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HomeMy WebLinkAbout14-6160 Y ' Supreme. Court of Pennsylvan a Cauq4 C ��.�tC om�ion Pleas r ffi O i ILe�I For Prothonotary'Else Oulu !r, Cuicberland Count, Docket No: �' F The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff Name: DEBRA LdFREEDEN C THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATF SCOTT M.FREEDEN T HOLDERS OF THE CWABS INC.ASSET-BACKED I Dollar Amount Requested within arbitration limits 0 Are money Damages requested?: ❑ Yes ® No (Check one) X outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO Name of Plaintiff/appellant's Attorney: KML Law Group,P.C. ❑ Check here if you are a Self-Represented(Pro Se Litigant Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff / Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation s ❑ Premises Liability ❑ Zoning Board ❑ Product Liability(does not include ❑ Statutory Appeal: Other � mass tort) ❑ Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other 1:1 Employment Dispute:Other T ❑ Other: I Q MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory ❑ Toxic Waste $ ❑ Other ❑ Eminent Domain/Condernnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure:Residential ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP,P.C. SUITE 5000-BNY MELLON INDEPENDENCE CENTER - 701 MARKET STREET PHILADELPHIA,PA 19106 (866)413-2311 W W W.KMI,i,A W GROUP.COM THE BANK OF NEW YORK MELLON FKA T Et BANK- r,;.., IC(i.,;,;LI THE COURT OF COMMON PLEAS OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE'1 HOLDERS OF THE CWABS, INC.ASSET-BACKED OF Cumberland COUNTY CERTIFICATES, SERIES 2005-1 c/o Greentree Servicing,LLC CIVIL ACTION-LAW 345 St Peter Street 1100 Landmark Towers ACTION OF MORTGAGE FORECLOSURE St Paul,MN 55102 Plaintiff vs. No. DEBRA L.FREEDEN SCOTT M.FREEDEN Mortgagor(s)and Record Owner(s) CM ►CTI®N:MORT AG! 453 Stonehedge Lane S Mechanicsburg,PA 17055 Defendant(s) NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes,usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted f S.75 _7%P I-L (21,20491 LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you,you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.asax. 5). Call the Plaintiff(your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(cr�,kmllawcroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-631.8 or Fax: 215-825-6418. Please reference our Attorney File Number of 135228FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE HOLDERS OF THE CWABS, INC. ASSET-BACKED CERTIFICATES, SERIES 2005-1, c/o Greentree Servicing,LLC 345 St Peter Street, 1100 Landmark Towers St Paul, MN 55102. 2. The name(s) and address(es) of the Defendant(s) is/are DEBRA L. FREEDEN,453 Stonehedge Lane, Mechanicsburg,PA 17055 and SCOTT M.FREEDEN, 453 Stonehedge Lane, Mechanicsburg, PA 17055,who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On March 14, 2005 mortgagor(s)made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR COUNTRYWIDE HOME LOANS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on March 18, 2005 as Book 1900, Page 2268. The mortgage has been assigned to: THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE HOLDERS OF THE CWABS, INC.,ASSET- BACKED CERTIFICATES, SERIES 2005-1 by assignment of Mortgage recorded on May 04, 2012 as Instrument#: 201213343. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property") 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for February 01,2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more,the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance..................................................................................$126,263.61 Interest from 01/01/2013 to 09/12/2014 at 7.1250%..............................$15,265.15 Per Diem interest rate at$24.65 LateCharges ...............................................................................................$472.00 EscrowBalance..........................................................................................$3,862.07 Corporate Advance...................................................................................$1,205.23 Reasonable Attorney's Fee.......................................................................