicing, LLC
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER,GOLDBERG &ACKERMAN, LLC
Scott A. Dietterick, Esquire PA I.D.#55650
Kimberly A. Bonner, Esquire- PA I.D.#89705
Joel A.Ackerman, Esquire-PA I.D.#202729
Ashleigh Levy Marin, Esquire-PA I.D.#306799
Ralph M.Salvia, Esquire-PA I.D.#202946
Jaime R.Ackerman, Esquire- PA I.D.#311032
Jana Fridfinnsdottir, Esquire- PA I.D.#315944
Brian Nicholas, Esquire- PA I.D.#317240
Denise Carlon, Esquire- PA I.D.#317226
Roger Fay, Esquire; PA I.D.#315987
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908)233-1390 FAX
office@zuckergoldberg.com
File No.:XFP-173739/dlaw
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff
vs. NO.: 13-2452 CIVIL
Patricia R. Eberts;William E. Lovett a/k/a
William Lovett
Defendants
AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE
FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT
I, Ste,- A . I/?OTM Q Esquire,attorney for Plaintiff, Ocwen Loan Servicing, LLC, being
duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's
Complaint in Mortgage Foreclosure on Defendant,William E. Lovett a/k/a William Lovett, as follows:
1. On or about July 28, 2014,an Order of Court was entered granting Plaintiffs Motion for
Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct
copy of said Order is marked Exhibit"A",attached hereto and made a part hereof.
2. Pursuant to said Order,on or about August 13, 2014,Zucker, Goldberg&Ackerman,
LLC,the counsel for Plaintiff served Defendant,William E. Lovett a/k/a William Lovett with a true and
correct copy of Plaintiff's Complaint in Mortgage Foreclosure,via First Class U.S. Mail and Certified Mail
Return Receipt Requested to the defendant's last known address being 600 East Keller Street,
Mechanicsburg, PA 17055,243 East Main Street, Camp Hill, PA 17011, 241 Main Street,Camp Hill, PA
17011 and to 367 S 2nd Street Steelton, PA 17113-2524. A true and correct copy of said returned
receipt and certificate of mailing are marked Exhibit"B",attached hereto and made a part hereof.
3. Pursuant to said Order, on or about August 12,2014,the Sheriff of Cumberland County
posted the property subject to the Mortgage, being 600 East Keller Street, Mechanicsburg, PA 17055
with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure. A true and correct copy of
the Service Form from the Sheriff of Cumberland County is marked Exhibit"C, attached hereto and
made a part hereof.
ZUCKER, A , LLC
By:
Scott A. Diet erick, Esquire; PA I.D.#55650
Kimberly A. Bonner, Esquire; PA I.D.#89705
Joel A.Ackerman, Esquire; PA I.D.#202729
Ashleigh Levy Marin, Esquire; PA I.D.#306799
Ralph M.Salvia, Esquire; PA I.D.#202946
Jaime R.Ackerman, Esquire; PA I.D.#311032
Jana Fridfinnsdottir, Esquire; PA I.D.#315944
Brian Nicholas, Esquire; PA I.D.#317240
Denise Carlon, Esquire; PA I.D.#317226
Roger Fay, Esquire; PA I.D.#315987
Atty File No.:XFP-173739
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
Email: Office@zuckergoldberg.com
(908)233-8500; (908)233-1390 FAX
Dated: October q ,2014
Sworn to and subscribed before
me this day of October, 201
UMVl C r PAUL C. NADRATOWSKI
Notary Public Notary Public of New Jersey
ID# 2407850
MY COMMISSION EXPIRES: My Commission Expires 4/27/2016
Exhibit A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs. NO.:13-2452 CIVIL
`oz
Patricia R. Eberts William E. Lovett a/k/a :zm - f,
William Lovett; tet— r ,
Defendants. rT
ORDER OF COURT '
ti
AND NOW,this e;�ay of , 2014, upon consideration of
Plaintiff's Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that
Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on
Defendant William E. Lovett a/k/a William Lovett, by instructing the Sheriff of Cumberland
County to POST a copy of same on the Mortgaged Premises, being 600 East Keller Street,
Mechanicsburg PA 17055, and by mailing a copy, via Certified Mail, no signature required and
First Class U.S. Mail, Postage Prepaid to 600 East Kehler Street, Mechanicsburg, PA 17055, 243
East Main Street, Camp Hill, PA 17011, 241 MAIN ST CAMP HILL, PA 17011 and to 367 S 2nd
Street Steelton, PA 17113-2524, with said service being valid and complete upon such posting
and mailing in accordance with Pa.R.C.P. 430.
