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HomeMy WebLinkAbout14-0382 Fax Jan 21 2014 09:45am /`001/001 Supreme C� unsylvania :!!``!ii'a� ": ''�........ °r("• z >'r,. 'iHi:y:Nt , y.:. .('., _.,n.:grz Cou leas a ; E<Ps'...,, County %y^ %.`% , 1 Sr:elrltL 11::1: � I.1� F "•: . :r .p Ln.'. , :: E Jlil�� f`: P• ��. t- •�'i�l,,l.:;.• " .,r'CrY>' lli , F '1 The in collected on this form is used solely for court administration purposes- This form does not sup plement or replace the ling and service o pleadings or other pa r as required by law or rules o court. Commencement of Action: s 0 Complaint ® Writ of Summons © Petition Transfer from Another Jurisdiction 13 Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: U.S. Bank National Association MICHAEL HARRIS A/K/A MICHAEL P. HARRIS; et al 1. Ar e money damages requested? E3 Yes Dollar Amount Req uested: No (check one) El El arbitration limits Is this a Class Action Suit? ® Yes 0 No Is this an MJAppeal? 13 Yes 0 No r Name ofPlaintiff/Appellarat's Attorney: Elizabeth Wassail ( Cheep here if you have no attorney (are a Self-Represented [Pro Se] .Litigant) N l a of ati�e: Casre is ; ;:Puce azii `'� ". ;t ; fine e ; ;o the , ONE ?c cateao atul ", `ai at : osY arc descrii o .. ou 'a �+.� ,�dv. to r Y CASE J f you:'ate' almz ' a ' y d r b . e thau oiio' ; r o :.¢ ck the oiie e. • you. orxsider,tnost::trn ortaiit: TORT (do not include Mass Tort) CO NTRA CT (do not include Judgments) CIVIL APPEALS y ,3 Intentional 13 Buyer Plaintiff Administrative Agencies © Malicious Prosecution ® Debt Collection: Credit Card ® Board of Assessment Motor Vehicle [3 Debt Collection: Other [3 Board of Elections ® Nuisance Dept_ of Transportation ® Premises Liability ® Statutory Appeal: Other ® Product Liability (does not include Y S mass tort) 13 Employment Dispute: 13 Slander/Libel/ Defamation Discrimination C1 Other: © Employment Dispute: Other ® Zoning Board © other: ® Other: MASS TORT 0. Asbestos Tobacco 0 Toxic Tort - DES 13 Toxic Tort - Implant REAL PROPERTY MSCELLANEOUS Toxic Waste ® Other: ® Ejectment ® Common Law /Statutory Arbitration ® Eminent Domain/Condemnation [3 Declaratory Judgment „.! ® Ground Rent ® Mandamus ® Landlord/Tenant Dispute Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIA,BLITY Q Mortgage Foreclosure: Commercial © Quo wwranto ® Dental ® Partition ® Replevin ® Legal 13 Quiet Title Other: Q Medical [3 Other: Y i t� E3 Other Professional: p�J a' Updated 1/1/2011 0 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINT„ BY: MARK J. UDREN, ESQUIRE - ID #04302'; STUART WINNEG, ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID #77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 NICOLE B. LABLETTA, ESQUIRE - ID #202194 DAVID NEEREN, ESQUIRE - ID #204252 JORDAN DAVID, ESQUIRE - ID #311968 AMANDA RAVER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 pleadings @udren.com U.S. Bank National Association, as Trustee for Asset COURT OF COMMON Backed Securities Corporation Home Equity Loan Trust, PLEAS Series OOMC 2006 -HE5, Asset Backed Pass - Through CIVIL DIVISION Certificates, Series OOMC 2006 -HE5 CUMBERLAND County C/O Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 NO. Plaintiff V. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE Q a *-3) YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990 -9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 -3620 (856) 669 -5400 a 1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Sand Canyon Corporation f/k/a Option One Mortgage Corporation Assignee: U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006 -HE5, Asset Backed Pass - Through Certificates, Series OOMC 2006 -HE5 Date of Assignment: 08/18/2011 Recorded Date: 09/09/2011 Book/Instrument #: Instrument Number: 201125088 Page: NA 2. Upon information and belief Defendant(s) and /or their predecessor: Michael Harris a/k/a Michael P. Harris and Carrie Vogelsong a/k/a Carrie M. Vogelsong (hereinafter "Defendants "), are the owners of property located at 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013, by virtue of Deed dated 04/28/2006 and recorded 05/01/2006 in Official Records Book 274 at Page 1409 of the Public Records of Cumberland County, Pennsylvania (hereinafter the 'Property "). 3. On 04/28/2006, Defendant(s) and /or their predecessor: MICHAEL HARRIS A /K/A MICHAEL P. HARRIS AND CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG promised to pay to the order of Option One Mortgage Corporation, a California Corporation, the principal sum of $ 107,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 04/28/2006, Defendant(s) and /or their predecessor: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS AND CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG to secure the Note, mortgaged to Option One Mortgage Corporation, A California Corporation, the Property which is the subject of this action. The Mortgage was recorded on 05/01/2006 in Official Records Book 1948 at Page 4106 .Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 04/01/2012, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $113,491.22 Accumulated Interest $9,625.53 Accumulated Late Charges $502.20 Escrow Deficit /(Reserve) $5,358.86 Title Report $300.00 Attorney Fee $1,650.00 Property Inspection Fee $73.50 Property Valuation Fee $392.00 Prior Servicer Fees $80.00 Bankruptcy Cost $176.00 Grand Total $131,649.31 The above figures are calculated as of 11/08/2013: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 5.12500 %. The per diem interest accruing on this debt is $15.5300 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $41.85. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and /or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A ". WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $ 131,649.31 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW fCES, P.C. BY: c'/ c, t7Anc�, ecc ALL, ESQ PA ID 77788 . 'VERIFICATION I am Doris Franco �Q0M*AW of Ocwen Loan Servicing, LLC ( "Ocwen ") the servicing agent (or servicer) for U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006 -HE5, Asset Backed Pass - Through Certificates, Series OOMC 2006 -HE5 ('Plaintiff'), am authorized to make this verification on behalf of Ocwen and hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and /or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocwen's mortgage servicing business conducted on Plaintiffs behalf. In making this verification, I understand that it is a crime under 18 PA C.S. Section 4904 to make a written statement to a public servant, or to invite a public servant's reliance upon a written statement or instrument, which I do not believe to be true o which I know to be false Date: ��� 3 Name: Doris Franco Title: conwMra w#0Cow or Company: Ocwen Loan Servicing, LLC the servicing agent (or servicer) for U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006 -HE5, Asset Backed Pass - Through Certificates, Series OOMC 2006 -HE5 Borrower: MICHAEL HARRIS A /K/A MICHAEL P. HARRIS CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG Property Address: 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 MJU #: 11080180 -2 SCHEDULE C Legal Description Commitment Number: 1606 ALL that certain lot, parcel, piece of ground, with the improvements thereon erected, situate in Mechanicsburg Borough, Cumberland County, Pennsylvania, bounded and described in accordance with a survey prepared by D.P. Raffensberger Associates, dated August 13, 1982, as follows, to wit: BEGINNING at an iron pin on the northeast line of West Green Street at corner of property now or late of John A.H. Zeigler and Anna Zeigler, his wife; thence along said last mentioned land, North 2 degrees 15 minutes East, 12.80 feet of a point; thence along the same, North 9 degrees 54 minutes West, 16.43 feet to a point; thence along the same, North 80 degrees 4 minutes 38 seconds East, 4.19 feet to a point thence along the same, North 2 degrees 15 minutes East 92.40 feet to a post at a 15 foot alley; thence by said alley, North 79 degrees 15 minutes East 27 feet to a point at the dividing line between the lot herein described and Lot No_ 2 ' as described in the above - referenced survey: thence along said last mentioned dividing line South 2 degrees 15 minutes West 122 feet to a point on the northern side of West Green Street; thene along the