$2,350.00 $149,418.06 7. If the Mortgage is reinstated prior to a Sheriff's Sale,the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit,process serving and skip tracing,title searches,recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam'judgment)against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding,this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy,but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Plaintiff sent Defendants the notice as required by 35 P.S. Section 1680.401 et. seq. (Act 91 of 1983) or by 41 P.S. Section 403 (Act 6 of 1974) or as required by the Mortgage ("Notice"). A true and correct copy of the Notice is attached and incorporated as Exhibit"B". WHEREFORE,Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$149,418.06, together with interest at the rate of$24.65,per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: KML LAW.GROUP,PW Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff VERIFICATION �� , as the re resentative of Green Tree Servicin LLC p g as servicer for the Plaintiff within named do hereby verify that I am authorized to and do make this verification on behalf of Green Tree Servicing LLC as servicer for the Plaintiff and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I , understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: k 'Yr Q a )y i Gr n Tree Servicing LLC as servicer for THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE HOLDERS OF THE CWABS,INC.ASSET- BACKED CERTIFICATES,SERIES 2005-1 #13522817C-DEBRA L. FREEDEN and SCOTT M.FREEDEN 453 Stonehedge Lane Mechanicsburg,PA 17055 I i EyihibitA i J { i 453 STONEHEDGE LAN MECHANICSBURG, PA 11055 CUMBERLAND County ALL that certain Unit, being Unit No. 453 (the "Unit"), of Stonehedge, A Townhome Condominium. (the "Condominium"), located in Upper' Allen - Township, Cumberland County, Pennsylvania, which Unit is designated in the Declaration of Condominium of Stonehedge, A Townhome Condominium (the "Declaration of Condominium") and Declaration Plats and Plans recorded in the Office of the Cumberland County Recorder of Deeds .in Miscellaneous Book 681, Page 4605 and Right of way Plan Book 12, Page ' 142 respectively, together with any and all amendments thereto. TOGETHER with the undivided percentage interest in the Common Elements appurtenant to the Unit as more particularly set forth in the aforesaid i Declaration of Condominium, as last amended, TOGETHER with the right to use the Limited Common Elements applicable to the Unit being conveyed herein, pursuant to the Declaration of Condominium and Declaration Plats and Plans, as last amended. UNDER AND SUBJECT to any and all covenants, conditions, restrictions, .- rights-of-way, easements and agreements of record in the aforesaid Office, the aforesaid Declaration of Condominium, and matters which a y physical inspection and survey of the Unit and Common Elements 1 would disclose. THE Grantee, for and on behalf of the Grantee and the Grantee's heirs, personal representatives, successors and assigns, by the acceptance of this Deed, covenants and agrees to pay such charges for maintenance, repairs, replacements and other expenses in connection with the Common Elements, and the Limited.Common Elements appurtenant to said Unit, as j may be assessed against him, her, them, it, or said Unit, from time to j time by the Executive Board of the Stonehedge Condominium Association in accordance with the Uniform Condominium Act.of Pennsylvania, and further covenants and agrees that the Unit conveyed by this Deed shall be subject to a lien for all amounts so assessed except insofar as ' Section 3407 (c) of said Uniform Condominium Act may relieve a subsequent Unit Owner of liability for prior unpaid assessments. This covenant shall run with and bind the Unit hereby conveyed and all subsequent owners thereof. i i I l i tt F Ey,hibit (B JV\,/ *Exhibit has been redacted to remove all personally identifiable information or non-public information 9307 1200 1910 0007 3106 93 Home Equity Division 88 Scott M.Freeden 453 Stonehedge Ln Mechanicsburg PA 17055-7010 Green Tree Servicing LLC USPS CERTIFIED MAII ' FIRST-CLASS MAILU.S.POSTAGE AND Tempe FEES PAID NCP 7360 South Kyrene Rd Tempe, AZ 85283-4583 9307 1200 1910 0007 3106 93 RETURN RECEIPT REQUESTED SCOTT M,FREEDEN 453 STONEHEDGE LN MECHANICSBURG PA 17055-7010 +0486529 000000001 09GO01 0061225 relationships that work green trey Date of Notice: 06/11/2014 Green Tree Servicing LLC Scott Freeden 3012 Business Park Circle, Ste 100 453 Stonehedge Ln Goodlettsville, TN 37070 Mechanicsburg PA 17055-7010 800-643-0202 RE: Loan No: ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HE" can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342- 