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Home My WebLink About09-1377 SHAPIRO & DENARDO, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929 I ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger COURT OF COMMON PLEAS to LaSalle Bank, N.A., as Trustee for ; CUMBERLAND COUNTY Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 NO: A 1 3 7? c Na? /- Trust PLAINTIFF VS. Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard ; Carlisle, PA 17015 Ruth Nieman ; 1331 Kiner Boulevard Carlisle, PA 17015 DEFENDANT(S) COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 ENTRAR UNA ORDEN CONTRA LISTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO ALA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & DENARDO, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 MICHAEL CLARK., ESQ., ATTORNEY I.D. NO. 202929 ALANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 09-034651 Bank of America, N.A. successor by merger COURT OF COMMON PLEAS to LaSalle Bank, N.A., as Trustee for CUMBERLAND COUNTY Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 NO: 1 7 c rji Trust PLAINTIFF VS. Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman ; 1331 Kiner Boulevard Carlisle, PA 17015 DEFENDANT(S) COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust, the address of which is, 7255 Baymeadows Way Jacksonville, Florida 32256, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: Mortgage Electronic Registration Systems, Inc., as nominee for Financial Mortgage, Inc. Mortgagor(s): or(s): Ruth Nieman, Cole E. Pierce and April Pierce (b) Date of Mortgage: August 24, 2006 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1964 Page 3022 Date: September 1, 2006 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Financial Mortgage, Inc. Assignee: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust Date of Assignment: As Recorded Recording Date: As Recorded 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 1331 Kiner Boulevard, Carlisle, Pa 17015 and is more specifically described as attached as part of Exhibit "A": 4. The name and mailing address of each Defendant is: Cole E. Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015; April Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015; Ruth Nieman, 1331 Kiner Boulevard, Carlisle, PA 17015 5. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 6. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of August 1, 2008 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 7. The following amounts are due as of February 28, 2009: Principal of Mortgage debt due and unpaid Interest currently due and owing at 7.5% per annum calculated from July 1, 2008 at $33.70 each day Late Charge of $51.25 per month assessed on the 16th of each month from August 16, 2008 to February 16, 2009, (7 Months) Escrow Advances made by Plaintiff Suspense/Unapplied Balance Accrued Late Charges Property Inspection Title Search/Report Fees Attorneys' Fees and Costs TOTAL $164,000.00 $8,189.10 $358.75 $159.34 ($51.90) $312.95 $39.50 $250.00 $5,000.00 $178,257.74 8. Interest accrues at a per diem rate of 33.70 each day after February 28, 2009, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 9. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 10. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et sew., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "B". WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DENARDO, LLC Date: S & D File No. 09-034651 BY: G? 01? Attorneys for Plaint' ? b p? 1. ?IEB?ER RECORDER OF DEEDS Gj;.4BEpi.A`10 CCL: IT1 4% ax bold liieadbulm Nwdat 324ff44YA4 trtwNoc tl?fiD p ?vr. a+?l DM mt 347 )Elw[aWee: laT[t14 MMM MOR AGE b mim % IL IL A 70 fod IL Comb zM eeprft ft mp @tau* met lit dbi deanmm in do po t Is bWm A . ?? . (A1 bltllMr ? ddb &VAM a deed AMPAt Z0. 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II.?, ttltl?tMIM MII1tRYlIONr lift awe trot i? s orfa 8K i 964 PG3030 . . w uop??M ? ? .IM 51964PG303I' 6.." * 9nflF mm - pwna in 027 Lou Na mm 00 D. 317 At s Kwk of dem: e • trlaf?r• l1oMiMIR et ft W146 =mW kvm AN MEMO do dedta em (sty af?bt be M1 a joft - 0 la sr'a P! 0 ilK 161 l F imoraffift Is hr laertiet dtl of tr IrIyA/e irteelr9 drk or atdoltM him ltweh Bile 101- r M/ Kit 10011% IN it Jerre Itc s dM?K a! 6m }tdpi ut pW to 60 *M% do mmops et it aft m watt %Ip m i M Ark a& rrWW1W Mkt Wd INOW 60 NEWS 110 SNOW its Wd w M t+r LoeerMq, ar ttq MIr?1 rirlt trMMa? a- is at Movers tips s td`rd. 7>ee aMMe t1i11 ors f4 rle1? TtI111toM= A tMt OtrMM maw p,L /fir sldl MrtelMterll ?/ sw Iho Matwe bes • Ke>? • sIM ? i. tbt ?1lrlrisetY??le?b?•r.ral?idrtlMiarMgr?M? 11Mts ?.yr b1?tk1 10 IMAM Odds (WretlUr r dbteil a?? ? IM ??? ? 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WOW MAW "be to. micom P .YMIIA • tppM Hw1? • t?teeM wIYI1M+N Itta INVOIM NOWI OW know Im "P tl d Ta s°MPrI 8K t 964PG3032 Loan No: ouldd 17W IDO 47 in to araat of a p nW taft dadewm " or 166 in VAM d ft FfWNV III Oft d it J* am"m aoeo d tblt ?te'oep ba?os tip l tell 4"Mim of bn is rwlre is Im do the WIM Of do woe ; Ibe tom, • or 1. in Win, adw buso m ad Udor MbmWte WN AOe00i< w t is OB IN" NVA" by Ift- ;r mat eta aas as dw dot: Z die !'mp M it dMI1010d by R A'jdw own b >LWr to lataam do do pppgy > on ddo d io do 04 Itmemo -- at orir all maapl to tide a eYlt fbNOaapa?? Beno?atr Alit w aelp a to Lames W" 7o dM bW ft dad die aadea S Mo% LwMec is ado" to god amd If* ft I No" III" m a11ee1Mot of t>p& d *0 p or a film ? "am t/ to i ioeoMrtegt. Ids at am da #^ % po ft =60" I ' mt in paw o pm ?rbOt0. iIn ? ! 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Tt ?-?few WWO d?a irshkirdh dto am l/[?tdw? g tb? is / td i astbb MOM ? IT? q ? tlfli Iw or OdM< dksiaoeed tha peed 506 Ow a? lm dryo om w tMawd' tlM A* old do* - - afar doe to doft mom is "dow *c t• ? as aft 401wwi =0 , IV niwq em tf a ?e4od w O aw v?doc Iw?acidl i¦1 a wAdreMda bo tww4 • • ?1 Pa+Mr+ d?N hie ast p?orO do r pml tirdls 8eaa ?er we eeomltrn t rrdwt of aw dpld at sun sec be b0? amts bo doomed m Iran Mea Oaa of ilattit m ri= 4tt dim as w M*i -& d*mA 14 Oe? 1 % Bad" alduu r oat 6r Ober "m lwlOto q w aro ftmm e1W mimim 0*1 oo. I fir .w rye awn Wi m did be aN 1rt ?i 1 ?itrNae odder M..,L.aa1eF, It eww•Ntin ?I Ladee ??NMM? dn?/_rt? ytl?eio! ?M?i A? me Mati.ar M l?s aaaw aww N 11MI i a beat Itch aeoW ioFod a hmd at do ' INM' '1016 or It Np. be sM W d it dim ZIIL way la mM eoea `aet dw aim ? &b SWJ* reroma m at the m V WW WOW dm MXIft PrNN4ri?Ai1M • ? Ria?lt • MoMh+wtre ZAa? Few Ap 70 a.ttAlvo WI964PG3034 ?.... anna,?nar. aeno ? a nr ?s Deb a: ?47 LO?a No: OOS1b6 _ did ad Waft AS 00 In *b lWOM (w woes won and auaa WA arwords $tti0 11,1111,11V ?? ?? m IeM1 ayr 11. ,sane COW. gmewee Ad bs On aaa CM of the 14m we at dig NON 'a kmnmm .? ropmq ar a slow boom Ia on, -1 As NOW b< di ?eaaea la d raaae lw ae bmw "m is be 10 alr TAM q d?oeo aoaaOoW r sisal or ?a by at dm aa?a?e ae o?i+ou a?aematd< ? ?. at ? ? and x .x .ta? m ct mo IMPS is sOMM 1, eNi er q atc „ grad. Limidu MW iAAM ! a mb tc pmt. mucoa, eaa apdm Ad wA b. i s lip °? aee?mad?. 'nv aodae S4 51111 ,o >wAim a VWW of sot lees aaa 8A Ewa . dto dta teM b Join In so110e6e0 db Irbil sddm is oft wft a? 1elt?s ? Ma M pw tbm mm p w io as - now or mow oa swam ?. paM AMW AM p., M?a slalom etliiir Man?? a w . b" p ? • pefoc a tba adho of so *p m oft 49 Nw Ay Wo W M M lbr do areb? ai s ?yraae aell?irt eo a 00 wwa qrf tades Bamwen ieaea dieee sae tYt Bo.