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Home My WebLink About13-3730 Supreme Co > l ennsylvania Con l' Co %rno y leas For Prothonotary Use Only: 1 l� 1 J.i' t u Docket No: C r ari' )� County 1 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 IM Complaint 0 Writ of Summons O Petition ® Transfer from Another Jurisdiction ® Declaration of Taking f C Lead Plaintiff's Name: Lead Defendant's Name: C HSBC Bank USA... David A. Wait; etal T Dollar Amount Requested: ®within arbitration limits I Are money damages requested? ® Yes IR No (check one) ®x outside arbitration limits O N Is this a Class Action Suit? Yes 0 No Is this an MDJAppeal? ® Yes El No CAROLLO, ESQUIRE A Name of Plaintiff /Appellant's Attorney: PA !D 311050 ® Check here if you have no attorney (are a Self - Represented [Pro Sel 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 O Malicious Prosecution ® Debt Collection: Credit Card O Board of Assessment ® Motor Vehicle O Debt Collection: Other ® Board of Elections ® Nuisance ® Dept. of Transportation ® Premises Liability ® Statutory Appeal: Other S O Product Liability (does not include E mass tort) ®Employment Dispute: ® Slander/Libel /Defamation Discrimination C ® Other: ® Employment Dispute: Other ® Zoning Board � Other: , I ' ® Other: O MASS TORT ® Asbestos N ® Tobacco ® Toxic Tort - DES ® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: 13 Ejectment 13 Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation ® Declaratory Judgment ® Ground Rent ® Mandamus ® Landlord/Tenant Dispute ® Non- Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Commercial O Quo Warranto D Dental ® Partition O Replevin ® Legal ® Quiet Title ® Other: ® Medical (3 Other: ® Other Professional: Updated 1/1/2011 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL, ESQUIRE - ID477788 w JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194_ DAVID NEEREN, ESQUIRE - ID#204252 ` JORDAN DAVID, ESQUIRE - ID#311968Y; WOODCREST CORPORATE CENTER C-) 111 WOODCREST ROAD, SUITE 200 C- CHERRY HILL, NJ 08003 -3620 C: 856 - 669 -5400 leadi @u w HSBC Bank USA, National Associ7Home COURT OF COMMON PLEAS Trustee for ACE Securities Corp. CIVIL DIVISION Equit y Loan Trust, Series 200 -NCUMBERLAND County Backed Pass - Through Certificates C/O Ocwen Loan Servicing, LLC 1661 Worthington Road NO. Suite 100 West Palm Beach, FL 33409 Plaintiff V. DAVID A. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 FAITH E. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you am] Ck k 4:�� S> 8Co a9aY�g by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiffs favor: Assignor: New Century Mortgage Corporation Assignee: Deutsche Bank Trust Company Americas, as trustee and custodian for HSBC Bank USA, NA ACE 2006 -NC1 by: Saxon Mortgage Services Inc as its attorney in fact Date of Assignment: 09/07/2005 Recorded Date: 12/15/2006 Book/Instrument #: 0732 Page: 4124 Assignor: Deutsche Bank Trust Company Americas, as trustee and custodian for HSBC Bank USA, NA ACE 2006 -NC1 by: Saxon Mortgage Services Inc as its attorney in fact Assignee: HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NCI Date of Assignment: 03/03/2009 Recorded Date: 03/30/2009 Book/Instrument #: Instrument Number: 200909502 Page: N/A Assignor: HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1 Assignee: HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates Date of Assignment: 02/19/2013 Recorded Date: 04/03/2013 Book/Instrument #: Inst# 201310535 Page: N/A 2. Upon information and belief Defendant(s) and/or their predecessor: David A. Wait and Faith E. Wait (hereinafter 'Defendants "), are the owners of property located at 1103 Bridge Street, New Cumberland, PA 17070, by virtue of Deed dated 07/16/1999 and recorded 07/19/1999 in Official Records Book 204 at Page 123 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property")- 3. On 08/26/2005, Defendant(s) and/or their predecessor: DAVID A. WAIT promised to pay to the order of New Century Mortgage Corporation, the principal sum of $117,700.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 08/26/2005, Defendant(s) and/or their predecessor: DAVID A. WAIT FAITH E. WAIT to secure the Note, mortgaged to New Century Mortgage Corporation, the Property which is the subject of this action. The Mortgage was recorded on 09/23/2005 in Official Records Book 1924 at Page 0914. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 09/01/2012, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $107,785.21 Accumulated Interest $4,288.95 Accumulated Late Charges $205.75 Escrow Deficit /(Reserve) $274.31 Title Report $300.00 Attorney Fees $1,650.00 Other Suspense Balance $ -41.15 Property Inspection Fee $42.00 Property Valuation Fee - BPO $292.00 Prior Servicer Fees $763.00 Grand Total $115,560.07 The above figures are calculated as of 02/08/13: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 7.50000 %. The per diem interest accruing on this debt is $22.4600 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $41.15. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A ". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $ 115,560.07 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: v SALVATORE CAROLLO, ESQUIRE PA TD 311050 VERIFICATION Contract Management 1, the undersigned, a(n) Coordinator of Ocwen Loan Servicing, LLC ( "Ocwen ") attorney in fact for HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 - NC1, Asset Backed Pass - Through Certificates ('Plaintiff'), am authorized to make this verification on behalf of Ocwen and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocweri s mortgage servicing business conducted on Plaintiffs behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do not believe to be true or which I know to be false Date: ?!� 13 Name: Title: Contract Management Coordinator Company: Ocwen Loan Servicing LLC. as attorney in fact for HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NCI, Asset Backed Pass - Through Certificates Borrower: DAVID A. WAIT FAITH E. WAIT Property Address: 1103 Bridge Street, New Cumberland, PA 17070 MJU #: 13010172 -1 Legal Description: MMUIT " TAUL VZOM ' ON ll'R" COLVA= piece or palvol of land situate in tU* A"venob of Now CUMIn*rIand, Cumberlaad Sty,, l'aansy+ vanfa, bowded end dertiribed as follows, to nit. Inaxld at a point on the eaatrtly line of arl go Street, w poiast is fartp and thirty - six o�tw- hmisd�t).38j tarot :North of tha Ioostbseetatly Dorset o�d 81+r*eatb (11!]t) awd Bsi straeta; "once aloe the easterly line of SrAfts 9tseet, sth 27 degrees 3 aittattaa 00 reoasds 'fart thicty-*10t and tt tty -foux ane- bundvodth {39.31) feat to a point at wimtheril* line of land Sane or fats of Cbew er Xop er; thanoe a1mg awes $*nth 70 dogroor 32 tetra 00 asoamw s Xast one brad tan wad forty - six one- but4sedthe foot to a point on the ~tawarlf line of a ton (10) feat wide pcblic &11 tbut we along mare setnth 19 degrees 27 niaotae 00 aaooadr lset; thirty -eight and swro coo- hundredth s (30.00) feet to a point; twos Aoath 70 degrees 32 xisub" 00 seconds Hest, one hundx*d tiv. and Ulm 000-t;aodredtha (105.09) feet to a point, the pleon of lls�tlp. Sam XXXCUD MRSM. a dwellitq hoses briW kam m and numInved a .1203 Utdow Stz"t, tiew Co"Cland, V*ww Ylvanio. l lKa PAPA= XCMM: 26- 23- 0541 -294 MOM the ease proftiess trbich C are N. UJA and Mary C. Mal a, bnoband and wife, by dead dated Jbly 16, 1999 and rea 5ded July 19, 1999 in Cadbexland County in 'Deed Sock volvae 206 at V4MM 129 graetid and convoyind unto David A. llait and Wth X. Shit, bunbend . and wife. T Certify this to be r ecorded In Cumberland County PA Rcc ardcr ofD KI 9424KO9 3 1 January 9, 2013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1- 800 -342 -2397. (Persons with impaired hearing can call (717) 780 - 1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAIVIADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Exhibit A HOMEOWNER'S NAME(S): David A. Wait Faith E. id Wait__ _ _ PROPERTY ADDRESS: 1103 Brge S New Cumberland, PA 17070 LOAN ACCT. NO.: ORIGINAL LENDER: New Century Mortgage Corporation CURRENT LENDER/SERVICER: HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NCI, Asset Backe Pass - T hrough C ertificate s HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOUMAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CANSAVE YOUR HOME FROMFORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENT'S ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE — Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APP_ LY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED D "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face -to face meeting. Advise your lender immediately ofyour intentions. APPLICATION FOR MORTGAGE ASSISTANCE —Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days ofyour -to face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HA VE A MEETING WITH A. COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE,,. YOU HAVE THE RIGHT TO FILE A HENAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application NOTE: IF YOUARE CURRENTLY PRO TECTED BY THE FILING OF PETITION IN BANKR UPTCY, THE FOLLO WING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLYAND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGEDEFAULT (Bring it up to date). NATURE OF THE DEFAULT — The MORTGAGE debt held by the above lender on your property located at: 1103 Bridge Street, New Cumberland, PA 17070 IS SERIOUSLYINDEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due:_ Monthly Pa yment of $1,0 67.25 Fo Sept 1 , 2 012 t hrough Janu 1, 2013 $5, 336.25 Late Cha - $ 2 05 .75 $2 05.75 - -- — Other Charges (explain /itemize) -- P roperty Inspec Fee $31.50 Property Valuation Fees/131`0 - - $292.0 S uspen se $ 41.15 Total Amo unt Past Due $ B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable HOW TO CURE THE DEFAULT — You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 5,824.35, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check; certified check or money order made payable and sent to: Udren Law Offices, P.C. _Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 You can cure any other default by taking the following action within'THIRTY (30) DAYS of the date of this letter: ( Do not use i not applicable ) IF YOUDO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt; This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's,fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYperiod, you will not be required to pay attorney's fees OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -= it is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name Lender /Servicer: Ocwe n_Loa_ n Se rvicin_g a LLC Address: 1661 Worthington Road, Suite 100, West Palm B each, FL 33409 Phone Number: 87 596 -858 Fax Number. 