2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. This communication is from a debt collector. It is an attempt to collect a debt, and any information obtained will be used for that purpose. PA.Act91.NOD.2 YFNODPA 1 1.1 08/05 +0486529 000000001 09GO01 0061225 Page 1 of 5 relationships that work green tree, Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 Date of Notice: 06/11/2014 TO: Scott M. Freeden Loan No: 453 Stonehedge Ln Mortgaged Premises: Mechanicsburg PA 17055-7010 453 Stonehedge Ln Mechanicsburg, PA 17055 Certified Mail #: 9307 1200 1910 0007 3106 93 From: Green Tree Servicing LLC ("Green Tree") 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-three (33) days from the date of this Notice. 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 THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES ----If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. 08/05 PA.Act91.NOD.2 YFNODPAI 1.1 Page 2 of 5 +0486529 000000001 09GO01 0061225 relationships that work green tree Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 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.) If you have tried and are unable to resolve this problem with the lender, 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. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORAILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION ----Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES s ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT ---- The MORTGAGE debt held by the above lender on your property located at: 453 Stonehedge Ln, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly principal and interest payments due for 02/01/2013 through 06/01/2014 in the amount of$16,048.17. Other charges (explain/itemize): Late Fees $377.60, NSF Fee: $0.00, Escrow/Other: $3,435.87, Insurance: $0.00, Taxes advanced: $0.00. TOTAL AMOUNT PAST DUE: $19,861.64. HOW TO CURE THE DEFAULT ----You may cure the default within THIRTY-THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $19,861.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-THREE (33) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: Green Tree, PO Box 94710, Palatine, IL 60094- 4710 (do not send cash). PA.Act91.NOD.2 YFNODPA 1 1.1 08/05 Page 3 of 5 relationships that work green tree, Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 IF YOU DO NOT CURE THE DEFAULT ---- If you do not cure the default within THIRTY-THREE (33) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Please review your mortgage or deed of trust for any right you may have to reinstate your loan after acceleration but prior to the earlier of (a) five days before the sale of the property under any power of sale in the Security Instrument or(b) entry of judgment enforcing the Security Instrument, by paying the Creditor all sums then due as if no acceleration had occurred. You may also have the right to assert in the foreclosure proceeding the non- existence of a default or any other defense available to you. If full payment of the total amount past due is not made within THIRTY-THREE (33) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON ---- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY-THREE (33) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES ---- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE ---- If you have not cured the default within the THIRTY-THREE (33) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your.default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE ---- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately no less than three(3) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Green Tree Servicing LLC Address: 3012 Business Park Circle, Ste 100, Goodlettsville, TN 37070-0000 Phone Number: 800-643-0202 Fax Number: 866-870-9919 Contact Person: Collection Department 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. PA.Act91.NOD.2 YFNODPAI 1.1 08105 +0486529 000000001 09GO01 0061225 Page 4 of 5 relationships that work green tree® Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 ASSUMPTION OF MORTGAGE ----You_X_may or may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: ---- TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ---- TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ---- TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT, (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ---- TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ---- TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ---- TO