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HomeMy WebLinkAbout14-1762 Supreme Court- of Pennsylvania Cour COm • , Pleas For Prothonotary Use Only: v>lov et �. CU Elii `ANDS County Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. S Commencement of Action: Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: OCWEN LOAN SERVICING, Lead Defendant's Name: SULTANA SIDDIQUI A/K/A T LLC SULTANA K. SIDDIQUI I Are money damages requested? El Yes 0 No lim its Dollar Amount Requested: ❑ within arbitration its 0 (Check one) outside arbitration limits N Is this a Class Action Suit? ❑ Yes Z No Is this an MDJ Appeal? ❑ Yes ❑x No A Name of Plaintiff /Appellant's Attorney: John D. Krohn, Esq., Id. No.312244, Phelan Hallinan, LLP ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections • Nuisance ❑ Dept. of Transportation • Premises Liability ❑ Statutory Appeal: Other • Product Liability (does not S include mass tort) ❑ Employment Dispute: • Slander/Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES • Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS • Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration $ ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY 0 Mortgage Foreclosure: Commercial ❑ Quo Warranto • Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: • Medical ❑ Other: ❑ Other Professional: Pa.R.CP. 205.5 Updated 0110112011 2E>1 (o <R c0 A H, 10 19 3ERL. c0U14TY PE N'S"Yk _VANIii PHELAN HALLINAN, LLP John D. Krohn, Esq., Id. No.312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 john.krohn@phelanhallinan.com 215 -563 -7000 OCWEN LOAN SERVICING, LLC 1661 WORTHINGTON ROAD, SUITE 100 COURT OF COMMON PLEAS WEST PALM BEACH, FL 33409 CIVIL DIVISION Plaintiff V. TERM SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI NO. 101 SHERWOOD DRIVE CARLISLE, PA 17015 -8296 CUMBERLAND COUNTY SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015 -8296 ALIOBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015 -8296 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE S 113:�Spda�lc File #: 759812 0 �-t* ' 1 4 6 " 36-39 �� 1. Plaintiff is OCWEN LOAN SERVICING, LLC 1661 WORTHINGTON ROAD, SUITE 100 WEST PALM BEACH, FL 33409 2. The name(s) and last known address(es) of the Defendant(s) are: SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015 -8296 SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015 -8296 ALIOBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015 -8296 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 03/08/2001 SULTANA SIDDIQUI and SAIFULLAH SIDDIQUI made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR GREENPOINT MORTGAGE FUNDING, INC., which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1685, Page 235. By Assignment of Mortgage recorded 07/30/2013 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No. 201325133. Said Mortgage was modified as set forth in the modification agreement recorded December 1, 2010, in Instrument No. 201035106. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. File #: 759812 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 01/31/2014: Principal Balance $207,971.64 Interest $23,396.80 10/01/2010 through 01/31/2014 Late Charges $0.00 Property Inspections $45.00 Escrow Deficit $12,967.09 TOTAL $244,380.53 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). File #: 759812 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $244,380.53, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: ( a John D. K/cohn, Esq., Id. No.312244 Attorney for Plaintiff VERIFICATION Lori Ann Dasch , hereby states that he /she is contract Management Coordinator of OCWEN LOAN SERVICING, LLC, Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: � (/'� tee Lori Ann Dasch Title: Authorized Signer OCWEN LOAN SERVICING, LLC File #: 759812 Name: SIDDIQUI File #: 759812 LEGAL DESCRIPTION ALL THAT CEDRTAIN tract of land Situate in Silver Spring Township, Cumberland county, Pennsylvania, bounded and described according to a survey for Mary E. McCahan, dated August 2, 1978, by Robert G. Hart, Jr. E.D. as follows: BEGINNING at a point in the center line of the legal right -of -way line of Foxanna Drive, which point is referenced 72 feet to the center line of the intersection of She5rwood Road and Foxanna Drive; thence along the said center line of the legal right -of -way line of Foxanna Drive, North 14 degrees 12 minutes 30 seconds west 245.60 feet to a point, thence along the center line of the legal right -of -way line of Sherwood Road (T -503), South 67 degrees 09 minutes 218.68 feet to a point, thence along Lot No. 1 now or late formerly of Larry D. Hinson, and through an iron pin, 25 feet from the center line of Sherwood Road (T -503) south 04 degrees 30 minutes east, 208.38 feet to an iron pin, thence along Lot No. 6 north 85 degrees 30 minutes east 260 feet to a point in the center line of Foxanna Drive, the place of beginning. CONTAINING 1.345 acres including the dedicated right -of -way and being lot no. 96 on the above referred to plan of Mary E. McCahan as recorded in plan book 29 page 89, Cumberland County Records having thereon erected a dwelling house known and numbered as 101 Sherwood Road, Carlisle Pennsylvania. PARCEL NO. 38 -05- 0433 -022. File #: 759812 BEING THE SAME PREMISES which Athusain E. Emadi, etal by deed dated 3/24/00 and recorded 3/31/00 in Deed Book 218 page 546 granted and conveyed unto Saifullah Siddiqui and Sultana K. Siddiqui, h/w in fee. PROPERTY ADDRESS: 101 SHERWOOD DRIVE, CARLISLE, PA 17015 -8296 PARCEL #38 -05- 0433 -022 File #: 759812 FORM 1 IN THE COURT OF COMMON PLEAS-)..,, OCWEN LOAN SERVICING, LLC OF CUMBERLAND COUNTY, PENNSYL)'&1A.