8Y THE COURT:
J.
Zucker,Goldberg&Ackerman,LLC
XFP-173739
Exhibit B
-A s-POSTAL SERVICE CERTIFICATE OF MAILING
�cnrrn t7nhtA1 �, �r'T
MAIL,ODES NOT
MA � 'A ZUCKER GOLl78ERG&A ,• `
PR( ACKERMAN � �.. cc
,.
Gabriella Marchi, Legal Assistant
Ilk
R 240 Gettysburg Pike w, ;r "
Mechanicsburg,PA 17055
M postage $
Certified Fos
a CI Return Reuroipt F€triPostmark
One piece of ordinary mail addressed toe c,'n_ O (Endo aett�ert Requini) J Rem
( C) Restricted Delivery t=ee
cc p (E:tdo:wmert Required)
Witham E.Lovett RITC°a William Lovett � s
Total Postage�Fee $
167 S.2nd Street air
Steelton PA 17113-2524 ru
m c3 William E,Lovett a!k!a William Lovett -------
367� t` 367 S.2nd Street .................
PS Form 3817, Mar. 1989 ` Steelton, PA 17113-2524
ts,s.p STAL SERVICE CERTIFtCA7E F MAlLin�t3
PRO In USED FOR DUMESTiC AN t}INTERNATioNAL MAIL,DOES NOT " � �,. RECEIPT
PRflti<lktnc sna ra;�*unwa�nr. �'� ,+�"a`
ZUCKER GOLDBERG&ACKERMAN .. •
Recce .- Provided)
Gabriella Marchi, Legal Assistant ru
240 Gettysburg Pike71
Mechanicsburg,PA 11.1 wl
7055 7
'— r hE rrt Postage
I ' 0
CarfflOd Fee
One piece of ord(nary mail addressed to: Posmak
i C3 RetLrnReceiptF Meru
C3 (Endorsement Regeired)
M Restricted Delivery Fee
_(Endorso nt Required)
William E.1-o1-e:lt at'L'a William Loi=ett � S :l r-1
243 East Main Street
� n,► Tsuei Postage a�Fa� .
i anteiit,PA 17011
_.__.- A9 ru
f C3 William E.Lovett a/k/a William Lovett-------- -�
` r` a
PS Farm 3$17, Mar, 198$ 243 East Main Street _.._....... __
Z Camp Hits,PA 17011
y
u s i�DSTAL SrRvicFRT.#FICATE UP MAf.iNG_ ,;, � ,.
Ay BE USED FDR pOMESTtC AND INTERNA rIONAL MAIL.DOES NOT ni
PRO\ ZUCKER GOLDBERG&ACKERMAN
net Gabriella Marelli,Legal Assistant Q
1,mt
240 Gettysburg Pikem
Postage $
$
M
T Mechanicsburg,PA 17055 Codified Fee
C3
(erb# mrteeptFe
Here
nagtd)
Restricted Doivery fee
one piece at ordinary mail addressed o: Pastmar9c
(Endorsement Required)
rr €
—^— nj Total Postage&Fees
nj
William E,.Lovett aJi to William Lovett ��^�
600 East Keller Street �
' � William E. Lovett a/k/a William Cavett
Mochanicsburg,PA 17055 r-3 �� 600 East Keller Street
Mechanicsburg,PA 17055
PS Form 3817, Mar. 1989 ,.
a
U.S.POSTAL SERVICE CERTIFICATE OF MAILING �- {� � �> •
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL.DOES ESOT
PROVIDE FOR INSURANCE—POSTMASTER 7j
V
R' ZUCKER GOLDBERG&ACKERMAN
Gabriella Marchi, Legal Assistant z �
240 Gettysburg Pike
s
M Postage s f mI ~
z
Mechanicsburg' PA 17055 I '` C3
a
Codified Fee
r s
' Iftit
Return Receipt Fee alls
One piece of ordinary mail addressed to: - (Endorsement Required)
Restricted Delivery Fee
e (Endorsement Re€tukred)
William L:.Lci-vett a/k/a William Lovett U� � Total Postage&Fees
241 Main Street
Camp hill,FA 17€1 i � � �
r Wiliam E. Lovett a/k/a William Lovett �:., _.».;....,
or 241 Main Street
PS Form 3817, Mar. 1 689 6;r Camp Hill,PA 17011
i E#
Exhibit C
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Ocwen Loan Servicing, LLC Case Number
vs. 2013-2452
Patricia R. Eberts(et al.)