northern side of West Green Street, South 79 degrees 15 minutes West 27.65 feet to an i iron pin, the Place of BEGINNING. f i A ot.Inty PA 0 Recorder of Deeds I i K 9 �� � STEWART TITLE GUARANTY COMPANY Homeward Residential, Inc. PRESORT PO Box 9092 First Class Mail Temecula, CA 92589 -9092 U.S. Postage and Fees Paid WSO 7196 9006 9296 5089 6998 Send Payments to: Homeward Residential, Inc. P.O. Box 660029 Dallas, TX 75266 -0029 20130125 -156 �nlliilllrli�Il�li�Illililllll�lill�lr�ii���r � �Illll�llu CARRIE M VOGELSONG 138 W GREEN ST Send Correspondence to: MECHANICSBURG, PA 17055 -6251 Homeward Residential, Inc. P.O. Box 632237 Irving, TX 75063 -2237 ��, ^� OP001PA Date: 01/25/2013 Sent Via Certified Mail 7196 9006 9296 5089 6998 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 save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITHA 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 the Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at (800) 342 -2397. (Persons with unpaired 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 NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. OP001 PA Page3 of 10 7196 9006 9296 5089 6998 HOMEOWNER'S NAME(S): MICHAEL HARRIS CARRIE M VOGELSONG PROPERTY ADDRESS: 138 W GREEN ST MECHANICSBURG, PA 17055 LOAN ACCT. NO.: ORIGINAL LENDER: OPTION ONE MORTGAGE CORPORATION CURRENT LENDER/SERVICER: HOMEWARD RESIDENTIAL, INC. 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 consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face -to face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature ofyour 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 APPLICATIONAS SOONAS POSSIBLE. IF YOU HAVE A MEETING WITH OP001_PA Page4of10 7196 9006 9296 S089 6998 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, 1N 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 YOUARE CURRENTLY PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAULT (I3rhig it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 138 W GREEN ST MECHANICSBURG, PA 17055 IS SERIOUSLYIN DEFA ULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments from 04/01/2012 $9,781.33 (10 @ $978.61) Late Charge(s) (if applicable): $418.50 Other Charge(s): NSF and Advances (if applicable): $80.00 Less: Credit Balance: $0.00 TOTAL, AMOUNT PAST DUE: $10,279.83 HOW TO CURE THE DEFA UL - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $10279.83 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD_ Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: Homeward Residential, Inc. P.O. Box 632237 Dallas, TX 75063 -2237 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (3 0) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender * also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. OP001_PA Page 5of10 7196 9006 9296 5069 6996 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 attorneys' fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anytime 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 Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before Elie 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. HOLY TO CONTACT THE LENDER: Name of Lender. Homeward Residential, hie. Address: P.O. Box 632237 Dallas 75063 -2237 Phone Number. (877) 304 -3100 Fax Number: (866) 546 -6746 Contact Person: Karen Williams E -Mail Address: Karen.Williams @gohomeward.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may 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 other requirements of the mortgage are satisfied. OP007 PA Page 6of10 7196 9006 9296 5089 6998 YOU MAY ALSO HAYE 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 (3) TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST Sincerely, Homeward Residential, Inc. P.O. Box 632237 Dallas, TX 75063 -2237 OP001_PA Page7of10 7196 9006 9296 5089 6998 HEMAP Consumer Credit Counseling Agencies YORK County Report last updated: 01/0912013 10:27 AM 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 HC Page 8of10 7196 9006 9296 5089 6996 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 01/09/2013 10:27 AM Advantage Credit Counseling Service/CCCS of Western PA Conmiunity 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 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717 -234 -661.6 717 - 264 -5913 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 HC Page 9 of] 0 7196 9006 9296 5089 6998 Homeward Residential, Inc. PRESORT PO Box 9092 Temecula, CA 92589 -9092 First -Class Mail U.S. Postage and Fees Paid WSO 7196 9006 9296 5089 6981 Send Payments to: Homeward Residential, Inc. P.O. Box 660029 Dallas, TX 75266 -0029 20130125 -156 1i1nll- li Ill-- l�i�iin��111 1 MICHAEL HARRIS 138 W GREEN ST Send Correspondence to: MECHANICSBURG, PA 17055 -6251 Homeward Residential, Inc. P.O. Box 632237 Irving, TX 75063 -2237 Exhibit A O P001 _PA Date: 01/25/2013 Sent Via Certified Mail 7196 9006 9296 5089 6981 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 save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITHA 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 the Notice. If you have any questions, you may call the Pennsylvaiiia Housing Finance Agency toll free at (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 NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. OP001_PA Page3of10 7196 9006 9296 5089 6981 HOMEOWNER'S NAME(S): MICHAEL HARRIS CARRIE M VOGELSONG PROPERTY ADDRESS: 138 W GREEN ST MECHANICSBURG, PA 17055 LOAN ACCT. NO.: ORIGINAL LENDER: OPTION ONE MORTGAGE CORPORATION CURRENT LENDER/SERVICER: HOMEWARD RESIDENTIAL, INC. 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 consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOTI' TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOPI' 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 APPLICATIONAS SOONAS POSSIBLE. IF YOU HAVE A MEETING WITH OP001_PA Page 4of10 7196 9006 9296 S089 6981 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 PREYENTED 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 PREYENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPR0YED 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 sixtv (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOUARE CURRENTLY PROTECTED BY THE FILING OFA PETITION IN BANKRUPTCY, THE PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFA ULT - The MORTGAGE debt held by the above lender on your property located at: 138 W GREEN ST MECHANICSBURG, PA 17055 IS SERIOUSL YIN DEFA UL T because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Payments from 04/01/2012 $9,781.33 (10 @ $978.61) Late Charge(s) (if applicable): $418.50 Other Charge(s): NSF and Advances (if applicable): $80.00 Less: Credit Balance: $0.00 TOTAL AMOUNT PAST DUE: $10,279.83 HOW TO CURE_ THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $10279.83 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check, or money order made payable and sent to: Homeward Residential, hie. P.O. Box 632237 Dallas, TX 75063 -2237 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. OP001_PA Page 5of10 7196 9006 9296 5089 6981 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 attorneys' fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at 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 per forming 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 Sheriff's Sale of the mortgaged property could be held would be approximately 6 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting die lender. HOW TO CONTACT THE LENDER: Name of Lender. Homeward Residential, Inc. Address: P.O. Box 632237 Dallas, TX 75063 -2237 Phone Number: (877) 304 -3100 Fax Number: (866) 546 -6746 Contact Person. Karen Williams EMailAddress: Karen.Williams @gohomeward.