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COURT OF COMMON PLEAS CIVIL D...

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COURT OF COMMON PLEAS CIVIL DIVISION PHILADELPHIA COUNTY, PA NO. 111004818 AMENDED COMPLAINT IN MORTGAGEFORECLOSURE HSBC Bank USA, N.A., as Indenture Trusteefor the Registered Holders of the RenaissanceHome Equity Loan Asset-Backed Certificates,Series 2005-1, PLAINTIFF vs. Estate of RonaldE. Bell, c/o Wanda P. Nell, Administratrix,Wanda P. Bell, Administratrix of the Estate ofRonald E. Bell and Unknown Heirs, Success-ors, Assigns and All Persons, Firms or Asso-ciations Claiming Right Title or Interest Fromor Under Ronald E. Bell, Deceased,DEFENDANT(S). TO: Unknown Heirs, Successors, Assigns, andAll Persons, Firms or Associations ClaimingRight, Title or Interest From or Under RonaldE. Bell, Deceased, Defendant(s), whose lastknown address is 7954 Forrest Ave., Phila.,PA 19150. TAKE NOTICE THAT PLAINTIFF,HSBC Bank USA, N.A., as Indenture Trusteefor the Registered Holders of the RenaissanceHome Equity Loan Asset-Backed Certificates,Series 2005-1, has filed an Amended Com-plaint in Mortgage Foreclosure, endorsed witha Notice to Defend against you, in the Courtof Common Pleas, Philadelphia County, PAdocketed to No. 111004818, wherein Plaintiffseeks to foreclose on the mortgage securedon your property located at 7954 Forrest Ave.,Phila., PA 19150 whereupon your propertywould be sold by the Sheriff of PhiladelphiaCounty. NOTICE You have been sued in court. If you wish todefend against the claims set forth above, youmust take action within twenty (20) days afterthe Complaint and Notice are served, by en-tering a written appearance personally or byattorney and filing in writing with the courtyour defenses or objections to the claims setforth against you. You are warned that if youfail to do so the case may proceed withoutyou and a judgment may be entered againstyou by the Court without further notice forany money claimed in the Complaint for anyother claim or relief requested by the Plaintiff.You may lose money or property or otherrights important to you. You should take thispaper to your lawyer at once. If you do nothave a lawyer or cannot afford one, go to ortelephone the office set forth below. This of-fice can provide you with information abouthiring a lawyer. If you cannot afford to hire aLawyer, this office may be able to provide youwith information about agencies that may offerlegal services to eligible persons at a reducedfee or no fee. Philadelphia Bar Association - Lawyer ReferralService 1101 Market St., 10th Fl. Philadelphia, PA 19107 215-238-6333 Udren Law Offices, P.C. Attys. for Plaintiff 111 Woodcrest Rd., Ste. 200 Cherry Hill NJ 08003 856-669-5400 Ref# 0003123669-01

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