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
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{
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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
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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
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SERVICE COVER SHEET m
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(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
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Phone:
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DEBRA L FREEDEN
128 DICKENS DRIVE
LANCASTER, PA 17603 �k CA
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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
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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
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Phone:
SCOTT M FREEDEN
128 DICKENS DRIVE � 1
LANCASTER, PA 17603
DOB:
Final Service:
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Relation:
Date:
Deputy:
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KML LAW GROUP
Phone:
215-627-1322
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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