407- 737 -5693 ` -- Contact Person: Cu Service " E- Mail Address: EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You ®may or ❑ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU HAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUTF INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER- TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. PLEASE SEE ATTACHED LIST OF CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY HEM_4P Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 08/17/2012 11:26 AM Community Action Commission of Capital Region CCCS of Western PA 1514 Derry Street 2000 Linglestown Road Harrisburg, PA 17104 Harrisburg, PA 17102 717 - 232 -9757 888 -511 -2227 Maranatha PA Interfaith Community Programs Inc 43 Philadelphia Avenue 40 E High Street Waynesboro, PA 17268 Gettysburg, PA I7325 717 -762 -3285 717- 334 -1518 PHFA 211 North Front Street Harrisburg PA 17110 717- 780 -3940 800 - 342 -2397 _ .............. - - -- __ ...... . 1 UDREN LAW OFFICES, P.G WOCOCREST CORPORATE CENTER 111 WOODCREST ROAD � •'` ;`� a�rzssis�rs CHERRY HiU., NJ 08003 "_`� 05.53 7012 2210 0001 4358 9939 � a�., � uiifur2uis dg003 U3 POST -AGE To: David A. Wait 1103 Bridge Street New Cumberland, PA 17070 t � WREN LAW OFFICES, P.C. WOCOCRtSTCORPORATE CENTER i i 111 WOODCI�I =ST ROAD �� '�`` • "t�1 &s�zs5t9216 1 CHERRY HIU , NJ 08003 $ 05.952 1 �at h �tw �•� U it 10i? SS.uicd Ptuttt C8003 7012 2210 8001 4358 9946 US POSTAGE 1 " To: l+aith E. 'Wait 1103 Bridge Street ' New Cumberland, PA 17070 FORM 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNTSYLVANIA { �:.. - C_ s, \'S A ern Ck i� q14 Cl t C Defendant(s) ' 3�...( / Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLO � Y 1 !0 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 fonyard. If you are represented by a layer, you and your lawyer must take the following steps to he eligible for a conciliation conference. it Ls not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative. of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE TI3E STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully s fitted: Date [Signature of Counsel for Plaintiff] SALVATORE CAROLLO, ESQUIRE PA iD 311050 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, vour lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOME, r ,R .. A s APPLICANT 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: .LET of people in household: How long? 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: S Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ .......................... ... _........._......... _ ..... ..... . If yes.. provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds:. $ $ Investments: $ $ Checking: S Savings: S $ Other: S $ Automobile #1: Model: Year: Amount owed: Value: Automobile 42 : Model: Year: Amount owed: Value: Other transportation (automobiles. boats motorcycles): .Model: Year: Amount owed: Value Monthly Income Name of Employers: I. I � AddixionaI Income Description (not wages): 1. monthly amount: 2 monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthiv Expenses: (Please only include expenses you are currently pa) ing) I EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" I�lortea Utilities Car Payment(s) Condo/Neich. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Pa yment Cable TV Child. Support/Alien. Spending Money Day /Child Care /Tuit. Other Expenses i 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 foltowing information: Counseling Agency: Counselor: Phone (Office): Fax: _ ..................................._......... ......._.... ........- ...... ........ ...... .. -_ - -- Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (blame): 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 sea provided by the above named Borrower Signature Date Co- Borrower Signature Date Please fonvard this document along with the following information to lender and lender's counsel: Y Proof of income Past 2 bank statements - Y Proof of any expected income for the last 45 days V Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) ........... _._............ ........ ...._...................... ._.... _ . .... ._.._.... FORM 3 IN THE COURT OF COMMON PLEAS OF I'lainti.ff(s) CUMBERLAND COUNTY, PENNSYLVANIA vs. `G l Defendant(s) : Cl VI.L REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 �0overning the Cumberland County Residential Mortaaac Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure. action.; 2. Defendant lives in the subject real property, which is defendant's primary residence, �. Defendant has been served with a 'Notice of Residential MortLtage Foreclosure Diversion .Program" and has taken al.] of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true. and correct. 