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HomeMy WebLinkAbout13-6930 Supreme Court of Peiinsylvaii Coui 'af Coml on Pleas Far PP'othOP art t'se 01111•. C�► Coy er Sheet, CUM o: , County Docker fix, The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: Lead Defendant's Name: C OCWEN LOAN SERVICING, LLC GEORGE L. SHUGHART T I Dollar Amount Requested within arbitration limits O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintifflappellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se Litigant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include .Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation 5 ❑ Premises Liability ❑ Zoning Board i ❑ Product Liability (does not include ❑ Statutory Appeal: Other 1E mass tort) ❑Employment dispute: C ❑ Slander/Libel Defamation Discrimination 11 Other ❑Employment Dispute: Other T ❑ Other: 0 MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco • Toxic Tort - DES REAL PROPERTY MISCELLANEOUS • Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration $ ❑Other ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order • Dental ❑ Partition ❑ Quo Warranto • Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 1/112011 i KML LAW GROUP, P.C. SUITE 5000 — BNY MELLON INDEPENDENCE CENTER " ' « — r, •.- 701 MARKET STREET t, + `s ° f i U C i PHILADELPHIA, PA 19106 {' (866) 413 -2311 5 v tom, r _ WWW.KMLLAWGROUP_COM OCWEN LOAN SERVICING, LLC -.� IN THE COURT OF COMMON PLEAS 1100 Virginia Drive ;' i s t`� ti k' N l r Suite 175 OF Cumberland COUNTY Fort Washington, PA 19034 Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE GEORGE L. SHUGHART Mortgagor(s) and Record Owner(s) 39 Wilson Street �'9�:�IL AC "' 99 - C) 6 - vii Carlisle, PA 17013 FGRECL0,SUl ,E Defendant(s) NOTICE 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of 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 OR CANNOT AFFORD ONE, 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. . CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 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 defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. 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 SERVCCO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. �.��98syq s a SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real. aspx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretentionnkmllawgroup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and /or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 12516017C. Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. � a COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is OCWEN LOAN SERVICING, LLC, 1100 Virginia Drive, Suite 175 Fort Washington, PA 19034. 2. The name(s) and address(es) of the Defendant(s) is /are GEORGE L. SHUGHART, 39 Wilson Street, Carlisle, PA 17013, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On February 28, 2007 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., SOLELY AS NOMINEE FOR AMERICAN BROKERS CONDUIT, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on March 01, 2007 as Book 1983, Page 3544. The mortgage has been assigned to: OCWEN LOAN SERVICING, LLC by assignment of Mortgage recorded on September 16, 2013 as Instrument # 201330626. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(8); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of September 18, 2013: Principal Balance ............................... ............................... ....................$107,785.97 Interest from 04/01/2013 to 09/18/2013 at 7.3750 % .......... ......................$3,682.39 Per Diem interest rate at $21.78 LateCharges ................................................................. ............................... $280.37 AdvanceEscrow ................................... ............................... ........... .............$660.70 $112,409.43 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. t f 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $112,409.43, together with interest at the rate of $21.78, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: e�� / KML LAW G1kOUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua 1. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION 1, J&fthew To King , hereby state that I am � � �� �? � C , 1 � � of Ocwen Loan Servicing, LLC, mortgage servicing agent for Plaintiff in this matter. The Plaintiff has delegated the mortgage servicing responsibility to Ocwen Loan Servicing, LLC for the mortgage loan which is the subject of this action. Ocwen Loan Servicing, LLC, maintains and is in control of all documents and records supporting the statements in the foregoing complaint and therefore the servicer, rather than the Plaintiff, is the appropriate entity to make this verification. I have reviewed the business records relating to this account, and am authorized to make this verification. I hereby verify that the statements a made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. §4904 relating to unsworn falsification to authorities. Date: Name: tth�w A g Title: Authorked Signer OCWEN LOAN SERVICING, LLC (Servicing Agent for Plaintiff) #I 25160FC - GEORGE L. SHUGHART 39 Wilson Street Carlisle, PA 17013 f`oa,v EythibitA Exhibit A - Legal Description Commitment No. 1291843ERIE ALL THAT CERTAIN tract of,land situate in the Borough of Carlisle, Cumberland County, Pennsylvania, Mooreland Addition to Carlisle, bounded and described as follows: BEGINNING at a point on the eastern building line of Wilson Street, said point being at the nortt line of lot of ground now or formerly of Samuel C. Boyer and Mary F. Boyer, husband and wife, an a,point being also ten feet South of the northern tine of Lot No. 232; thence North along linepl� Ian Wilson Street, a distance of fifty feet to a point being the southern line of Lot No. 230;'th n i h line East one hundred twenty feet to a sixteen foot alley; thence along the wes T (er sl of r to as southern in prior deed) line of said alley, a distance of fifty feet to a no n li f y i aforesaid; thence in a westerly direction along the northern line of the Bo r o dista of hundred twenty feet to the place of BEGINNING. THESE lot numbers are according to the Plan of Mooreland land o parry as the sam i recorded in the Office of the Recorder of Deeds in and for Cumberland County at li nnsyfvania, in Plan Book 1, Page 61. BEING PARCEL NO. 0421 - 0322 -054 O O O 0 OR1983P63560 Ey,fiibit *Exhibit has been redacted to remove all personally identifiable information or non-public information a [ Ocwen Loan Servicing, LLC PO Box 780 3451 Hammond Avenue Waterloo IA 50704 -0780 DATE OF NOTICE: 07/02/13 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 EMERGENCY 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 f ree 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM," EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): GEORGE L SHUGHART ADDRESS: 39 WILSON ST CARLISLE PA 17013 LOAN ACCOUNT NUMBER: _4858 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Ocwen Loan Servicing, LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE — Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) 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 designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 33 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES — If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE — Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) 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 of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. to AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND 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 MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT — The MORTGAGE debt held by the above lender on your property located at 39 WILSON ST CARLISLE PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Monthly Payments from 05/01/13 through 07/01/13 $ 3174.42 b) Late charges from 05/01/13 through 07/01/13 $ 160.22 c) Other charges: (Escrow, Inspection Fees, other) $ 0.00 d) Other provisions of the mortgage obligation, if any $0.00 e) Less Suspense Balance $- 0.00 f) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $ 3334.64 HOW TO CURE THE DEFAULT — You may cure the default within THIRTY -THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 3334.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY -THREE (33) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: LENDER NAME: Ocwen Loan Servicing, LLC ADDRESS: PO Box 780 3451 Hammond Avenue Waterloo , IA 50704 -0780 IF YOU DO NOT CURE THE DEFAULT — If you do not cure the default within THIRTY -THREE (33) 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 -THREE (33) 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) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES — The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE — If you have not cured the default within the THIRTY -THREE (33) 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 Sheriff's Sale. You may do so by Paying the total amount then east 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 Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE — It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Ocwen Loan Servicing, LLC Address: PO Box 780 3451 Hammond Avenue Waterloo IA 50704 -0780 Phone Number: 800 - 850 -4622 Fax Number: 866 - 709 -4744 Contact Person: Collection Department Email Address: Ocwen.mortgagebanksite.com *If you prefer to contact us via email, please access our website at the above address. EFFECT OF SHERIFF'S SALE — You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTAGE — You may or may not 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 MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. 5041 Ocwen Loan Servicing, LLC PO Box 780 3451 Hammond Avenue Waterloo IA 50704 -0780 DATE OF NOTICE: 07/02/13 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 EMERGENCY 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION, OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM," EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): GEORGE L SHUGHART ADDRESS: 34 PRICKLY PEAR DR CARLISLE PA 17013 LOAN ACCOUNT NUMBER: 7144724858 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Ocwen Loan Servicing, LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE — Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) 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 designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 33 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES — If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE — Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default,) 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 of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND 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 MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT — The MORTGAGE debt held by the above lender on your property located at 39 WILSON ST CARLISLE PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Monthly Payments from 05/01/13 through 07/01/13 $ 3174.42 b) Late charges from 05/01/13 through 07/01/13 $ 160.22 c) Other charges: (Escrow, Inspection Fees, other) $ 0.00 d) Other provisions of the mortgage obligation, if any $0.00 e) Less Suspense Balance $- 0.00 f) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $ 3334.64 HOW TO CURE THE DEFAULT — You may cure the default within THIRTY -THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 3334.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY -THREE (33) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: LENDER NAME: Ocwen Loan Servicing, LLC ADDRESS: PO Box 780 3451 Hammond Avenue Waterloo , IA 50704 -0780 IF YOU DO NOT CURE THE DEFAULT — If you do not cure the default within THIRTY -THREE (33) 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 -THREE (33) 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) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES — The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE — If you have not cured the default within the THIRTY -THREE (33) 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 Sheriff's 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 Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE — It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Ocwen Loan Servicing, LLC Address: PO Box 780 3451 Hammond Avenue Waterloo IA 50704 -0780 Phone Number: 800 - 850 -4622 Fax Number: 866 - 709 -4744 Contact Person: Collection Department Email Address: Ocwen.mortgagebanksite.com *If you prefer to contact us via email, please access our website at the above address. EFFECT OF SHERIFF'S SALE — You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTAGE — You may or may not 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 MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. 