SHERIFF'S RETURN OF SERVICE
08/1212014 04;27 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 upon the
within named Defendant,to wit:William E. Lovett,pursuant to Order of Court by"Posting"the premises
located at 600 E, Keller Street, Mechanicsburg Borough, Mechanicsburg, PA 17055 with a true and
correct copy according to law.
DEN S FRY, DEPUTY
SHERIFF COST: $45.30 SO ANSWERS,
August 14,2014 RON R ANDERSON, SHERIFF
L S;Ya 3✓L, -.,0.. i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
NO.: 13-2452 CIVIL
SECOND MOTION FOR ALTERNATE SERVICE PURSUANT TO Pa.R.C.P. 430
AND NOW, comes the Plaintiff, Ocwen Loan Servicing, LLC, by and through its attorneys,
Zucker, Goldberg & Ackerman, LLC, and files the within Motion for Alternate Service pursuant to
Pa.R.C.P. 430 as follows:
1. On or about May 3, 2013, Plaintiff filed its original Complaint in Mortgage
Foreclosure ("Complaint") against the Defendants, Patricia R. Eberts, an adult individual and
William Lovett, an adult individual ("Defendant(s)"), at the above -captioned number and term.
2. Plaintiff has effectuated personal service upon Defendant, Patricia R. Eberts.
3. On July 23, 2014, Plaintiff filed Motion for Alternative Service upon William
Lovett. Plaintiff's Motion was granted on July 28, 2014. A true and correct copy of the Order is
attached hereto as Exhibit "A."
4. The Order granted is not valid due to being entered during Defendant's
Bankruptcy filing. However, said Bankruptcy has since been discharged and Plaintiff
respectfully requests this Court grant the instant Motion for Alternative Service.
5. Plaintiff directed the Sheriff of Cumberland County to serve Defendant, William
Lovett, with the Complaint in Mortgage Foreclosure at Defendant's last known address being 600
East Keller Street, Mechanicsburg, PA 17055 but service was returned property is vacant. A true
and correct copy of said Return of Service from the Cumberland County Sheriff's Office is marked
Exhibit "B," attached hereto and made a part hereof.
6. A search of the U.S. Postmaster's records for 600 East Keller Street,
Mechanicsburg, PA 17055 replied moved, left no forwarding address. A true and correct copy
of Plaintiff's U.S. Postmaster's Search is marked Exhibit "C," attached hereto and made apart
hereof.
7. Also, Plaintiff attempted service of the Defendant by instructing the Sheriff of
Cumberland County to serve Defendant at an alternate address being 243 East Main Street, Camp
Hill, PA 17011, but return of service indicated Defendant not known at address. A copy of said
return is marked Exhibit "B," attached hereto and made a part hereof.
8. A search of the U.S. Postmaster's records for 243 East Main Street, Camp Hill, PA
17011 replied not known at address given. A true and correct copy of Plaintiff's U.S. Postmaster's
Search is marked Exhibit "D," attached hereto and made apart hereof.
9. Also, Plaintiff attempted service of the Defendant by instructing the Sheriff of
Cumberland County to serve Defendant at an alternate address being 241 MAIN ST CAMP HILL,
PA 17011 , but return of service indicated not known at address given. A copy of said return is
marked Exhibit "B," attached hereto and made a part hereof.
10. A search of the U.S. Postmaster's records for 241 MAIN ST CAMP HILL, PA 17011
replied not known at address given. A true and correct copy of Plaintiff's U.S. Postmaster's
Search is marked Exhibit "E," attached hereto and made apart hereof.
11. Also, Plaintiff attempted service of the Defendant by instructing the Sheriff of
Dauphin County to serve Defendant at an alternate address being 367 S 2nd Street Steelton, PA
17113-2524, but return of service indicated Defendant does not reside at this address. A copy of
said return is marked Exhibit "F," attached hereto and made a part hereof.
12. A search of the U.S. Postmaster's records for 367 S 2nd Street Steelton, PA 17113-
2524 replied no change of address order on file. A true and correct copy of Plaintiff's U.S.