+Mw? (+I'1? Y?e?ir • raarti wYab thes wait is doe est Iba lN1e ape?mod udhMann WIN" bw aet? adddb MMr IM 611111110111 lb drz dt a, nalat 141 ? ? e so now tlar? i?mla?? reeoo,t M dl0 lmDpeer +d ' t0doom? ?Mbwdmm t lease amen d+1?e' ?? a:r yrl ) v? e ? %%a eee tiebedo? ' lM ?' ,i do1-- P" ' >r db*m ac ff ao Ift ae MA 40014 rani bby MAW" bw olaunlL i dried n1teY10 ad Dot lp* is to an ad aoe bait =die ftom AL pw?9Nl.VMA • r r -14tenN WMho11l. U..1MN!!OIYI N Ito pM K of to Nqw Ri 1964PG3035 Va#20MUW • Pep 14 of 27 Eau * ON160 Dda M 247 st fw alit" aaw dam ttm" q Della d Qdmooa MN P p • 1 is the Npoa (e4ttiwc tm 8aorliyt es IN ooid aim ae mm df. dw'lm oe A6re 4 1 or Tfote? N !1000[ loo olfle` ? i0? A¦fm nix? T•??a wriisd a at?r of li Ms M Imw d ba see ar do op at IMo r ?e Lao MIS ? Cle a/i sa ?a06 at aw Mm FIX iftulft A rogdm0 k wommum IML S WAW at astlleit- *8 ab is low sad IrO mdm the is 1otrloed A a Loa Oltrhre aft da an }IreMlnt al dr ttillh The NM* To to LM SWAM a bo "Odin" oe a?r 300;; ?wd see y by tba 1W?le pedena aoe sir t?1r? ? ar bo jOied a aoy?lelitifl aeioa ? ? 1?e?er?aod ao do w" s M wrr NMar w? ? of IhK dr edlar?I?r Mr txattia?d fqr ooad bresfte aiA tLiO tlomlt? n011 feiitlMirlwe OrLMke Atsauroi lie sim P" (w>lit aleL ffdot bets in >?b?tMa atdeoeot !sy a! Mldl ? MAMt?Od i?dOL dr ?dl0e ? ?NOOIa a iwwefMM IMO ? OM01 aafba M ItllO a0tragb0 oaiam iKA la UW 0 a01lt aae?it fod00 Oa M l" ft tloe paw at be a ba ano¦iY of diMb The soda a! . Oo0ot01?aa f0i b ? ?A_ a ad dle of Otoehoatia0 irOMtowr< MII? ta_?ilb?' dM O ad _. wbwt dliaNl 4?ou0 t oaiweer?awit tie tobeooooet: ?tooliA iloeoeal? 1.11" =`tiMer mom" lti?a Merl dle fibs is w "Ma al'?rlrt ?I?Itpit ?? qtr a comma thlx cm 6804 commk" 14 or 84tw sot ovate ae p40it tlw lnlooeot, t ae ai;ata of f? Of< ar dsaaa q arl? ea a! if dle now" e 000 AIM ?o~io w an b hi0 ~ w4 ofL? ?iM1o1r. haolw • drt sire. ? ? d iiMullNrrO IIANI ? 91M OK ?so??dlb-, k ?a fend st??wa I bltIIM1010N of do llepe0?i .ttli me d,. m, tlmOlow moat it aovtl¦a pwdeadj. t 1N.VA?NA- &V6 FmAy-Fmu& WWR.aw. Ow t00l!OM eli.atlY'?IY ftwo# Ito fWHNf0ft" UK 1964PG3036 LAaa Nay WIN Elm D 347 Bae?oa dfri Isader wift of (Q ilk Alm" y d740@ bMaalt adia aadoa by aw ?iejr.lulaL Cb p Ir ea In ?Y ?1111t t?4? &.&oot #lid M, do q t I the= a* Louder ie illdbeNNlrtdll aaY?A1eA. irbe?Me aDi ? aeeeuac ?eeNt11 aw_eor Ilet_wa _ fa owes to --- hill Im low -FM-71 -Al 11 wi' " voccrip" d 14 wimi; awd rleitauwt dd NOS ? unks s and Waim vilL ArlOr anti deaaoear, Lmadet' di a i alowa swam rMi air ea?eddMs mMr, lamw aw di b EdN he RfflM 0 a dead ?? Us am of wlNl l f mak aad taWq iae die wm* t p1mot ar WOW - - It d eamaidea, daearea o! aa? is o eda iM..*rd 39 bw Oft fm dw ae?11Ma01ao R uh 6f ad& akpmom 10 a 9 ON d &:ddic sprAw or ob soft* aaweaa? 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Pierce 1331 Kiner Boulevard Carlisle, PA 17015 7007 2680 0000 016 7 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 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 wah the Counseling Agency. The name, address and Pphone 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 NOTIFICACION 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. i 6 - ¦ HOMEOWNER'S NAME(S): Cole E. Pierce; April Pierce; and Ruth Nieman PROPERTY ADDRESS: 1331 Kiner Boulevard, Carlisle, PA 17015 LOAN ACCT. NO.: 5303973209 ORIGINAL LENDER: Mortgage Electronic Registration Systems, Inc., as nominee for Financial Mortgage Inc. CURRENT LENDER/SERVICER: JPMorgan Chase Bank, National Association LAW FIRM FILE NO.: 09-034651 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU 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 ROUI MENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY- THREE (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. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP 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 PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY 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,$hat_time, no foreclosure proceedings will be pursued against you if you have met the time requirem "se4rth above. You will be notified directly by the Pennsylvania Housi ' " 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 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: 1331 Kiner Boulevard, Carlisle, PA 17015 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 1, 2008 to January 1, 2009 @ $1,227.91 = $7,367.46 Other charges (explain/itemize): Late Charges: August 16, 2008 to January 16, 2009 @ _ 51.25 307.50 Pre-Default Late Charges: Suspense Credit to Borrower: Inspection Fees: $312.95 $(51.90) $39.50 TOTAL AMOUNT PAST DUE: = $7,975.51 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not a licable : HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7.975.51, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: JPMorgan Chase Bank, National Association c/o Shapiro & DeNardo, LLC 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 --- You can cure any other default by taking the followi cti within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, th a lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable 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 (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the 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 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: C/O The Law Firm of Shapiro and Shapiro & DeNardo, LLC Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number _ .--(610) 278-9980 Contact person: Ilana Zion, Esquire EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You 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 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 PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Adams County Interfaith 40 E High Street Gettysburg, PA 17325 717.334.1518 Housing Authority CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA -17110 717.232,27 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Date: 7007 2680 0000 0161 7494 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 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 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 numb i' -106-nsumer 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES 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. HOMEOWNER'S NAME(S): Cole E. Pierce; April Pierce; and Ruth Nieman PROPERTY ADDRESS: 1331 Kiner Boulevard, Carlisle, PA 17015 LOAN ACCT. NO.: 5303973209 ORIGINAL LENDER: Mortgage Electronic Registration Systems, Inc., as nominee for Financial Mortgage Inc. CURRENT LENDER/SERVICER: JPMorgan Chase Bank, National Association LAW FIRM FILE NO.: 09-034651 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU 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 -VOU MEET OTHER ELIGIBILITY REQUIREMENTS ES -- L *1ED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY- THREE (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. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMP APPLICATION AS SOON AS POSSIBLE IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, 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 foreclosur : ediugs will be pursued against you if you have met the time requirements set forth above. You' lotified 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 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 uu to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 1331 Kiner Boulevard, Carlisle, PA 17015 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 1, 2008 to January 1, 2009 @ $1,227.91 = $7,367.46 Other charges (explain/itemize): Late Charges: August 16, 2008 to January 16, 2009 @ _ 51.25 $307.50 Pre-Default Late Charges: _ $312.95 Suspense Credit to Borrower: $(51.90) Inspection Fees: $39.50 TOTAL AMOUNT PAST DUE: _ $7,975.51 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not gpplicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7,975.51, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: JPMorgan Chase Bank, National Association c/o Shapiro & DeNardo, LLC 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 Y ar Vare any other default-by taking the following action within THIR 30, AYS of th ewof-this letter: (Do not use if not applicable.) IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, th a lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable 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 (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. You may do so by paying the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the 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 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: C/O The Law Firm of Shapiro and Shapiro & DeNardo, LLC Address: 3600 Horizon Drive, Suite 150, King of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number: (610) 278-99$0 Contact person: Ilana Zion, Esquire EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You 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 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 PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Date: 00 ?161 7463 2680 00 Ruth Nieman 7007 1331 Kiner Boulevard Carlisle, PA 17015 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 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 Cre&.-tounseling Agencies serving your County are listed at the end of this Notice If you have any ques_hons, 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 NOTIFICACION 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 HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: nominee for Financial Mortgage Inc. CURRENT LENDER/SERVICER: LAW FIRM FILE NO.: Cole E. Pierce; April Pierce; and Ruth Nieman 1331 Kiner Boulevard, Carlisle, PA 17015 5303973209 Mortgage Electronic Registration Systems, Inc., as JPMorgan Chase Bank, National Association 09-034651 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 PROVISION OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOU 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 6THEI ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING YOU DO NOT OCCUR PPLY OR EMERGENCY MORH?AGE TG THREE (33) DAYS. IF RTGAGE UP TO DATE. T OF ASSISTANCE YOU MUST BRING YOUR YOOUR MORTGAGE DEFAULT EXPLAINS THIS NOTICE CALLED "HOW T 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 ro ert is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications have for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, 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 directlyLy tennsylvania 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 ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can sti11 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: 1331 Kiner Boulevard, Carlisle, PA 17015 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 1, 2008 to January 1, 2009 @ $1,227.91 = $7.367.46 Other charges (explain/itemize): Late Charges: August 16, 2008 to January 16, 2009 @ _ $51.25 $307.50 Pre-Default Late Charges: _ $312.95 Suspense Credit to Borrower: $(51.90) Inspection Fees: $39.50 TOTAL AMOUNT PAST DUE: _ $7.975.51 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not Mlicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7.975.51, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: JPMorgan Chase Bank, National Association c/o Shapiro & DeNardo, LLC 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 You can cure any other (klf"anIt tylaking the following action within THIRTY (30) DAYS of the date of this letter. (D61°not tif not applicable.) IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, th a lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. ]IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable 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 TIMTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ripht 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 anv 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 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: C/O The Law Firm of Shapiro and Shapiro & DeNardo, LLC Address: 3600 Horizon Drive, Suite 150, Kina of Prussia, PA 19406 Phone number: (610) 278-6800 Fax number: (610) 278-9980 -, Contact person: Ilana Zion, Esquire EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-You 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. 6 r YOU 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 PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Fill in a list of all Counseling Agencies listed in Appendix C, FOR THE COUNTY in which the property is located, using additional pages if necessary). HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 r- Bank of America, N.A. successor by merger to LaSalle Bank NA as trustee for Washington Mutual Mortgage Pass-Trough Certificates WMALT Series 2006-AR 10 Trust v. Cole E. Pierce; April Pierce; and Ruth Nieman VERIFICATION The undersigned is .9&*VIei1V6- A-OF*'-Tof Bank of America, N.A. successor by merger to LaSalle Bank NA as trustee for Washington Mutual Mortgage Pass-Trough Certificates WMALT Series 2006-AR 10 Trust and as such is familiar with the records of said corporation, and being authorized to make this verification on behalf of Plaintiff an officer of the corporation and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Bank of America, N.A. successor by merger to LaSalle Bank NA as trustee for Washington Mutual Mortgage Pass-Trough Certificates WMALT Series 2006-AR10 Trust Date: r' Name: Enso Ustovic Title: Sl>eckd1st Company: JP Morgan Chase Bank National Association Loan: 5303973209 09-034651 -44 A-- °9t QP w ° ?J w n N W ' tJi Sheriffs Office of Cumberland County R Thomas Kline of c umbe, Edward L Schorpp Sheriff 400, Solicitor Ronny R Anderson Jody S Smith Chief Deputy wicE or T"E SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/09/2009 03:00 PM - R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Occupant at 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania but was unable to locate him in his bailiwick he therefore returns the within Complaint as not found as to the defendant, Occupant. There are no additional residents at given address. 