5041 H9MAP Consumer Credit Counseling Agencies. ADAMS County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Housing Alliance of York/Y Housing Resources 2000 Linglestown Road 290 West Market Street Harrisburg, PA 17102 York, PA 17401 888 -511 -2227 717- 855 -2752 Maranatha PA Interfaith Community Programs Inc 43 Philadelphia Avenue 40 E High Street Waynesboro, PA 17268 Gettysburg, PA 17325 717 -762 -3285 717 - 334 -1518 ALLEGHENY County Report last updated: 09/20/2012 03:40 PM Action Housing, Inc Advantage Credit Counseling Service /CCCS of Western PA 425 6th Avenue River Park Commons Suite 950 2403 Sidney Street, Suite 400 Pittsburgh, PA 15219 Pittsburgh, PA 15203 412 -281 -2102 800 - 792 -2801 888 -511 -2227 Community Action Southwest Fair Housing Partnership of Greater Pittsburgh, Inc. 58 East Greene Street 2840 Liberty Avenue Waynesburg, PA 15370 Suite 205 724 -852 -2893 Pittsburgh, PA 15222 412- 391 -2535 Garfield Jubilee Associates Mon Valley Unemployment Committee 5138 Penn Avenue 338 E Ninth Avenue Pittsburgh, PA 15224 2nd Floor 412 - 665 -5200 Homestead, PA 15120 412462 -9962 Nazareth Housing Services NeighborWorks of Western Pennsylvania 301 Bellevue Road 710 5th Avenue Pittsburgh, PA 15229 Suite 1000 412 - 931 -6996 Pittsburgh, PA 15219 412 - 281 -9773 Pennsylvania Housing Finance Agency Urban League Of Pittsburgh 2275 Swallow Hill Road 610 Wood Street Bldg 200 Pittsburgh, PA 15222 Pittsburgh, PA 15220 412- 227 -4802 412- 429 -2842 ARMSTRONG County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Armstrong County Community Action Agency Royal Remax Plaza 705 Butler Road 917 A Logan Boulevard Kittanning, PA 16201 Altoona, PA 16602 724 -545 -3659 888 - 511 -2227 HEMAP Consumer Credit Counseling Agencies ARMSTRONG County (Continued...) Report last updated: 09/20/2012 03:40 PM Indiana Co. Community Action Program NeighborWorks of Western Pennsylvania 827 Water Street 710 5th Avenue Box 187 Suite 1000 Indiana, PA 15701 Pittsburgh, PA 15219 724 - 465 -2657 412 - 281 -9773 BEAVER County Report last updated: 09/20/2012 03:40 PM Action Housing, Inc Housing Opportunities of Beaver County 425 6th Avenue 282 East End Suite 950 Unit 1 Pittsburgh, PA 15219 Beaver, PA 15009 412 - 281 -2102 800 - 792 -2801 724 - 728 -7511 NeighborWorks of Western Pennsylvania 710 5th Avenue Suite 1000 Pittsburgh, PA 15219 412- 281 -9773 BEDFORD County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Royal Remax Plaza 917 A Logan Boulevard Altoona, PA 16602 888 -511 -2227 BERKS County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute Budget Counseling Center 100 Porter Road 247 North Fifth Street Suite 108 Reading, PA 19601 Pottstown, PA 19464 610 - 375 -7866 888 - 212 -6741 Community Action Committee Money Management International of the Lehigh Valley 2101 Centre Avenue 1337 East Fifth Street (located at CTCE Credit Union) Bethlehem, PA 18015 Reading, PA 19605 610 - 691 -5620 888 - 845 -5669 Neighborhood Housing Services of Greater Berks, Inc. Schuylkill Community Action 213 N 5th Street 225 N. Centre Street Suite 1030 Pottsville, PA 17901 Reading, PA 19601 570- 622 -1995 610 - 372 -8433 HLMAP Consumer Credit Counseling Agencies BLAIR County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Blair County Community Action Agency Royal Remax Plaza 2100 6th Avenue Suite 102 917 A Logan Boulevard PO Box 1833 Altoona, PA 16602 Altoona, PA 16602 888 -511 -2227 814- 946 -3651 CCCS of Northeastern PA 129 Rolling Ridge Drive State College, PA 16801 814- 238 -3668 800 - 922 -9537 BRADFORD County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 201 Basin Street Pittston, PA 18640 Suite 6 570- 602 -2227 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 CCCS of Northeastern PA PA Interfaith Community Programs Inc. 411 Main Street 630 Lincoln Street Suite 104 Milton, PA 17847 Stroudsburg, PA 18360 570- 742 -3399 570- 420 -8980 800 - 922 -9537 Trehab Center of Northeastern PA 147 Oak Ridge Drive Towanda, PA 18848 570- 265 -6179 800 - 982 -4045 BUCKS County Report last updated: 09/20/2012 03:40 PM American Credit Alliance American Credit Counseling Institute 2 South Delmorr Avenue 100 Porter Road Morrisville, PA 19067 Suite 108 215- 295 -7195 Pottstown, PA 19464 888 - 212 -6741 American Credit Counseling Institute Bucks County Housing Group 586 West Street Road 2324 Second Street Pike Warminster, PA 18974 Suite 17 215- 444 -9429 888 - 212 -6741 Wrightstown, PA 18940 866 - 866 -0280 Bucks County Housing Group Bucks County Housing Group 200 West Bridge Street 349 Durham Road Morrisville, PA 19067 Penndel, PA 19047 866 - 866 -0280 866 - 866 -0280 H9MAP Consumer Credit Counseling Agencies BUCKS County (Continued...) Report last updated: 09/20/2012 03:40 PM Bucks County Housing Group Bucks County Housing Group 470 Old Dublin Pike 515 West End Boulevard Doylestown, PA 18901 Quakertown, PA 18951 866 - 866 -0280 866 - 866 -0280 Clarifi /CCCS of Delaware Valley Clarifi /CCCS of Delaware Valley 1608 Walnut Street Catholic Social Services Building 10th Floor 7340 Jackson Street Philadelphia, PA 19107 Philadelphia, PA 19136 215 -563 -5665 215 -563 -5665 Clarifi /CCCS of Delaware Valley Clarifi /CCCS of Delaware Valley 4400 North Reese Street 101 Greenwood Avenue Philadelphia, PA 19140 Suite LC -70 215 -563 -5665 Jenkintown, PA 19046 215 -563 -5665 Credit Counseling Center Credit Counseling Center 832 Second Street Pike 60 North Main Street Richboro, PA 18954 Lower Level 215- 348 -8003 877 - 900 -4222 Doylestown, PA 18901 215- 348 -8003 877 - 900 -4222 Credit Counseling Center Diversified Community Services 8150 Route 13 Dixon House Levittown, PA 19057 1920 South 20th Street 215- 348 -8003 877 - 900 -4222 Philadelphia, PA 19145 215- 336 -3511 HACE RACE 167 W Allegheny Avenue 4660 Frankford Avenue 2nd Floor Philadelphia, PA 19124 Philadelphia, PA 19140 215 -437 -7867 215- 426 -8025 Intercultural Family Services, Inc. Northwest Counseling Service 4225 Chestnut Street 5001 North Broad Street Philadelphia, PA 19104 Philadelphia, PA 19141 215- 386 -1298 215- 324 -7500 Urban League of Philadelphia 121 S Broad St 9th Floor Philadelphia, PA 19107 215- 985 -3220 HtMAP Consumer Credit Counseling Agencies BUTLER County Report last updated: 09/20/2012 03:40 PM Action Housing, Inc Advantage Credit Counseling Service /CCCS of Western PA 425 6th Avenue River Park Commons Suite 950 2403 Sidney Street, Suite 400 Pittsburgh, PA 15219 Pittsburgh, PA 15203 412- 281 -2102 800 - 792 -2801 888 -511 -2227 Housing Authority of Butler County NeighborWorks of Western Pennsylvania 114 Woody Drive 710 5th Avenue Butler, PA 16001 Suite 1000 724 - 287 -6797 Pittsburgh, PA 15219 412 - 281 -9773 CAMBRIA County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Indiana Co. Community Action Program Royal Remax Plaza 827 Water Street 917 A Logan Boulevard Box 187 Altoona, PA 16602 Indiana, PA 15701 888 -511 -2227 724465 -2657 CAMERON County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA Northern Tier Community Action Corp. 129 Rolling Ridge Drive P.O. Box 389 State College, PA 16801 135 West 4th Street 814 - 238 -3668 800 - 922 -9537 Emporium, PA 15834 814486 -1161 CARBON County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute American Credit Counseling Institute 212 Berwick - Hazelton Hwy 827 N 19th Street Nescopeck, PA 18635 Allentown, PA 18104 888 - 468 -8847 888468 -8847 American Credit Counseling Institute Comm. on Econ Opportunity of Luzerne County Route 115 165 Amber Lane Time Plaza Suite 3 Wilkes - Barre, PA 18702 Blakeslee, PA 18610 570- 826 -0510 800 - 822 -0359 888 - 468 -8847 Community Action Committee CCCS of Northeastern PA of the Lehigh Valley 401 Laurel Street 1337 East Fifth Street Pittston, PA 18640 Bethlehem, PA 18015 570- 602 -2227 800 - 922 -9537 610- 691 -5620 H9MAP Consumer Credit Counseling Agencies CARBON County (Continued...) Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 411 Main Street 214 W. Walnut Street Suite 104 Hazleton, PA 18201 Stroudsburg, PA 18360 800- 922 -9537 570- 420 -8980 800 - 922 -9537 Money Management International Money Management International 3671 Crescent Court East 306 Spring Garden Street Whitehall, PA 18052 Easton, PA 18042 888 - 845 -5669 888 - 845 -5669 Schuylkill Community Action 225 N. Centre Street Pottsville, PA 17901 570- 622 -1995 CENTRE County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Central Pennsylvania Community Action, Inc. Royal Remax Plaza PO Box 792 917 A Logan Boulevard 207 East Cherry Street Altoona, PA 16602 Clearfield, PA 16830 888 -511 -2227 814 - 765 -1551 CCCS of Northeastern PA CCCS of Northeastern PA 129 Rolling Ridge Drive 201 Basin Street State College, PA 16801 Suite 6 814- 238 -3668 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 Lycoming- Clinton Co (STEP) 2138 Lincoln Street P.O. Box 3568 Williamsport, PA 17703 570- 326 -0587 CHESTER County Report last updated: 09/20/2012 03:40 PM American Angel Housing Counseling/RHD American Credit Counseling Institute 102 Pickering Way 227 E Chestnut Street Suite 200 1st Floor Exton, PA 19341 Coatesville, PA 19320 610- 768 -2811 888 -212 -6741 American Credit Counseling Institute APM 100 Porter Road 600 W Diamond Street Suite 108 Philadelphia, PA 19122 Pottstown, PA 19464 215- 235 -6070 888 - 212 -6741 HtMAP Consumer Credit Counseling Agencies CHESTER County (Continued...) Report last updated: 09/20/2012 03:40 PM Budget Counseling Center Chester Community Improvement Project 247 North Fifth Street 412 Avenue of the States Reading, PA 19601 PO Box 541 610 - 375 -7866 Chester, PA 19016 610 - 876 -8663 Clarifi /CCCS of Delaware Valley Clarifi /CCCS of Delaware Valley 770 E Market Street 4400 North Reese Street Suite 190 Philadelphia, PA 19140 West Chester, PA 19382 215 -563 -5665 215 -563 -5665 Diversified Community Services RACE Dixon House 167 W Allegheny Avenue 1920 South 20th Street 2nd Floor Philadelphia, PA 19145 Philadelphia, PA 19140 215- 336 -3511 215426 -8025 HACE Intercultural Family Services, Inc. 4660 Frankford Avenue 4225 Chestnut Street Philadelphia, PA 19124 Philadelphia, PA 19104 215- 437 -7867 215- 386 -1298 Media Fellowship House Money Management International 302 South Jackson Street 265 West High Street Media, PA 19063 Suite 2 610 -565 -0434 Pottstown, PA 19464 888 - 845 -5669 Northwest Counseling Service Phila Council For Community Advmnt 5001 North Broad Street 1617 John F Kennedy Blvd Philadelphia, PA 19141 Suite 1550 215- 324 -7500 Philadelphia, PA 19103 215 -567 -7803 800 - 930 -4663 Tabor Community Services, Inc. Urban League of Philadelphia 308 E King Street 121 S Broad St Suite 1 9th Floor Lancaster, PA 17602 Philadelphia, PA 19107 717 - 397 -5182 800 - 788 -5062 215- 985 -3220 CLARION County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA River Park Commons 2403 Sidney Street, Suite 400 Pittsburgh, PA 15203 888 -511 -2227 HtMAP Consumer Credit Counseling Agencies CLEARFIELD County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Central Pennsylvania Community Action, Inc. Royal Remax Plaza PO Box 792 917 A Logan Boulevard 207 East Cherry Street Altoona, PA 16602 Clearfield, PA 16830 888 -511 -2227 814- 765 -1551 CCCS of Northeastern PA Indiana Co. Community Action Program 129 Rolling Ridge Drive 827 Water Street State College, PA 16801 Box 187 814- 238 -3668 800 - 922 -9537 Indiana, PA 15701 724465 -2657 CLINTON County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 129 Rolling Ridge Drive 201 Basin Street State College, PA 16801 Suite 6 814- 238 -3668 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 Lycoming - Clinton Co (STEP) PA Interfaith Community Programs Inc. 2138 Lincoln Street 630 Lincoln Street P.O. Box 3568 Milton, PA 17847 Williamsport, PA 17703 570- 742 -3399 570- 326 -0587 COLUMBIA County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute CCCS of Northeastern PA 212 Berwick - Hazelton Hwy 401 Laurel Street Nescopeck, PA 18635 Pittston, PA 18640 888 - 468 -8847 570- 602 -2227 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 201 Basin Street 702 Sawmill Road Suite 6 Bloomsburg, PA 17815 Williamsport, PA 17701 800 - 922 -9537 570- 323 -6627 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 214 W. Walnut Street 217 N. Center Street Hazleton, PA 18201 Sunbury, PA 17801 800 - 922 -9537 800 - 922 -9537 Lycoming - Clinton Co (STEP) PA Interfaith Community Programs Inc. 2138 Lincoln Street 630 Lincoln Street P.O. Box 3568 Milton, PA 17847 Williamsport, PA 17703 570- 742 -3399 570- 