SEEK PROTECTON UNDER THE FEDERAL BANKRUPTCY LAW. Enclosures:Pennsylvania Consumer Credit Counseling Agency List Cc: HEMAP office (PHFA-HEMAP, 211 North Front St., PO Box 15530, Harrisburg, PA 17105- 5530) 0 n 0 0 N This communication is from a debt collector. It is an attempt to collect a debt, and any information obtained will be used for that purpose. PA.Act91.NOD.2 YFNODPA 1 1.1 08/05 Page 5 of 5 Government Approved Housing Counseling Agencies in your region: 1. CCCS of Western PA 114 N Hanover St Carlisle, PA 17013 888-511-2227 2. CCCS of Western PA 55. Clover Hill Road Dallastown, PA 17313 888-511-2227 3. Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717-232-9757 4. Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717-238-9540 5. Housing & Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle, PA 17013 717-249-0789 0486529 000000001 09GO01 0061225 9307 1200 1910 0007 3107 30 Home Equity Division 88 Debra L.Freeden 453 Stonehedge Ln Mechanicsburg PA 17055-7010 FIRST-CLASS MAIL Green Tree Servicing LLC USPS CERTHUD MAEL- U.S.POSTAGE AND FEES PAID NCP Tempe 7360 South Kyrene Rd Tempe, AZ 85283-4583 9307 1200 1910 0007 3107 30 RETURN RECEIPT REQUESTED DEBRA L.FREEDEN 453 STONEHEDGE LN MECHANICSBURG PA 17055-7010 Il�ll���r���lll�l��ll���ll��'I�I�"IIIIIIII��'I�II'�'1�II1'lll�l� +0486529 000000002 09GO01 0061225 relationships that work green treer Date of Notice: 06/11/2014 Green Tree Servicing LLC Debra L. Freeden 3012 Business Park Circle, Ste 100 453 Stonehedge Ln Goodlettsville, TN 37070 Mechanicsburg PA 17055-7010 800-643-0202 RE: Loan No ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (IdEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342- 2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. Ifyou 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 NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. This communication is from a debt collector. It is an attempt to collect a debt,and any information obtained will be used for that purpose. PA.Act91.NOD.2 YFNODPA 1 1.I 08/05 +0486529 000000002 09GO01 0061225 Page 1 of 5 relationships that work green tree Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 Date of Notice: 06/11/2014 TO: Debra L. Freeden Loan No: 453 Stonehedge Ln Mortgaged Premises: Mechanicsburg PA 17055-7010 453 Stonehedge Ln Mechanicsburg, PA 17055 Certified Mail #: 9307 1200 1910 0007 3107 30 From: Green Tree Servicing LLC ("Green Tree") 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-three (33) days from the date of this Notice. 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 THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES ---- If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. PA.Act91.NOD.2 YFNODPA 1 1.1 08/05 +0486529 000000002 09GO01 0061225 Page 2 of 5 relationships that work green tree® Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 - 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.) If you have tried and are unable to resolve this problem with the lender, 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. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORAILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION ----Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES g ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT ---- The MORTGAGE debt held by the above lender on your property located at: 453 Stonehedge Ln, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly principal and interest payments due for 02/01/2013 through 06/01/2014 in the amount of$16,048.17. Other charges (explain/itemize): Late Fees $377.60, NSF Fee: $0.00, Escrow/Other: $3,435.87, Insurance: $0.00, Taxes advanced: $0.00. TOTAL AMOUNT PAST DUE: $19,861.64. HOW TO CURE THE DEFAULT ----You may cure the default within THIRTY-THREE (33) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $19,861.64, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY-THREE (33) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: Green Tree, PO Box 94710, Palatine, IL 60094= 4710 (do not send cash). PA.Act91.NOD.2 YFNODPA 1 1.1 08/05 Page 3 of 5 relationships that work green tree, Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 IF YOU DO NOT CURE THE DEFAULT ---- If you do not cure the default within THIRTY-THREE (33) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Please review your mortgage or deed of trust for any right you