%­ Plaintiff(s) � �o "A0 VS. 's CF' SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI y� 7 SAIFULLAH SIDDIQUI I % C" i Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 3 y Date John D. (ohn, Esq., Id. No.312244 Attorney for Plaintiff 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 counseling agency. Please provide the following information to the best of your knowledge: CUSTOM E10"RIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # 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 #l: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 ° Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care/Tuit. Other Ex enses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the counseling 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: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 759812 FILED -OFFICE C THE PROTHONOTARY 2i -n 4 SEPI 7 AM (U: 07 CUMBERLAND COUNTY PENNSYLVANIA PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Attorney for Plaintiff OCWEN LOAN SERVICING, LLC Court of Common Pleas 1661 WORTHINGTON ROAD, SUITE 100 WEST PALM BEACH, FL 33409 Civil Division Plaintiff No. 14 -1762 -CIVIL v. Cumberland County SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 ALI OBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 Defendants MOTION TO LIFT CONCILIATION STAY Plaintiff, Ocwen Loan Servicing, LLC (hereinafter "Plaintiff'), by its attorney, Joseph P. Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1 On .March_ 26,. 2014, , Plaintiff filed. a.. Complaint in_ Mortgage,,Foreclosure.. against 759812 Defendants Sultana Siddiqui A/K/A Sultana K. Siddiqui, Saifullah Siddiqui, and Ali Obaidullah Siddiqui (hereinafter "Defendants") for their failure to make monthly payments of principal and interest upon their mortgage due November 1, 2010, and eachmonth thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as. Exhibit "A". 2. On March 31, 2014, Plaintiff completed service of the Complaint in Mortgage Foreclosure along with the Cumberland County Residential Mortgage Foreclosure Diversion Program Notice upon the Defendants. A true and correct copy of the Sheriffs Return of Service is attached hereto, made part hereof and marked as Exhibit `B". 3. Pursuant to the Cumberland County Administrative Order February 28, 2012, which created the Cumberland County Residential Mortgage Foreclosure Diversion Program, the Foreclosure action is stayed for sixty (60) days from- the date of service. 4. Within 60 days after service of the complaint, the Defendants may opt into the program by filing a Request for Conciliation Conference with the Court. Upon the filing of the request, the Court will schedule a Conciliation Conference. The program provides that Defendants must contact MidPenn Legal Services within the first twenty (20) days of receipt of notice if not represented by counsel. 5. If more than sixty (60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendants have not opted to participate in the Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the Diversion Program. 6. Defendants have failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty (60) days of service. 7. Since Defendants have opted not to participate in the Diversion Program, it is appropriate, for the, stay. to. be . lifted.. 759812 Exhibit "A" S E C T 4 N A S E C T I 0 N Supreme Cour. Cour Pennsylvania Pleas et County For Prothonotary Use Only: io. )(IIDocket No: 1(1 {p� The information collected on this, form is used solely for court administration purposes. This form does not ;supplement or replace the g and service afpleadings or other paper•s as rat urred by law or rules of court. Commencement of Action: 0 Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiff's Name: OCWEN LOAN SERVICING, LLC Lead Defendant's Name: SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI Dollar Amount Requested: 0 within arbitration limits (:Check one) © outside arbitration limits Are money damages requested? ■Yes No Is this a Class Action Suit? ■ Yes i No Is this an MDJ Appeal? ■ Yes © No Name of Plaintiff/Appellant's Attorney: John D. Krohn, Esq., Id. No.312244, Phelan Hallinan, LLP (are a Self -Represented [Pro Se] Litigant) • Check here if