326 -0587 HEMAP Consumer Credit Counseling Agencies CRAWFORD County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Center for Family Services, Inc. 4402 Peach Street 213 Center Street Erie, PA 16509 Meadville, PA 16335 888 -511 -2227 814 - 337 -8450 Greater Erie Community Action Committee Shenango Valley Urban League, Inc. 18 West 9TH Street 601 Indiana Avenue Erie, PA 16501 Farrell, PA 16121 814- 459 -4581 724 - 981 -5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814 - 452 -6113 CUMBERLAND County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717 - 232 -9757 Housing Alliance of York/Y Housing Resources Maranatha 290 West Market Street 43 Philadelphia Avenue York, PA 17401 Waynesboro, PA 17268 717 - 855 -2752 717- 762 -3285 PA Interfaith Community Programs Inc PHFA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717 - 334 -1518 717 - 780 -3940 800 - 342 -2397 DAUPHIN County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717 - 232 -9757 PHFA 211 North,Front Street Harrisburg, PA 17110 717- 780 -3940 800 - 342 -2397 H9MAP Consumer Credit Counseling Agencies DELAWARE County Report last updated: 09/20/2012 03:40 PM American Angel Housing Counseling/RHD American Credit Counseling Institute 150 North Radnor Chester Road 526 -528 Dekalb Street Suite F 200 Norristown, PA 19401 Radnor, PA 19087 610 - 971 -2210 888 - 212 -6741 610- 768 -2811 American Credit Counseling Institute APM 6800 Market Street 600 W Diamond Street 1 st Floor Philadelphia, PA 19122 Upper Darby, PA 19082 215- 235 -6070 888 - 212 -6741 Chester Community Improvement Project Clarifi /CCCS of Delaware Valley 412 Avenue of the States_ 1608 Walnut Street PO Box 541 10th Floor Chester, PA 19016 Philadelphia, PA 19107 610- 876 -8663 215 -563 -5665 Clarifi /CCCS of Delaware Valley Clarifi /CCCS of Delaware Valley 280 North Providence Road 770 E Market Street Media, PA 19063 Suite 190 215 -563 -5665 West Chester, PA 19382 215 -563 -5665 Clarifi /CCCS of Delaware Valley Diversified Community Services 4400 North Reese Street Dixon House Philadelphia, PA 19140 1920 South 20th Street 215 -563 -5665 Philadelphia, PA 19145 215- 336 -3511 HACE RACE 167 W Allegheny Avenue 4660 Frankford Avenue 2nd Floor Philadelphia, PA 19124 Philadelphia, PA 19140 215 -437 -7867 215- 426 -8025 Intercultural Family Services, Inc. Media Fellowship House 4225 Chestnut Street 302 South Jackson Street Philadelphia, PA 19104 Media, PA 19063 215- 386 -1298 610 -565 -0434 Northwest Counseling Service Phila Council For Community Advmnt 5001 North Broad Street 1617 John F Kennedy Blvd Philadelphia, PA 19141 Suite 1550 215- 324 -7500 Philadelphia, PA 19103 215 -567 -7803 800 - 930 -4663 Urban League of Philadelphia West Oak Lane CDC 121 S Broad St 7300 Ogontz Avenue 9th Floor Philadelphia, PA 19138 Philadelphia, PA 19107 215- 224 -0880 215- 985 -3220 HtMAP Consumer Credit Counseling Agencies ELK County Report last updated: 09/20/2012 03:40 PM Northern Tier Community Action Corp. P.O. Box 389 135 West 4th Street Emporium, PA 15834 814 - 486 -1161 ERIE County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Greater Erie Community Action Committee 4402 Peach Street 18 West 9TH Street Erie, PA 16509 Erie, PA 16501 888 -511 -2227 814459 -4581 St. Martin Center 1701 Parade Street Erie, PA 16503 814- 452 -6113 FAYETTE County Report last updated: 09/20/2012 03:40 PM Action Housing, Inc Advantage Credit Counseling Service /CCCS of Western PA 425 6th Avenue 1 North Gate Square Suite 950 #2 Garden Center Drive Pittsburgh, PA 15219 Greensburg, PA 15601 412 - 281 -2102 800 - 792 -2801 888 -511 -2227 Community Action Southwest Fayette Co. Community Action Agency, Inc. 58 East Greene Street 140 North Beeson Avenue Waynesburg, PA 15370 Uniontown, PA 15401 724 - 852 -2893 724437 -6050 800 - 427 -4636 NeighborWorks of Western Pennsylvania Southwestern Pennsylvania Legal Services Inc. 710 5th Avenue 45 East Main Street Suite 1000 Suite 200 Pittsburgh, PA 15219 Uniontown, PA 15401 412 - 281 -9773 724 -439 -3591 FOREST County Report last updated: 09/20/2012 03:40 PM Warren- Forest Counties Economic Opportunity Council 1209 Pennsylvania Ave, West PO Box 547 Warren, PA 16365 814- 726 -2400 HEMAP Consumer Credit Counseling Agencies FRANKLIN County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Advantage Credit Counseling Service /CCCS of Western PA 2000 Linglestown Road 55 Clover Hill Road Harrisburg, PA 17102 Dallastown, PA 17313 888 -511 -2227 888 -511 -2227 Community Action Commission of Capital Region Housing Alliance of York/Y Housing Resources 1514 Derry Street 290 West Market Street Harrisburg, PA 17104 York, PA 17401 717 - 232 -9757 717 - 855 -2752 Maranatha PA Interfaith Community Programs Inc 43 Philadelphia Avenue 40 E High Street Waynesboro, PA 17268 Gettysburg, PA 17325 717- 762 -3285 717 - 334 -1518 FULTON County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Maranatha 55 Clover Hill Road 43 Philadelphia Avenue Dallastown, PA 17313 Waynesboro, PA 17268 888 -511 -2227 717 - 762 -3285 GREENE County Report last updated: 09/20/2012 03:40 PM Action Housing, Inc Advantage Credit Counseling Service /CCCS of Western PA 425 6th Avenue 1 North Gate Square Suite 950 #2 Garden Center Drive Pittsburgh, PA 15219 Greensburg, PA 15601 412 - 281 -2102 800 - 792 -2801 888 -511 -2227 Community Action Southwest Southwestern Pennsylvania Legal Services Inc. 58 East Greene Street 63 South Washington St. Waynesburg, PA 15370 Waynesburg, PA 15370 724 - 852 -2893 724 - 627 -3127 HUNTINGDON County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA CCCS of Northeastern PA Royal Remax Plaza 129 Rolling Ridge Drive 917 A Logan Boulevard State College, PA 16801 Altoona, PA 16602 814 - 238 -3668 800 - 922 -9537 888 -511 -2227 HEMAP Consumer Credit Counseling Agencies INDIANA County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Indiana Co. Community Action Program 1 North Gate Square 827 Water Street #2 Garden Center Drive Box 187 Greensburg, PA 15601 Indiana, PA 15701 888 -511 -2227 724465 -2657 JEFFERSON County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Indiana Co. Community Action Program River Park Commons 827 Water Street 2403 Sidney Street, Suite 400 Box 187 Pittsburgh, PA 15203 Indiana, PA 15701 888 -511 -2227 724465 -2657 JUNIATA County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA CCCS of Northeastern PA Royal Remax Plaza 129 Rolling Ridge Drive 917 A Logan Boulevard State College, PA 16801 Altoona, PA 16602 814 - 238 -3668 800 - 922 -9537 888 -511 -2227 CCCS of Northeastern PA 217 N. Center Street Sunbury, PA 17801 800 - 922 -9537 LACKAWANNA County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute CCCS of Northeastern PA 212 Berwick - Hazelton Hwy 401 Laurel Street Nescopeck, PA 18635 Pittston, PA 18640 888- 468 -8847 570- 602 -2227 800 - 922 -9537 NeighborWorks Northeastern Pennsylvania United Neighborhood Centers of Northeastern PA (formerly Neighborhood Housing Svcs - Lackawanna) 425 Alder Street 709 East Market Street Scranton, PA 18505 Scranton, PA 18509 570- 346 -0759 570 -558 -2490 HLMAP Consumer Credit Counseling Agencies LANCASTER County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA American Credit Counseling Institute 55 Clover Hill Road 227 E Chestnut Street Dallastown, PA 17313 1 st Floor 888 -511 -2227 Coatesville, PA 19320 888 - 212 -6741 Base, Inc. Housing Alliance of York/Y Housing Resources 447 South Prince Street 290 West Market Street Lancaster, PA 17603 York, PA 17401 717- 392 -5467 717 - 855 -2752 Money Management International Tabor Community Services, Inc. 2101 Centre Avenue 308 E King Street (located at CTCE Credit Union) Suite 1 Reading, PA 19605 Lancaster, PA 17602 888 - 845 -5669 717- 397 -5182 800 - 788 -5062 LAWRENCE County Report last updated: 09/20/2012 03:40 PM Housing Opportunities of Beaver County Shenango Valley Urban League, Inc. 282 East End 601 Indiana Avenue Unit 1 Farrell, PA 16121 Beaver, PA 15009 724 - 981 -5310 724 - 728 -7511 LEBANON County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Schuylkill Community Action 2000 Linglestown Road 225 N. Centre Street Harrisburg, PA 17102 Pottsville, PA 17901 888 -511 -2227 570- 622 -1995 Tabor Community Services, Inc. 308 E King Street Suite 1 Lancaster, PA 17602 717 - 397 -5182 800- 788 -5062 LEHIGH County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute American Credit Counseling Institute 212 Berwick - Hazelton Hwy 827 N 19th Street Nescopeck, PA 18635 Allentown, PA 18104 888 - 468 -8847 888468 -8847 American Credit Counseling Institute Community Action Committee 230 East 4th St of the Lehigh Valley Bethlehem, PA 18015 1337 East Fifth Street 610- 991 -3140 Bethlehem, PA 18015 610 - 691 -5620 H9MAP Consumer Credit Counseling Agencies LEHIGH County (Continued...) Report last updated: 09/20/2012 03:40 PM Money Management International Schuylkill Community Action 3671 Crescent Court East 225 N. Centre Street Whitehall, PA 18052 Pottsville, PA 17901 888 - 845 -5669 570- 622 -1995 LUZERNE County Report last updated: 09/20 /2012 03:40 PM American Credit Counseling institute American Credit Counseling institute 239 W. Borad Street 212 Berwick - Hazelton Hwy Hazleton, PA 18201 Nescopeck, PA 18635 888 - 212 -6741 8881168 -8847 Comm. on Econ Opportunity of Luzerne County CCCS of Northeastern PA 165 Amber Lane 401 Laurel Street Wilkes - Barre, PA 18702 Pittston, PA 18640 570- 826 -0510 800 - 822 -0359 570- 602 -2227 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 702 Sawmill Road 214 W. Walnut Street Bloomsburg, PA 17815 Hazleton, PA 18201 800 - 922 -9537 800 - 922 -9537 NeighborWorks Northeastern Pennsylvania Schuylkill Community Action (formerly Neighborhood Housing Svcs - Lackawanna) 225 N. Centre Street 709 East Market Street Pottsville, PA 17901 Scranton, PA 18509 570- 622 -1995 570 -558 -2490 United Neighborhood Centers of Northeastern PA 425 Alder Street Scranton, PA 18505 570- 346 -0759 LYCOMING County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 201 Basin Street Pittston, PA 18640 Suite 6 570- 602 -2227 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 Lycoming- Clinton Co (STEP) PA Interfaith Community Programs Inc. 2138 Lincoln Street 630 Lincoln Street P.O. Box 3568 Milton, PA 17847 Williamsport, PA 17703 570- 742 -3399 570- 326 -0587 HIEMAP Consumer Credit Counseling Agencies MCKEAN County Report last updated: 09/20/2012 03:40 PM Northern Tier Community Action Corp. P.O. Box 389 135 West 4th Street Emporium, PA 15834 814 - 486 -1161 MERCER County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Shenango Valley Urban League, Inc. River Park Commons 601 Indiana Avenue 2403 Sidney Street, Suite 400 Farrell, PA 16121 Pittsburgh, PA 15203 724 - 981 -5310 888 -511 -2227 MIFFLIN County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA CCCS of Northeastern PA Royal Remax Plaza 129 Rolling Ridge Drive 917 A Logan Boulevard State College, PA 16801 Altoona, PA 16602 814 - 238 -3668 800 - 922 -9537 888 -511 -2227 CCCS of Northeastern PA CCCS of Northeastern PA 201 Basin Street 217 N. Center Street Suite 6 Sunbury, PA 17801 Williamsport, PA 17701 800 - 922 -9537 570- 323 -6627 800 - 922 -9537 MONROE County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute American Credit Counseling Institute 212 Berwick - Hazelton Hwy 827 N 19th Street Nescopeck, PA 18635 Allentown, PA 18104 888 - 468 -8847 888 -468 -8847 American Credit Counseling Institute Community Action Committee Route 115 of the Lehigh Valley Time Plaza Suite 3 1337 East Fifth Street Blakeslee, PA 18610 Bethlehem, PA 18015 888 - 468 -8847 610 - 691 -5620 CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 411 Main Street Pittston, PA 18640 Suite 104 570- 602 -2227 800 - 922 -9537 Stroudsburg, PA 18360 570420 -8980 800 - 922 -9537 149MAP Consumer Credit Counseling Agencies MONROE County (Continued...) Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA Money Management International 214 W. Walnut Street 306 Spring Garden Street Hazleton, PA 18201 Easton, PA 18042 800 - 922 -9537 888- 845 -5669 MONTGOMERY County Report last updated: 09/20/2012 03:40 PM American Angel Housing Counseling/RHD American Angel Housing Counseling/RHD 1060 First Avenue Two Bala Plaza Suite 400 Suite 300 King of Prussia, PA 19406 Bala Cynwyd, PA 19004 610 - 733 -2985 610- 768 -2811 American Angel Housing Counseling/RHD American Credit Alliance 600 West Germantown Pike 2 South Delmorr Avenue Suite 400 Morrisville, PA 19067 Plymouth Meeting, PA 19462 215- 295 -7195 610- 768 -2811 American Credit Counseling Institute American Credit Counseling Institute 100 Porter Road 586 West Street Road Suite 108 Warminster, PA 18974 Pottstown, PA 19464 215444 -9429 888 - 212 -6741 888 - 212 -6741 American Credit Counseling Institute Chester Community Improvement Project 526 -528 Dekalb Street 412 Avenue of the States Norristown, PA 19401 PO Box 541 610- 971 -2210 888 - 212 -6741 Chester, PA 19016 610 - 876 -8663 Clarifi/CCCS of Delaware Valley Clarifi /CCCS of Delaware Valley 1608 Walnut Street 4400 North Reese Street 10th Floor Philadelphia, PA 19140 Philadelphia, PA 19107 215 -563 -5665 215 -563 -5665 Clarifi /CCCS of Delaware Valley Credit Counseling Center 101 Greenwood Avenue 832 Second Street Pike Suite LC -70 Richboro, PA 18954 Jenkintown, PA 19046 215- 348 -8003 877 - 900 -4222 215 -563 -5665 Credit Counseling Center Credit Counseling Center 60 North Main Street 8150 Route 13 Lower Level Levittown, PA 19057 Doylestown, PA 18901 215- 348 -8003 877 - 900 -4222 215- 348 -8003 877 - 900 -4222 Intercultural Family Services, Inc. Media Fellowship House 4225 Chestnut Street 302 South Jackson Street Philadelphia, PA 19104 Media, PA 19063 215- 386 -1298 610 -565 -0434 HWMAP Consumer Credit Counseling Agencies MONTGOMERY County (Continued...) Report last updated: 09/20/2012 03:40 PM Money Management International Northwest Counseling Service 265 West High Street 5001 North Broad Street Suite 2 Philadelphia, PA 19141 Pottstown, PA 19464 215- 324 -7500 888 - 845 -5669 Phila Council For Community Advmnt West Oak Lane CDC 1617 John F Kennedy Blvd 7300 Ogontz Avenue Suite 1550 Philadelphia, PA 19138 Philadelphia, PA 19103 215- 224 -0880 215 -567 -7803 800 - 930 -4663 MONTOUR County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 201 Basin Street Pittston, PA 18640 Suite 6 570- 602 -2227 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 702 Sawmill Road 217 N. Center Street Bloomsburg, PA 17815 Sunbury, PA 17801 800 - 922 -9537 800 - 922 -9537 Lycoming- Clinton Co (STEP) PA Interfaith Community Programs Inc. 2138 Lincoln Street 630 Lincoln Street P.O. Box 3568 Milton, PA 17847 Williamsport, PA 17703 570- 742 -3399 570- 326 -0587 NORTHAMPTON County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute American Credit Counseling institute 827 N 19th Street 230 East 4th St Allentown, PA 18104 Bethlehem, PA 18015 888 - 468 -8847 610 - 991 -3140 Community Action Committee CCCS of Northeastern PA of the Lehigh Valley 411 Main Street 1337 East Fifth Street Suite 104 Bethlehem, PA 18015 Stroudsburg, PA 18360 610 - 691 -5620 570 -420 -8980 800 - 922 -9537 CCCS of Northeastern PA Money Management International 214 W. Walnut Street 3671 Crescent Court East Hazleton, PA 18201 Whitehall, PA 18052 800 - 922 -9537 888 - 845 -5669 HEMAP Consumer Credit Counseling Agencies NORTHAMPTON County (Continued...) Report last updated: 09/20/2012 03:40 PM Money Management International 306 Spring Garden Street Easton, PA 18042 888 - 845 -5669 NORTHUMBERLAND County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 201 Basin Street Pittston, PA 18640 Suite 6 570- 602 -2227 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 702 Sawmill Road 214 W. Walnut Street Bloomsburg, PA 17815 Hazleton, PA 18201 800 - 922 -9537 800 - 922 -9537 CCCS of Northeastern PA Lycoming- Clinton Co (STEP) 217 N. Center Street 2138 Lincoln Street Sunbury, PA 17801 P.O. Box 3568 800 - 922 -9537 Williamsport, PA 17703 570- 326 -0587 PA Interfaith Community Programs Inc. Schuylkill Community Action 630 Lincoln Street 225 N. Centre Street Milton, PA 17847 Pottsville, PA 17901 570- 742 -3399 570- 622 -1995 PERRY County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717 - 232 -9757 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717 - 762 -3285 PHILADELPHIA County Report last updated: 09/20/2012 03:40 PM Affordable Housing Centers of America American Angel Housing Counseling/RHD 846 North Broad Street Two Penn Center Plaza 1st Floor Suite 200 Philadelphia, PA 19130 Philadelphia, PA 19102 215- 765 -1221 610 - 768 -2811 HEMAP Consumer Credit Counseling Agencies PHILADELPHIA County (Continued...) Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute American Credit Counseling Institute 586 West Street Road 6800 Market Street Warminster, PA 18974 1st Floor 215- 444 -9429 888 - 212 -6741 Upper Darby, PA 19082 888 - 212 -6741 APM Center in the Park 600 W Diamond Street 5818 Germantown Avenue Philadelphia, PA 19122 Philadelphia, PA 19144 215- 235 -6070 215- 848 -7722 Chester Community Improvement Project Clarifi /CCCS of Delaware Valley 412 Avenue of the States 1608 Walnut Street PO Box 541 10th Floor Chester, PA 19016 Philadelphia, PA 19107 610- 876 -8663 215 -563 -5665 Clarifi /CCCS of Delaware Valley Clarifi /CCCS of Delaware Valley One Cherry Hill Catholic Social Services Building Suite 215 7340 Jackson Street Cherry Hill, PA 18002 Philadelphia, PA 19136 215 -563 -5665 215 -563 -5665 Clarifi /CCCS of Delaware Valley Clarifi /CCCS of Delaware Valley 4400 North Reese Street 101 Greenwood Avenue Philadelphia, PA 19140 Suite LC -70 215 -563 -5665 Jenkintown, PA 19046 215 -563 -5665 Congreso Council of Spanish Speaking Organization 216 West Somerset Street 705 -09 North Franklin Street Philadelphia, PA 19133 Philadelphia, PA 19123 215- 763 -8870 215- 627 -3100 Credit Counseling Center Credit Counseling Center 832 Second Street Pike 60 North Main Street Richboro, PA 18954 Lower Level 215- 348 -8003 877 - 900 -4222 Doylestown, PA 18901 215- 348 -8003 877 - 900 -4222 Credit Counseling Center Deliverance Community Development Corp, Inc. 8150 Route 13 2001 West Lehigh Avenue Levittown, PA 19057 Philadelphia, PA 19132 215- 348 -8003 877 - 900 -4222 215- 226 -7600 Diversified Community Services Esperanza Dixon House 4261 North 5th Street 1920 South 20th Street Philadelphia, PA 19140 Philadelphia, PA 19145 215- 324 -0746 215- 336 -3511 Greater Philadelphia Asian Social Service Center (GPASS) HACE 4943 North 5th Street 167 W Allegheny Avenue Philadelphia, PA 19120 2nd Floor 215- 456 -1662 Philadelphia, PA 19140 215426 -8025 1 HEMAP Consumer Credit Counseling Agencies PHILADELPHIA County (Continued...) Report last updated: 09/20/2012 03:40 PM HACE Intercommunity Action, Inc 4660 Frankford Avenue 403 Rector Street Philadelphia, PA 19124 Philadelphia, PA 19128 215- 437 -7867 215 -487 -1750 Intercultural Family Services, Inc. Korean Community Development Services Center 4225 Chestnut Street 6055 North 5th Street Philadelphia, PA 19104 Philadelphia, PA 19120 215- 386 -1298 215- 276 -8830 Liberty Resources Mt. Airy, USA 714 Market Street 6703 Germantown Avenue Suite 100 Suite 200 Philadelphia, PA 19106 Philadelphia, PA 19119 215- 634 -2000 215- 844 -6021 New Kensington Community Development Corp Norris Square Civic Association 2515 Frankford Avenue 149 West Susquehanna Avenue Philadelphia, PA 19125 Philadelphia, PA 19122 215- 427 -0350 215426 -8723 Northwest Counseling Service Partnership CDC 5001 North Broad Street 4020 Market Street Philadelphia, PA 19141 Suite 100 215- 324 -7500 Philadelphia, PA 19104 215- 662 -1612 Phila Council For Community Advmnt South Philadelphia H.O.M.E.S. 1617 John F Kennedy Blvd 1444 Point Breeze Avenue Suite 1550 Philadelphia, PA 19146 Philadelphia, PA 19103 215- 334 -4430 215 -567 -7803 800 - 930 -4663 Southwest Community Development Corporation United Communities Southeast Philadelphia 6328 Paschall Avenue 2029 South 8th Street Philadelphia, PA 19142 Philadelphia, PA 19148 215- 729 -0800 215468 -1645 Universal Companies Urban League of Philadelphia 800 South 15th Street 121 S Broad St Philadelphia, PA 19146 9th Floor 215- 732 -6518 Philadelphia, PA 19107 215- 985 -3220 West Oak Lane CDC 7300 Ogontz Avenue Philadelphia, PA 19138 215- 224 -0880 v HEMAP Consumer Credit Counseling Agencies PIKE County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute CCCS of Northeastern PA Route 115 401 Laurel Street Time Plaza Suite 3 Pittston, PA 18640 Blakeslee, PA 18610 570- 602 -2227 800 - 922 -9537 888 -468 -8847 CCCS of Northeastern PA 411 Main Street Suite 104 Stroudsburg, PA 18360 570- 420 -8980 800 - 922 -9537 POTTER County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 129 Rolling Ridge Drive 201 Basin Street State College, PA 16801 Suite 6 814 - 238 -3668 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 Northern Tier Community Action Corp. P.O. Box 389 135 West 4th Street Emporium, PA 15834 814 - 486 -1161 SCHUYLKILL County Report last updated: 09/20/2012 03:40 PM American Credit Counseling Institute American Credit Counseling Institute 212 Berwick - Hazelton Hwy 827 N 19th Street Nescopeck, PA 18635 Allentown, PA 18104 888 - 468 -8847 888468 -8847 Budget Counseling Center Comm. on Econ Opportunity of Luzerne County 247 North Fifth Street 165 Amber Lane Reading, PA 19601 Wilkes - Barre, PA 18702 610 - 375 -7866 570- 826 -0510 800 - 822 -0359 CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 702 Sawmill Road Pittston, PA 18640 Bloomsburg, PA 17815 570- 602 -2227 800 - 922 -9537 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 214 W. Walnut Street 217 N. Center Street Hazleton, PA 18201 Sunbury, PA 17801 800 - 922 -9537 800 - 922 -9537 Schuylkill Community Action 225 N. Centre Street Pottsville, PA 17901 570- 622 -1995 HLMAP Consumer Credit Counseling Agencies SNYDER County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Community Action Commission of Capital Region 2000 Linglestown Road 1514 Derry Street Harrisburg, PA 17102 Harrisburg, PA 17104 888 -511 -2227 717 - 232 -9757 CCCS of Northeastern PA CCCS of Northeastern PA 129 Rolling Ridge Drive 201 Basin Street State College, PA 16801 Suite 6 814- 238 -3668 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 702 Sawmill Road 217 N. Center Street Bloomsburg, PA 17815 Sunbury, PA 17801 800 - 922 -9537 800 - 922 -9537 Lycoming- Clinton Co (STEP) PA Interfaith Community Programs Inc. 2138 Lincoln Street 630 Lincoln Street P.O. Box 3568 Milton, PA 17847 Williamsport, PA 17703 570- 742 -3399 570- 326 -0587 SOMERSET County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Fayette Co. Community Action Agency, Inc. 1 North Gate Square 140 North Beeson Avenue #2 Garden Center Drive Uniontown, PA 15401 Greensburg, PA 15601 7241137 -6050 800- 427 -4636 888 -511 -2227 Southwestern Pennsylvania Legal Services Inc. 218 West Kimberly Avenue Suite 101 Somerset, PA 15501 814 - 443 -4615 SULLIVAN County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 201 Basin Street Pittston, PA 18640 Suite 6 570- 602 -2227 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 Trehab Center of Northeastern PA 210 Center Street P.O. Box 389 Dushore, PA 18614 570- 928 -9668 800 - 982 -4045 HEMAP Consumer Credit Counseling Agencies SUSQUEHANNA County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA Trehab Center of Northeastern PA 401 Laurel Street 36 Public Avenue Pittston, PA 18640 PO Box 366 570- 602 -2227 800 - 922 -9537 Montrose, PA 18801 570- 278 -3338 800 - 982 -4045 TIOGA County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 201 Basin Street Pittston, PA 18640 Suite 6 570- 602 -2227 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 PA Interfaith Community Programs Inc. Trehab Center of Northeastern PA 630 Lincoln Street 14 South Main Street Milton, PA 17847 Suite 202 570- 742 -3399 Mansfield, PA 16933 570- 662 -8113 866- 656 -7788 UNION County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA CCCS of Northeastern PA Royal Remax Plaza 401 Laurel Street 917 A Logan Boulevard Pittston, PA 18640 Altoona, PA 16602 570- 602 -2227 800 - 922 -9537 888 -511 -2227 CCCS of Northeastern PA CCCS of Northeastern PA 129 Rolling Ridge Drive 201 Basin Street State College, PA 16801 Suite 6 814- 238 -3668 800 - 922 -9537 Williamsport, PA 17701 570- 323 -6627 800 - 922 -9537 CCCS of Northeastern PA CCCS of Northeastern PA 702 Sawmill Road 217 N. Center Street Bloomsburg, PA 17815 Sunbury, PA 17801 800 - 922 -9537 800 - 922 -9537 Lycoming- Clinton Co (STEP) PA Interfaith Community Programs Inc. 2138 Lincoln Street 630 Lincoln Street P.O. Box 3568 Milton, PA 17847 Williamsport, PA 17703 570- 742 -3399 570- 326 -0587 i HEMAP Consumer Credit Counseling Agencies VENANGO County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Center for Family Services, Inc. River Park Commons 213 Center Street 2403 Sidney Street, Suite 400 Meadville, PA 16335 Pittsburgh, PA 15203 814 - 337 -8450 888 -511 -2227 Greater Erie Community Action Committee St. Martin Center 18 West 9TH Street 1701 Parade Street Erie, PA 16501 Erie, PA 16503 814- 459 -4581 814 -452 -6113 WARREN County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Greater Erie Community Action Committee 4402 Peach Street 18 West 9TH Street Erie, PA 16509 Erie, PA 16501 888 -511 -2227 814459 -4581 St. Martin Center Warren- Forest Counties Economic Opportunity Council 1701 Parade Street 1209 Pennsylvania Ave, West Erie, PA 16503 PO Box 547 814 - 452 -6113 Warren, PA 16365 814- 726 -2400 WASHINGTON County. Report last updated: 09/20/2012 03:40 PM Action Housing, Inc Advantage Credit Counseling Service /CCCS of Western PA 425 6th Avenue I North Gate Square Suite 950 #2 Garden Center Drive Pittsburgh, PA 15219 Greensburg, PA 15601 412 - 281 -2102 800 - 792 -2801 888 -511 -2227 Community Action Southwest Community Action Southwest 58 East Greene Street 150 West Beau Street Waynesburg, PA 15370 Suite 304 724 - 852 -2893 Washington, PA 15301 724 - 225 -9550 Mon Valley Unemployment Committee NeighborWorks of Western Pennsylvania 338 E Ninth Avenue 710 5th Avenue 2nd Floor Suite 1000 Homestead, PA 15120 Pittsburgh, PA 15219 412- 462 -9962 412 -281 -9773 Southwestern Pennsylvania Legal Services Inc. 10 West Cherry Avenue Washington, PA 15301 724 - 225 -6170 MMAP Consumer Credit Counseling Agencies WAYNE County Report last updated: 09/20/2012 03:40 PM CCCS of Northeastern PA CCCS of Northeastern PA 401 Laurel Street 411 Main Street Pittston, PA 18640 Suite 104 570- 602 -2227 800 - 922 -9537 Stroudsburg, PA 18360 570 -420 -8980 800 - 922 -9537 NeighborWorks Northeastern Pennsylvania Trehab Center of Northeastern PA (formerly Neighborhood Housing Svcs - Lackawanna) 100 4th Street 709 East Market Street Suite 20 Scranton, PA 18509 Honesdale, PA 18431 570 -558 -2490 570- 253 -8941 888 -524 -2107 United Neighborhood Centers of Northeastern PA 425 Alder Street Scranton, PA 18505 570- 346 -0759 WESTMORELAND County Report last updated: 09/20/2012 03:40 PM Action Housing, Inc Advantage Credit Counseling Service /CCCS of Western PA 425 6th Avenue 1 North Gate Square Suite 950 #2 Garden Center Drive Pittsburgh, PA 15219 Greensburg, PA 15601 412- 281 -2102 800 - 792 -2801 888 -511 -2227 Community Action Southwest Indiana Co. Community Action Program 58 East Greene Street 827 Water Street Waynesburg, PA 15370 Box 187 724 - 852 -2893 Indiana, PA 15701 724 -465 -2657 Mon Valley Unemployment Committee NeighborWorks of Western Pennsylvania 338 E Ninth Avenue 710 5th Avenue 2nd Floor Suite 1000 Homestead, PA 15120 Pittsburgh, PA 15219 412 - 462 -9962 412- 281 -9773 WYOMING County Report last updated: 09/20/2012 03:40 PM Comm. on Econ Opportunity of Luzerne County CCCS of Northeastern PA 165 Amber Lane 401 Laurel Street Wilkes - Barre, PA 18702 Pittston, PA 18640 570- 826 -0510 800 - 822 -0359 570- 602 -2227 800 - 922 -9537 NeighborWorks Northeastern Pennsylvania Trehab Center of Northeastern PA (formerly Neighborhood Housing Svcs - Lackawanna) 36 Public Avenue 709 East Market Street PO Box 366 Scranton, PA 18509 Montrose, PA 18801 570 -558 -2490 570- 278 -3338 800 - 982 -4045 EMAP Consumer Credit Counseling Agencies WYOMING County (Continued...) Report last updated: 09/20/2012 03:40 PM United Neighborhood Centers of Northeastern PA 425 Alder Street Scranton, PA 18505 570- 346 -0759 YORK County Report last updated: 09/20/2012 03:40 PM Advantage Credit Counseling Service /CCCS of Western PA Advantage Credit Counseling Service /CCCS of Western PA 2000 Linglestown Road 55 Clover Hill Road Harrisburg, PA 17102 Dallastown, PA 17313 888 -511 -2227 888 -511 -2227 Base, Inc. Housing Alliance of York/Y Housing Resources 447 South Prince Street 290 West Market Street Lancaster, PA 17603 York, PA 17401 717 - 392 -5467 717 - 855 -2752 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717 - 334 -1518 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA OCWEN LOAN SERVICING, LLC Plaintiff J� � ' � q b vs. Case No. c� GEORGE L. SHUGHART Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you 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 within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: (Signature o Counsel for Plaintiff) 11/21/2013 rte_ r C Date �= Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket #� BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete -your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: 1:: ClJST0A-'1ER/PRIMARV APPLICANT Borrower name(s). Property Address: City: State: Zip: Is the property for sale? Yes EI No 0 Listing date; Price: $ Realtor Name: _ Realtor Phone: Borrower Occupied? Yes 11 No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: of people in household.: How long? Mailing Address; City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #t cif people in household: How Iona? ` INFORMATION: First Mortgage Lender: Type of Marx: Loan Nurnbe�r: Hate You Closed Your Doan: Second Mortgage sender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment, Primary Reason for Default: Is the loan in Bankruptcy? 'Yes El No 0 If yes provide names, location of court, care number & attorney. A=Ls Amount Owed Value: Home: $ $ Other Real Estate: $ Retirement Funds: S $ Investments: $ Checking $ $ Savings: S S Usher: $ $ Automobile "l; Model: Year: Amount owed: Value- Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats. motorcycles): Model Year: Amount owed: Value Monthly Income Name o f Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount- 2z monthly amount:. Borrower Pay Days: Co- Borrower Pay lays: Monthly Expenses: (Please only include expenses you are currently paying) E 'ENSE AMOUNT EXPENSl✓ AMOUNT Mo a e Food 2 Ivlort a .e Utilities f Car PaM. eats Condo/Neigh. Pees Auto insurance Med. aot covered - Auto fuelf irs Other prop, payment Install. Loan Payment Cable TV Cbild Su rtlAllm, S ndin Move Da /Chilli CarelTuit. Other Ex erases Amount Available for Monthly Mortgage Payments Based on Income & Expenses Have you been working with a Housing Counseling Agency? Yes E] No ❑ If yes, please provide the following information: Coumeling Agency: Coudselor: Phone.(Oaf ce): Fax: 1~n�ail: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes l] No (,� ? If yes, please indicate the status of the applications Have you had any prior negotiations with your tender or lendear's loan servicing company to resolve your delinquency? Yes ❑ No El 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 (Name): Phone; Servicing Company (Name): Contact: Phone: authorize the above named to uselrefer this iiztfarrnativn to my lenderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. TJWe understand that Itwe am/are under no ablution to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Y Proof of any expected income for the last 45 days. } Copy of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation f (.hardship letter) Y Listing agreement (if property is currently on the market) i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , „ J Sheriff Jody S Smith Chief Deputy "; ?' 13 DEC 19 fAN l I: Richard W Stewart �sl1iLa; l� -� ,� Solicitor Ocwen Loan Servicing, LLC Case Number vs. 2013-6930 George Shughart SHERIFF'S RETURN OF SERVICE 12/02/2013 07:30 PM- Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Jennifer Almeida, Occupant,who accepted as "Adult Person in Charge"for OCCUPANT at 39 Wilson Street, Carlisle Borough, Carlisle, PA 17013. i DEI11NIS FRY, D T 12/05/2013 08:12 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: George Shughart at 34 Prickly Pear Drive, North Middleton Township, CarlisI PA 17013. TS L, DEPUTY SHERIFF COST: $51.56 SO ANSWERS, December 06, 2013 RbNW R ANDERSON, SHERIFF In the Court of Common Pleas of Cumberland County OCWEN LOAN SERVICING,LLC ^' 1100 Virginia Drive - y Suite 175 Fort Washington,PA 19034 No. 13-6930-v b r f Plaintiff ' N vs. [ - GEORGE L. SHUGHART "� ; (Mortgagor(s)and Record Owner(s)) c_ 39 Wilson Street >Carlisle,PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against GEORGE L. SHUGHART by default for want of an Answer. Assess damages as follows: $116,351.61 Debt Interest from 3/19/2014 to Date of Sale per diem at$21.78 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached. R.C.P. 237.1 By: KML LA GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 9238 CO 1 / �/ (et 1P4( (4 Attorneys for Plaintiff ' C 510191.1 AND NOW clO•fit March apI`f ,Judgment is entered in favor of OCWEN LOAN SERVICING,LLC and against GEORGE L.SHUGHART b efault wan Answer and ages assessed in the sum of$116,351.61 as per the above certification. oth 4I iv,JO PD Arr./ 6-07101 a'21 p-tv3O3cLII NiufiCe Wailed • Rule of Civil Procedure No. 236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW OCWEN LOAN SERVICING,LLC 1100 Virginia Drive Suite 175 Fort Washington,PA 19034 Plaintiff No. 13-6930-civil vs. GEORGE L. SHUGHART (Mortgagors and Record Owner(s)) 39 Wilson Street Carlisle,PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County joba3041400 1 Courthouse Square Carlisle,PA 17013 Prothonotary By: Deputy If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 - — • 125160FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 14,2014 TO: GEORGE L.SHUGHART SHUGHART,GEORGE L. 39 Wilson Street Carlisle,PA 17013 In the Court of OCWEN LOAN SERVICING,LLC Common Pleas 1100 Virginia Drive of Cumberland County Suite 175 Fort Washington,PA 19034 Plaintiff CIVIL ACTION-LAW vs. - GEORGE L. SHUGHART Action of (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 39 Wilson Street Carlisle,PA 17013 No. 13-6930-civil Defendant(s) TO: GEORGE L.SHUGHART 39 Wilson Street Carlisle,PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIYIEN 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 (10) 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: KML LAW L.ROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 1 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 1 _ ......._.-. - -__. ._:._. I. .. . _ 125160FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE %. PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 14,2014 TO: GEORGE L.SHUGHART SHUGHART,GEORGE L. 34 Prickly Pear Drive Carlisle,PA 17013 In the Court of OCWEN LOAN SERVICING,LLC Common Pleas 1100 Virginia Drive of Cumberland County Suite 175 Fort Washington,PA 19034 Plaintiff CIVIL ACTION-LAW vs. GEORGE L.SHUGHART Action of f, (Mortgagor(s)and Record Owner(s)) Mortgage Foreclosure 39 Wilson Street Carlisle,PA 17013 No. 13-6930-civil Defendant(s) TO: GEORGE L.SHUGHART 34 Prickly Pear Drive Carlisle,PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI'1I EN 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 (10) 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 (61. By: KML LAW OUP,P.C. Michael McKeever Pa.ID 56129 • Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA OCWEN LOAN SERVICING,LLC Plaintiff vs. GEORGE L.SHUGHART NO. 13-6930-civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): GEORGE L. SHUGHART,has a last known residence of 34 Prickly Pear Drive, Carlisle, PA 17013. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. Date 3//q/2. ) By: KML LAW GROUP,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa.ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Mar-18-2014 09:18:52 AM SCRA 3.0 * `aa Status Report , ._ want to Servicememb is Civil Relief Act Last Name: SHUGHART First Name: GEORGE Middle Name: L. Active Duty Status As Of: Mar-18-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Cat-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOM,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. Afloat y/t. at ` 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: F81002F4U0F5IC0 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff OCWEN LOAN SERVICING,LLC 1100 Virginia Drive IN THE COURT OF COMMON PLEAS Suite 175 Fort Washington,PA 19034 of Cumberland County Plaintiff vs. CIVIL ACTION LAW GEORGE L. SHUGHART (Mortgagor(s)and Record owner(s)) 39 Wilson Street ACTION OF MORTGAGE FORECLOSURE Carlisle,PA 17013 Defendant(s) No. 13-6930-civil ORDER FOR JUDGMENT Please enter Judgment in favor of OCWEN LOAN SERVICING,LLC,and against GEORGE L. SHUGHART for failure to file an Answer in the above action within(20)days from the date of service of the Complaint,in the sum of $116,351.61. By: KML LAW ROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff /94 (A I hereby certify that the above names are correct and that the precise residence address of the judgment creditor isd u-�/az�� OCWEN LOAN SERVICING,LLC 1100 Virginia Drive Suite 175 Fort Washington,PA 19034 and that the name(s)and last,7 known address(es)of the Defendant(s)is/are GEORGE L. SHUGHART,34 Prickly Pear Drive Carlisle,PA 17013; By: (.•''ll��]J y KML LAW GROUP,P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I.Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff �/_1��d -kr 1117L- 641 xo ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $107,785.97 Interest from 04/01/2013 through $7,624.57 03/18/2014 Late Charges $280.37 Advance Escrow $660.70 $116,351.61 By: L '—Y, KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa. ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff J /� AND NOW,this 317 day of Math ,2014 damages are assessed as above. )1004)41„i Pro rothy 13-6930-civil/125160FC • PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff OCWEN LOAN SERVICING,LLC 1100 Virginia Drive Suite 175 IN THE COURT OF COMMON PLEAS Fort Washington,PA 19034 Plaintiff of Cumberland County vs. CIVIL ACTION—LAW GEORGE L.SHUGHART Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 39 Wilson Street Carlisle,PA 17013..., Defendant(s) No. 13-6930-civil - CD PRAECIPE FOR WRIT OF EXECUTION = D — C= TO THE PROTHONOTARY: ( � Issue Writ of Execution in the above matter: Amount Due $116,351.61 Interest from 3/19/2014 to Date of Sale per diem at $21.78 sa$,50 P 13 ATI/ (Costs to be added) 51. 5(Q C8F 103. 15 u Ito•50 X00.31 - Pb ATrY By: a1 KML LAW GROUP,P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 d.a 5 Du�Co Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 '50 LL. Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff �) c 7b14�3 L �) a2c. /1 3039II /y k_ L (� �a Ziotu (,OrifuitQ' I 2 _ 0 / U U . U w § 8 _ \ - ƒ / - � k / \ / f ) cp VD \ q \ / \ \ \ � \ C 0 — % U * _ ° � o ca Eg � a - $ 44 $ / \ / a k � / / o5 / a\ \ x § / b \ w 9 @ 4 m � 7 © / § 0 ? 0J ? � � \_ Q , / \ 3 U \ E \ wk � / \ s \ J t 5 / P.1.1 U c U 2 \ / \ PO KML Law Group,P.C. Suite 5000—BNY Independence Center , 1 701 Market Street , t t Philadelphia,PA 19106 `` i f a t 20 1'-!} i I: 215-627-1322 Attorney for Plaintiff OCWEN LOAN SERVICING, LLC 1100 Virginia Drive Suite 175 IN THE COURT OF Fort Washington,PA 19034 COMMON PLEAS Plaintiff vs. of Cumberland County GEORGE L. SHUGHART CIVIL ACTION-LAW Mortgagor(s) and Record Owner(s) 39 Wilson Street ACTION OF Carlisle,PA 17013 MORTGAGE FORECLOSURE Defendant(s) NO. 13-6930-civil CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff,by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: KML LAW GROUP,P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa. ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff / 3/4 9/ KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff OCWEN LOAN SERVICING, LLC 1100 Virginia Drive IN THE COURT OF COMMON PLEAS Suite 175 Fort Washington,PA 19034 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW GEORGE L. SHUGHART (Mortgagor(s) and Record Owner(s)) 39 Wilson Street ACTION OF MORTGAGE FORECLOSURE Carlisle,PA 17013 Defendant(s) No. 13-6930-civil AFFIDAVIT PURSUANT TO RULE 3129 OCWEN LOAN SERVICING,LLC,Plaintiff in the above action,by counsel, KML Law Group,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: 39 Wilson Street Carlisle,PA 17013 1.Name and address of Owner(s)or Reputed Owner(s): C-3 GEORGE L. SHUGHART 34 Prickly Pear Drive 1 :L: Carlisle,PA 17013 - '� ` ' r re) c-_,`... 2.Name and address of Defendant(s)in the judgment: GEORGE L. SHUGHART -•..am._ 34 Prickly Pear Drive Carlisle,PA 17013 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 39 Wilson Street Carlisle,PA 17013 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. Section 4904 relating to unsworn falsification to authorities. DATED: 3/1 q/Z--v lc( aTh' By KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa.ID 92382 Attorneys for Plaintiff o 01-97a 13-6930-civil KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff OCWEN LOAN SERVICING,LLC 1100 Virginia Drive IN THE COURT OF COMMON PLEAS Suite 175 Fort Washington,PA 19034 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. GEORGE L. SHUGHART ACTION OF MORTGAGE Mortgagor(s)and Record Owner(s) FORECLOSURE 39 Wilson Street Carlisle,PA 17013 Docket No. 13-6930-civil Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE . USED FOR THAT PURPOSE. rn C7) r-1ia r} spa NOTICE OF SHERIFF'S SALE OF REAL PROPERTY SHUGHART,GEORGE L. 2:CC7,1 GEORGE L. SHUGHART 34 Prickly Pear Drive Carlisle,PA 17013 Your house at 39 Wilson Street,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday,September 03,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$116,351.61 obtained by OCWEN LOAN SERVICING,LLC against you. 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 OCWEN LOAN SERVICING,LLC,the back payments, late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 13-6930-civil 4. 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a 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 thirty(30)days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 • r 13-6930-civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 125160FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ' 13-6930-civil KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff OCWEN LOAN SERVICING,LLC 1100 Virginia Drive IN THE COURT OF COMMON PLEAS Suite 175 Fort Washington,PA 19034 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. GEORGE L. SHUGHART ACTION OF MORTGAGE Mortgagor(s)and Record Owner(s) FORECLOSURE 39 Wilson Street Carlisle, PA 17013 Docket No. 13-6930-civil Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. " - a r r n`"a - NOTICE OF SHERIFF'S SALE OF REAL PROPERTY n rv ` TO: SHUGHART,GEORGE L. _^ GEORGE L. SHUGHART 39 Wilson Street Carlisle,PA 17013 • Your house at 39 Wilson Street,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$116,351.61 obtained by OCWEN LOAN SERVICING,LLC against you. 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 OCWEN LOAN SERVICING,LLC,the back payments, late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 13-6930-civil 4. 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 below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a 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 thirty(30)days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-6930-civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 125160FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. F _f0M'' ,•.\., , THE COURT OF COMMON PLEAS �� - ' CUMBERLAND COUNTY PA '0( _PT_ )',;'1 Z DAVID D. BUELL,PROTHONOTARY "'�, Aok�"�V'-, 10 One Courthouse Square• Suite100 • Carlisle, PA• 17013 !����� (717)240-6195 \.117 iii www.ccpa.net OCWEN LOAN SERVICING,LLC Vs. NO 2013-6930 Civil Term CIVIL ACTION—LAW GEORGE L. SHUGHART 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: $116,351.61 L.L.: $.50 Interest FROM 3/19/2014 TO DATE OF SALE PER DIEM AT$21.78 Atty's Comm: Due Prothy: $2.25 Atty Paid: $200.31 Other Costs: Plaintiff Paid: �[,t���/�/_n'Date: MARCH 20,2014 1.........LI, David D.Buell,Prothonotary (Sed!) t : I, i, • . API i,i i_ Deputy REQUESTING PARTY: Name: ALYK L. OFLAVIAN,ESQUIRE Address: KML LAW GROUP,PC SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No.312912 KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff OCWEN LOAN SERVICING, LLC 1100 Virginia Drive Suite 175 Fort Washington, PA 19034 vs. GEORGE L. SHUGHART Mortgagor(s) and Record Owner(s) 39 Wilson Street Carlisle, PA 17013 Plaintiff Defendant(s) sf,`t(1iYu1 R 1014 4Uc -5 f4ti 1U: 35 • C(J �g��� fir 125160FC CF: 11/22/2013 SD: 09/03/2014 $116,351.61 Witt OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13 -6930 -civil CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Genevieve Mautz, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. 131 ectfully submitted BY: Genevieve M Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA OCWEN LOAN SERVICING, LLC; et seq. Plaintiff (Petitioner) V. GEORGE L. SHUGHART; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13 -6930 -CIVIL Sheriff's Sale Date: 9/3/2014 AFFIDAVIT OF SERVICE ❑ Complaint ❑ Summons El Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served GEORGE L. SHUGHART•the above process on the 23 day of April, 2014, at 3:22 o'clock, PM, at 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: [I By handing a copy to the Defendant(s) Description: Approximate Age 3640 Height 5'9 Weight 230 Race WHITE Sex MALE Hair BROWN Military Status: [I No Ll Yes Branch: Commonwealth/State of P4 • ) ) SS: County of 1164cl ) Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: %till'''. C4 0t a to me known, who being I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) File Number:125160FC Case ID #:3956293 Subscribed and swot re me this i f day of 4 ••• I , 20 1Y . COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflorbach, Notary Public Washington Township, Barks County My Comrnission Expircs islovembfin 113. 201? Notary Public Name and Address of Sender :ML LAW GROUP, P.C. QUITE 5000 01 MARKET STREET rHILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified ❑ Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation E Insured Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street, City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Free 1. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 TENANTS/OCCUPANTS 39 Wilson Carlisle, Street PA 17013 2. PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 3. 7 Harrisburg, PA 17105-2675 4. ' . •,› 4 • 2 • w L P'4974,46 PITNEY BI 021M $01 0004285957 MAR 2' MAILED FROM ZIP CODE 5. ..-- 6. 6. 7. 8. Total Number of Pieces Listed by Sender Total Number Pieces Received at Office Postmaster, Per e f receiving employee) See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) 125160FC Cumberland County Sale Date: 09/03/2014 GEORGE L. SHUGHART Complete by Typewriter, Ink, or Ball Point Pen KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff OCWEN LOAN SERVICING, LLC 1100 Virginia Drive Suite 175 Fort Washington, PA 19034 vs. GEORGE L. SHUGHART Mortgagor(s) and Record Owner(s) 39 Wilson Street Carlisle, PA 17013 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Tenn No. 13 -6930 -civil AFFIDAVIT PURSUANT TO RULE 3129 OCWEN LOAN SERVICING, LLC, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, 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: 39 Wilson Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): GEORGE L. SHUGHART 34 Prickly Pear Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: GEORGE L. SHUGHART 34 Prickly Pear Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 39 Wilson Street Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief..I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: July 28, 2014 .i1 -- KML Law Group, P.C. BY: Genevieve Mautz Legal Assistant PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 OCWEN LOAN SERVICING, LLC Plaintiff vs. GEORGE L. SHUGHART Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 2013-06930 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance as counsel on behalf of the Plaintiff, OCWEN LOAN SERVICING, LLC in the above captioned matter. Date: PH # 951090 B 11311y Phelan Hallinan, LLP By: Jo (han Lob., Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP C7.) C-) cri PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 OCWEN LOAN SERVICING, LLC Plaintiff vs. GEORGE L. SHUGHART Defendant CERTIFICATION OF SERVICE Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 2013-06930 I hereby certify a true and correct copy of the foregoing Entry of Appearance was served by regular mail on Defendant(s) on the date listed below: GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 Date: PH # 951090 GEORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 17013 CUMBERLAND COUNTY SHERIFFS OFFICE SHERIFF R THOMAS KLINE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 Phelan Hallinan, LLP By: Jfathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP tJ t:ILED-OF FiC,Z THE PRO THONO 2014 AUG 21 AMID: 07 CUMBERLAND COUNTY PENNS YLVANIA PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA OCWEN LOAN SERVICING, LLC Plaintiff Attorney for Plaintiff : CIVIL DIVISION v. : No.: 2013-06930 GEORGE L. SHUGHART Defendant(s) NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for 09/03/2014 at 10:00 AM in the above -captioned matter has been continued until 10/01/2014 at 10:00 AM. Date: PH # 951090 Jonath bb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Attorney for Plaintiff OCWEN LOAN SERVICING, LLC Plaintiff : CIVIL DIVISION v. : No.: 2013-06930 GEORGE L. SHUGHART Defendant(s) CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Notice of the Date of Continued Sheriffs Sale and Certificate of Filing were served by regular mail on the person(s) on the date listed below: GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 Date: /yB 1 t y PH # 951090 GEORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 170 3-2843 Jo an Lobb, Esq., Id. No.312174 Attorney for Plaintiff Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan c 215-563-7000 .?r THE PROTHONO--, 20A6Atic2 7 A TORNEY FOR PLAINTIFF H9.53 CUMBERLAND COU�i `` PENNSYLVANIA OCWEN LOAN SERVICING, LLC Plaintiff om Court of Common Pleas Civil Division v. GEORGE L. SHUGHART Defendant PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its Attorneys, Phelan Hallinan, LLP, moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. 