may have to reinstate your loan after acceleration but prior to the earlier of (a) five days before the sale of the property under any power of sale in the Security Instrument or(b) entry of judgment enforcing the Security Instrument, by paying the Creditor all sums then due as if no acceleration had occurred. You may also have the right to assert in the foreclosure proceeding the non- existence of a default or any other defense available to you. If full payment of the total amount past due is not made within THIRTY-THREE (33) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON ---- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY-THREE (33) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES ---- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE ---- If you have not cured the default within the THIRTY-THREE (33) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE ---- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately no less than three(3) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Green Tree Servicing LLC Address: 3012 Business Park Circle, Ste 100, Goodlettsville, TN 37070-0000 Phone Number: 800-643-0202 Fax Number: 866-870-9919 Contact Person: Collection Department 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. PA.Act91.NOD.2 YFNODPA 11.1 08/05 +0486529 000000002 09GO01 0061225 Page 4 of L relationships that work green tree, Green Tree Servicing LLC 3012 Business Park Circle, Ste 100 Goodlettsville, TN 37070 800-643-0202 ASSUMPTION OF MORTGAGE ---- You_X_may or may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt,.provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: ---- TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. ---- TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. ---- TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT, (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ---- TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. ---- TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. ---- TO SEEK PROTECTON UNDER THE FEDERAL BANKRUPTCY LAW. Enclosures:Pennsylvania Consumer Credit Counseling Agency List Cc: HEMAP office (PHFA-HEMAP, 211 North Front St., PO Box 15530, Harrisburg, PA 17105- 5530) 0 a N This communication is from a debt collector. It is an attempt to collect a debt, and any information obtained will be used for that purpose. PA.AcO LNOD.2 YFNODPA 1 1.1 08/05 Page 5 of 5 i Government Approved Housing Counseling Agencies in your region: 1. CCCS of Western PA 114 N Hanover St Carlisle, PA 17013 888-511-2227 2. CCCS of Western PA 55 Clover Hill Road Dallastown, PA 17313 888-511-2227 3. Community Action Commission - Capital Region 1514 Derry St Harrisburg, PA 17104 717-232-9757 4. Harrisburg Fair Housing Council 2100 N 6th St Harrisburg, PA 17110 717-238-9540 5. Housing & Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle, PA 17013 717-249-0789 0486529 000000002 016001 0061225 Inst. # 201213343 - Page 1 of •3 Recording Requested By: Bank of America CERTIFIED PROPERTY IDENTIFICATION NUMBERS Prepared By: 42-10-0646-079 -U21453 UPPER ALLEN TP Bank of America CCGIS REGISTRY 05/04/2012 BY CM 8004"-4302 1800 Tapo Canyon Road Simi Valley,CA 93063 When recorded mail to: CoreLogic 450 E.Boundary St Attn:Release Dept. Cha 'in,SC2"36 DocIDff 1635925287562457 Tax ID: 42..10.0646.079.021453 Property Address: 453 Stonehedge Ln Mechanicsburg,PA 17055-7010 Property Location: Township of UPPER ALLEN PAO-AM 171 WAi 512!2012 This spur,for Recw4e$us, NIIN C 1000157-M4644137-0 MMS Phone#t: 888-679-6377 � ASSIGNMENT OF MORTGAGE For Value Received,the undersigned holder of a Mortgage(herein"Assignor")whose address is 1901 E Voorhees Street,Suite C,Danville,IL 61834 does hereby grant,sell,assign,transfer and convey unto THE BANK OF NEW YORK MMELLON FKA THE BANK OF NEW YORK AS TRUSTEE:FOR THE CERTIPTCATEROLDERS OF THE CWABS,INC.,ASSET-BACKED CERTIF;CATES,SERIES 2005-1 whose address is 101 BARCLAY STT-4W,NEW YORK,.NY 10286 all beneficial interest under that certain Mortgage described below together with the Dote(s)and obligations therein described and the money due and to become due thereon with interest and all rights accrued or to accrue under said Mortgage. Original lender: COUNTRYWIDE HOME LOANS,INC. Mortgagor(s): SCOTT M FREEDEN,AND DEBRA L FREEDEN,HUSBAND AND WIFE }date of Mortgage: 311.412005 Original Loan Amount: $133,000.00 Recorded in Cumberland County,PA on:311812005,book 1900,page 2265 and instrument