you have no attorney Nature of the C t Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) O Intentional ❑ Malicious Prosecution ❑ Motor Vehicle O Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Other: MASS TORT 0 Asbestos 0 Tobacco ❑ Toxic Tort - DES El Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL 0 Dental ❑ Legal ❑ Medical ❑ Other Professional: LIABILITY Pa.R.C.P. 205.5 CONTRACT (do not include Judgments) ❑ Buyer Plaintiff 0 Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other 0 Other: . REAL PROPERTY ❑ Ejectment ❑ Eminent Domain/Condemnation El Ground Rent 0 Landlord/Tenant Dispute ® Mortgage Foreclosure: Residential ❑ Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet Title 0 Other: CIVIL APPEALS Administrative Agencies 0 Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other 0 Zoning Board ❑ Other: MISCELLANEOUS 0 Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non -Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin ❑ Other: Updated 01/01/2011 PHELAN HALLINAN, LLP John D. Krohn, Esq„ Id. No.312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 john.krohn@phelanhallinan.com 215-563-7000 _ OFFICE i t:E ', O l H.O:N O TA R '. 2Ci4 NPR 26 P;t,10: 19 C;UMBERL.AND COUNTY PENNSYLVANIA ATTORNEY FOR PLAINTIFF OCWEN LOAN SERVICING, LLC 1661 WORTHINGTON ROAD, SUITE 100 COURT OF COMMON PLEAS WEST PALM BEACH, FL 33409 CIVIL DIVISION Plaintiff v TERM SULTANA SIDDIQUI.A/KJA SULTANA K. SIDDIQUI NO. 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 ALI OBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 Defendants CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 759812 cokkk %)(sgDs o k C� iLib35) a 124_36-39 �`� 1. Plaintiff is OCWEN LOAN SERVICING, LLC 1661 WORTHINGTON ROAD, SUITE 100 WEST PALM BEACH, FL 33409 2. The name(s) and last known address(es) of the Defendant(s) are: SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 ALI OBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 03/08/2001 SULTANA SIDDIQUI and SAIFULLAH SIDDIQUI made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR GREENPOINT MORTGAGE FUNDING, INC., which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1685, Page 235. By Assignment of Mortgage recorded 07/30/2013 the mortgage was assigned to PLAINTIFF, which Assignment is recorded in Assignment of Mortgage Instrument No. 201325133. Said Mortgage was modified as set forth in the modification agreement recorded December 1, 2010, in Instrument No. 201035106. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. File H: 759812 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 01/31/2014: Principal Balance Interest 10/01/2010 through 01/31/2014 Late Charges Property Inspections Escrow Deficit TOTAL $207,971.64 $23,396.80 $0.00 $4.-)() $1.2,967.09 -$2440380-.3: 7,. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). File fl: 759812 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $244,380.53, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: John D. dm, Esq., Id. No.312244 Attorney or Plaintiff VERIFICATION Lori Ann Dasch hereby states that he/she is Contract Management Coordinator of OCWEN LOAN SERVICING, LLC, Plaintiff in this matter, that he/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.. DATE: Filet 759812 Name: SIDDIQUI File #: 759812 nisi Lori Ann Dasch Title: Authorized Signer OCWEN LOAN SERVICING, LLC LEGAL DESCRIPTION ALL THAT CEDRTAIN tract of land Situate in Silver Spring Township, Cumberland county, Pennsylvania, bounded and described according to a survey for Mary E. McCahan, dated August 2, 1978, by Robert G. Hart, Jr. E.D. as follows: BEGINNING at a point in the center line of the legal right-of-way line of Foxanna Drive, which point is referenced 72 feet to the center line of the intersection of She5rwood Road and Foxanna Drive; thence along the said center line of the legal right-of-way line of Foxanna Drive, North 14 degrees 12 minutes 30 seconds west 245.60 feet to a point, thence along the center line of the legal right-of-way line of Sherwood Road (T-503), South 67 degrees 09 minutes 218.68 feet to a point, thence along Lot No. 1 now or late formerly of Larry D. Hinson, and through an iron pin, 25 feet from the center line of Sherwood Road (T-503) south 04 degrees 30 minutes east, 208.38 feet to an iron pin, thence along Lot No. 6 north 85 degrees 30 minutes east 260 feet to a point in the center line of Foxanna Drive, the place of beginning. CONTAINING 1.345 acres including the dedicated right-of-way and being lot no. 96 on the above referred to plan of Mary E. McCahan as recorded in plan book 29 page 89, Cumberland County Records having thereon erected a dwelling house known and numbered as 101 Sherwood Road, Carlisle Pennsylvania. PARCEL NO. 38-05-0433-022. Fte 1t: 759812 BEING THE SAME PREMISES which Athusain E. Emadi, etal by deed dated 3/24/00 and recorded 3/31/00 in Deed Book 218 page 546 granted and conveyed unto Saifullah