1 understand that false statements are made subject to the penalties of 18 Pa. C.S. §4404 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed. Date Legal Representative Signature. of Defendant Date Sianatu.re of Defendant Date UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 - SALVATORE CAROLLO, ESQUIRE - ID #311050 HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID #77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 �-- NICOLE B. LABLETTA, ESQUIRE - ID #202194: R . >. DAVID NEEREN, ESQUIRE - ID #204252' y y= JORDAN DAVID, ESQUIRE - ID #311968 c'ti WOODCREST CORPORATE CENTER �J+� 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 .. 856- 669 -5400 Pleadings(a) udren.com. HSBC Bank USA, National Association, as Trustee COURT OF COMMON PLEAS for ACE Securities Corp. Home Equity Loan Trust, CIVIL DIVISION Series 2006 -NC1, Asset Backed Pass - Through CUMBERLAND County Certificates 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 NO. Plaintiff V. David A. Wait 1103 Bridge Street New Cumberland, PA 17070 Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire, and Jordan David, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREN LAW O CES, P.C. BY• _. SALVATORE CAROLLO, ESQUIRE PA 1D 311050 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FfL E 9-0 -10E Sheriff C'� PF�OTHONOTARY Jody S Smith Chief Deputy ' x F 2013 JUL .12 AM 10- 24 Richard W Stewart Solicitor OPME w;FTKSMERIrr CUMBERLAND COV14 Y PENNSYLVANIA HSBC Bank USA Case Number vs. David A.Wait(et al.) 2013 3734 SHERIFF'S RETURN OF SERVICE 07103/2013 05:35 PM-Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Clifford Jansen, Son,who accepted as"Adult Person in Charge"for David A.Wait at 1103 Bridge Street, New Cumberland Bo ugh, New Cumberland, PA 17070. L AM CLINE, DEPUTY 07103/2013 05:35 PM-Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Clifford Jansen, Son,who accepted as"Adult Person in Charge"for Faith E.Wait at 1103 Bridge Street, New Cumberland Bor gh, New Cumberland, PA 17070. L IAM CLINE, D SHERIFF COST: $63.21 SO ANSWERS, July 05, 2013 RON W R ANDERSON, SHERIFF {o}CountySuita Sheriff,Toleosofi.Inc. Y UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin • s ' udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff V. DAVID A. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 FAITH E. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13- 3730 -Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: CD Cr) Gt i CD Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), DAVID A. WAIT; FAITH E. WAIT; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Title Report Attorney Fees Other Suspense Balance Property Inspection Fee Property Valuation Fee -BPO Prior Servicer Fees Grand Total FROM TO 02/09/2013 03/18/2014 02/09/2013 03/18/2014 $107,785.21 $4,288.95 $9,051.38 $205.75 $576.10 $274.31 $300.00 $1,650.00 $ -41.15 $42.00 $292.00 $763.00 $125,187.55 GLW} la.sond1 tet l� �C)'-1 tV)elrn. $(A18):\e (2 -hk '('3 0` I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: 3 iihq MJU#: 13010172 CASE#: 13010172-1 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 JORDAN DAVID, ESQUIRE - ID#311968 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates C/O Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. DAVID A. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 FAITH E. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County O.. � No. 12/373b U YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you } . t2oi(1tq?° { Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Dl entuot .0101 OFFICE OF THE stfERIP: HSBC Bank USA vs. David A. Wait (et al.) Case Number 2013-3730 SHERIFF'S RETURN OF SERVICE 07/03/2013 05:35 PM - Deputy Wiliam Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Clifford Jansen, Son, who accepted as "Adult Person in Charge" for David A. Wait at 1103 Bridge Street, New Cumberland BoJ gh, New Cumbedand, PA 17070. LAM CLINE, DEPUTY 07/03/2013 05:35 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Clifford Jansen, Son, who accepted as "Adult Person in Charge" for Faith E. Wait at 1103 Bridge Street, New Cumberland Bo a ugh, New Cumberland, PA 17070. SHERIFF COST: $63.21 July 05, 2013 (c) CountySuiia Chant'', TiVeosalt Inc LAM CLINE, D SO ANSWERS, R NNY R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY FILL, NJ 08003 -3620 856 - 669 -5400 HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates Plaintiff v. David A. Wait, Faith E. Wait Defendant(s) TO: Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 Date of Notice: March 4, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13- 3730 -Civil IMPORTANT NOTICE r YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMJNO DE DMZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRTTA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Assocladon 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 13010172 CASE#: 13010172-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CW RRY HILL, NJ 08003 -3620 856 - 669 -5400 HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates Plaintiff v. David A. Wait, Faith E. Wait Defendant(s) TO: David A. Walt 1103 Bridge Street New Cumberland, PA 17070 Date of Notice: March 4, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 3730 -Civil IMPORTANT NOTICE, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFF ER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE D117.7 (1 0) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO T1ENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. BY: 144,;Tek ttorney for Plaintiff Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 13010172 CASE: 13010172-1 UDREN LAW 01411 ICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY MIL, NJ 08003 -3620 856- 669 -5400 pleadings @udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates Plaintiff v. DAVID A. WAIT, FAITH E. WAIT, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -3730 -Civil AFFIDAVIT OF NON - MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), DAVID A. WAIT, who /each of whom is over 18 years of age is /are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is /are attached hereto as Exhibit "A ". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) FAITH E. WAIT, to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relatin falsification to authorities. Dated: March 14, 2014 MJU #: 13010172 CASE #: 13010172 -1 n, s PAID 20 <i Department of Defense Manpower Data Center Last Name: WAIT First Name: DAVID Middle Name: A Active Duty Status As Of: Mar-14-2014 Results as of : Mar-14-2014 06:40:55 AM Civil Relief Act SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ./..L.,4 ' 114.!:A, :1.4- . J,I.A-1,c-c,...-.., ,I4d).'S.,\1/4 NA This response refa5tki14-uataglriul);1atusUatcin;theAtfive 601Alatus Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component _ NA 1/1-1TIA — ''''. '-9.F. i.1_,--L.,,,irit-, 4e,:41 NA This response reflects 'OW indtjidual left acti-V%:t uTstatuerwithlhfidays precedi4 thjir ci;eib'uty Status Date The Member or His/Her Unit Was Notified of a Futu e Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA i,-.1;zi,-N,NN. --k, _ .....„.- ...-, ,,„, ,.., __,,„:„..... -.7.4110 -00.71 41 NA ,:Fa':`,""N, ....,,e," . _. ,1 This response reflects whethertne inctividtfairor„his/her-unit has-received,early notifiCationo report for active duty Upon searching the data banks of the Department of Defense ManpOwer-Obta enter, the individual on the active duty status date as to all branches of the Uniformed Se •1-.-- sed on the information that you provided, the above is the status of s (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink .mil /faq /pis /PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: Z8S7Z0D3E05DV00 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings@udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass- Through Certificates Plaintiff v. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13- 3730 -Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 3/19/2014 to Date of Sale 9/3/2014 Ongoing Per Diem of $22.46 to actual date of sale including ifsale is held at a later date (Costs to be added) 511 tog. Ai 11F 1b its it `MJU #: 13010172 CASE #: 13010172 -1 l�uG Pd $ 125,187.55 $ 3,795.74 or Plaintiff Davis Neeren, Esq PA ID X04252 k#0 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 •leadin s udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass-Through Certificates Plaintiff V. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13-3730-Civil AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: DAVID A. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 FAITH E. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 C7.) —75 ..c- 7P0 7-0 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unswo falsification to authorities. PAID UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass-Through Certificates Plaintiff V. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County (7) MORTGAGE FORECLOSURE z r- cr) NO. 13-3730-Civil r---- c--) T." CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: El Act 91 procedures have been fulfilled ji Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. PA ID 04252 7.723 CD IJDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin • s r udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates Plaintiff v. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13- 3730 -Civil Ci) 1- AFFIDAVIT PURSUANT TO RULE 3129.1 -< w co AND RULE 76 v ° HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home E0 4-1:y Loan 'Oust, Series 2006 -NC1, Asset Backed Pass - Through Certificates, Plaintiff in the above action, by is undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 1103 Bridge Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): David A. Wait 1103 Bridge Street New Cumberland, PA 17070 Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: David A. Wait 1103 Bridge Street New Cumberland, PA 17070 Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Pennsylvania Department of Revenue PO Box 280948 Harrisburg , PA 17128 -0948 4. Name and address of the last recorded holder of every mortgage of record: HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Fulton