Postmaster's Search is marked Exhibit "G," attached hereto and made apart hereof.
13. An internet person locator search provided no alternative address for Defendant.
14. Plaintiff conducted an investigation to determine the whereabouts of Defendant,
William E. Lovett a/k/a William Lovett, but all sources indicated no alternative address other than
that of the Mortgaged Premises. An affidavit of Plaintiff's counsel regarding the investigation
taken to determine the whereabouts of Defendant is marked Exhibit "H," attached hereto and
made a part hereof.
15. Plaintiff attempted to obtain concurrence of Defendant William E. Lovett a/k/a
William Lovett with the Motion, but Defendant cannot be located, therefore no concurrence was
obtained.
16. There has been no other motion filed in this case.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court to permit Plaintiff
to serve Defendant, William E. Lovett a/k/a William Lovett, with the Complaint and Notice of
Sale, if necessary, by instructing the Cumberland County Sheriff's Office to POST a copy of same
on the Mortgaged Premises, being 600 East Keller Street, Mechanicsburg PA 17055 and by
mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid
to 600 East Keller Street, Mechanicsburg, PA 17055, 243 East Main Street, Camp Hill, PA 17011,
241 MAIN ST CAMP HILL, PA 17011 and to 367 S 2nd Street Steelton, PA 17113-2524, with said
service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 430.
Dated: hi y./I
ZUCKER CKERMAN, LLC
BY:
Scot A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh Levy Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Roger Fay, Esquire; PA I.D. #315987
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-173739
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
EXHIEIIT "A"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Omen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs..
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
AND NOW, this cay of
NO.: 13-2452 CIVIL
ORDER OF COURT
, 2014, upon consideration of
Plaintiff's Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that
Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on
Defendant William E. Lovett a/k/a William Lovett, by instructing the Sheriff of Cumberland
County to POST a copy of same on the Mortgaged Premises, being 600 East Keller Street,
Mechanicsburg PA 17055, and by mailing a copy, via Certified Mail, no signature required and
First Class U.S. Mail, Postage Prepaid to 600 East Keller Street, Mechanicsburg, PA 17055, 243
East Main Street, Camp Hill, PA 17011, 241 MAIN ST CAMP HILL, PA 17011 and to 367 S 2nd
Street Steelton, PA 17113-2524, with said service being valid and complete upon such posting
and mailing in accordance with Pa.R.C.P. 430.
BY THE COURT:
Li • �..✓
✓ 1.
Zucker, Goldberg & Ackerman, LLC
XFP-173739
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
i°9.��r ct CuraGPr,
�7d
Fes;kn
OFFICE Cr 'l -E ; hEPJFF
THE P;ROTH0UO7 :
1014 MAY—I AM ICP 20
CUMBERLAND COUNTY
PENNSYLVANIA
Ocwen Loan Servicing, LLC
vs.Case Number
Patricia R. Eberts (et al.) 2013-2452
SHERIFF'S RETURN OF SERVICE
05/10/2013 Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Patricia R. Eberts, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 600 E. Keller Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence Is vacant.
05/10/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: William E. Lovett, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore retums the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 600 E. Keller Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vacant.
05/10/2013 07:18 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search
and inquiry for the within named Defendant to wit: William E. Lovett, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore retums the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 241
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Per current tenant defendant does
not reside at this address.
05/10/2013 07:18 PM - Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Patricia R. Eberts, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore retums the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 241
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. Per current tenant defendant does
not reside at this address.
05/20/2013 08:55 PM - Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search
and inquiry for the within named Defendant to wit: William E. Lovett, but was unable to locate the
Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 243
E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011. The Mechanicsburg Postmaster
confirms that the defendant is not known at the address provided.
05/20/2013 08:55 PM - Deputy Noah Cline, being duly swom according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally" handing a true copy to a person representing themselves to be the Defendant, to wit:
Patricia R. Eberts at 243 E. Main Street, Shiremanstown Borough, Shiremanstown, PA 17011.
SHERIFF COST: $105.95
April 28, 2014
(c) Countysulte Sheriff, Teleosoft, Inc.