03/09/2009 03:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 9, 2009 at 1500 hours, he served a true copy of the within Complaint and Notice upon the within named defendant, to wit: Cole E. Pierce, by making known unto April Pierce, person in charge, at 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 03/09/2009 03:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 9, 2009 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: April Pierce, by making known unto April Pierce personally, at 1331 Kiner Avenue, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 03/09/2009 03:00 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 9, 2009 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ruth Nieman, by making known unto April Pierce, person in charge, at 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $81.40 April 20, 2009 2009-1377 Bank of America VS Cole E. Pierce SO ANSWERS, 10'al A10' R THOMAS KLINE, SHERIFF B Deputy Sheriff 0 Mr- - N) y ~ ?T •J ?A 71 ( ,•. I ? 1?.- SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF vs. Cole E. Pierce and April Pierce and Ruth Nieman COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:09-1377-CIVIL DEFENDANT(S) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $180,633.26 in favor of the Plaintiff and against the defendant(s), jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid $164,000.00 Interest at 7.5% from July 1, 2008 to April 27, 2009 (301 days @ $33.70 per diem) $10,143.70 Late charges $620.45 Escrow Advance $631.51 Property Inspections $39.50 Suspense/Unapplied Balance ($-51.90) Title Search Report Fees $250.00 Attorneys Fees $5,000.00 TOTAL AMOUNT DUE $180,633.26 BY: L Michael J. Clark, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $180,633.26. 09-034651 Pro. Prothy. SHAPIRO & DENARDO, LLC BY: DANIELLE BOYLE-EBERSOLE, ESQ. MICHAEL CLARK, ESQ. CHRISTOPHER A. DENARDO, ESQ. AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 81747, 202929, 78447 & 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank NA as trustee for Washington Mutual Mortgage Pass-Trough Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 DEFENDANT(S) STATE OF: Florida COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: ()vt -1 311 (V,11 COUNTY OF: Dwal AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the Plaintiff and that the above-captioned Defendants' last known address is as set forth in the caption and they are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Bank of America, N.A. successor by merger to LaSalle Bank NA as trustee for Washington Mutual Mortgage Pass-Trough Certificates WMALT Series 2006-AR10 Trust By: Z??4_ r k NAME: Enso Ugovic TITLE: Specialist Sworn to and subscribed before me this q day of F"?V94?- , 2009. $A11E1.A At.W , Notary qa" Fdit - li1W of FVMNW blic * Iowa. ralol Jo*& M CewN?N +! 0won SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce, April Pierce and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, April 17, 2009 to the following Defendants: Cole E. Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 April Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 Ruth Nieman, 13 31 Kiner Boulevard, Carlisle, PA 17015 Laraine Colwell, Legal Assistant to Ilana Zion, Esquire for Shapiro & DeNardo, LLC SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL VS. Cole E. Pierce, April Pierce and Ruth Nieman DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Cole E. Pierce DATE OF NOTICE: April 17, 2009 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o flame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Cole E. Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 April Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 Ruth Nieman, 1331 Kiner Boulevard, Carlisle, PA 17015 Ilana Zion, Esquire Shapiro & DeNardo, LLC Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL VS. Cole E. Pierce, April Pierce and Ruth Nieman DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: April Pierce DATE OF NOTICE: April 17, 2009 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Cole E. Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 April Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 Ruth Nieman, 1331 Kiner Boulevard, Carlisle, PA 17015 Ilana Zion, Esquire Shapiro & DeNardo, LLC Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL PLAINTIFF VS. Cole E. Pierce, April Pierce and Ruth Nieman DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Ruth Nieman DATE OF NOTICE: April 17, 2009 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Cole E. Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 April Pierce, 1331 Kiner Boulevard, Carlisle, PA 17015 Ruth Nieman, 1331 Kiner Boulevard, Carlisle, PA 17015 F? Ilana Zion, Esquire Shapiro & DeNardo, LLC Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust ' PLAINTIFF vs. Cole E. Pierce and April Pierce and ; Ruth Nieman DEFENDANT(S) ; COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:09-1377-CIVIL CERTIFICATE OF SERVICE I, Michael J. Clark, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 Date mailed: ?? 0 9 SHAPIRO & DENARDO, LLC BY: \? 6 UN Michael J. Clar , Esquire Attorney for Plaintiff 09-034651 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger COURT OF COMMON PLEAS to LaSalle Bank, N.A., as Trustee for CIVIL DIVISION Washington Mutual Mortgage Pass-Through CUMBERLAND COUNTY Certificates WMALT Series 2006-AR10 Trust NO:09-1377-CIVIL PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANT(S) CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust 7255 Baymeadows Way Jacksonville, FL 32256 and that the last known address(es) of the judgment debtor (Defendant(s)) is: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 SHAPIRO & DENARDO, LLC BY: Michael J. Clark, Esquire Attorney for Plaintiff 09-034651 CF TF't PIMU '?ONOTFRY 1009 MAY -7 Ph 1: 1 *14.00 Po Am! ae 3at"94 8 oc" ti? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CURTIS R. LONG Prothonotary TO: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for ; Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust ; PLAINTIFF vs. Cole E. Pierce and April Pierce and Ruth Nieman COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:09-1377-CIVIL DEFENDANT(S) ; NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceedi as indicated below. URTI ON Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CURTIS R. LONG Prothonotary TO: April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF vs. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:09-1377-CIVIL NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceed in as indicated below. URTIS N Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 CURTIS R. LONG Prothonotary TO: Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust ; PLAINTIFF vs. Cole E. Pierce and April Pierce and Ruth Nieman COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:09-1377-CIVIL DEFENDANT(S) ; NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding indicated below. TIS NG Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY MICHAEL J. CLARK, ESQUIRE AT (610) 278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: () Confessed Judgment () Other - Bank of America, N.A. successor by merger File No. ??