Siddiqui and Sultana K. Siddiqui, h/w in fee. PROPERTY ADDRESS: 101 SHERWOOD DRIVE, CARLISLE, PA 17015-8296 PARCEL #38-05-0433-022 798I2 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 counseling agency, Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: Realtor Name: Realtor. Phone: Borrower Occupied? Yes D No 0 Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Horne: Office: Cell; Other: Email: # of people in household: How long? First Mortgage Lender: , -- Type of Loan: Loan Number:. Date You Closed Your Loan: Second Mortgage Lender; Type of Loan: Loan Number: Total Mortgage Payments Amount: $ . Included Taxes & Insurance: Date of Last Payment Primary Reason for Default: Is the loan in Bankruptcy? Yes D No LJ If yes, provide names, location of court, case number & attorney: Assets Home: Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other: AmountOwed: Value: $$ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net 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 Mortgagc Food 2Mortgage Utilities Car Pa men s) Condo/Nei :h. Fees Auto nsuranc Med. (not v Auto fuel/repairs Other prop. payment Cable TV Instail. Loan Payment Child Su. e ort/Alim. S endin : M on e Day/Child Careauit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? YesD No If yes, please provide the following information: Counseling Agency. Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations. Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name):. ._:Phone: Servicing Company (Name): Contact: Phone: I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the counseling 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: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 759812 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ocwen Loan Servicing Center, LLC II Case Number vs. 2014-1762 Sultana Siddiqul (stat.) F SHERIFF'S RETURN OF SERVICE 03/31/2014 08:48 PM - Deputy Dennis Fry, being duty sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint In Mortgage Foreclosure by handing a true copy to a person representing themselves to be All Obaidullah Siddiqui, son, who accepted es "Adult Person in Charge" for Sultana`Siddiqul at 101 Sherwood Drive, Silver Spring Twp, Carlisle, PA 17013. DENNIS FRY, DEPU 03/31/2014 08:48 PM - Deputy Dennis Fry, being dulyswom according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Ali Obaidullah Siddiqul, son, who accepted as "Adult Person in Charge" for Salfullah Siddiqui at 101 Sherwood Drive, Silver Spring Twp, Carlisle, PA 17013. DENNI8 RY, DEPU 03/31/2014 08:46 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint In Mortgage Foreclosure by "personalty" handing a tnue copy to a person representing themselves to be the Defendant, to wit: Ali Obaidullah Siddiqui at 101 Sherwood Drive, Silver Spring, Carlisle, PA 17015. DE DEPU?( SHERIFF COST: $66.78 SO ANSWERS, April 02, 2014 RONNY,R ANDERSON, SHERIFF 4. (U CountySu4a Stere, Teleosol. Inc. PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Attorney for Plaintiff OCWEN LOAN SERVICING, LLC Court of Common Pleas 1661 WORTHINGTON ROAD, SUITE 100 WEST PALM BEACH, FL 33409 Civil Division _ Plaintiff No. 14 -1762 -CIVIL v. Cumberland County SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 ALI OBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 Defendants CERTIFICATION OF SERVICE I, Joseph P. Schalk, Esquire, certify that I caused true and correct copies of Plaintiff's Motion to Lift Conciliation Stay and proposed Order to be sent sent via first class mail to the person listed below on the date indicated: SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 Date: 759812 B Schalk, Esquire ney-forPlaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA OCWEN LOAN SERVICING, LLC 1661 WORTHINGTON ROAD, SUITE 100 WEST PALM BEACH, FL 33409 Plaintiff v. SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 ALI OBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 Defendants Court of Common Pleas Civil Division No. 14 -1762 -CIVIL Cumberland County (/) Fri 0 IN) ORDER AND NOW, this 2'7 day of glitofriiart" , 2014, upon consideration of Plaintiffs Motion to Lift Conciliation Stay in the above captioned matter, it is hereby ORDERED and DECREED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. ,i.,. BY T COURT: I cc: SULTANA SIDDIQUI A/KIA SULTANA . SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI ......‹Ioseph P. Schalk, Esquire, Id. No.,91656 Attorney for Plaintiff Cith.w*g.s. EQUAIS-44.