2013. CUMBERLAND County No.: 2013-06930 Plaintiff commenced this foreclosure action by filing a Complaint on November 22, 2. Judgment was entered on March 20, 2014 in the amount of $116,351.61. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit "A". 3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item which can be calculated from the complaint, i.e. bringing the interest current. However, new items cannot be added at the time of entry of the judgment. 4. The Property is listed for Sheriffs Sale on October 1, 2014. 951090 1 5. Additional sums have been incurred or expended on Defendant's behalf since the Complaint was filed and Defendant has been given credit for any payments that have been made since the judgment. The amount of damages should now read as follows: Principal Balance Interest Through August 13, 2014 Late Charges Legal fees Cost of Suit and Title Property Inspections Escrow Deficit $107,785.97 $10,860.22 $80.12 $2,350.00 $225.00 $105.00 $2,045.56 TOTAL $123,451.87 6. The judgment formerly entered is insufficient to satisfy the amounts due on the Mortgage. 7. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of judgment against the Defendant. 8. Plaintiff's foreclosure judgment is in rem only and does not include personal liability, as addressed in Plaintiffs attached brief. 9. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on August 26, 2014 and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. A true and correct copy of Plaintiffs letter pursuant to Local Rule 208.3(9) and certification of mailing are attached hereto, made part hereof, and marked as Exhibit "B". 10. No judge has previously entered a ruling in this case. 951090 2 WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. DATE: 726/q By: Phelan Hallinan, LLP Al , Jon., . ' M. Etkowicz, Esquire AT � e ' EY FOR PLAINTIFF 3 951090 Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan.com 215-563-7000 OCWEN LOAN SERVICING, LLC Plaintiff v. GEORGE L. SHUGHART Defendant ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 2013-06930 MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES I. BACKGROUND OF CASE GEORGE L. SHUGHART executed a Promissory Note agreeing to pay principal, interest, late charges, real estate taxes, hazard insurance premiums, and mortgage insurance premiums as these sums became due. Plaintiffs Note was secured by a Mortgage on the Property located at 39 WILSON STREET, CARLISLE, PA 17013-2843. The Mortgage indicates that in the event of a default in the mortgage, Plaintiff may advance any necessary sums, including taxes, insurance, and other items, in order to protect the security of the Mortgage. In the instant case, Defendant defaulted under the Mortgage by failing to tender numerous, promised monthly mortgage payments. Accordingly, after it was clear that the default would not be cured, Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently entered by the Court, and the Property is currently scheduled for Sheriffs Sale. 951090 1 Because of the excessive period of time between the initiation of the mortgage foreclosure action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums, costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage in order to protect its interests. It is also appropriate to give Defendant credit for monthly payments tendered through bankruptcy, if any. II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM JUDGMENT It is settled law in Pennsylvania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase Home Mortgage Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super. 1988). The Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its judgment prior to the Sheriffs sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489 (Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. v. Mowl, 705 A.2d 923 (Pa. Super. 1998). Union National Bank of Pittsburgh v. Ciongoli, 407 Pa.Super. 171, 595 A.2d 179 (1991). The Supreme Court of Pennsylvania recognized in Landau v. Western Pa. Nat. Bank, 445 Pa. 117, 282 A.2d 335 (1971), that the debt owed on a Mortgage is subject to change and, in fact, can be expected to change from day to day because the bank must advance sums in order to protect its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d 826 (1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality 951090 2 Company v. Burns, 414 Pa. 495, 200 A.2d 335 (1971). Plaintiff submits that if it goes to sale without the requested amended judgment, and if there is competitive bidding for the Property, Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to protect its interests. Conversely, amending the in rem judgment will not be detrimental to Defendant as it imputes no personal liability. In B.C.Y. v. Bukovich, the Pennsylvania Superior Court reiterated its long standing rule that a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa. Super. 157, 390 A.2d 276 (1978). In the within case, the amount of the original judgment does not adequately reflect the additional sums due on the Mortgage due to Defendant's failure to tender payments during the foreclosure proceeding and the advances made by the mortgage company. The Mortgage plainly requires the mortgagor to tender to the mortgagee monthly payments of principal and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagor is also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance premiums, fire insurance premiums, taxes and other assessments relating to the Property. The mortgagor has breached the terms of the Mortgage, and Plaintiff has been forced to incur significant unjust financial losses on this loan. III. THE FORECLOSURE JUDGMENT IS IN REM ONLY The within case is a mortgage foreclosure action, the sole purpose of which is to take the mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage foreclosure is strictly in rem and does not include any personal liability. Newtown Village Partnership v. Kimmel, 424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer 951090 3 Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978). Pennsylvania Rule of Civil Procedure 1141(a). However, Pennsylvania law requires that the foreclosure action demand judgment for the amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for bidding at the Sheriffs Sale. In the event that a third party real estate speculator were to bid on the mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would receive the amount of the in rem judgment from the Sheriff. IV. INTEREST The Mortgage clearly requires that the Defendant shall promptly pay when due the principal and interest due on the outstanding debt. In addition, the Note specifies the rate of interest to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days prior to the date of default through the date of the impending Sheriffs sale has been requested. V. TAXES AND INSURANCE If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale, Plaintiffs interest very well may be divested, and Plaintiff would sustain a complete loss on the outstanding balance due on the loan. If the Property were damaged in a fire, Plaintiff would not be able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums. Most importantly, the Mortgage specifically provides that the mortgagee may advance the monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is simply seeking to have the Court enforce the terms of the Mortgage. 951090 4 VI. ATTORNEY'S FEES The Plaintiffs foreclosure fees are very modest. They cover all of the legal work done throughout the course of the foreclosure action to date, including reviewing the Act 6 or Act 91 letters, loan documents, account records, title reports and supporting documents, preparing and reviewing the mortgage foreclosure complaint, filing and service of the complaint, Rule 237.1 Notice, Department of Defense search, entry of judgment, the writ of execution process, lien holder notices, and all of the other legal work that goes into handling the mortgage foreclosure lawsuit. The Mortgage specifically provides for Plaintiff's recovery of its attorney fees. The amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded that a request of five percent of the outstanding principal balance is reasonable and enforceable as an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865); First Federal Savings and Loan Association v. Street Road Shopping Center, 68 D&C 2d 751, 755 (1974). In Federal Land Bank of Baltimore v. Fetner, the Superior Court held that an attorney's fee of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super. 1979). The Superior Court cited Fetner in confirming that an attorney's fee of ten percent included in the judgment in mortgage foreclosure action was reasonable. Citicorp v. Morrisville Hampton Realty, 662 A.2d 1120 (Pa. Super. 1995). Plaintiffs legal fees are not a percentage but are significantly less than what is permitted by Pennsylvania law. 951090 5 VII. COST OF SUIT AND TITLE Pursuant to the terms of the mortgage, Plaintiff is entitled to recover all expenses incurred in the foreclosure action. The amount claimed for the costs of suit and title are the expenses Plaintiff paid to date as a result of the mortgage default. The title report is necessary to determine the record owners of the property, as Pa.R.C.P. 1144 requires all record owners to be named as Defendants in the foreclosure action. It is also necessary to determine whether there are any prior liens to be cleared, so that the Sheriff's sale purchaser acquires clear title to the property. It is necessary to determine if there are IRS liens on the property, whether the Defendants are divorced (which could affect service of the complaint), and numerous other legal issues. The title bringdown is necessary to identify any new liens on the property or new owners between the time of filing and complaint and the writ date. The Freedom of Information Act inquiries and the investigation into Defendants' whereabouts are necessary to effectively attempt personal service of the complaint and notice of sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1 and 3129.2 to notify all lienholders, owners, and interested persons of the Sheriff's sale date, as their interests will be divested by the Sheriffs sale. Accordingly, the modest sums Plaintiff has incurred for the costs of suit and title were necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incurred. The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of suit and title in their entirety, which will not cause harm to the Defendants. 951090 6 VIII. PROPERTY INSPECTIONS AND PRESERVATION The terms of the mortgage provide for property inspections and property preservation charges. The lender or its agent may make reasonable inspections of the property pursuant to the terms of the mortgage. When a borrower defaults under the terms of the mortgage, the lender may do, or pay for, whatever is reasonable to protect its interest in the collateral, including property maintenance. Any amounts disbursed by the lender for property inspections and preservation become additional debt of the borrower secured by the mortgage. The lender may charge the borrower for services performed in connection with the default, for the purpose of protecting the lender's interest in the property, including property inspections and valuation costs. When a loan is in default, the lender's risk increases. Mortgage companies typically have a vendor visit the premises to determine if any windows need to be boarded up, if the property is vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection reveals any problems at the mortgaged premises, then the mortgage company may proceed to take whatever steps are necessary to secure the collateral, such as boarding windows, winterizing, removing hazards or debris, etc. The mortgage company generally pays a vendor to handle these tasks, which are referred to in the industry as "property preservation". These services avoid code violations and avoid the property becoming an eyesore in the neighborhood. Property preservation helps maintain property values in the neighborhood. Accordingly, line items included in Motions to Reassess Damages for property inspections and property preservation represent amounts which the mortgage company has paid out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract. Since the terms of the mortgage provide that such expenses by the mortgage company become 951090 7 part of the borrower's debt secured by the mortgage, those expenses are properly included in the Plaintiff's Motion to Reassess Damages. IX. CONCLUSION Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by legal proceedings, and such delays require the mortgagee to expend additional sums provided for by the Mortgage, then the expenses necessarily become part of the mortgagee's lien and should be included in the judgment. Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance with the Mortgage, and has relied on terms of the Mortgage with the understanding that it would recover the monies it expended to protect its collateral. WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. DATE: By: Phelan H man, LLP Jonatha r . tkowicz, Esquire Attorne or Plaintiff 8 951090 Exhibit "A" In the Court of Common Pleas of Cumberland County OCWEN LOAN SERVICING, LLC 1100 Virginia Drive Suite 175 Fort Washington, PA 19034 vs. GEORGE L. SHUGHART (Mortgagor(s) and Record Owner(s)) 39 Wilson Street Carlisle, PA 17013 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 13-69304N:4 =w > C-.) 0 C) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against GEORGE L. SHUGHART by default for want of an Answer: Assess damages as follows: Debt $116,351.61 Interest from 3/19/2014 to Date of Sale per diem at $21.78 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 _Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 _Thomas Puleo Pa. ID 27615 Joshua 1. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gomalt Pa. ID 92382 Attorneys for Plaintiff AND NOW oZ041` March o2Df OCWEN LOAN SERVICING, LLC and against GEORGE L. SHUGHART b assessed in the sum of $116,351.61 as per the above certification. k 31.19f.). , Judgment is entered in favor'of efault wan�,�t Answer and ei ages gitt 119. 4110.5o Pn An'/ 01710143 X3830211 64ice. JJatt d Exhibit "B" PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan, LLP Representing Lenders in Pennsylvania August 19, 2014 GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 RE: OCWEN LOAN SERVICING, LLC v. GEORGE L. SHUGHART Premises Address: 39 WILSON STREET CARLISLE, PA 17013 CUMBERLAND County CCP, No. 2013-06930 Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by 8/25/2014. Should you have further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. V. :T. I. lily !your, Jona Etkovvicz, Esq., Id. No.208786 Atto for Plaintiff Enclosure 951090 Name and Address Of Sender us+ Phelan. Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 JOH Line Article Number Name of Addressee, Street, and Post Office Address I. GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 Postage $0.47 2 GEORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 $0.47 RE: GEORGE L. SHUGHART (CUMBERLAND) PH # 951090/1200 Page I of 1 $0.94 Total Number of Pieces Listed by Sender Form 3877 Facsimile Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Employee) 'The full declaration of value. required on all'domestfc and international registered mail. The maximum inde. 'for thereconstntctioisof nann gotiable document, under Express Mail document reconstruction insurance is 5: piece subject to a limit ofS500,000 per occuncnee, The maximum indemnity payable on Express Mail mercha The maximum indemnity payable is S25,006 for registered mail,sent with optional insurance. See Domestic M 8900 S913 and 5921 for limitations of coverage, 95109( Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan corn 215-563-7000 OCWEN LOAN SERVICING, LLC Plaintiff v. GEORGE L. SHUGHART Defendant CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, were sent to the following individual on the date indicated below. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 2013-06930 GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 DATE: By: GEORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 Phelan Hallinan, LLP Jonath ATTO II.Li f.: Etkowicz, Esquire ' EY FOR PLAINTIFF 951090 h y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA OCWEN LOAN SERVICING, LLC Plaintiff v. GEORGE L.SHUGHART Defendant RULE Court of Common Pleas Civil Division CUMBERLAND County No.: 2013-06930 AND NOW, this Z$4. day of `" 2014, a Rule is entered upon the Defendant to show cause why an Order should not be entered granting Plaintiffs Motion to Reassess Damages. Defendant shall have twenty (20) days from the date of this Order to file a response to Plaintiff s Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. c N t,© 951090 r t • Jonathan M. Etkowicz, Esq., Id. No.208786 P1helan Hallinan, LLP 617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 TEL: (215) 563-7000 FAX: (215) 563-3459 //GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 co ties lam. ep9/At ,."FORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 951090 951090 PHELAN HALLINAN, LLP Paul Cressman, Esq., Id. No.318079 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 paul.cressman@phelanhallinan.com 215-563-7000 2014 SEP -2afi � qq fYfty for Plaintiff CUMBERLAND COUNTY PENNS YLVAtdIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA OCWEN LOAN SERVICING, LLC Plaintiff, v. GEORGE L. SHUGHART Defendant(s) . CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.: 2013-06930 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817 and/or Certified Mail Return Receipt stamped by the U.S. Postal Service i Date: ed hereto Ex 99 Paul Cress •rney A an, Esq., Id. No.318079 or Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PH # 951090 OCWEN Loan Servicing, LLC Plaintiff V. George L. Shughart Defendant(s) 21ReiSEP -2 AM 9:58 CUMBERLAND COIPU T Y PENNSYLVANIA: COURT OF COMMON PLEAS CIVIL DIVISION NO.: 2013-06930 CUMBERLAND COUNTY AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 OCWEN Loan Servicing, LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 39 Wilson Street, Carlisle, PA 17013-2843. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) George L. Shughart 34 Prickly Pear Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Name George L. Shughart Address (if address cannot be reasonably ascertained, please so indicate) 34 Prickly Pear Drive Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) 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. Name Address (if address cannot be reasonably ascertained, please indicate) None. 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: PH # 951090 Name Tenant/Occupant Commonwealth of Pennsylvania Bureau of Individual Taxes Inheritance Tax Division Domestic Relations of Cumberland County Heather Armstrong Shughart Heather Armstrong Shughart C/O Marcus A. Mcknight III, Esq. PA Department of Public Welfare-bueau of Child Support Enforcement PA Department of Revenue Bureau of Individual Taxes Inheritance Tax Division Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for The Middle District of PA Federal Building Address (if address cannot be reasonably ascertained, please indicate) 39 Wilson Street Carlisle, PA 17013-2843 6th Floor, Strawberry Sq. Dept 280601 Harrisburg, PA 17128 PO Box 320 Carlisle, PA 17013 9 Wiltshire West Street Carlisle, PA 17015-7100 Irwin & Mcknight PC 60 W Pomfret St. Carlisle, PA 17013-2222 Health and Welfare Bldg -room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 P.O. Box 280601 Harrisburg, PA 17128-0601 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to Date: PH # 951090 elan HaIli an, LLP /attorneyNa e/ Attorney or laintiff PHELAN LINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 Name and Address Of Sender Phelan Hallinan, LLP IMO 16171 B FK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 VS Line Article Number /.n4 IWV IriV I4 JALC Name of Addressee, Street, and Post Office Address t LJ Posta8 ' h- 1 '••• TENANT/OCCUPANT 39 WILSON STREET CARLISLE, PA 17013-2843 ./ 50.47 " ' .s> .:7 2 *•'• Commonwealth of Pennsylvania Bureau of Individual Taxes Inheritance Tax Division50.47 6th Floor, Strawberry Sq. Dept 280601 ,� Harrisburg, PA 17128 3 **•• Domestic Relations of Cumberland County PO BOX 320 CARLISLE, PA 17013 50.47 4 Heather Armstrong Shughart 9 WILTSHIRE WEST STREET CARLISLE, PA 17015-7100 50.47 to 5 •••* Heather Armstrong Shughart C/0 Marcus A. Mcknight 111, Esq. IRWIN & MCKNIGHT PC 60 W POMFRET ST ' CARLISLE, PA 17013-2222 50.47 6 •*** PA Department of Public Welfare-bueau of Child Support Enforcement HEALTH AND WELFARE BLDG -ROOM 432 P.O. BOX 2675 a HARRISBURG, PA 17105-2675 ..•. PA Department of Revenue Bureau of Individual Taxes Inheritance Tax Division P.O. Box 280601( Harrisburg, PA 17128-0601 .- Domestic Relations of Cumberland County r - 13 North Hanover Street Carlisle, PA 17013 50.47 50.47 {.� 50.47 L� 7 •••• $ '•'• 9 **•* Commonwealth of Pennsylvania a.. Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 1 30.47(,.`" d, \ r0 ✓ v l a 10 •*** Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 50.47 11 '•*• U.S. Department of Justice U.S. Attorney for The Middle District of PA Federal Building 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, P�121081154_ — - --- —" __ , _ r T 50.47 Cis, :GEORGE-) SHUGHART (CUMBERLAND) PH # 951090/1021 Pagel of 1 '- -Wrill Team 55.64 Total Nomber of Pieces Listed by Sender Fnrm iS177 Foncineaa Total Number of Pieces Remised at Post Office Postmaster, Per (Name of ReceivingEmployee)0 The full declaration civet= is required on all domestic and imemational registered mail. The maxilnhm indemnity fa the reconstruction of nonnegotiable documents render Express Mail doenmenl reconstruction insurance � 550,(10(1 per pper piece subject to a limit 01'5500000 per occurrence, The maximum indemnity payable on Express Mnil merchandise is 5500. The maximum Indemmry payable is 85,000 for registered mil, sent with optional jasmines. Sen Domestic Mail Manual R900 5913 and 5921 for limitations of coverage. Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan.com 215-563-7000 OCWEN LOAN SERVICING, LLC Plaintiff vs. GEORGE L. SHUGHART Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's August 28, 2014 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 2013-06930 GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 DATE: By: GEORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 Phelan H.I�!<: LLP Jonathan Attorney e= t owicz, Esq., Id. No.208Pig laintiff ,,---rn„ r c,a .:- 951090 Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adarn.Davis@PhelanHallinan.com 215-563-7000 OCWEN LOAN SERVICING, LLC Plaintiff vs. GEORGE L. SHUGHART HEATHER A. ARMSTRONG-SHUGHART ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 2013-06930 Defendants PRAECIPE TO WITHDRAW MOTION TO REASSESS DAMAGES TO THE PROTHONOTARY: Plaintiff hereby withdraws its Motion to Reassess Damages, filed on August 27, 2014 in the above referenced action. Phelan Hallinan, LLP DATE: By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 951090 Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 OCWEN LOAN SERVICING, LLC Plaintiff vs. GEORGE L. SHUGHART HEATHER A. ARMSTRONG-SHUGHART ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 2013-06930 Defendants CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Praecipe to Withdraw its Motion to Reassess Damages was served upon the following interested parties on the date indicated below. GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 GEORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 HEATHER A. ARMSTRONG-SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 951090 HEATHER A. ARMSTRONG-SHUGHART 34 PRICKLY PEAR DR CARLISLE, PA 17013-8545 DATE: Phelan Hallinan, LLP 7707/7 By: Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 951090 OF FiLED-OFPICL. THE PROTHONOTAR- 2014 SEP 23 AM 10: 01 CUMBERLAND O PEN SYLVANC14UNTY PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA OCWEN LOAN SERVICING, LLC Plaintiff V. GEORGE L. SHUGHART HEATHER A. ARMSTRONG-SHUGHART Defendant(s) Attorney for Plaintiff : CIVIL DIVISION : No.: 2013-06930 NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for 10/01/2014 at 10:00 AM in the above -captioned matter has been continued until 01/07/2015 at 10:00 AM. Date: PH # 951090 Jothan Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Attorney for Plaintiff OCWEN LOAN SERVICING, LLC Plaintiff : CIVIL DIVISION v. : No.: 2013-06930 GEORGE L. SHUGHART HEATHER A. ARMSTRONG-SHUGHART Defendant(s) CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Notice of the Date of Continued Sheriffs Sale and Certificate of Filing were served by regular mail on the person(s) on the date listed below: GEORGE L. SHUGHART 34 PRICKLY PEAR DRIVE CARLISLE, PA 17013 HEATHER A. ARMSTRONG-SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 Date: PH # 951090 GEORGE L. SHUGHART 39 WILSON STREET CARLISLE, PA 17013-2843 HEATHER A. ARMSTRONG-SHUGHART 34 PRICKLY PEAR DR CARLISLE, PA 17013-8545 Jon an Lobb, Esq., Id. No.312174 At orney for Plaintiff