- f3-n-(, -4,1 to LaSalle Bank, N.A., as Trustee for Amount Due $180,633.26 Washington Mutual Mortgage Pass-Through Interest April 28, 2009 to September 2, Certificates WMALT Series 2006-AR10 2009 is $4,750.85 I Trust Atty's Comm PLAINTIFF Costs I I VS. , 1 Cole E. Pierce and April Pierce and ; Ruth Nieman DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(*} for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said gamishee(s). (Indicate) Index this writ against the gamishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. , Date: Z1 u1 Signature: \f\l-" All, Print Name: Michael J. lark Es uire Address: 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 202929 0 aED-UPCE OF THE PROTHONOTARY 2009 MAY -7 PH 1: 15 PENNSYLVANIA p a A? +M,00 $t.4d C6F ?g 5o 14.00 a.so ,401D . ?l 0 ~ Pp a.oo Dx 00 . 5Du- ce 39 to 49 a44 3xf SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for ; Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF vs. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 09-1377-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1331 Kiner Boulevard, Carlisle, PA 17015. 1. Name and address of Owner(s) or Reputed Owner(s) Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 2. Name and address of Defendant(s) in the judgment: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 _94. Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust 7255 Baymeadows Way Jacksonville, FL 32256 4. Name and address of the last recorded holder of every mortgage of record: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust, Plaintiff 7255 Baymeadows Way Jacksonville, FL 32256 MFRS Inc. as nominee for Financial Mortgage Inc. P.O. Box 2026 Flint, MI 48501 MERS Inc. as nominee for Financial Mortgage Inc. 11211 Wafles Mill Road Fairfax, VA 22030 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: ENANT OR OCCUPANT 1331 Kiner Boulevard Carlisle, PA 17015 s , 114N. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. SHAPIRO & DENARDO, LLC BY: ?Arv\ ? (I AV Michael J. Cl k, Esquire 09-034651 'a SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger COURT OF COMMON PLEAS to LaSalle Bank, N.A., as Trustee for CUMBERLAND COUNTY Washington Mutual Mortgage Pass-Through ; Certificates WMALT Series 2006-AR10 NO: 09-1377-CIVIL Trust ; PLAINTIFF vs. ; Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS ; NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on September 2, 2009 at 10:00 am, in Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $180,633.26 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to the mortgagee the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 2. You may be able to stop the sale through other legal proceedings. 3. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will recorded only if the purchaser pays the Sheriff the full amount of the bid. To find out if this has happened yet, you may call the Sheriff's Office at: 717-240-6390. 4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be rescheduled. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings, if necessary, to evict you. 6. You may be entitled to a share of the proceeds, which were paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of said schedule of distribution. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on he south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2005 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. FILED-OFFICE OF THE PROT DINOTARY 2009 MAY -7 PM 1: 15 ,at SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-03.4651 Bank of America, N.A. successor by merger COURT OF COMMON PLEAS to LaSalle Bank, N.A., as Trustee for CUMBERLAND COUNTY Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 NO: 09-1377-CIVIL Trust ; PLAINTIFF vs. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on September 2, 2009 at 10:00 am, in Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $180,633.26 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to the mortgagee the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 1. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 2. You may be able to stop the sale through other legal proceedings. 3. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 1 h 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will recorded only if the purchaser pays the Sheriff the full amount of the bid. To find out if this has happened yet, you may call the Sheriff's Office at: 717-240-6390. 4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be rescheduled. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings, if necessary, to evict you. 6. You may be entitled to a share of the proceeds, which were paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of said schedule of distribution. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 .,4% ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on he south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2005 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. --1 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger COURT OF COMMON PLEAS to LaSalle Bank, N.A., as Trustee for CUMBERLAND COUNTY Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 NO: 09-1377-CIVIL Trust PLAINTIFF vs. Cole E. Pierce and April Pierce and Ruth Nieman ; DEFENDANTS NOTICE OF SHERIFF'S SALE, OF REAL PROPERTY TO: Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on September 2, 2009 at 10:00 am, in Cumberland County Sheriffs Office, 1 Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $180,633.26 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to the mortgagee the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 2. You may be able to stop the sale through other legal proceedings. 3. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will recorded only if the purchaser pays the Sheriff the full amount of the bid. To find out if this has happened yet, you may call the Sheriff's Office at: 717-240-6390. 4. If the amount due from the purchaser is not paid to the Sheriff, the sale must be rescheduled. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings, if necessary, to evict you. 6. You may be entitled to a share of the proceeds, which were paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within thirty (30) days from the date of the sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of said schedule of distribution. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTIONS PRACTICE ACT, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 T" ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on he south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2005 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1377 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A. successor by merger to LaSALLE BANK, N.A., as Trustee for WASHINGTON MUTUAL MORTGAGE PASS-THROUGH CERTIFICATES WMALT SERIES 2006-AR10 TRUST, Plaintiff (s) From COLE E. PIERCE and APRIL PIERCE and RUTH NIEMAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $180,633.26 L.L. $.50 Interest from 4/28/09 to 9/02/09 - $4,750.85 Atty's Comm % Atty Paid $200.40 Plaintiff Paid Date: 5/07/09 Due Prothy $2.00 Other Costs Curtis R. Lo g, Prothono y (Seal) REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DeNARDO, LLC 3600 HORIZON DIRVE, STE.150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 By: Deputy Supreme Court ID No. 202929 Sheriffs Office of Cumberland County ?-7- ° R Thomas Kline r7: Sheriff ol -?? Ronny R Anderson V r_ c '- Chief Deputy - ? Jody S Smith C y,i _ co ;- 7 M Civil Process Sergeant Edward L Schorpp Solicitor Bank of America NA vs. Case Number Cole E Pierce 2009-1377 SHERIFF'S RETURN OF SERVICE 06/24/2009 03:35 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 24, 2009 at 1532 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Cole E. Pierce, April Pierce and Ruth Nieman, located at, 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania according to law. 06/24/2009 03:35 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 24, 2009 at 1532 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: Cole Pierce, by making known unto, April Pierce, adult in charge, at, 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/24/2009 03:35 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 24, 2009 at 1532 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant(s), to wit: April Pierce, by making known unto, April Pierce, personally, at, 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/24/2009 03:35 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 24, 2009 at 1532 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: Ruth Nieman, by making known unto, April Pierce, adult in charge, at, 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 07/07/2009 Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 6/24/09 at 1532 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant to wit: April Pierce, by making known unto, April Pierce, personally, at, 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. R. Thomas Kline, Deputy Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Michael J. Clark SHERIFF COST: $109.14 July 07, 2009 SO ANSWERS, rooa'??- R THOMAS KLINE, SHERIFF c 14'?°EDUR ? as Real Estate Sale # On May 15, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA Known and numbered as, 1331 Kiner Boulevard Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 15, 2009 By: Real s 5? I Z v Z I `j"I uoz F7UV SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce; April Pierce; and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the Plaintiff's Default Judgment entered on May 7, 2009, against Defendant Cole E. Pierce only in the above entitled action without prejudice to Plaintiff. SHAPIRO & DeNARDO, LLC BY: k Michael J /Clark, Esquire Attorney or Plaintiff 4 CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Vacate Mortgage Foreclosure Judgment on d to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 SHAPIRO & DeNARDO, LLC BY: h"n, cl-, Michael J. C ark, Esquir Attorney for Plaintiff OF 209 JUL - 8 ??'? ? ? ? l g . oo p a A-t'N c? -sMLH4 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce; April Pierce; and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Plaintiff s Default Judgment entered on May 7, 2009, against Defendant Ruth Nieman in the above entitled action without prejudice to Plaintiff. SHAPIRO & eNARDO, LI C BY: Michael J. C ark, Esquire Attorney for Plaintiff Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce; April Pierce; and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Vacate Mortgage Foreclosure Judgment on to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid:. Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 SHAPIRO & DeNARDO, LLC V ~ BY: Michael J. Cl k, Esquire Attorney for Plaintiff ,._'1 _--- a ~ u ~00~ ~l-~~.. 1 ~' Y- l~~ } !' CPe~ 3.3 / ~t 33 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: ()Confessed Judgment ()Other File No. QQ- 13'1 Amount Due $184,870.36 Interest November 10, 2009 to December 8, 2010 is $14,968.06 Atty's Comm Costs ~ '=~, -c,,-r, c_.. . ` r= #- uz ~,~t _=' .~ ~- ~ -= 0 The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens a inst real estate of the defendant(s) described in the attached exhibit. ,gate: (D ~ ~~Z~~ Signature: t~ p A,~ Print Name: Michae J. Clark Es wire ~a~.oo P Address. 3600 orizon Drive, Suite 150 $ (. 4 o C~BF Kin of Prussia, PA 19406 loa. iy g ht .5p Attorney for: Plaintiff 1~1. oo Supreme Court ID # PA Bar # 202929 a~ . oo ,~ 8.00 a 8 . oo ~• g • oo .#a. oo pue Co I+1. oo ~~ 3to4.b~} PQ A'rr^I C~ 3y7I81 I~ d'f3lo'1~ '121= U~rit~,SSt~Qc,~ SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS FILE~'..;;i= ~~~E ~~~ Tyr r~~.^,-r.'~,,,,*.~r~-E-aRY Z~10 JU~~7 15 ~'~~ 1 ~ i 0 C~PJ~~ ~ ~~u4i~'i'Y ,+ j . ,., C } ~ n COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1331 Kiner Boulevard, Carlisle, PA 17015. Name and address of Owner(s) or Reputed Owner(s) Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 2. Name and address of Defendants in the judgment: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust c/o JPMorgan Chase Bank, National Association 7255 Baymeadows Way Jacksonville, FL 32256 Chase Bank USA, N.A. 3700 Wiseman Blvd San Antonio, TX 78251 4. Name and address of the last recorded holder of every mortgage of record: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust, Plaintiff c/o JPMorgan Chase Bank, National Association 7255 Bayrneadows Way Jacksonville, FL 32256 MERS Inc. as nominee for Financial Mortgage Inc PO Box 2026 Flint, MI 48501 MERS Inc. as nominee for Financial Mortgage Inc. 11211 Wafles Mill Road Fairfax, VA 22030 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: TENANT OR OCCUPANT 1331 Kiner Boulevard Carlisle, PA 17015 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. eNARDO, LLC BY: ~~ __ Michael .Clark, Esquire 09-034651 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0:09-1377-CIVIL n ~ ' ~ y -~ ~~, ~-- ~ ~_ ~.... - ' T'4 ~ . ` ~- --- :_a CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust c/o JPMorgan Chase Bank, National Association 7255 Baymeadows Way Jacksonville, FL 32256 and that the last known addresses of the judgment debtors (Defendants) are: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 SHAPIRO & DeNARDO, LLC ~^ BY: f -' 1 Michael J Clark, Esquire Attorney for Plaintiff 09-034651 a.~ ,r v F!Li~~ ".~~~` 'lam '~.~~ is r,~ i ~ ~n~'r'1~~ i ~'~ i i~ SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF Maio ~~~~ i ~ G~~ ~: ~ a COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL. PROPERTY TO: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 22-25-0047-004 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at: Cumberland County Sheriff s Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $184,870.36 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass- Through Certificates WMALT Series 2006-AR10 Trust against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You maybe able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may ca11717-240-6390. 8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. You maybe entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2006 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. 1 ` ; i ~'. ~L~~J_"a.1 ~~J . E SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF ZOID J~~~ 15 a~ 1 ~ ~ 0 GUM•~~~ ~.. .. " ~:~~i~NTY COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 22-25-0047-004 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $184,870.36 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass- Through Certificates WMALT Series 2006-AR10 Trust against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)278-6800. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You maybe able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may ca11717-240-6390. 8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. You maybe entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2006 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. FlL~Uw~,~ ~t E ~,/ SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS 2010 ~~i;~~ 15 °ci I ~ 10 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 22-25-0047-004 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $184,870.36 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass- Through Certificates WMALT Series 2006-AR10 Trust against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)278-6800. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You maybe able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may ca11717-240-6390. 8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. You maybe entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2006 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1377 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, NA, successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust Plaintiff (s) From COLE E. PIERCE and APRIL PIERCE and RUTH NIEMAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $184,870.36 L.L. Interest from 11/10/09 - 12/8/10 - $14,968.06 Atty's Comm % Due Prothy $2.00 Atty Paid $369.04 Other Costs Plaintiff Paid Date: 6/15!10 / I L David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DENARDO,LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for ' Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS FILED-OFFICE OF THE PROTHONOTARY 1010 BEC -1 AM 10:3 8 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:09-1377-CIVIL CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Meghan Williams, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff, Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on October 22, 2010, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, SHAPIRO & DeNARDO, LLC BY: Megh Williams Legal Assistant 09-034651 C7 0 , U- N NN 1 m °Lu 11 ? o ? M N LL a a) ??-No w 1,4 0 C) to _ O d 1 ' ? m c> ?d m m > N t0 ? tyJ 4 "= C N _ rn v C L ' N? 6E o LL a i d m o ? o _ a E ? y V C v nom. b0° d C o ?8yE ? e m 0? N Of ..?. O ? "v tn ?C300 a? a ? G •i6 lC t. ? ..? d a1 {-+ d ? ? ? N o a3 > -°$, ? ? P'y G c °' ? 3 6 a m p' owl CfC]Cl?? a ? z ? " ? $ ? ? ?'w ? ? w U?U Ur' Vi U m C, 2 0 , f 0 o y 6 x y O ci c aaS •? ?' N ? r- -1 V? O It :uuiu°? aznl?uls u°11euuY ui r i a a. O m E N 4 v a m N m a C O 00 C m m r a U O '+ o 0 0 co Z .>_ a h? N tC m L4 o. m to M E T Z O ?m U- On a 06 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 71, Bank of America National Association Case Number vs. Cole E Pierce (et al.) 2009-1377 SHERIFF'S RETURN OF SERVICE 10/14/2010 02:23 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1419 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Cole E. Pierce„ April Pierce and Ruth Nieman located at, 1331 Kiner Boulevard, Carlisle, Cumberland County, Pennsylvania according to law. 10/14/2010 02:23 PM - Deputy Robert Bitner, being duly sworn according to law, attempted service to the Defendant, to wit: April Pierce at 1331 Kiner Blvd, Monroe Township, Carlisle, PA 17013. The address was found to be vacant. 10/14/2010 02:23 PM -Deputy Robert Bitner, being duly sworn according to law, attempted service to the Defendant, to wit: Ruth Nieman at 1331 Kiner Blvd, Monroe Township, Carlisle, PA 17013. The address was found to be vacant. 10/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Ruth Nieman, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Ruth Nieman, property is Vacant, defendant did not leave a forwarding with the post office. 10/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Cole E. Pierce, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Cole E. Pierce, property is Vacant, defendant did not leave a forwarding with the post office. 10/26/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: April Pierce, but was unable to locate her in his bailiwick He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, April Pierce, property is Vacant, defendant did not leave a forwarding with the post office. 12/06/2010 As directed by Michael J Clark, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 02/28/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney on 2/28/11 . SHERIFF COST: $754.50 February 28, 2011 SO ANSWERS, 6Z RbNl`V R ANDERSON, SHERIFF its ash 3/a I SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger COURT OF COMMON PLEAS to LaSalle Bank, N.A., as Trustee for CIVIL DIVISION Washington Mutual Mortgage Pass-Through CUMBERLAND COUNTY Certificates WMALT Series 2006-AR10 Trust NO: 09-1377-CIVIL PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS ; AFFIDAVIT PURSUANT TO RULE 3129.1 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1331 Kiner Boulevard, Carlisle, PA 17015. 1. Name and address of Owner(s) or Reputed Owner(s) Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 2. Name and address of Defendants in the judgment: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust c/o JPMorgan Chase Bank, National Association 7255 Baymeadows Way Jacksonville, FL 32256 Chase Bank USA, N.A. 3700 Wiseman Blvd San Antonio, TX 78251 4. Name and address of the last recorded holder of every mortgage of record: Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust, Plaintiff c/o JPMorgan Chase Bank, National Association 7255 Baymeadows Way Jacksonville, FL 32256 MERS Inc. as nominee for Financial Mortgage Inc PO Box 2026 Flint, MI 48501 MERS Inc. as nominee for Financial Mortgage Inc. 11211 Wafles Mill Road Fairfax, VA 22030 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANT OR OCCUPANT 1331 Kiner Boulevard Carlisle, PA 17015 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. HA I keNARDO, LLC BY: k Michael y. Clark, Esquire 09-034651 4 SHAPIRO & DeNARDO, LE C BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-ARIO Trust PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 22-25-0047-004 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:OOAM to enforce the court judgment of $184,870.36 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass- Through Certificates WMALT Series 2006-AR10 Trust against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will' have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 ALL THAT CERTAIN piece,or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams &Wa James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2006 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. 1 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I. D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 22-25-0047-004 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $184,870.36 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass- Through Certificates WMALT Series 2006-AR 10 Trust against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State bf Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2006 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. SHAPIRO & DeNARDO, L'LC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust PLAINTIFF VS. Cole E. Pierce and April Pierce and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 Your house (real estate) at: 1331 Kiner Boulevard, Carlisle, PA 17015 22-25-0047-004 is scheduled to be sold at Sheriffs Sale on December 8, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $184,870.36 obtained by Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass- Through Certificates WMALT Series 2006-AR10 Trust against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-ARI0 Trust the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 717-240-6390. 8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 9. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 10. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 09-034651 ALL THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State'of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on the south side of Kiner Drive, at the dividing line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/a James L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2006 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1377 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, NA, successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR10 Trust Plaintiff (s) From COLE E. PIERCE and APRIL PIERCE and RUTH NIEMAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $184,870.36 L.L. Interest from 11/10/09 - 12/8/10 - $14,968.06 Atty's Comm % Due Prothy $2.00 Atty Paid $369.04 Other Costs Plaintiff Paid Date: 6/15/10 'DTv'id D. Buell, rothonotary (Seal) By: REQUESTING PARTY: Deputy Name: MICHAEL J. CLARK, ESQUIRE Address: SHAPIRO & DENARDO,LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 202929 TRUE COPY FROM RECORD to Teatimony Mweat, l hero unto set my hand and the seal of "M at cadisle, Pa. This k dayd"IDne 20 /o ??OdQ Prodiana a y I On September 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, Known and numbered as, 1331 Kiner Boulevard, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: Real Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Visa Marie Coyne, E itor LI/ SWORN TO AND SUBSCRIBED before me this 5 day of November, 2010 C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 46. CUMBERLAND LAW JOURNAL Writ No. 2009-1377 civil Bank of America National Association, successor by merger to LaSalle Bank, N.A. As Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006- AR10 Trust VS. Cole E Pierce, April Pierce, Ruth Nieman Atty.: Michael J. Clark ALL THAT CERTAIN piece or par- cel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stake on he south side of Kiner Drive, at the di- viding line between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots; thence by Kiner Drive North 71 degrees 28 minutes East, one hun- dred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, South 13 degrees East, one hundred forty-five (145) feet to a stake at lands now or formerly of Charles F. Eslinger; thence by lands of Eslinger, South 71 degrees 28 minutes West, one hundred (100) feet to a stake at the dividing line between lots nos. 1 and 2 on said plan; thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to a point; the place of BEGINNING. BEING the same premises which James Adams a/k/aJames L. Adams and Teresa M. Adams, husband and wife by Deed dated June 15, 2005 and recorded in the Cumberland County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, Page 2250, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. 98 The Patriot-News Co. 220 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patr1*0tJWXeW5 Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain. being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid-, that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since- That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true-, and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/15/10 10/22/10 - 10/29/10 Sworn to avid scribedbefiore me this'10- y of November, 2010 A.D. A Notary Public COMMONWEALTH OF PENNSYLVANIA Note" Seat Sherrie L Klsner, Notary Public 4 Lower Paxton T wp., Dauphin County My Commission Wres Nov. 26, 2011 _ J Member, Pennsylvania Association of Notaries 2000-1377 QVII Tenn Bank of /f Assockaw , s norosr 10 U44" 861*' N-k As Trustee Ift n M Pass'TNVtqh Cerwicafft WMAiT Trust $0948 20WARio vs Cole B PI" A11y: motel AU THAT CERTAIN piece or parcel of land situate in the Township of Monroe, County of Cumberland and State of Pennsylvania, bounded and dest *W as follows, to wit: BEGINNING at a stake on he south side of Kiner Drive, at the dividing line between Lots Nos. I and 2 on the hereinafter mentioned plan of lots; thence byKinerDrive North 71 degrees 28 mutes East, one hundred (100) feet to a stake at an open ditch as shown on said plan; thence by said ditch, S" ,13 degros East, one hundred f6q-five (145) {ect to a stake at lands now or formerly of Charles I. Edinger; thence by ]ands of &U-9e1, South 71 degrees 28 minutes West, one hundred (100) "feet to a stake at the dividing line between Ift nos. 1 and 2 on said plan. thence by said dividing line, North 13 degrees West, one hundred forty-five (145) feet to apoint the BEGINNING. Place of .dams BEING the same premises which James', a/k/a James L. Adams and kresa M. Ad ams; husband and wdfe by Deed dated June 15, 2005 and recorded in the C mbedaad County Recorder of Deeds Office on September 1, 2006 in Deed Book 276, page 225(1, granted and conveyed unto Ruth Nieman, single individual and Cole E. Pierce and April C. Pierce, husband and wife. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust PLAINTIFF 2a12HAY -9 ri1 3': 1 CUMBERLAND MY-''' PENNSYLVt' N " COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL VS. Cole E. Pierce; April Pierce; and Ruth Nieman DEFENDANTS PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment entered on November 9, 2009 in the above entitled action vacated without prejudice to Plaintiff. BY: SHAPIRO & DkNARDO, LLC Michael J. Bark, Esquire Attorney fo# Plaintiff c %9, sofa C?lw? ?lD-sj330 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust PLAINTIFF VS. Cole E. Pierce; April Pierce; and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Vacate Mortgage Foreclosure Judgment on &63?vd to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 SHAPIRO & De 1ARDO, LLC BY: Michael J. C k, Esquire Attorney fori'Plaintiff 11 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006 .AR10 Trust PLAINTIFF VS. Cole E. Pierce; April Pierce; and Ruth Nieman DEFENDANTS E?.iar!,, -r -? p n t ' J. S 'ND COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. SHAPIRO TeNARDO, LLC , BY: Michael . Clark, Esquire Attorne for Plaintiff SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 09-034651 Bank of America, N.A. successor by merger to LaSalle Bank, N.A., as Trustee for Washington Mutual Mortgage Pass-Through Certificates WMALT Series 2006-AR 10 Trust PLAINTIFF VS. Cole E. Pierce; April Pierce; and Ruth Nieman DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 09-1377-CIVIL CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Settle, Discontinue and End on ?- to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Cole E. Pierce 1331 Kiner Boulevard Carlisle, PA 17015 April Pierce 1331 Kiner Boulevard Carlisle, PA 17015 Ruth Nieman 1331 Kiner Boulevard Carlisle, PA 17015 SHAPIRO & D NARDO, LLC BY: Michael Jf ark, Esquire Attorney Plaintiff