- 759812 VA an PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 759812 PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) . P.R.C.P. 3180-3183 OCWEN Loan Servicing, LLC Plaintiff v. Sultana Siddiqui a/k/a Sultana K. Siddiqui Saifullah Siddiqui Mi Obaidullah Siddiqui Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 11/19/2014 to Date of Sale ($40.17 per diem) TOTAL Note: Please attach description of property. PH # 759812 P\ 657 : COURT OF COMMON PLEAS CIVIL DIVISION : NO.: 14 -1762 -CIVIL . CUMBERLAND COUNTY $244,380.53 C: $4,258.02 C: rrk $248,638.55 rrt rs1 C 7, K� % -�- (:)Y Phelan Hallinan, LL Attorney for Plaintiff Adam H. Davis, Esq., Id. No.203034 LEGAL DESCRIPTION ALL THAT CEDRTAIN tract of land Situate in Silver Spying Township, Cumberland county, Pennsylvania, bounded and described according to a survey for Mary E. McCahan, dated August 2, 1978, by Robert G. Hart, Jr. E.D. as follows: BEGINNING at a point in the center line of the legal right-of-way line of Foxanna Drive, which point is referenced 72 feet to the center line of the intersection of She5rwood Road and Foxanna Drive; thence along the said center line of the legal right-of-way line of Foxanna Drive, North 14 degrees 12 minutes 30 seconds west 245.60 feet to a point, thence along the center line of the legal right-of-way line of Sherwood Road (T-503), South 67 degrees 09 minutes 218.68 feet to a point, thence along Lot No. 1 now or late formerly of Larry D. Hinson, and through an iron pin, 25 feet from the center line of Sherwood Road (T-503) south 04 degrees 30 minutes east, 208.38 feet to an iron pin, thence along Lot No. 6 north 85 degrees 30 minutes east 260 feet to a point in the center line of Foxanna Drive, the place of beginning. CONTAINING 1.345 acres including the dedicated right-of-way and being lot no. 96 on the above referred to plan of Mary E. McCahan as recorded in plan book 29 page 89, Cumberland County Records having thereon erected a dwelling house . TITLE TO SAID PREMISES IS VESTED IN Saifullah Siddiqui and Sultana K. Siddiqui, his wife, by Deed from Athusain E. Emadi and Asma A. Emadi, his wife and Nasirali A. Emadi and Maleka Emadi, his wife, by Athusain E. Emadi, their attorney in fact and Asad A. Siddiqui and Obaid A. Siddiqui and Ebad A. Siddiqui, dated 03/24/2000, recorded 03/31/2000 in Book 218, Page 546. PREMISES BEING: 101 Sherwood Drive, Carlisle, PA 17015-8296 PARCEL NO. 38-05-0433-022 PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1'400 " One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 OCWEN Loan Servicing, LLC Plaintiff v. Ci- 017 .ilt;i.s T.Fi' 20 LTV I8 A -r' 11:2i CW.113E11,4;,11 ,4;,11 COUN Y PE\'Nc YLVANI Sultana Siddiqui a/k/a Sultana K. Siddiqui Saifullah Siddiqui Ali Obaidullah Siddiqui Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 14 -1762 -CIVIL . CUMBERLAND County The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non -owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff t1011 13 E1111: 21 Sultana Siddiqui a/k/a Sultana K. Si4diqui,I A) .),)tit' Saifullah Siddiqui Ali Obaidullah Siddiqui Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 14 -1762 -CIVIL CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 OCWEN Loan Servicing, LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 101 Sherwood Drive, Carlisle, PA 17015-8296. Name and address of Owner(s) or reputed Owner(s): Name Sultana Siddiqui a/k/a Sultana K. Siddiqui Saifullah Siddiqui 2. Name and address of Defendant(s) in the judgment: Name Sultana Siddiqui a/k/a Sultana K. Siddiqui Saifullah Siddiqui Ali Obaidullah Siddiqui Address (if address cannot be reasonably ascertained, please so indicate) 101 Sherwood Drive Carlisle, PA 17015-8296 101 Sherwood Drive Carlisle, PA 17015-8296 Address (if address cannot be reasonably ascertained, please so indicate) 101 Sherwood Drive Carlisle, PA 17015-8296 101 Sherwood Drive Carlisle, PA 17015-8296 101 Sherwood Drive Carlisle, PA 17015-8296 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) GMAC Mortgage, LLC. GMAC Mortgage LLC CIO Scott Rothman, Esquire GMAC Mortgage, LLC. Leiby'S Mhc Leiby'S Mhc C/O Andrew Sheely, Esquire PH # 759812 500 Enterprise Road Suite 150 Horsham, PA 19044.0969 1100 E Hector st Ste 425 Conshohocken, PA 19428 1100 Virginia Drive Fort Washington, PA 19034 7075 Carlisle Pike Carlisle, PA 17015 127 South Market Street PO Box 95 Mechanicsburg, PA 17055 Country Manor West 2 Apple Alley Carlisle, PA 17015 Country Manor West 111 East Market Street, Suite 101 C/O Joseph Gothic, Esquire York, PA 17401-1274 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address'cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 101 Sherwood Drive Carlisle, PA 17015-8296 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice U.S. Attorney for The Middle District of PA Federal Building 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: f(7/77/ PH # 759812 By: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 4 OCWEN Loan Servicing, LLC : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : NO.: 14 -1762 -CIVIL Sultana Siddiqui a/k/a Sultana K. Siddiqui Saifullah Siddiqui Ali Obaidullah Siddiqui : CUMBERLAND County Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Sultana Siddiqui a/k/a Sultana K. Siddiqui Saifullah Siddiqui Ali Obaidullah Siddiqui 101 Sherwood Drive Carlisle, PA 17015-8296 