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may 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 other requirements of the mortgage are satisfied. OP00]_PA Page 6of10 7196 9006 9296 5089 6961 YOU MA F ALSO HA YE 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 (3) TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CAN BE LOCATED ON THE ATTACHED LIST Sincerely, Homeward Residential, Inc. P.O. Box 632237 Dallas, TX 75063 -2237 OP001_PA Page7of10 7196 9006 9296 S089 6961 HEMAP Consumer Credit Counseling Agencies YORK County Report last updated: 011091201310:27 AM 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 HC Page 8of10 7196 9006 9296 5089 6981 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 01/09/201310:27 AM Advantage Credit Counseling ServJce1CCCS 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 PathStone Corporation PathStone Corporation 1625 North Front St 450 Cleveland Ave Harrisburg, PA 17102 Chambersburg, PA 17201 717 -234 -6616 717- 264 -5913 PA Interfaith Community Programs Inc PHPA 40 E High Street 211 North Front Street Gettysburg, PA 17325 Harrisburg, PA 17110 717 - 334 -1518 717- 780 -3940 800 - 342 -2397 HC Page9of10 7196 9006 9296 5089 6961 FORM I II IN THE COURT OF COMMON PLEAS O�' LA .S R)an K Nati ona l : CUMBERLAND COUNTY, PENNSYLV�*A ASSO Plaintiff(s) y� VO vs. a -- Mi chOe l �o� Defendants) Civil G ;7 M&OCI P. HQrriS; et al 14 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 i.nforma.tion 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. I.f you and your lawyer complete a. financial worksbeet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to wor k out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO. SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE TI3E STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully s miffed: Ll is Date [Signature of CCffis V HPL1 #9 ]ALL, ES(, PA ID 77788 FORM 2 Cumberland County .Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland. County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CCISTONIER/PRIMARY Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date:. Prise: $ Realtor Name: Realtor Phone: Borrower Occupied.? Yes ❑ No ❑ Mailing. Address (if different): City: State: Zip: Phone Numbers: Home: Officer Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last. Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile 92 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): .Model: Year: Amount owed: Value Monthly Income Name of Employers: J Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mart age Utilities Car Payment(s) Cundo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other p rop. payment Install. Loan Pa. yment Cable TV Child Su ort/Alim. Spending Money Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling .Agency: Counselor; Phone (Office): Fax: i _. _ ... _...... _ ......... --- - - - - -- - -- . Email: Have you m.ade.application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use /refer this information to my lender /servi.cer for the sole purpose of evaluating my financial situation for possible mortgage options. l/We understand that I /we am /are under no obligation to use the services provided by the above named. Borrower Signature Date Co- Borrower Signature Date. Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements .Proof of any expected income for the last 45 days Copy of a current utiliO7 bill V Letter explaining reason for delinquency and any supporting documentation -1 (hardship letter) Y Listing agreement (if property is currently on the market) FORM 3 (�/� IN THE COURT OF COMMON PLEAS OF �I S IJUI Nat, On a I : CUMBERLAND COUNTY, PENNSYLVANIA ASSONCN M Plaintiff(s) VS. Michael iJicAry s o lrlc�, Defendant(s) : CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1: Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that. Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 1.8 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG ESQUIRE - ID #45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID #34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 SALVATORE CAROLLO, ESQUIRE - ID #311050' HARRY B. REESE, ESQUIRE - ID #310501 ELIZABETH L. WASSALL, ESQUIRE - ID #77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID #33078 NICOLE B. LABLETTA, ESQUIRE - ID #202194 DAVID NEEREN, ESQUIRE - ID #204252 JORDAN DAVID, ESQUIRE - ID #311968 AMANDA RAUER, ESQUIRE - ID #307028 p: WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 Pleadin udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities COURT OF COMMON Corporation Home Equity Loan Trust, Series OOMC 2006 -HE5, Asset PLEAS Backed Pass - Through Certificates, Series OOMC 2006 -HE5 CIVIL DIVISION 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409 CUMBERLAND County Plaintiff Michael Harris a /k/a Michael P. Harris NO. 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a /k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Gazzara Doyle, Esquire; Sherri J. Braunstein, Esquire; Harry B. Reese, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; John Eric Kishbaugh, Esquire; Nicole B. LaBletta, Esquire; David Neeren, Esquire, Jordan David, Esquire, and Amanda Rauer, Esquire on behalf of the Plaintiff, in the above - captioned matter. UDREN LAW OFFICES, P.C. BY. —E BETH L WASSALL, ESQ �— A ID 77788 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 U.S. Bank National Association, as Trustee COURT OF COMMON PLEAS for Asset Backed Securities Corporation CIVIL DIVISION Home Equity Loan Trust, Series OOMC Cumberland County 2006-HE5,Asset Backed Pass-Through Certificates, Series OOMC 2006-HE5 Plaintiff NO. 14-382 Civil V. MICHAEL HARRIS A/K/A MICHAEL P. `�. . HARRIS; CARRIE VOGELSONG A/K/A -" CARRIE M.VOGELSONG; et al , Defendant(s) PRAECIPE TO REINSTATE COMPLAINT -- TO THE PROTHONOTARY: "� Kindly reinstate the Complaint on the above-captioned matter. DATE: UDREN LAW OFFICES, P.C. B Att eys for Plaint' HARRY B. RE E, ESQUIRE PA ID . 10501 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Jody S Smith Chief Deputy ` 11.; Ronny RAnderson Sheriff \ q ` o MuVm" 2 �on�R C �i e�o**/� R�hp.dwStp"a* US Bank National Association vs. Michael P. Harris (et al.) Case Number SHERIFF'S RETURN OF SERVICE 02/102014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent nquiry for the within named Defendant to wit: Michael P. Harris, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Notified attorney's office that one of the defendants has filed bankruptcy and to please send Bankrupty dismissal, as of this date the dismissal has not been received and the Compalint has expired. 02/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie M. Vogelsong, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Notified attorney's office that one of the defendants has filed bankruptcy and to please send Bankrupty dismissal, as of this date the dismissal has not been recived and the Compalint has expired. 04/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie M. Vogelsong, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vancant and to this date the Mechanicsburg Postmaster has not been able to provide a good forwarding address. 04/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael P. Harris, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in M rt Foreclosure as "Not Found" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vancant and to this date the Mechanicsburg Postmaster has not been able to provide a good forwarding address. SHERIFF COST: $65.30 SO ANSWERS, April 15, 2014 RDNNYR ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006 -HE5, Asset Backed Pass - Through Certificates, Series OOMC 2006 -HE5 Plaintiff v. Michael Harris a /k/a Michael P. Harris; Carrie Vogelsong a /k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 14 -382 Civil MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT C. cn co - ) LID Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the Complaint in Mortgage Foreclosure upon Defendant(s): MICHAEL HARRIS A/K/A MICHAEL P. HARRIS, CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG, by regular mail and certified mail, and by posting the mortgaged premises and in support thereof avers the following: 1. Process was unable to be served at the then last known address of said Defendant(s) as follows: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 A copy of the Return of Service is attached hereto as Exhibit "A ". 2. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report thereof being attached hereto as Exhibit `B ". 3. Said investigation was unable to determine an alternate address for said Defendant(s). 4. Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or information. A copy of the Postal Search results is attached hereto as Exhibit "C ". 5. The last known address of Defendant(s) is as set forth in the attached Exhibits. WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint in Mortgage Foreclosure upon said in paragraph 1, by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. 2 BY: Attorneys for Plaintiff ELIZABETH L WASSALL, ESQ, PA ID 77788 Apr. 22. 2014 3:03PM Cumberland County Sherrif - No. 9729 P. 2/2 Ronny R Anderson Sheriff Jody 8 Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �ouvdT o1 uiniti,11Ad OFF ICE OF THE Ea<EFOEF US Bank National Association vs. Michael P. Harris (et al.) Case Number 2014 -382 SHERIFF'S RETURN OF SERVICE 02/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael P. Harris, but was unable to locate the•Defendant In his bailiwick, The Sheriff therefore retums the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Notified attorney's office that one of the defendants has filed bankruptcy and to please send Bankrupty dismissal, as of this date the dismissal has not been received and the Compalint has expired. 02/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie M. Vogelsong, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore retums the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Notified attorney's office that one of the defendants has filed bankruptcy and to please send Bankrupty dismissal, as of this date the dismissal has not been reclved and the Compalint has expired. 04/15/2014 Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie M. Vogelsong, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence is vancant and to this date the Mechanicsburg Postmaster has not been able to provide a good forwarding address. 04/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael P. Harris, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. Residence Is vancant and to this date the Mechanicsburg Postmaster has not been able to provide a good forwarding address. SHERIFF COST: $65.30 SO ANSWERS, •April 15, 2014 RON R ANDERSON, SHERIFF EXHIBIT A tc) Couni9Suite SHontf, 7aeauefr ic. Commonwealth County of Cumberland Court of Common Pleas Of Pennsylvania Civil Division Plaintiff(s) Ocwen Loan Servicing, LLC vs Defendant(s) Michael Harris aka Michael P. Harris, Carrie Vogelsong aka Carrie M. Vogelsong AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY I, Randy Sheppard, II, do hereby swear and affirm that I made the following diligent search and inquiry on defendant, Michael Harris aka Michael P. Harris: 1. On March 3o, 2014, I conducted a Skip Trace, the results of which indicated the defendant's current residence is 138 West Green Street, Mechanicsburg, PA, 17055. 2. On March 3o, 2014, I conducted an Internet search for the Death Records of the Defendant, the results of which indicated that the defendant is not deceased. 3. On March 30, 2014, I conducted an Internet search for the Voter Registration Records of the Defendant, the results of which indicated that the defendant is a registered voter at the address of 138 West Green Street, Mechanicsburg, PA, 17055. 4. On March 3o, 2014, I conducted an Internet search for the Motor Vehicle Records of the Defendant, with no results obtained from the search. 5. On March 30, 2014, I conducted an Internet search of Facebook, Twitter, Yahoo!, Google and Bing with no results obtained from the search. 6. On March 3o, 2014 at 3:23pm I placed a phone call to defendant's neighbor, Samuel Rupp (717) 697 -2691, of 142 West Green Street, Mechanicsburg, PA, 17055 to inquire about defendant's last known address. There was no answer. 7. On March 3o, 2014 at 3:24pm I placed a phone call to defendant's neighbor, T. Webber (717) 766 -7694, of 134 West Green Street, Mechanicsburg, PA, 17055 to inquire about defendant's last known address. There was no answer. I SOLEMNLY swear and affirm that the foregoing statements are true and correct to the best of my knowledge, 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. 03/30/2014 Date Randy Sheppard, II Skip Trace Manager De Novo Attorney Services, Inc. P.O. Box 20215 Baltimore, MD 21284 Our Job Serial Number: NOV- 2014002197 Ref: 11080180 -2 EXHIBIT B Commonwealth County of Cumberland Court of Common Pleas Of Pennsylvania Civil Division Plaintiff(s) Ocwen Loan Servicing, LLC vs Defendant(s) Carrie Vogelsong aka Carrie M. Vogelsong AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY I, Randy Sheppard, II, do hereby swear and affirm that I made the following diligent search and inquiry on defendant, Carrie Vogelsong aka Carrie M. Vogelsong: 1. On March 3o, 2014, I conducted a Skip Trace, the results of which indicated the defendant's current residence is 138 West Green Street, Mechanicsburg, PA, 17055. 2. On March 3o, 2014, I conducted an Internet search for the Death Records of the Defendant, the results of which indicated that the defendant is not deceased. 3. On March 3o, 2014, I conducted an Internet search for the Voter Registration Records of the Defendant, the results of which indicated that the defendant is a registered voter at the address of 138 West Green Street, Mechanicsburg, PA, 17055. 4. On March 3o, 2014, I conducted an Internet search for the Motor Vehicle Records of the Defendant, with no results obtained from the search. 5. On March 3o, 2014, I conducted an Internet search of Facebook, Twitter, Yahoo!, Google and Bing with results from intelius.com indicating the defendant is living in Mechanicsburg, PA. 6. On March 3o, 2014 at 3:23pm I placed a phone call to defendant's neighbor, Samuel Rupp (717) 697 -2691, of 142 West Green Street, Mechanicsburg, PA, 17055 to inquire about defendant's last known address. There was no answer. 7. On March 3o, 2014 at 3:24pm I placed a phone call to defendant's neighbor, T. Webber (717) 766 -7694, of 134 West Green Street, Mechanicsburg, PA, 17055 to inquire about defendant's last known address. There was no answer. I SOLEMNLY swear and affirm that the foregoing statements are true and correct to the best of my knowledge, 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. 03/30/2014 Date RaSheppard, II Skip Trace Manager De Novo Attorney Services, Inc. P.O. Box 20215 Baltimore, MD 21284 Our Job Serial Number: NOV- 2014002198 Ref: 11080180 -2 Udren Law Offices, PC. 111 Woodcrest Road Cherry Hill, NJ 08003 TO: POSTMASTER DATE: March 31, 2014 Carlisle, PA, 17013 CASE No.: 11080180-2 Please furnish the new address or the name and street address (if a boxholder) for the following. Please take special note that this request deals with a matter pending in Court and, therefore, any information available would be greatly appreciated, even if any existing forwarding order has expired. NAME: Carrie Vogelsong a/k/a Carrie M. Vogelsong LAST KNOWN ADDRESS: 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39CFR 265.6(d)(6Xii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(dx1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester. Attorney at Law 2. Statute /regulation that empowers me to serve process (not required if requester is an attorney) 3. The names of known parties to the litigation: (Ocwen Loan Servicing, LLC) vs. NAME: Michael Harris a/k/a Michael P. Harris 4. The Court in which the case has been or will be heard: Cumberland County 5. The docket or other identifying number if one has been issued: 14-382 Civil 6. The capacity in which this individual is to be served (defendant, witness): Defendant(s) WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITHACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10, 000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C. SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Udren Law Offices, PC. ass*** sss******** ss******* sss* s*s ss sss****** sssssssss ss ssses *ssssassss *************ss* POST OFFICE USE ONLY NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS of known at address given _ No such number AFFIX POSTMARK IiERE Left no forwarding _ No change of address on file No such street GOOD AS ADDRESSED EXHIBIT C Udren Law Offices, PC. 111 Woodcrest Road Cherry Hill, NJ 08003 TO: POSTMASTER DATE: March 31, 2014 Carlisle, PA, 17013 CASE No.: 11080180-2 Please furnish the new address or the name and street address (if a boxholder) for the following. Please take special note that this request deals with a matter pending in Court and, therefore, any information available would be greatly appreciated, even if any existing forwarding order has expired. NAME: Michael Harris a/k/a Michael P. Harris LAST KNOWN ADDRESS: 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 NOTE: The name and last known address are required for change of address information. The name, if brown, and post office box address are required for boxholder information. The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(dX1) and (2) and corresponding Administrative Support Manual 352.44a and b. I. Capacity of requester: Attorney at Law 2. Statute/regulation that empowers me to serve process (not required if requester is an attorney) 3. The names of known parties to the litigation: (Ocwen Loan Servicing, LLC) vs. NAME: Michael Harris a/k/a Michael P. 4. The Court in which the case has been or will be heard: Cumberland County 5. The docket or other identifying number if one has been issued: 14 -382 Civil 6. The capacity in which this individual is to be served (defendant, witness): Defendant(s) WARNING THE SUBMISSION OF FALSE INFORMATIONTO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER 1NFORMATIONFOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVELITIGATIONCOULD RESULT INCRIM1NAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE 77IANFIVE YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001) I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Udren Law Offices, PC. BY: ******************************************************* * * * * ** * * * * * * * * ** * * * * * ** * * * * * * ** POST OFFICE USE ONLY NEW ADDRESSBOXHOLDER'S NAME AND STREET ADDRESS Not known at address given No such number AFFIX POSTMARK HERE y Left no forwarding No change of address on file No such street GOOD AS ADDRESSED UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006 -HE5, Asset Backed Pass - Through Certificates, Series OOMC 2006 -HE5 Plaintiff v. Michael Harris a /k/a Michael P. Harris; Carrie Vogelsong a /k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 14 -382 Civil MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. NOTE: A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976). An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As set forth in the Return of Service marked Exhibit "A ", the Sheriff and /or Process Server has been unable to serve the following Defendant(s) at their last known addresses. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation marked Exhibit "B ". Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or information. A copy of the Postal Search results is attached hereto as Exhibit "C ". WHEREFORE, Plaintiff prays and respectfully requests service of the Complaint in Mortgage Foreclosure upon Defendant(s) by regular mail and certified mail, and by posting the mortgaged premises. UDREN LAW OFFICES, P.C. Attorneys foF 'a i L WASSALL, ES( ID 77788 VERIFICATION The undersigned hereby states that he /she is the Attorney for the Plaintiff in this action, that he /she is authorized to make this Verification, and that the statements made in the foregoing MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his /her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec 4904 relating to unsworn falsification to authorities. Date: 1,q 5_ UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff ELIZABETH L WASSALL, ES( PA ID 77788 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 -3620 856- 669 -5400 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006 -11E5, Asset Backed Pass - Through Certificates, Series OOMC 2006 -HE5 Plaintiff v. Michael Harris a /k/a Michael P. Harris; Carrie Vogelsong a /k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 14 -382 Civil CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on each of the attached parties or their attorneys this 25day of April, 2014. Udren Law Offices, P.C. Attorney for Plaintiff By: ELIZABETH L WASSM• PA ID 77788 SERVICE LIST CUMBERLAND COUNTY, PENNSYLVANIA CCP. No. Docket Number: 14 -382 Civil NAME: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS MAILING ADDRESS: 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 NAME: CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG MAILING ADDRESS: 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC C= 2006-HE5,Asset Backed Pass-Through t 3 rr, Certificates, Series OOMC 2006-HE5 �'o _-a -,r- Plaintiff V. Michael Harris a/k/a Michael P. Harris; NO. 14-382 Civil =- - . Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ORDER AND NOW, this 30day of , 2014,upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s), Michael Harris a/k/a Michael P. Harris, Carrie Vogelsong a/k/a Carrie M.Vogelsong, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET,MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 CARRIE VOGELSONG A/K/A CARRIE M.VOGELSONG 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 BY THE COURT: J. L.o4vs-'aLr UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS; CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG; et al Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-382 Civil PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above -captioned matter. DATE: UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff Nicole LaBetta, Esquire r: 202194 Via. ys I CK� L,58z,5 �2� aos99J Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 314 MAY 28 PM 2: CUMBERLAND COUNTY US Bank National Association vs. Michael P. Harris (et al.) Case Number 2014 -382 SHERIFF'S RETURN OF SERVICE 05/20/2014 11:06 AM - Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Michael P. Harris, pursuant to Order of Court by "Posting" the premises located at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055 with a true and correct copy according to law. KOCODZI, DEPUTY 05/20/2014 11:06 AM - Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Carrie M. Vogelsong, pursuant to Order of Court by "Posting" the premises located at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055 with a true and correct copy according to law. KdLODZI, DEPUTY SHERIFF COST: $67.79 SO ANSWERS, May 21, 2014 RON -R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris; Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-382 Civil VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER c • The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter a true and correct copy of the Complaint in Mortgage Foreclosure was mailed to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: 5/30/14 Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ceDlri BY: Atto.for Plain David Neeren, Esquire PA ID 204952 LAW OFFICES, P.C. T CORPORATE CENTER )ODCREST ROAD RY HILL NJ 08003 N\aria:d 1--(a.ms MK (I\ ./-11‘.,ulosj p. '3% \AQ -(3i7- Gfesn Sk(e-1\-- Wfinc),ntc_.so,) ire ?P, VIZS4- C-nCiA ced CAjiWQ- P LAW OFFICES, P.C. ST CORPORATE CENTER 11 WOODCREST ROAD HERRY HILL NJ 08003 \(0 t ( Caff M. r\3`6 S4 -fed t3s GA-tt 3-14t C_a4-1\skt_ \°k.. \-1\5 N LAW OFFICES, P.C. ST CORPORATE CENTER VOODCREST ROAD RRY MIL, NJ 08003 1 11 1 11 I 11111111111 91 7199 9991 ?033 2443 8060 _ Caine. VdoricCor M.Voyi5c30c-\ \-5s4 \-AQ&k- C-ffe_e_A-A 1\\AQ0ocir\‘csWic , \-M55 kHik I V\1& C-ve-ex\ Skce-6- CP-(1\sk_ 'PP\ nor5 '. • • t 2 Ltnr 1-,.,,ft,o,c 0A, 2014 W oFf ICES, RC. CORPORATE CENTS1 ODCREST ROAD YI-LL NJ CSCO3 11 1 91 7199 9991 7033 2443 8077 •Nj\kCjr\ ;Lt.:\ '1\11 U./nail 1 CS b‘) r 2\ Mk cMs Q_ 34- CrUx) a'ree.,t Car I si V UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s udren.com ATTORNEY FOR PLAINTIFF U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: sa Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), MICHAEL HARRIS A/K/A MICHAEL P. HARRIS; CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Escrow Per Complaint Title Report Attorney Fee Property Inspection Fee Property Valuation Fee Prior Servicer Fees Bankruptcy Cost Grand Total FROM TO 11/09/2013 08/18/2014 $113,491.22 $9,625.53 $4,394.99 $502.20 $5,358.86 $300.00 $1,650.00 $73.50 $392.00 $80.00 $176.00 $136,044.30 so k-� l�gs�;°t�`i /1/o-ke kI 3900s0 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE HE BY ASSESSED AS INDICATED DATE: O PRO PROTHY` MJU#: 11080180 CASE#: 11080180-2 UDREN LAW OFFICES, F.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 HARRY B. REESE, ESQUIRE - ID#310501 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 JORDAN DAVID, ESQUIRE - ID#311968 AMANDA RAUER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 • @udren.com ATTORNEY FOR PLAINTIFF U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trost, Series OOMC 200641E5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 C/O Ocwen Loan Servicing, LLC 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 Defendant(s) COPY COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County %;•Vt ` NO. 14-3ga COMPLAINT IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006 -HES, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris; Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) NO. 14-382 Civil C? "., r=' Z• ri -.p ▪ • rn-- z 73 73r - en ▪ ."0° c "<A © oca r'2 —ac r) 5 = S.,r,, -4 -- ...t a< CA) ;t ORDER AND NOW, this .361"rlay of , 2014, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s), Michael Harris a/k/a Michael P. Harris, Carrie Vogelsong a/k/a Carrie M. Vogelsong, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 BY THE COURT: Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �4w. nt earh tint OFFICF OF mI SHERIFF US Bank National Association vs. Michael P. Harris (et al.) Case Number 2014-382 SHERIFF'S RETURN OF SERVICE 05/20/2014 11:06 AM - Deputy Jeff Kolodzi, being duly swom according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Michael P. Harris, pursuant to Order of Court by "Posting" the premises located at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055 with a true and correct copy according to law. KO ODZI, DEPUTY 05/20/2014 11:06 AM - Deputy Jeff Kolodzi, being duly swom according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint In Mortgage Foreclosure upon the within named Defendant, to wit: Carrie M. Vogelsong, pursuant to Order of Court by "Posting" the premises located at 138 W. Green Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, ith a true and correct copy according to law. dier r K.' ODZI, DEPUTY SHERIFF COST: $67.79 SO ANSWERS, May 21, 2014 RONPTY R ANDERSON, SHERIFF (c) i:ountySuite Shenlf, Teleoeof Inc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris; Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-382 Civil VERIFICATION OF SERVICE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER -•o rrt yG The undersigned hereby verifies that he is counsel for Plaintiff in the above case and that pursuant to the Court order issued in this matter a true and correct copy of the Complaint in Mortgage Foreclosure was mailed to Defendant(s), by certified mail and regular first class mail, to the last known address of Defendant(s) as follows: DATE MAILED: 5/30/14 Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 60 I! l w oFFIC BY: Atto f for Plain David Neeren, Esquire PA ID 204252 ACOCREST RY4041., 0,41.00003 • vrts•M,t4(1\ 1\A \YAt.st.GrJ Stite-LNAP-dflkik$ \AQ.4.—. T\SVis 1i . • '4 • j• 4,0 1 --q7470) t{e�RYHtU-, N fa 47, • 1- rPQ- tI$Q-f t arylt NA. v0a o ma, kePt, PN -4, vt-z 'Ciyuf) S - A sk \0111.1. �wY•.y J` 1 y 1 1 1 11 1 111 1 11 1 91 7199 9991 7033 21443 80130 ;-; 44.r- • • ; (0, to".," ••• „„4 ,•• - , 14 : : • .f :� 4r ,........r. L _ 4"1 ;'.237 Re ii :L. NJ 11 NSI 11 111 11 91 7199 9991 7033 2443 8077 Nkkt.v4AA r:ks PAv.AK ktvkc),6 T. • s; •w - r o• rte` 'C:S�` ‘ickn,lcstn,� NS:-Srlrzerreftel'amjiVrill TPS loss fict • • is • 11. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 200641E5, Asset Backed Pass -Through Certificates, Series OOMC 200641E5 Plaintiff v. Michael Harris a/k/a Michael P. Harris, Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Ci''I TO: Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Date of Notice: July 30, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION 1 MPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. pT%`df419 wooaP4bD,2Q442 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 11080180 CASE#: 11080180-2 ire UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 200641E5 Plaintiff v. Michael Harris a/k/a Michael P. Harris, Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil TO: Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Date of Notice: July 30, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 yOTIFICACION LMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PA A TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 06fr, woRAtIa2a4253 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 11080180 CASE#: 11080180-2 Pennsylvania Office 100 W. 3rd Ave. Suite 200 Conshohocken, PA 19428 (PH) 215-568-9500 Mark) Udren, Esq. Licensed:: FA, NJ,, LZ UDREN LAW OFFICES, P. C. New Jersey Office Woodcrest Corporate Center 111 Woodcrest Rd. Suite 200 Cherry Hill, NJ 08003 (PH)856-669-5400 (FX)856-669-5399 www.udren.com Prothonotary of Cumberland County One Courthouse Square Carlisle, PA 17013 Florida Office 2101 W. Commercial Blvd Suite 5100 Fort Lauderdale, FL 33309 (PH) 954-378-1757 (FX) 954-378-1758 Re: U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-11E5 vs. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS, CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG, Cumberland County C.C.P. No. 14-382 Civil MJU#: 11080180 CASE#: 11080180-2 Dear Sir or Madam: Enclosed please find Affidavit of Non -Military Service for the above captioned matter. I have also enclosed a copy of the Affidavit of Non -Military Service to be time stamped and returned in the enclosed self-addressed stamped envelope. Thank you for your assistance in this matter. Sincerely yours, Kevin Kerr Foreclosure Specialist MJU/ Enclosures MJU#: 11080180 CASE#: 11080180-2 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsnaudren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS, CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), MICHAEL HARRIS A/K/A MICHAEL P. HARRIS, CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S falsification to authorities. Dated: August 19, 2014 MJU#: 11080180 CASE#: 11080180-2 eeren, Esqu PAID 204252 'Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: HARRIS First Name: MICHAEL Middle Name: Active Duty Status As Of: Aug -18-2014 Results as of : Aug -18-2014 11:17:08 AM EXHIBIT A SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA .'k 1 ," : - - - ' No , NA This response reflects the Individualsactive duty status based 0n 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 1 r 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 Noted of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA -No NA This response reflects whether the individual of 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 (Arrny, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: GCN6M6F8HOCCYAO Department of Defense Manpower Data Center Status Report Pursuant to Servicenembers Civil Relief Act LastName: HARRIS First Name: MICHAEL Middle Name: P. Active Duty Status As Of: Aug -18-2014 Results as of : Aug -18-2014 11:18:45 AM exHG SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA,.,a., - - -- _ No NA This response reflects the individuals' active duty status based on the Active Duty Status Date • S ' I 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 _ i NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date t The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA . NA -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, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 01. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 DzioN- 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/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: XC21Z63800CES30 Department of Defense Manpower Data Center Status Report Pursuant to Servicernernbers Civil Relief Act Last Name: VOGELSONG First Name: CARRIE Middle Name: Active Duty Status As Of: Aug -18-2014 Results as of : Aug -18-2014 1120:43 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ,i _ : - No' . NA f 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 t t, The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA - - -No NA This response reflects whether the indlvidual 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, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the. Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, ,is 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: 6C0076F8V0F1YE0 bepartment of Defense Manpower Data Center Status Report Pursuant to Servicemennbers Civil Relief Act Last Name: VOGELSONG First Name: CARRIE Middle Name: M. Active Duty Status As Of: Aug -18-2014 Results as of : Aug -18-2014 11:21:40 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA /- j - .-- ---- No ^. NA This response reflects the Individuals' active duty status based on the Active Duty Status Date / Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NAI NA - - —. i=/ — 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 Noted of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty 5.- - / Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 01.. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 if:44 -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/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 1 C75F638T0F11 E0 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings na,udren. com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Ci C) MORTGAGE FORECLOSUREG-3 • W Qct rco s� (;)�, C, cam. zQ p �' NO. 14-382 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 136,044.30 Interest From 08/19/2014 to Date of Sale 12/03/2014 Ongoing Per Diem of $15.53 to actual date of sale including if sale is held at a later date. (Costs to be added) cokl mss.s��la ' 1o5.3o Ctr?..-79 " /! 03:7S ti ti MJU#: 11080180 CASE#: 11080180-2 \1."")5 `t " 3a�3N P UDREN $ 1,661.71 OFFICES, P BY: Attorney fo LiSol sD David Neeren, Esquire 'AID 202:: tjj (pq.CqJ SiRA aOSa UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil CERTIFICATE OF ACT 91 CT.) L I hereby state that as the attorney for the Plaintiff in the above -captioned matter: 12 Act 91 procedures have been fulfilled j1 Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: Attorne o ' aintiff Dcvid Nee PAIL i UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Yellowbook, Inc. Address to follow. 4. Name and address of the last recorded holder of every mortgage of record: U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Option One Mortgage Corporation, a California Corporation 3 Ada Irvine, CA 92618 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenants/Occupants 138 West Green Street Mechanicsburg, PA 17055 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: 15 I (611 11 U EN LAW OFFICES-(P.C. MJU#: 11080180 CASE#: 11080180-2 B a 1/ Atirr W' ►i PAID 204252 dire UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS, CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS c CIVIL DIVISION Cumberland County c�'��., -0 oCD MORTGAGE FORECLOSURE -c �ry a-• ry ,ter, NO. 14-382 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Your house (real estate) at 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on 12/03/2014 at 10:00 A.M at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $136,044.30, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR ASSET BACKED SECURITIES CORPORATION HOME EQUITY LOAN TRUST, SERIES OOMC 2006-HE5, ASSET BACKED PASS-THROUGH CERTIFICATES, SERIES OOMC 2006-HE5 Vs. NO 14-382 Civil Term CIVIL ACTION — LAW MICHAEL HARRIS A/K/A MICHAEL P. HARRIS CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 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: $136,044.30 L.L.: $.50 Interest FROM 8/19/2014 TO DATE OF SALE 12/03/2014 - ONGOING PER DIEM OF $15.53 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE. - $1,661.71 Atty's Comm: Due Prothy: $2.25 Atty Paid: $305.34 Other Costs: Plaintiff Paid: Date: 8/20/14 (Seal) la€L David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: DAVID NEEREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 204252 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669=5400 pleadings@udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS, CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: m ▪ ��� f"' -o -• r.11 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa. Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to aut ities. Dated: 41>51 MJU#: 11080180 CASE#: 11080180-2 AMANDA L. RAUER. ESQUIRE PA. La # 30702.8 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(i udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Yellowbook, Inc. c/o Justin N. Davis, Esquire 107 North Commerce Way Bethlehem, PA 18017 4. Name and address of the last recorded holder of every mortgage of record: U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Sr Mortgage Holders - None Option One Mortgage Corporation, a California Corporation 3 Ada Irvine, CA 92618 5. Name and address of every other person who has any record lien on the property: Borough of Mechanicsburg 36 West Allen Street Mechanicsburg, PA 17055 Borough of Mechanicsburg c/o Coyne & Coyne, PC 3901 Market Street Camp Hill, PA 17011-4227 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Tenants/Occupants 138 West Green Street Mechanicsburg, PA 17055 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDRE BY: Atto MJU#: 11080180 CASE#: 11080180-2 AMANDA L. R. UER. ESQU E PA. LD. # 307028 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ationa ssoctation, as rustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 200641E5, Asset Backed Pass -Through Certificates, Series OOMC 2006-8E5 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS; CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG; Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-382 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): MICHAEL HARRIS A/K/A MICHAEL P. HARRIS; CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG; PROPERTY: 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 12/03/2014 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a Mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 11080180 CASE#: 11080180-2 EXHIBIT A Name and Address of Sender Henrietta Crommarty UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ri Registered [11 Insured ri COD il Certified EIJ Merchandise ri Return Receipt for Int'l Recorded Del. Express Mail Check appropriate block for Registered Mail: D With Postal Insurance Lhl Without postal Insurance Affix stamp here certificate of additional copies Postmark and Due Sender If COD if issued mailing or of this Date of R.R. Fee as for bill. Receipt S.D. Fee S.H. Fee Rst. Del. Fee Remarks Line Art 'cle Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value 1 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 2 Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 3 Commonwealth of PA, Department of Revenue Bureau of Ccmtpliance, PO Box 281230 Harrisburg, PA 17128-1230 4 14-382-CivilTenants/Occupants 138 West Green Street Mechanicsburg, PA 17055 5 Borough of Mechanicsburg c/o Coyne & Coyne, PC 3901 Market Street, Camp Hill, PA 170114227 6 12/03/2014 Option One Mortgage Corporation, a Califomia Corporation 3 Ada Irvine, CA 92618 0-111.7: arum 03 $ 170 90 7 Yellow Book, Inc. c/o Justin N. Davis, Esquire 107 North Commerce Way, Bethlehem, PA 18017 < Borough of Mechanicsburg .0 36 West Allen Street, Mec .. , ;,11. L • 7 1110 " 41z 11 cD X III r 12 13 14 15 Total number of Pieces Listed by Sender 8 Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail The maximum indemnity payable for the reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is E50,000 per time subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500, The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parceis. f PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Michael Harris a/k/a Michael P. Harris - MJU# 11080180-2 (Cumberland County) Carrie Vogelsong a/k/a Carrie M. Vogelsong - MJU# 11080180-2 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s ' udren.com U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS, CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County MORTGAGE FORECLOSURE NO. 14-382 Civil VERIFICATION OF SERVICE OF NOTICE OF SALE BY CERTIFIED MAIL AND REGULAR MAIL PURSUANT TO COURT ORDER The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by certified mail and regular first class mail as follows: TO: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET, CARLISLE, PA 17013 CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET, CARLISLE, PA 17013 DATE MAILED: August 26, 2014 I verify that the statements made herein are true and correct and I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: Septembe , 2014 MJU#: 11080180 CASE#: 11080180-2 EXHIBIT B B Att. - or Plaintiff CES, P.C. AMANDA L. RAUER, ESQUIRE PA. I.O. # 307028 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris; Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) NO. 14-382 Civil ORDER AND NOW, this 50' day of Arid , 2014, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s), Michael Harris a/k/a Michael P. Harris, Carrie Vogelsong a/k/a Carrie M. Vogelsong, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 EXHIBIT B CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 138 WEST GREEN STREET, MECHAMCSBURG, PA 17055 AJK/A 138 WEST GREEN STREET CARLISLE, PA 17013 co y BY THE COURT: EXHIBIT B J. Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) #11080180-2 1 11 111 1 11 111 1 1 11 91 7199 9991 7034 2538 7038 CARRIE VOGELSONG A/K/A CARRIE M. VOGELSON 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET, CARLISLE, PA 17013 Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 HAC (PA -3129) #11080180-2 ERTIFIE AIL p 91 7199 9991 7034 2538 7045 MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET, CARLISLE, PA 17013 U.S. POSTAGE* PITNEY BOWES %�- it +1101__rrr! ZIP 08003 $ 005.130 02 1* 0001387090 AUG 26 2014 CCI H CO H X U.S. POSTAGE )) PITNEY BOWES ZIP 08003 ll 02 10 $ 005.13 0001387090 AUG 26 2014 Name and Address of Sender Henrietta Crommar}�, `J UDREN LAW OFFICES, P.C. 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003 ❑ Registered ❑ Insured ❑ COD ❑ Certified ❑ Return Receipt for Merchandise ❑ InPI Recorded Del. ❑ Express Mail Check appropriate block for Registered Mail: ❑ With Postal Insurancep ❑ Without postal Insurance Affix stamp here if issued as certificate of mailing or for additional copies of this bill. Postmark and Date of Receipt Line cle Number Name of Addressee, Street, and Post Office Address Postage Fee Handling Charge Act. Value (If Regis.) Insured Value Due Sender If COD R.R. Fee S.D. Fee S.H. Fee Rst. Del. Fee Remarks 1 Michael Harris a/k/a Michael P. Harris 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 2 Carrie Vogelsong a/k/a Carrie M. Vogelsong 138 West Green Street, Mechanicsburg, PA 17055 a/k/a 138 West Green Street, Carlisle, PA 17013 3 4 14 -382 -Civil CO W 5 6 12/03/2014 CO 7 ti 8003 $ C 387090 AU F _ 8 9 (,%, cam W 10 11 12 13 14 15 Total number of Pieces Listed by Sender 2 Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnego iable documents under Express Mail document reconstruction insurance is $50,000 per p'ece subject to a limit of $500,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and 5921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Special handling charges apply only to third and forth class parcels. PS Form 3877, February 1994 Form Must be Completed by Typewriter, Ink or Ball Point Pen Michael Harris a/k/a Michael P. Harris - MJU# 11080180-2 (Cumberland County) Carrie Vogelsong a/k/a Carrie M. Vogelsong - MJU# 11080180-2 (Cumberland County) UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. MICHAEL HARRIS A/K/A MICHAEL P. HARRIS; CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG; et al ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-382 Civil Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: ot, AMAN EXHIBIT 6 UDREN LAW OFFICES, P.C. PA. LD. # 307028 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL TRIAL DIVISION U.S. Bank National Association, as Trustee for Asset Backed Securities Corporation Home Equity Loan Trust, Series OOMC 2006-HE5, Asset Backed Pass -Through Certificates, Series OOMC 2006-HE5 Plaintiff v. Michael Harris a/k/a Michael P. Harris; Carrie Vogelsong a/k/a Carrie M. Vogelsong Defendant(s) NO. 14-382 Civil 1-1 ):?" CZ) " • ' • ORDER AND NOW, this 30. day of Apo) , 2014, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Complaint in Mortgage Foreclosure on Defendant(s), Michael Harris a/k/a Michael P. Harris, Carrie Vogelsong a/k/a Carrie M. Vogelsong, shall be complete when Plaintiff or its counsel or agent has served true and correct copies of the Complaint in Mortgage Foreclosure by posting the mortgage premises at: 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 And by mailing by certified mail and regular mail to the last known address of Defendant(s) as follows: MICHAEL HARRIS A/K/A MICHAEL P. HARRIS 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 EXHIBIT B . t. , CARRIE VOGELSONG A/K/A CARRIE M. VOGELSONG 138 WEST GREEN STREET, MECHANICSBURG, PA 17055 A/K/A 138 WEST GREEN STREET CARLISLE, PA 17013 BY THE COURT: 4441 EXHIBIT B IIS Bank, National Association. as Trustee, et. al., Plaintiff(s) vs.f Michael Harris aka Michael P. Harris, et. al, Defendant(s) UDREN LAW OFFICES Ms. Henni Crommarty 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 Service of Process by APS International, Ltd. 1-800-328-7171 Ars INTFKNATr0NA7. APS International Plaza 7800 Glenroy Rd. Minneapolis. MN 55439-3122 APS File N: 130840-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Carrie Vogelsong, aka Carrie M. Vogelsong by posting Court Case No. Comberland Co 14-382 Civil Name of Server: Date/Time of Service: Place of Service: Documents Served: Service of Process on: Person Served. and Method of Service: undersigned. being duly sworn, deposes and says that at the time of service. s/he was of legal age and was not a party to this action: x that on they ay of �( .(A4- . 20 k , ato'clock at 138 West Green Street, Mechanicsburg. PA 17055 aka • 111 Carlisle, PA 17013_. 138 West Green Street the undersigned served the documents described as: Notice of Sheriff's Sale of Real Property w/ Order M A true and correct copy of the aforesaid document(s) was served on: Carrie Vogelsong, aka Carrie M. Vogelsong by posting B personally delivering them into th By delivering them into the hands of of suitable age. who verified. or who upon questioning ated. that he/she resides with Carric Vogelsong, aka Carrie M. Vogelsong by posting ids of the person to be served. a person at the place of service. and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Signature of Server: Sex : Skin Color : Hair Color Approx. Age : Facial Hair : Approx. Height : Approx. Weight To the best of m knowledge and belief. said person was not engaged in the US Military at the time s under true and erjury Subscriped an APS International, Ltd. EXHIBIT B COMMONWEALTH OF PENNSYLVANI NOTARIAL SEAL Tammie L. Crutcher, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 9, 2015 dEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES swo a AO _,/.., ! .1,x ublic ,(Commission Expires) to before me this 20 US Bank. National Association, as Trustee, et. al., Plaintiff(s) Michael Harris aka Michael P. Harris, et. al., Defendant(s) UDREN LAW OFFICES Ms. Henni Crornmarty III Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 State of: County ofc,c..t,J(`() Name of Server: Service of Process by - ' APS International, Ltd. 1-800-328-7171 itcrERNATiormi, APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 130840-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: --Michael Harris, aka Michael P. Harris by posting Court Case No. Contberland Co 14-382 Civil S ��hU l�lDV ) ss. ‘s' r lie C�- Aq A -on that at the time of service. s/he was of legal Date/'Time of Service: Place of Service: Documents Served: Service of Process on: Person Served, and Method of Service: Description of Person Receiving Documents: Signature of Server: that on the e.flay of undersigned, being duly sworn, deposes and says age and was not a party to this action: . 20 l 4(�- ata a° o'clock ti_. M 3t?s�- at 138 West Green Street, Mechanicsburg. PA 17055 aka 138 West Green Street the undersigned served the documents described as: Notice of Sheriffs Sale of Real Property w/ Order , in Carlisle, PA 17013 A true and correct copy of the aforesaid document(s) was served on: Michael Harris, aka Michael P. Harris by posting ! By personally delivering them into the hands of the person to be served. By delivering them into the hands of of suitable age. who verified, or who upon questio n fated, that he/she resides with Michael Harris, aka Michael P. Harris by posting SA -1N . a person at the place of service, and whose relationship to the person is: The person receiving documents is described as follows: Sex ; Skin Color : Hair Color Approx. Age : Approx. Height ; Facial Hair_ : Approx. Weight To the best of my knowledge and belief, said person was not engaged in the US Military at th- ime of s icier p-nalty o corre lorwAtort7. iature o Se r Subs ibed d./, • APS International, Ltd. EXHIBIT B COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Tammie L. Crutcher, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 9, 2015 :EMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES d sw f20 It' to befo e me this ev (Commission Expires) Notary Public