NOAH CLINE, DEPUTY
SO ANSWERS,
RONRR ANDERSON, SHERIFF
June 11, 2014
Attn: PA Service Team
Postmaster of Mechanicsburg, PA 17055
XFP-173739
C_173739PD021X1 C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: William E. Lovettajk/a William Lovett
Address: 600 East Keller Street,Mechanicsburg, PA 17055
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(S}(ii). There Is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting pro se must cite statute): Not Applicable.
3. The names of all known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricia R. Eberts, et al.
4. The court in which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or b must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity in which this individual is to be served (e.g., defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN ANO USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
/s/ Sear if Die/toad
Signature
SCOTT A. DIETTERICK
Printed Name
No Change of Address order on file.
Moved, left no forwarding address.
No such address.
c/o Zucker Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Address:
Mountainside, NJ 07092
City, State, ZIP Code
POST OFFICE USE ONLY
NEW ADDRESS OR BOXHOLDER'S NAME AND
STREET ADDRESS
EXHIBIT "D" .
June 11, 2014
Attn: PA Service Team
Postmaster of Camp Hill, PA 17011
XFP-173739
C_173739PD022X1_C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new addressor the name and street address (if a boxholder) for the following:
Name: William E. Lovett a/kja William Lovett
Address: 243 East Main Street, Camp Hill, PA 17011
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(5)(ii). There is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting pro se must cite statute): Not Applicable.
3. The names of all known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricla R. Eberts, et al.
4. The court in which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or h must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity in which this individual is to be served (e.g., defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER. THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
/s/ Seat ,+. VGA
Signature
SCOTT A. DIETTERICK
Printed Name
No Change of Address order on file.
Moved, left no forwarding address.
No such address.
nab ,nd 't,1- 4 i (y
c/o Zucker Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Address:
Mountainside, NJ 07092
City, State, ZIP Code
POST OFFICE USE ONLY
NEW ADDRESS OR BOXHOLDER'S NAME AND
STREET ADDRESS
('POSTMARK, '',�
It�f.
• s's.JYd "i li b
June 11, 2014
Attn: PA Service Team
Postmaster of PA 17011
XFP-173739
C_173739PD023X1 C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: William E. Lovett a/k/a William Lovett
Address: 241 MAIN ST CAMP HILL, PA 17011
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d}(5)(ii). There is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting pro se must cite statute): Not Applicable.
3. The names of all known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricia R. Eberts, et al.
4. The court in which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or b must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity In which this individual is to be served (e.g, defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
Salt /1. Vtarettei
c/o Zucker Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Signature Address:
SCOTT A. DIETTERICK Mountainside, Ni 07092
Printed Name
City, State, ZIP Code
POST OFFICE USE ONLY
No Change of Address order on file. NEW ADDRESS OR BOXHOLDER'S NAME AND
Moved, left no forwarding address. STREET ADDRESS
No such address.
v' itAin v� L+ c" Lif1CS.I
POST MARK
t I
Zucker, Goldberg & Ackerman, LLC
«Field2»-«Fieldl»
iITf tF L Sheriff
,
Shelley Ruhl
Real Estate Deputy
Matthew L. Owens
Solicitor
Commonwealth of Pennsylvania
County of Dauphin
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
67-69
OCWEN LOAN SERVICING, LLC
VS
WILLIAM E. LOVETT A/K/A WILLIAM
LOVETT
Sheriffs Return
No. 2014-T-1430
OTHER COUNTY NO. 2013-2452
#7/
I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that
I made diligent search and inquiry for WILLIAM E. LOVETT A/KJA WILLIAM LOVETT the
DEFENDANT named in the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and
that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND,
MAY 6, 2014.
PER. SALLY ANN LOPERT, RESIDENT OF ADDRESS 367 SOUTH 2ND STREET, STEELTON, PA
17113, HER SON'S NAME IS WILLIAM G. LOVETT AND IS CURRENTLY IN CUMBERLAND
COUNTY PRISON. SHE DOES NOT KNOW WHO WILLIAM E. LOVETT IS.
UNABLE TO OBTAIN GOOD ADDRESS THROUGH JNET.
Sworn and subscribed to
before me this 7TH day of May, 2014
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Karen M. Hoffman, Notary Public
City of Harrisburg. Dauphin County
My Commission Expires January 8. 2018
So Answers,
X.3/.71`(1._ ,
Sheriff of D hin Coun
By
Delay'heriff
Deputy: JEFF TEETER
Sheriffs Costs: $43.25 5/2/2014
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ocwen Loan Servicing, LLC Case Number
vs.
Patricia R. Eberts (et al.) 2013-2452
SHERIFF'S RETURN OF SERVICE
04/30/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: William E. Lovett, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within
Complaint in Mortgage Foreclosure according to law,
05/06/2014 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County, the within
named Defendant William E. Lovett, not found. Jack Lotwick, Sheriff, Return of Service attached to and
made part of the within record.
SHERIFF COST: $29.99
May 08, 2014
SO ANSWERS,
RON R ANDERSON, SHERIFF
�c1 County:3u.!o SIrorI'.f Teteosoft Int
fl273g
EXHIBIT "G"
Zucker, Goldberg & Ackerman, LLC
«Field2»-«Fieldl»
June 11, 2014
Attn: PA Service Team
Postmaster of Steelton, PA 17113-2524
XFP-173739
C 173739PD024X1 C
REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED
FOR SERVICE OF LEGAL PROCESS
Please furnish the new address or the name and street address (if a boxholder) for the following:
Name: William E. Lovett a/k/a William Lovett
Address: 367 S 2nd Street Steelton, PA 17113-2524
Note: Only one request may be made per completed form. The name and last known address are required for change of
address information. The name, if known, and Post Office box address are required for boxholder information.
The following information is provided in accordance with 39 CFR 265.6(d)(5)(ii). There is no fee for providing boxholder or change of
address information.
1. Capacity of requester (e.g., process server, attorney, party representing self): Attorney for Plaintiff.
2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se except a
corporation acting prose must cite statute): Not Applicable.
3. The names of at known parties to the litigation: Ocwen Loan Servicing, LLC v.Patricia R. Eberts, et al.
4. The court in which the case has been or will be heard: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
5. The docket or other identifying number (a or b must be completed):
a. Docket or other identifying number: 13-2452 CIVIL
b. Docket or other identifying number has not been issued.
6. The capacity In which this individual is to be served (e.g., defendant or witness):
WARNING
THE SUBMISSION OPFALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER
INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR
PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT
OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001).
I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in
conjunction with actual or prospective litigation.
/s/ Scold' At V tet `OKiek
c/o Zucker Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Signature Address:
SCOTT A. DIETTERICK Mountainside, NJ 07092
Printed Name
No Change of Address order on file.
Moved, left no forwarding address.
No such address.
City, State, ZIP Code
POST OFFICE USE ONLY
NEW ADDRESS OR BOXHOLDER'S NAME AND
STREET ADDRESS
EXHIBIT "H"
Zucker, Goldberg & Ackerman, LLC
«Field2»-«Field1»
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF DAUPHIN
NO.: 13-2452 CIVIL
AFFIDAVIT
Before me, the undersigned authority, a Notary Public in and for said County and
Commonwealth, personally appeared Ralph M. Salvia, Esquire, attorney for and authorized
representative of Plaintiff, who being duly sworn according to law, deposes and says that Plaintiff,
or counsel for Plaintiff, conducted an investigation to determine the whereabouts of Defendant,
which included, but was not limited to searches of the following records:
(X) Records of the U.S. Postmaster with results of same attached to the foregoing
Motion.
(X) Internet Person Locator Records
(X) Credit Report Agency.
(X) Telephone Directory
(X) Records of the County Recorder of Deeds and Prothonotary
Finally, Affidavit deposes and says that if Defendant is not located at the address
uncovered by this investigation, the whereabouts of Defendant is unknown to Plaintiff.
By:
Dated: � & �y
Sworn to and s b cried before me this
1 t
LA
211.611,./ 0
2014.
Nota
blic
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
ELIZABETH ANNE FAIRCHOK
Notary Public
SWATARA TWR,DAUPHIN COUNTY
My Commission Expires Jul 23, 2017
RG & ACKERMAN, LLC
Ralph M. Salvia, Esq., PA. ID#202946
Atty File No.: XFP-173739
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
Email: Office@zuckergoldberg.com
(908) 233-8500; (908) 233-1390 FAX
Person Search
Person Search Results
Search Terms Used - SSN: 195-644MIN
All
Full Name
SSN
Address
Phone
Page 1 of 7
Records: 1 to 17 of 17
Next Steps
1.
WILLIAM LOVETT
EBERTS
WILLAIM G LOVETT
WILLIAM LOVETT
WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM GENE
LOVETT
WILLIAM PORTER
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM LOVETT
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-5)
Setup Alert
195-6441110 600 E KELLER ST
LexID: 1553347303 MECHANICSBURG PA 17055-
3425
Oct 2008 - Mar 2014
717-795-6240 - EDT
Oct 08 - Jan 13
Possible non DA
WILLIAM LOVETT
We Also Found:
❑ Property Records
❑ Email Address
2. WILLIAM G LOVETT
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
ice' Setup Alert
195-6- N PIKE ST
LexID: 1553347303 BARRACKVILLE WV 26559
Aug 2013
3. WILLIAM LOVETT
WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM PORTER
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
WILLIAM G
PORTERLOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-4)
Setup Alert
195-64.11.10 367 S 2ND ST
LexID: 1553347303 STEELTON PA 17113-2524
Jan 1995 - Aug 2013
761-0784
Oct 13 - Apr 14
https://secure.accurint.com/app/bps/misc
4/23/2014
Person Search
Page 2 of 7
4, WILLIAM E LOVETT
WILLIAM PORTER
LOVETT
WILLIAM G PORTER
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-2)
Setup Alert
195-6411.10 11 RICHLAND LN APT 102
LexID: 1553347303 CAMP HILL PA 17011-2498
Jul 2013
4
5. WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM PORTER
LOVETT
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
**View Sources (-2)
i'+c Setup Alert
195-64.110 PO BOX 461
LexID: 1553347303 BARRACKVILLE WV 265594461
Oct 2012 - Mar 2013
6. WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
Setup Alert
195-640M 243 E MAIN ST APT
LexID: 1553347303 CAMP HILL PA 17011-6315
Jun 2012 - Oct 2012
7. WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM PORTER
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM LOVETT
PORTER
WILLIAM G PORTER-
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
**View Sources (-4)
, Setup Alert
195-641 . 224 REDWOOD ST
LexID: 1553347303 HARRISBURG PA 171094713
Sep 2006 - Apr 2009
8. WILLIAM E LOVETT
WILLIAM G LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
195-641.11111.0 241 E MAIN ST FL 1
LexID: 1553347303 CAMP HILL PA 17011-6315
Sep 2008
https://secure.accurint.com/app/bps/misc
4/23/2014
Person Search
*View Sources (-2)
Setup Alert
Page 3 of 7
9, WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM GENE
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM LOVETT
PORTER
WILLIAM PORTER
LOVETT
WILLIAM G PORTER-
LOVETT
WILLIAM G
PORTERLOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-4)
Setup Alert
195-64010 29 SUSSEX RD
LexID: 1553347303 CAMP HILL PA 17011-6649
Feb 1989 - Aug 2008
761-0784
10. WILLIAM E LOVETT 195-64/firab 1280 N FRONTAGE RD W UNIT 761-0784
WILLIAM G LOVETT LexID: 1553347303 M17
LOVETT WILLIAM VAIL CO 81657-4034
PORTER Apr 1988 - May 2008
WILLIAM G PORTER
WILLIAM GENE
PORTER
WILLIAM PORTER
LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-3)
10 Setup Alert
11.
WILLIAM LOVETT
WILLIAM E LOVETT
WILLIAM G LOVETT
WILLIAM GENE
LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-3)
ti Setup Alert
195-644P PO BOX 4906
LexID: 1553347303 VAIL CO 816584906
Nov 1999 - Jul 2000
12. LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM GENE
PORTER
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
Setup Alert
195-64111.0 10 YORK MECHANICSBURGPA 761-0784
LexID: 1553347303 MECHANICSBURG PA 17055
Nov 1999
https://secure.accurint.com/app/bps/misc
4/23/2014
Person Search
Page 4 of 7
13. WILLIAM E LOVETT
WILLIAM G LOVETT
LOVETT WILLIAM
PORTER
WILLIAM G PORTER
WILLIAM LOVETT
PORTER
WILLIAM G PORTER-
LOVETT
WILLIAM L PORTER-
LOVETT
WILLIAM G
PORTERLOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-3)
Setup Alert
195-641 6625 CARLISLE PIKE
LexID: 1553347303 MECHANICSBURG PA 17050-
1707
Jul 1993 - Jan 1999
14. WILLIAM G PORTER
WILLIAM GENE
PORTER
DOB: 12/1969
Age: 44
Gender: Male
*View Sources (-1)
7 .t Setup Alert
195-6441/0 6625 CARLISLE PI
LexID: 1553347303 BERRYSBURG PA 17005
May 1995
761.0784
15. WILLIAM G PORTER
WILLIAM GENE
PORTER
DOB: 12/1969
Age: 44
Gender: Male
*ViewViSources (-1)
) Setup Alert
195-641 10 YORK CIR
LexID: 1553347303 MECHANICSBURG PA 17050-
2751
Apr 1988
761-0784
16. WILLIAM G LOVETT
DOB: 12/23/1969
Age: 44
Gender: Male
*View Sources (-1)
Setup Alert
195-640M 600 E KELLER STREEET
LexID: 1553347303 MECHANICSBURG PA 17055
t�
17.
JENNIFER STOUT
Gender: Female
*View Sources (-1)
tg Setup Alert
195-6410WA 500 BLUE RIDGE RD
LexID: 2447029759 BLACK MOUNTAIN NC 28711-
8724
Dec 2013 - Mar 2014
Probable current address
828 -357 -5216 -
EDT
Mar 13 - Apr 14
'''Active Phone
STOUT JENNIFER
828-447-5720 -
EDT
Sep 10 - Jan 11
Possible Cell
Phone
JENNIFER STOUT
Records: 1 to 17 of 17
Your DPPA Permissible Use: Civil, Criminal, Administrative or Arbitral Proceedings
Your GLBA Permissible Use: Legal Compliance
https://secure.accurint.com/app/bps/misc
4/23/2014
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
NO.: 13-2452 CIVIL
ORDER OF COURT
AND NOW, this /0' day of No 1,-44.r" , 2014, upon consideration of
Plaintiff's Second Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED
that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary,
on Defendant William E. Lovett a/k/a William Lovett, by instructing the Sheriff of Cumberland
County to POST a copy of same on the Mortgaged Premises, being 600 East Keller Street,
Mechanicsburg PA 17055, and by mailing a copy, via Certified Mail, no signature required and
First Class U.S. Mail, Postage Prepaid to 600 East Keller Street, Mechanicsburg, PA 17055, 243
East Main Street, Camp Hill, PA 17011, 241 MAIN ST CAMP HILL, PA 17011 and to 367 S 2nd
Street Steelton, PA 17113-2524, with said service being valid and complete upon such posting
and mailing in accordance with Pa.R.C.P. 430,
7.14,ker 45/6/z67
eePp;e5 Ata led /
rn
CD
Zucker, Goldberg & Ackerman, LLC
XFP-173739
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ocwen Loan Servicing, LLC CIVIL DIVISION
Plaintiff,
vs.
Patricia R. Eberts; William E. Lovett a/k/a
William Lovett;
Defendants.
NO.: 13-2452 CIVIL
PRAECIPE TO REINSTATE COMPLAINT
rn
c-)
N)
C)
TO THE PROTHONOTARY:
Please mark the Complaint in Mortgage Foreclosure filed at the above -captioned term and
number reinstated.
Dated: 121 f b/ I
By:
AA-��
..ice
ZUCKER, GOLDBER
ERMAN, LLC
S tt A. Dietterick, Esq I•; PA I.D. #55650
mberly A. Bonner, Es e; PA I.D. #89705
oel A. Ackerman, Esquire. PA I.D. #202729
Ashleigh L. Marin, Esquire. PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Roger Fay, Esquire; PA I.D. #315987
Attorneys for Plaintiff
XFP-173739/jfa
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
411.15 Pp A
C X11435
3
j4594/
r -n
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFFICE. ;WTr F HFRIFF
0E22PI3:09
CUMBERLAND CC U N' '(
PENNSYLVANIA
Ocwen Loan Servicing, LLC
vs.
Patricia R. Eberts (et al.)
Case Number
2013-2452
SHERIFF'S RETURN OF SERVICE
12/16/2014 08:05 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the
within named Defendant, to wit: William E. Lovett, pursuant to Order of Court by "Posting" the premises
located at 600 E. Keller Street, Mechanicsburg Borough, Mechanicsburg, PA 17055 with a true and
correct copy according to law.
J ON KINSLER, DEPUTY
SHERIFF COST: $45.30 SO ANSWERS,
December 17, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuile Sheriff, roleosoft, Inc.