N) **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USEDFOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 101 Sherwood Drive, Carlisle, PA 17015-8296 is scheduled to be sold at the Sheriff's Sale on 03/04/2015 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $244,380.53 obtained by OCWEN Loan Servicing, LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1: If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 _ SHORT DESCRIPTION By virtue of a Writ of Execution No. 14 -1762 -CIVIL OCWEN Loan Servicing, LLC V. Sultana Siddiqui a/k/a Sultana K. Siddiqui Saifullah Siddiqui Ali Obaidullah Siddiqui owner(s) of property situate in SILVER SPRING TOWNSHIP, CUMBERLAND County, Pennsylvania, being 101 Sherwood Drive, Carlisle, PA 17015-8296 Parcel No. 38-05-0433-022 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $244,380.53 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CEDRTAIN tract of land Situate in Silver Spring Township, Cumberland county, Pennsylvania, bounded and described according to a survey for Mary E. McCahan, dated August 2, 1978, by Robert G. Hart, Jr. E.D. as follows: BEGINNING at a point in the center line of the legal right-of-way line of Foxanna Drive, which point is referenced 72 feet to the center line of the intersection of She5rwood Road and Foxanna Drive; thence along the said center line of the legal right-of-way line of Foxanna Drive, North 14 degrees 12 minutes 30 seconds west 245.60 feet to a point, thence along the center line of the legal right-of-way line of Sherwood Road (T-503), South 67 degrees 09 minutes 218.68 feet to a point, thence along Lot No. 1 now or late formerly of Larry D. Hinson, and through an iron pin, 25 feet from the center line of Sherwood Road (T-503) south 04 degrees 30 minutes east, 208.38 feet to an iron pin, thence along Lot No. 6 north 85 degrees 30 minutes east 260 feet to a point in the center line of Foxanna Drive, the place of beginning. CONTAINING 1.345 acres including the dedicated right-of-way and being lot no. 96 on the above referred to plan of Mary E. McCahan as recorded in plan book 29 page 89, Cumberland County Records having thereon erected a dwelling house . TITLE TO SAID PREMISES IS VESTED IN Saifullah Siddiqui and Sultana K. Siddiqui, his wife, by Deed from Athusain E. Emadi and Asma A. Emadi, his wife and Nasirali A. Emadi and Maleka Emadi, his wife, by Athusain E. Emadi, their attorney in fact and Asad A. Siddiqui and •Obaid A. Siddiqui and Ebad A. Siddiqui, dated 03/24/2000, recorded 03/31/2000 in Book 218, Page 546. PREMISES BEING: 101 Sherwood Drive, Carlisle, PA 17015-8296 PARCEL NO. 38-05-0433-022 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 OCWEN LOAN SERVICING, LLC . Vs. NO 14-1762 Civil Term CIVIL ACTION — LAW SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI 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: $244,380.53 L.L.: $50 Interest FROM 11/19/2014 TO DATE OF SALE ($40.17 PER DIEM) - $4,258.02 Atty's Comm: Atty Paid: $215.53 Plaintiff Paid: Date: 11/18/14 (Seal) REQUESTING PARTY: Name: ADAM H. DAVIS, ESQUIRE Address: PHELAN HALLINAN, LLP 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 203034 Due Prothy: $2.25 Other Costs: '124„;,LI David D. Buell, Prothonotary Deputy T1LL]-Qr ICE CF T!,_ ti ;_ } ONO ir',R PHELAN HALLINAN, LLP. Adam H. Davis, Esq., Id. No.2030 4' 1 NOV ! 3 A;-111: 15 1617 JFK Boulevard, Suite 1400 C W• I E LA NL1 COUNTY One P nn Center Plaza PE , A UU�iSl' E.1aNiA Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 Attorney for Plaintiff OCWEN LOAN SERVICING, LLC : CUMBERLAND COUNTY vs. : COURT OF COMMON PLEAS SULTANA SIDDIQUI : CIVIL DIVISION A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI : No. 14 -1762 -CIVIL ALT OBAIDULLAH SIDDIQUI PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against SULTANA SIDDIQUI . A/K/A SULTANA K. SIDDIQUI, SAIFULLAH SIDDIQUI, and ALI OBAIDULLAH _ SIDDIQUI, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $244,380.53 TOTAL $244,380.53 I hereby certify that (1) the Defendants' last known address is 101 SHERWOOD DRIVE, CARLISLE, PA 17015-8296, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: I 118/if" PH # 759812 PROTHONOTARY 759812 CA0 1ycfigie0 21366i / / PHELAN HALLINAN, LLP Adam, H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 OCWEN LOAN SERVICING, LLC vs. SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI Attorney for Plaintiff • : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14 -1762 -CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in -the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that the defendant SAIFULLAH SIDDIQUI's Social Security Number is not available because she is not the borrower on the loan, and thus, we are unable to determine whether or not SAIFULLAH SIDDIQUI is in military service. (c) that the defendant ALI OBAIDULLAH SIDDIQUI's Social Security Number is not available because she is not the borrower on the loan, and thus, we are unable to determine whether or not ALI OBAIDULLAH SIDDIQUI is in military service. (d) that defendant SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI is over 18 years of age and resides at 101 SHERWOOD DRIVE, CARLISLE, PA 17015-8296. (e) that defendant SAIFULLAH SIDDIQUI is over 18 years of age and resides at 101 SHERWOOD DRIVE, CARLISLE, PA 17015-8296. 