Bank One Penn Square Lancaster , PA 17602 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128 -1230 Tenants /Occupants 1103 Bridge Street New Cumberland, PA 17070 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: 5(/ 'V/7 MJU #: 13010172 CASE #: 13010172 -1 D. id Neeren PAID UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 leadin_s ' udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates Plaintiff v. DAVID A. WAIT, FAITH E. WAIT Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13- 3730 -Civil 2 rn03 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY c F Z TO: David A. Wait 1103 Bridge Street New Cumberland, PA 17070 Your house (real estate) at 1103 Bridge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on September 3, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $125,187.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669 -5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings @udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NC1, Asset Backed Pass - Through Certificates Plaintiff v. DAVID A. WAIT, FAITH E. WAIT Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13- 3730 -Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 C) -0 rrl rri -� ? r cx7 Your house (real estate) at 1103 Bridge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on September 3, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $125,187.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669 -5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-3730 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR ACE SECURITIES CORP. HOME EQUITY LOAN TRUST, SERIES 2006 -NC1, ASSET BACKED PASS - THROUGH CERTIFICATES Plaintiff (s) From DAVID A. WAIT, FAITH E. WAIT (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he /she has been added as a garnishee and is enjoined as above stated. Amount Due: $125,187.55 L.L.: $.50 Interest FROM 3/19/2014 TO DATE OF SALE 9/3/2014 - ONGOING PER DIEM OF $22.46 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,795.74 Atty's Comm: Atty Paid: $211.96 Plaintiff Paid: Date: 3/18/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonota Deputy REQUESTING PARTY: Name: DAVID NEEREN, .ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 Attorney for: PLAINTIFF Telephone: 856- 669 -5400 Supreme Court ID No. 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates Plaintiff v. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -3730 -Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $125,187.55 Interest From 3/19/2014 to Date of Sale 9/3/2014 Ongoing Per Diem of $22.46 to actual date of sale including if sale is held at a later date $ 3,795.74 (Costs to be added) $ py.Sopc a 03.0.1 Car 6 2.-6 l` < < MJU#: 13010172 CASE#: 13010172-1 2 4040j4 P UDREN LAW OFFICES, P.C. NI astui(g/lat/ .30(09 o u ur 27,21c; 1. crlu_ _Apex UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates Plaintiff v. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County s MORTGAGE FORECLOSURE f NO. 13 -3730 -Civil CERTIFICATE OF ACT 91 G' • I hereby state that as the attorney for the Plaintiff in the above -captioned matter: 12 Act 91 procedures have been fulfilled n Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: C1 Attorney Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates Plaintiff v. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE c NO. 13 -3730 -Civil "3-s-?",cr C AFFIDAVIT OF LAST KNOWN ADDRESS UNDER RULE 76 The Defendant(s) last known address is as follows: DAVID A. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 FAITH E. WAIT 1103 BRIDGE STREET NEW CUMBERLAND, PA 17070 This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. UDREN LAW OFF CEESS,, P.C. Attoiney for Plaintiff NFcoIe LaBiefta, Esqure riYd 202194 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsAudren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates Plaintiff v. David A. Wait Faith E. Wait Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County { MORTGAGE FORECLOSURE Cy \ NO. 13-3730-Civilcp AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 • HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 1103 Bridge Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or reputed Owner(s): David A. Wait 1103 Bridge Street New Cumberland, PA 17070 Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: David A. Wait 1103 Bridge Street New Cumberland, PA 17070 Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Pennsylvania Department of Revenue PO Box 280948 Harrisburg , PA 17128-0948 4. Name and address of the last recorded holder of every mortgage of record: HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Fulton Bank One Penn Square Lancaster , PA 17602 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 1103 Bridge Street New Cumberland, PA 17070 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: c0l��ry MJU#: 13010172 CASE#: 13010172-1 UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsudren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates Plaintiff v. DAVID A. WAIT, FAITH E. WAIT Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -3730 -Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: David A. Wait 1103 Bridge Street New Cumberland, PA 17070 Your house (real estate) at 1103 Bridge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on September 3, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $125,187.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin t s e udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates Plaintiff v. DAVID A. WAIT, FAITH E. WAIT Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -3730 -Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Faith E. Wait 1103 Bridge Street New Cumberland, PA 17070 CSS Cr! Your house (real estate) at 1103 Bridge Street, New Cumberland, PA 17070 is scheduled to be sold at the Sheriffs Sale on September 3, 2014 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $125,187.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR ACE SECURITIES CORP. HOME EQUITY LOAN TRUST, SERIES 2006 -NCI, ASSET BACKED PASS-THROUGH CERTIFICATES Vs. NO 13-3730 Civil Term CIVIL ACTION — LAW DAVID A. WAIT FAITH E. WAIT WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $125,187.55 L.L.: Mon" 3/03 .doif Interest/TO DATE OF SALE 9/3/2014 - ONGOING PER DIEM OF $22.46 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE - $3,795.74 Atty's Comm: Due Prothy: $2.25 Atty Paid: $2.146.Y6 Other Costs: Plaintiff Paid: Date: 6/6/14 (Seal) 11,mzei David D. Bell, Prothonotary Deputy REQUESTING PARTY: Name: NICOLE LABLETTA, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 202194 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com HSBC Bank USA, National Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates Plaintiff v. DAVID A. WAIT, FAITH E. WAIT, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -3730 -Civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: C.A.) 3170 OD 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made sub' • enalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authoriti Dated: {5711111ti MJU#: 13010172 CASE#: 13010172-1 N LAW OFF BY: Atto or Plaintiff David Neeren, Esquire PAID 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 H B - : an i SA, Nationa Association, as Trustee for ACE Securities Corp. Home Equity Loan Trust, Series 2006 -NCI, Asset Backed Pass -Through Certificates Plaintiff v. DAVID A. WAIT; FAITH E. WAIT; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 13 -3730 -Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): DAVID A. WAIT; FAITH E. WAIT; PROPERTY: 1103 Bridge Street, New Cumberland, PA 17070 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 09/03/2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 13010172 CASE#: 13010172-1 EzM%k!r � David A. Wait - MJU# 13010172-1 (Cumberland County) Faith E. Wait - MJU# 13010172-1 (Cumberland County) Name Address of Sender and Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 0 Registered 0 Insured E COD F. Certified LI Merchandise T n Return Receipt for Int' I Recorded Del. Express Mail Check appropriate block for Registered Mail: LJ With Postal Insurance n Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line Article Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value Of Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Co on ealth of PA, Departmento Rev ue Bureau of Compliance PO Box 281230 Hanisburg, PA 17128- 2 0 ..• 0 13-37304 Tenants/Occupants 1103 Bridge Street New Cumberland, PA 17070 2. N, ../csi • — 'cr 1 .. 7, Pennsylvania Department of Rev ue Lien Section, P.O. Box 280948 Harrisburg, PA 17128-0948 ,v : xi 0 _i 6 09/03/2014 Fulton Bank 0 One Penn Square Lancaster , PA 17602 w EA. o (7) o ' • Ira t '' II MID 8 (0. .... 0- N 0 0 9 •_. F" : , 10 • , :i. Aet-i!‘ 1 t id.r.:•". I L ' Y 11 ‘•2 ie. 12 MI 13 14 15 Total number of Pieces Listed by Sender 6 Total N . ber of Pieces Receiv• r at Post Office acoverage Postrnas e Per (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruclion of nonnego table documents under Express Mail document reconstruction insurance is 550,000 p er Voce subject to a LLCM of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance, See Domestic Mail Manual R900, S913, and S921 for limitations of on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling char es apply only to tlthd and forth class .P. PS Form 3877, February 1994 Form Must be Completed by Ty_pewriter, Ink or Ball Point Pen parcels. David A. Wait - MJU# 13010172-1 (Cumberland County) Faith E. Wait - MJU# 13010172-1 (Cumberland County) s Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE CFV E`FFAIFF HSBC Bank USA vs. David A. Wait (et al.) Case Number 2013-3730 SHERIFF'S RETURN OF SERVICE 06/17/2014 05:51 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 1103 Bridge Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland County. 06/17/2014 05:51 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Faith Wait, wife, who accepted as "Adult Person in Charge" for David A. Wait at 1103 Bridge Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland County. 06/17/2014 05:51 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Faith E. Wait at 1103 Bridge Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland County. SHERIFF COST: $944.24 SO ANSWERS, July 08, 2014 RONO R ANDERSON, SHERIFF c) < ountySu: e Sherif'. Teleoso tt. Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED -OFFICE THE PROTHONOTARY OV -It Ai.9:57 CUMBERLAND COUNTY PENNSYLVANIA HSBC Bank USA vs. David A. Wait (et al.) Case Number 2013-3730 SHERIFF'S RETURN OF SERVICE 06/17/2014 05:51 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 1103 Bridge Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland County. 06/17/2014 05:51 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Faith Wait, wife, who accepted as "Adult Person in Charge" for David A. Wait at 1103 Bridge Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland County. 06/17/2014 05:51 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Faith E. Wait at 1103 Bridge Street, New Cumberland Borough, New Cumberland, PA 17070, Cumberland County. 09/03/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on Wednesday, September, 3, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Udren Law Office, on behalf of HSBC Bank USA, National Association, as Trustee for ACE Securities Corp., Home Equity Loan Trust, Series 2006-NC1, Asset Backed Pass -Through Certificates, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,194.56 SO ANSWERS, September 30, 2014 c) County suer IC RONIV R ANDERSON, SHERIFF (2.3.- 4,0 . C�. /go 3 /3 Dao On June 10, 2014 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Known and numbered as, ti p 1103 Bridge Street, New Cumberland, as Exhibit "A" (n _) i Q Lj -C) • Q- filed with this Writ and by this Reference W incorporated herein. Date: June 10, 2014 Real Estate Coordinator 7" LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-3730 Civil HSBC BANK USA vs. DAVID A. WAIT Faith Wait ' Atty.: Mark Udren ALL THAT CERTIAN piece or par- cel of land situate in the 'Borough of New Cumberland, Cumberland County, Pennsylvania, bounded and described as follows, to wit: Begin- ning at a point on the easterly line of Bridge Street, which point is forty and thirty-six onehundredths (40.36) feet north of the northeasterly corner of Eleventh (ii th) and Bridge Streets; thence along the easterly line of Bridge Street, North 27 degrees 30 minutes 00 seconds West, thirtyeight and thirty-four one -hundredths (38.34) feet to a point at southerly line of land now or late of Charles Kepner; thence along same South 70 degrees 32 minutes 00 seconds East, one hundred ten and forty-six one -hundredths (110.46) feet to a point on the westerly line of a ten (10) feet wide public alley; thence along same South 19 degrees 27 minutes 00 seconds East, thirty-eight and zero onehundredths (38.00) feet to a point; thence South 70 degrees 32 minutes 00 seconds West, one hun- dred five and nine one- hundredths (105.09) feet to a point, the place of Beginning. Having erected thereon, a dwelling house being known and numbered as 1103 Bridge Street, New Cumberland, Pennsylvania. Be- ing Tax Parcel Number: 26-23-0541- 284 Being the same premises, which Clarence E. Hain and Mary G. Hain, husband and wife, by deed dated July 16, 1999 and recorded July 19, 1999 in Cumberland County in Deed Book Volume 204 at Page 122, granted and conveyed unto David A. Wait and Faith E. Wait, husband and wife. BEING KNOWN AS: 1103 Bridge Street, New Cumberland, PA 17070. PROPERTY ID NO.: 26-23-0541- 284. TITLE TO SAID PREMISES IS ;VESTED IN David A. Wait and Faith E. Wait, husband and wife BY DEED FROM Clarence E. Hain and Mary G. Hain, husband and wife DATED 07/16/1999 RECORDED 07/19/1999 IN DEED BOOK 204 PAGE 123. 104 The Patriot -News Co. 1900 P+athiot Drive -''Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriotNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY 20 3.3730 Civil Ter SBC BANK USA vs. DAVID A. WAIT Faith Wait Atty: Mark Udren ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, CUMBERLAND COUNTY, , PENNSYLVANIA, BOUNDED AND DESCRIBED AS - FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE EASTERLY LINE OF BRIDGE STgEET, WHICH POINTS ,P--GR-TY AND THIRTY-SIX ONE -HUNDREDTHS (40.36) FEET NORTH OF THE _ nnS?us.?� (NC r This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 iki6L Sworn to -rad ubsc bed before me this 20 day of August, 2014 A.D. otary Publi COMMONWEALTH OF P NNSYLyANIA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ACE Securities Corp Tr is the grantee the same having been sold to said grantee on the 3rd day of September A.D., 2014, under and by virtue of a writ Execution issued on the 6th day of June, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 3730, at the suit of ACE Securities Corp Tr against David A Wait & Faith E is duly recorded as Instrument Number 201425405. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this , A.D. oZ O / AJ )4/1.4A rder day of ecorder of Deeds m berIand County, Carlisle, PA y Commi, to,) E xpnes the First Monday of Jan. 2018 1 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11, July 18 and July 25, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. /11\•'' arie Coyne, Ed for SWORN TO AND SUBSCRIBED before me this 25 day of July, 2014 Notary 1 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018