number NIA This Mortgage has not been assigned unless otherwise stated below: IN WITNESS WHEREOF,the undersigned has caused this Assignment of Mortgage to be executed on PLAY 0 3 7117 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. By: As i-ttfant Sec tapy Ben PA�� • re i a E Inst. # 201213343 - Page 2 0£ 3 State of California County of Ventura on y 4 before me, MarCia J.00and Notary Public,personally appeared Bell Peck who proved tome on the basis of satisfactory evidence to be the person (s)whose name(s)is/are subscribed to the within instument and acknowledged to me that he/shetthey executed the same in hiAcr/their authorized capacity(ies),and that by hiAer/their sianature(s)on the instrument the person(s), or the entity upon behalf of which the person(s)acted,executed the instn.unent. I certify under PENALTY OF PERJURY under the laws of the State of California that.the foregoing . paragraph is true and correct. WITNESS my band and official seal. I MARCIA,t,�ORIANt} i . Commssion#•1$95521 ~s Notary Public-California � Los Angeles County My Comm.Expires Jul is,2014 NoAPulb (Seal) My Commission Expires: 1 hereby certify that the address of the within named assignee is: 101 RARCLA -4W,NEW YORK,NY 10286 Signature t DocID# 1638925287562457 f Inst. t 201213343 - Page 3 of 3 ROBERT P. ZIEGLER RECORDER OF DEEDS a CUMBERLAND COUNTY 1 COURTHOUSE SQUAREt CARLISLE, PA 17013 717-240-6370 - Instrument Number-201213343 Recorded On$1412012 At.3:29:01 PM Total Pages-3 *Instrument Type-ASSIGNMENT OF MORTGAGE Invoice Number- 107666 13,,mr ID-RZ x Mortgagor-FREEDEN, SCOTT M •Mortgagee-CERTIFICATE HOLDERS OF THE CrAI ABS INC ASSET BACKED CERT SERIES *Customer-SIMPLI:F'ILE LC E-RECORDING R FEES STATE WRIT TAX $0.50 Certification Page STATE JCS/ACCESS TO $23.50 A JUSTICE DQ NOT DETACH RECORDING FEES — $11.50 ... RECORDER OF DEEDS PARCEL• CERTIFICATION $10.00 This page is now part FEES of this legal document. COUNTY ARCHIVES FEE $2.00 E ROD ARCHIVES FEE $3.00 ` TOTAL PAID $50.50 i F I Certify this to be recorded in. Cumberland County PA ocu RECORDER OF DEEDS s -Information denoted by an asterisk may change dewing the verification process and may not be reflected on this page. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson rfL U- Ft-JUw Sheriff Jody S Smith Chief Deputy LLQ 1 ti* DEC - J AM gt 46 Richard W Stewart CUMBERLAND [✓��,,, r Solicitor OFFiCF. OF Tk SHERIFFCOUNT �' The Bank of New York Mellon FKA The Bank of New York as Trustee for vs. Debra L Freeden (et al.) Case Number 2014-6160 SHERIFF'S RETURN OF SERVICE 10/21/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Debra L Freeden, 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 453 Stonehedge Lane, Upper Allen, Mechanicsburg, PA 17055. Residence is vacant. 10/21/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Debra L Freeden, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lancaster, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 10/21/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Scott M Freeden, 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 453 Stonehedge Lane, Upper Allen, Mechanicsburg, PA 17055. Residence is vacant. 10/21/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Scott M Freeden, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lancaster, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 11/19/2014 01:28 PM - The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Lancaster County, the within named Defendant Scott M Freeden, not found. Mark S. Reese, Sheriff, Return of Service attached to and made part of the within record. 11/19/2014 01:28 PM - The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Lancaster County, the within named Defendant Debra L Freeden, not found. Mark S. Reese, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $84.79 SO ANSWERS, November 25, 2014 RONNY R ANDERSON, SHERIFF (ci CountySuito S!:os�i( Teleosoft Inc. Mark S. Reese Sheriff Charles Hamilton Chief Deputy SHERIFF'S OFFICE OF LANCASTER COUNTY 0 Brad Harris Solicitor James Montanez Lieutenant THE BANK OF NEW YORK MELLON TRUST COMPANY NA vs. SCOTT M FREEDEN (et al.) Case Number 2014-6160 SHERIFF'S RETURN OF SERVICE 11/19/2014 01:28 PM - DEPUTY ROBERT MUSSER, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: DEBRA L FREEDEN AT 128 DICKENS DRIVE, LANCASTER, PA 17603. THE ADDRESS WAS FOUND TO BE VACANT. ORIGINAL NOTE STILL WAS ON THE FRONT DOOR. THE FRONT DOOR WAS SLIGHTLY AJAR AND UNLOCKED, NO ANSWER. THE APARTMENT WAS VACANT. ROBERT M SSER, DEPUTY 11/19/2014 01:30 PM - DEPUTY ROBERT MUSSER, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED _. SERVICE TO THE DEFENDANT, TO WIT: SCOTT M FREEDEN AT 128 DICKENS DRIVE, LANCASTER, PA 17603. THE ADDRESS WAS FOUND TO BE VACANT. ORIGINAL NOTE STILL WAS ON THE FRONT DOOR. THE FRONT DOOR WAS SLIGHTLY AJAR AND UNLOCKED, NO ANSWER. THE APARTMENT WAS VACANT. • itfritoct ROBERT M SSER, DEPUTY SHERIFF COST: $78.46 SO ANSWERS, November 20, 2014 MARK S. REESE, SHERIFF DATE CATEGORY MEMO 10/22/2014 Advance Fee 10/22/2014 Receiving, Docketing & Return 10/22/2014 Service 10/22/2014 Affidavit 10/22/2014 Deputy Time 10/22/2014 Copies • 10/22/2014 Service (Additional Defendant) 10/22/2014 Affidavit - Additional Fees 11/06/2014 Service Mileage 11/19/2014 Service Mileage 11/20/2014 Not Found Return 11/20/2014 Refund COSTS Advance Fee 2X 2X 2X CHK # DEBIT CREDIT 778710 $0.00 $150.00 $9.00 $0.00 $9.00 $0.00 $2.50 $0.00 $20.00 $0.00 $12.00 $0.00 $6.00 $0.00 $1.00 $0.00 $4.48 $0.00 $4.48 $0.00 $10.00 $0.00 $71.54 $0.00 BALANCE: $150.00 $150.00 $0.00 1ttorney: KML LAW GROUP 701 MARKET STREET, SUITE 5000, MELLON INDEPENDENCE CENTER, PHILADELPHIA, F (c) CountySuite Sheriff, Teleosofl, Inc. SHERIFF'S OFFICE OF LANCASTER COUNTY Mark S. Reese sM . a. Bad Harris Sheriff Solicitor Charles Hamilton Chief Deputy James Montanez Lieutenant THE BANK OF NEW YORK MELLON TRUST COMPANY NA Case Number vs. SCOTT M FREEDEN (et al.) 2014-6160 m SERVICE COVER SHEET m m 1IIIIIq1111uest1111IH111111111111IIIII11111111111111111111 re 11111111111111111111110)11,11j111111111111111111111 I s 11111111111111111111111111111111111111111111111(1111111 m ledger ? (Service Details: Category: Manner: Notes: Civil Action - Complaint in Mortgage Foreclosure (CIMF) Adult in Charge Expires: 11/19/2014 Origin: Cumberland County 2 Zone: 03 Warrant: LCSO CLERK: YVETTE TURCO (717) 723-4519 MISC 20F2 Serve To: Name: Primary Address: Phone: Alternate Address: Phone: DEBRA L FREEDEN 128 DICKENS DRIVE LANCASTER, PA 17603 �k CA DOB: `Final Service:. -- Served: Personally • Adult In Charge • Posted Other Adult In Charge: Relation: Date: Deputy: Time: Mileage: Attorney / Originator Name: 1KML LAW GROUP Phone: 215-627-1322 Service Attem Date: Time: Mileage: Deputy: [Service Attempt Notes: 1. 2. 3. 4. 5. 6. (c) CountySuite Sheriff, Telaosott, Inc. 0 os as 0 128 DICKENS DRIVE, LANCASTER, PA 17603 P60Z/66/66 :dX3 i► 1pr�f t1Aj/ y 1 7 AY3 4 5 6 [Service Attempt Notes: 1. 2. 3. 4. 5. 6. (c) CountySuite Sheriff, Telaosott, Inc. 0 os as 0 128 DICKENS DRIVE, LANCASTER, PA 17603 P60Z/66/66 :dX3 Mark S. Reese Sheriff Charles Hamilton Chief Deputy SHERIFF'S OFFICE OF LANCASTER COUNTY 11 Brad Harris Solicitor THE BANK OF NEW YORK MELLON TRUST COMPANY NA vs. SCOTT M FREEDEN (et al.) James Montanez Lieutenant Case Number 2014-6160 SERVICE COVER SHEET 1re111111que11111111111111111111 1111111111111111111111111111 st 11111111111 111111111111111rvice111111 I I 1 1 1 1 1 1 1 1 I I I I I I I I I I se 1 11111111 1111111111111 11111 113 1111111111 111113g 1111 rn edger ? 1.§fritse Details: Category: Manner: Notes: Origin: Cumberland County Civil Action - Complaint in Mortgage Foreclosure (CIMF) Adult in Charge Expires: 11/19/2014 Zone: Warrant: LCSO CLERK: YVETTE TURCO (717) 723-4519 MISC 1 OF 2 Serve To: Name: Primary Address: Phone: Alternate Address: Phone: SCOTT M FREEDEN 128 DICKENS DRIVE � 1 LANCASTER, PA 17603 DOB: Final Service: Served: Adult In Charge: Relation: Date: Deputy: Personally • Adult In Charge • Posted • Other Time: Mileage: (Attorney / Originator: Name: KML LAW GROUP Phone: 215-627-1322 rService Attempts: Date: Time: Mileage: Deputy: / bt O T5 • 3 4 5 6 Service Attempt Notes: 1. 1 -00L -1 -d -11u— PU/14)g LIAthOrr A- 4 14 2. /+ ( !rl .bvGrio 9d < - - coy/ e Le/V (-1,L€ - r; 4. 5. x 6. (c) CountySu,to Sheriff. Tc z'csaft enc. tn 0 O O a1 01 0 128 DICKENS DRIVE, LANCASTER, PA 17603 171.OZ/66/66 :dX3 KML Law Group, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK AS TRUSTEE FOR THE CERTIFICATE HOLDERS OF THE CWABS, INC. ASSET-BACKED CERTIFICA IES, SERIES 2005-1 c/o Greentree Servicing, LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102 vs. DEBRA L FREEDEN SCOTT M FREEDEN 453 Stonehedge Lane Mechanicsburg, PA 17055 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: Term No. 14-6160 • ., KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 CnSt 1,\/rn Connor 31s,361 Attorneys for Plaintiff