759812 (f) that defendant ALI OBAIDULLAH SIDDIQUI is over 18 years of age and resides at 101 SHERWOOD DRIVE, CARLISLE, PA 17015-8296. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date ((//77/ Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 759812 7 Department of Defense Manppwar p ata center R at soant to ci..viriemembeis Civil Relief Act Last Name: SIDDIQUI First Name: SULTANA Middle Name: Active Duty Status As Of: Nov -17-2014 Results as of : Nov -17-2014 12:06:18 AM SCRA 3.0 , a4ler'N i' • MW,..t.,Zittra.-*- 647, -it fl . ' ,',,,..,. Z- - , ,47:* .'41hrs'ttiy'e7fitlyV;14''A'Y'cliy:?,ordYrtal,tts7sr°D.,ata:"::,-F27.-?4'',:-1,;3:f1M,,,,,,,, .., ,,ry%;;!.;:Z4,Ts''Y'::%:r,,;„'''j,ewzL;"--kw7;ft',,ef:e1..efv,,,,,,z:,,rft.,„f, W .,-,', ' ,...• M'tiketiirelDuty;Endi atw ,--.4,.., , ,,,,,,^ IIw`" t ''' iC4':`"1"ri2ftIVV't .,,, 4 , '...,. •4 .',' ... • a u.,,,,* -,,%",,,,,, ,,,,,, - 11'''-'4*-V4qS,tigN-'x'-14~47'1 .: q<04!exatt,serme,componendw,Vs,4,„Ait. ^ --, - ,--- - NA NA ....,ltiiiN1 ,04,477,11p,T600: NA v,:,ref rre,7,%._..ii0 ,,,,,,' ,;.a,,:Z ii,,ViV,re, ' ,-,--,-,,,,,,.. ,,..,,, s;',,,, NA " - rC'-'*:?Vi;'''4"i''''''111•;""rc;crri thelAdtiMity Status bate This response reflects vihereAheindividual et fl-ciliT:. 011,.:a atus!,withtn.,367idays re i 9 . , •,,,,,,,,,g,, ,„,,,a4 ,I.,gar...,-, . , , , ,-,,,f :,;gW., - This response reflectsitheindividuale active duty statusbased on the ActivePuty,Status Date 7f,* 2,,,..,11,,,,,i'-‘,,telellia't p •,,,,,,,,,,w,,m, •• - 7:3,-,oxi.g.--,4•04,--0.4,:',Wk'f-,,V;i$4$'.0".4..1•0'4.1- - ' • .- " • .' fr'''''r tyZ:- ' ' r4 -.*" - c '''',.: '..-4---w-,....---,175 . ."&tfiAetive-DlitONithii0674MisiotActive.DutyiSt1a r,'''f4r,,,' i, ' ^,-, Ss, i ..,,,a,vr- ,r,g, -. ' -,_.----1 • • :.•.;,, - ,-..e..z.,,tx.y. --."'viav:%,,,,,,,mi: • ..; ..1- -, -11p-, „,, _ ,,, . ..,,. , 4., evire.,,,,irl,., erW '47%P•v''''''''.. ,,,,,„,-4.,,,,,,,00., 13,,,,.q.:,,1654..,, k'l..V;'. '' • cove u y.„, , ..%4V-**As!,:f,„,k,status . ,_'-14 „,_ . '' ''''' ''''!'''Srvici;iD0.1111;tifle.iii „ ...,,,-..,- . _ .-...-ers'exi° NA NA ....,ltiiiN1 '' ' - ' . NA " - rC'-'*:?Vi;'''4"i''''''111•;""rc;crri thelAdtiMity Status bate This response reflects vihereAheindividual et fl-ciliT:. 011,.:a atus!,withtn.,367idays re i 9 . , ...,...,,,,....,, -,. At-Mtong#41,e,..:wq ,iit1,111rigki;' ..c.iMilralitut;70,-,.,x0Mrott- --, ' fp., r- • -4-0,,Av '.4.' . .,'''' 'Vfl. ,dAltiVOlder,Notlficatolii'llarafeM,V:,fi". 1Z.7!..*Vr; „prat utazgrowit,„ =%, : — :::.,..i...4,4. ,i,. t,=is is. .... 0-, /-4",e..fr - — NA. ... ' ' ',,WITA‘a:,:..‘.:,' i fife:i ';-1 ' NA This response reflecis;haTerfthi=id'unfiii;ihiiiiUnithaS.,rdiefaiillirlY7nWilriPtg,ZPori for active duty %*M Upomsearching the data banks of the Department of Defense'en;PSLeatetenter,,tbasedtomthe'in, ferma,tion that you provided, the above is the status of . .the,,inctividiial on•the active duty status Uniformechdate as to all branches of theServices4Arrny, Navy, Marine Corps, Air Force, NOAA, eyblic Health, and date . . Coast Guard). This status includes information on a Servicememberor his/her unit receiving notification of future orders to report for Active Duly'. Mary M. Snavely -Dixon, Director, Department of Defense - Manpower Data Center zttp().fyerkCenterDrive, Suite 94E25 Arlington, yit 22350 . (Rule of.Civil Procedure No. 236) - Revised OCWEN LOAN SERVICING, LLC CUMBERLAND COUNTY vs. SULTANA SIDDIQUI : COURT OF COMMON PLEAS A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI • ALI OBAIDULLAH SIDDIQUI : CIVIL DIVISION : No. 14 -1.762 -CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on k \Va 1I y . If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * 759812 OCWEN LOAN SERVICING, LLC Plaintiff V.. SULTANA SIDI3IQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBATDULLAH SIDDIQUI Delendant(s) TO: SULTANA SIDD1Q1a1. A/K/A SULTANA K. Si]DIQUT 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 DATE OF NOTICE: /'gid J COURT OF COMMON PLEAS CIVIL DIVISION. NO. 14-1762-C.rVII., CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION• OBTAINED FROM YOU WILL BE. USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE' IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. .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. • Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square - Carlisle, PA 17013 (717) 240-6195 By PH # 759812 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 Keaiya BaI&Esq., Id No.203664 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 OCWEN LOAN SERVICING, LLC Plaintiff v. SULTANA SIDDIQUI. A/K/A SULTANA K. . SIDDIQUI SAIFULLAH SIDDIQUI AI I.OBAIDULLAH SIDDIQUI COURT OF COMMON PLEAS C.IVI.L DIVISION • NO. 14 -1762 -CIV IL CUMBERLAND COUNTY Defendant(s) TO: SAIFULLAH SIDDIQUI 101 SHERWOOD DRIVE CARLISLE. PA :17015-8296 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS RE_FERR.ED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY. THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST • PROPERTY. 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 BF 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 759812 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET - CARLISLE, PA 17013 (717) 249-3166 By:;;, Kenya 744Esq., Id. No.203664 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 OCWEN LOAN SERVICING, LLC COURT OF COMMON PLEAS Plaintiff • CIVIL DIVISION - V. SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQU]. Defendant(s) TO: ALI O.BAIDULLAH SIDDIQUI ]0] SHERWOOD DRIVE CARLISLE, PA 17015-8296 DATE OF iNOTICE: /&// 7i / NO. 14-1762=CIV I I.. CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND.ANY.INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 NEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square • Carlisle, PA 17013 (7.17) 240-6195 PH # 759812 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 Kenya Jia es, Esq., Id. No.203664 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PLAINTIFF OCWEN LOAN SERVICING, LLC AFFIDAVIT OF SERVICE (FIILMC) CUMBERLAND COUNTY PH # 759812 SERVICE TEAM/ Ixh COURT NO.: 14 -1762 -CIVIL DEFENDANT SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI SERVE ALI OBAIDULLAH SIDDIQUI AT: 101 SHERWOOD DRIVE CARLISLE, PA 11015-8296 TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: March 4, 2015 SERVED Served and made known to ALI OBAIDULLAH SIDDIQUI, Defendant on the S.1 "day of bEGE/A' 20 14, at 7: 3 S, o'clock _A. M., at (0( St w 2oa D to, t.tft.Er P4, in the manner described below: Defendant personally served. ✓Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: / , Description: Age tour Height Sg s Weight A.00 Race Sex 4.... Other _ Ronald Moll . a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: i'' sil f NAME: On the da of • - 20_, at state that DefendantyNOT FOUND because: Vacant Does Not Exist PRINTED NAME: Ronald Moll 1'I'1LE: Proccss Server NOT SERVED • o'clock _ M., I, , a competent adult hereby Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY; PRINTED NAME: PLAINTIFF OCWEN LOAN SERVICING, LLC AFFIDAVIT OF SERVICE (FHLMC) CUMBERLAND COUNTY PH # 759812 SERVICE TEAM/ lxh COURT NO.: 14 -1762 -CIVIL DEFENDANT SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI SERVE SAIFULLAH SIDDIQUI AT: 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 • SERVED TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: March 4, 2015 Served and made known to SALFULLAH SIDDIOUI, Defendant on the 5± day of ?))=Cfalt8s .R 20 l4, at %T oclockM., at 10I S(Qwoaa DQ, Cth2Lt5tt r PA , in the manner described below: Defendant personalty served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: ,1 , Description: A �, fl Height .S $ Weight 2 0Of Race _ ._„. Sex ` Other _ Ronald Moll , I, , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: yf r�� I NAME: __....__...... .._ PRINTED NAME: Ronald Moll TITLE: Proccss Server NOT SERVED On the dayof ' 20, at o'clock _. M., I, , a competent adult hereby state that Defendnt NOT FOUND because: _ Vacant_ Does Not Exist __ Moved __ Does Not Reside (Not Vacant) _ No Answer on at , at Service Refused Other: 1 understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: PLAINTIFF OCWEN LOAN SERVICING, LLC AFFIDAVIT OF SERVICE (FHLMC) CUMBERLAND COUNTY PH #'759812 SERVICE TEAM/ Ixh COURT NO.: 14 -1762 -CIVIL DEFENDANT SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI SAIFULLAH SIDDIQUI ALI OBAIDULLAH SIDDIQUI SERVE SULTANA SIDDIQUI A/K/A SULTANA K. SIDDIQUI AT: 101 SHERWOOD DRIVE CARLISLE, PA 17015-8296 SERVED TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: March 4, 2015 Served and made known to SULTANA SIDDIOUI A/K/A SULTANA K. SIDDIOUI, Defendant on the C.day of b t ,201¢, at '7=35, o'clock M., at 101 SwooPAQ GcSt,J A., in the manner described below: Defendant personally served. 7 Adult family member with whom Defendant(s) reside(s). Relationship is 14-t . S &WC) Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age 6c) 5 Height 54" Weight/Z O0 Race Sex ._(M_ Other I Ronald Moll , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to thpenatties of 18 Pam S. Sec. 4904 relating to unsworn falsification to authorities. DATE: tgc1( ,, NAME: PRINTED NAME: Ronald Moll TITLE: Process Server NOT SERVED On the day of,20 , at o'clock_. M., I, _ , a competent adult hereby state that Defendant NOT FOUND ecause: Vacant Does Not Exisf Moved No Answer on at Service Refused Other. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. _ Does Not Reside (Not Vacant) at BY: PRINTED NAME: