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HomeMy WebLinkAbout09-2218Phelan Hallinan'& Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 ,rSheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 198645 COUNTRYWIDE HOME LOANS SERVICING LP 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff V. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ifq ';- )-l?, c +j; I ferm CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 198645 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 198645 1. Plaintiff is COUNTRYWIDE HOME LOANS SERVICING LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 11/05/2007 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS A NOMINEE FOR BAYROCK MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200744814. By Assignment of Mortgage recorded 03/23/09 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Document ID: 200908601. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 198645 6. The following amounts are due on the mortgage: Principal Balance $211,872.48 Interest $12,403.34 07/01/2008 through 04/07/2009 (Per Diem $44.14) Attorney's Fees $1,325.00 Cumulative Late Charges $521.29 11/05/2007 to 04/07/2009 Cost of Suit and Title Search 750.00 Subtotal $226,872.11 Escrow Credit $0.00 Deficit $722.01 Subtotal 722.01 TOTAL $227,594.12 7. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 198645 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $227,594.12, together with interest from 04/07/2009 at the rate of $44.14 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP 1 By: ? *Lawrence T. Phelan, squ re , Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire • Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Attorneys for Plaintiff File #: 198645 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE TOWNSHIP OF East PENNSBORO IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED IN DEED DATED July 27, 2000 IN BOOK 225 PAGE 287 GRANTED AND CONVEYED BY WILLIAM E. BROUGHER AND NICOLLE M. BROUGHER UNTO ANNIE A. KROL- KNIGHT, SINGLE INDIVIDUAL. BEING IN Lot NO. 66 OF FINAL SUBDIVISION Plan NO.3 OF SHERWOOD PARK AS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE ON October 4, 1988 IN Plan BOOK 56, PAGE 63. UNDER AND SUBJECT TO ACTS OF ASSEMBLY AND TOWNSHIP ORDINANCES, RIGHTS OF PUBLIC UTILITY AND PUBLIC SERVICE COMPANIES, EXISTING RESTRICTIONS AND EASEMENTS, VISIBLE OR OF RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED LEGAL RIGHTS THEREOF. PARCEL NO. 09-15-1288-118 PROPERTY BEING: 71 SHERWOOD CIRCLE File #: 198645 VERIFICATION I hereby state that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: Attorney for Plain 'ff 1r1./:? File 4: 198645 C fD OF 1}-r? p ??? JT,Py ?Q09 'AR CtlPrf?w,. _ vlvi 97cr,sd Pd a-?qf *a 9-116 A'Ab? ? 1- 3 Yek- Sheriffs Office of Cumberland County R Thomas Kline 4??1r of caunbrr i Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE C? THE s-?MFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/09/2009 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: Stephen M. Knight, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 04/13/2009 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: Stephen M. Knight, 71 Sherwood Circle, Enola, Cumberland County, Pennsylvania, 17025but was unable to locate him in his bailiwick. Defendant's wife advised that the defendant moved to 32 Dogwood Lane, Dillsburg, York County, Pennsylvania, 17019. 04/13/2009 10:52 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2009 at 1052 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Annie Krol-Knight by making known unto Annie Krol-Knight personally, at 671 Sherwood Circle, Enola, Cumberland County, Pennsylvania, 17025, its contents and at the same time handing to her personally the said true and correct copy of the same. 04/20/2009 York County Return: And now April 20, 2009 at 1435 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Stephen M. Knight by making known unto Stephen M. Knight personally, at 32 Dogwood Lane, Dillsburg, Pennsylvania 17019 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $87.92 SO ANSWERS, May 05, 2009 R T S INE, SHERIFF i uty Sheriff Docket No. 2009-2218 Countrywide Home Loans v Stephen Knight o° +J .may 1Y' nTl -7M 7? T jaj t ` -M c` co 0M Q A Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff VS. ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-2218 CIVIL STEPHEN M. KNIGHT CUMBERLAND COUNTY ANNIE A. KROL-KNIGHT Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE PHS #: 198645 TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorn for PI ' tiff , / t?' By: Lawrence T. Phelan, Esquire 'F'rancis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Date: 5-28-09 PHS #:198645 {- VERIFICATION Kathy Reoka hereby states that he/she is ASSISTANT SECREMRY of COUNTRYWIDE HOME LOANS SERVICING, LP, servicing agent for Plaintiff, COUNTRYWIDE HOME LOANS SERVICING, LP, in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsif n to authorities. Name: Katfly epka, Assistant Semfty DATE: APR Z 8 2009 Title: Company: COUNTRYWIDE HOME LOANS SERVICING, LP File #: 198645 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 COUNTRYWIDE HOME LOANS SERVICING LP : COURT OF COMMON PLEAS Plaintiff VS. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT Defendant(s) : CIVIL DIVISION : NO. 09-2218 CIVIL : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: STEPHEN M. KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 Phelan Hallinan & Schmieg, LLP Attorn for Plaintiff By: . Lawrence T. Phelan, Esquire .-Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Date: 5-28-09 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 COUNTRYWIDE HOME LOANS SERVICING LP VS. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT : CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION : No. 09-2218 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against STEPHEN M. KNIGHT, and ANNIE A. KROL-KNIGHT, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $227,594.12 Interest - 04/08/2009 to 06/29/2009 $3,663.62 TOTAL $231,257.74 I hereby certify that (1) the Defendants' last known addresses are 32 DOGWOOD LANE, DILLSBURG, PA 17019, and 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838, and (2) that notice has been given in accordance with Rule 237.1, copy attached. By:-:0. Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 1?/? PHS # 198645 PROTHONOTARY Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 COUNTRYWIDE HOME LOANS SERVICING LP VS. : CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT : No. 09-2218 CIVIL VERIFICATION OF NON-MILITARY SERVICE The undersigned Attorney hereby verifies that she/he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, she/he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant STEPHEN M. KNIGHT is over 18 years of age and resides at 32 DOGWOOD LANE, DILLSBURG, PA 17019. (c) that defendant ANNIE A. KROL-KNIGHT is over 18 years of age and resides at 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. By: C., &.&-- Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised COUNTRYWIDE HOME LOANS SERVICING LP CUMBERLAND COUNTY VS. STEPHEN M. KNIGHT 32 DOGWOOD LANE DILLSBURG, PA 17019 ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 COURT OF COMMON PLEAS CIVIL DIVISION No. 09-2218 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on By: If you have any questions concerning this matter please contact: By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Attorneys for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY. ** Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 COUNTRYWIDE HOME LOANS SERVICING LP V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2218 CIVIL STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT Defendant(s) TO: ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 DATE OF NOTICE: June 11, 2009 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. PHS # 198645 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 ,-Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 198645 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 COUNTRYWIDE HOME LOANS SERVICING LP V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2218 CIVIL STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT Defendant(s) TO: STEPHEN M. KNIGHT 32 DOGWOOD LANE DILLSBURG, PA 17019 DATE OF NOTICE: June 11, 2009 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. PHS # 198645 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES, THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 249-3166 By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 --Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 198645 Y FILE C THE, 249 Jt??? 3U P? IZ? U:? C,? $e2.14 5d ?-?- ,?.z7348 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-2218 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, It Plaintiff (s) From STEPHEN M. KNIGHT AND ANNIE A. KROL-KNIGHT (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: $231,257.74 L.L.: $.50 Interest FROM 6/30/2009 TO DATE OF SALE ($38.01 PER DIEM) - $37,325.82 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $206.92 Other Costs: Plaintiff Paid: Date: DECEMBER 1, 2011 David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC COURT OF COMMON PLEAS HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff v STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 06/30/2009 to Date of Sale ($38.01 per diem) TOTAL Note: Please attach description of property. PHS # 198645 14. oo u a L9 NO.: 09-2218 CIVIL CUMBERLAND COUNTY $231 257 74 ` z i , . $37,325.82 < 31 8583.5 5 Phelan Hallinan & Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 Attorney for Plaintiff k? ab?r?n a i1ft LU , ct X ;?? a U W V] a O W ? a C7 ;to O 1? \ ,a V w za ?o o ?a O H ,n. oA ?w? zl? yE"' ? ? O U ?a v T r O 00 ? ''a ? w ' 3 U u, x O ,, l x O ? cn Q Cl)Q E}F O 1 H ?l w? x o ?, F+? ? i? W on O l? 1 ? ' O H o o? ?o 6J cL', PHELAN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 LP f 215-563-7000 v?r ?F ?- ? „ BANK OF AMERICA, N.A., AS SUCCESSOR BY M&4i''% BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 09-2218 CIVIL CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relatin 'worn falsification to authorities. e inan LLP Allison F. Wells, Esq., Id. No. 09519 Attorney for Plaintiff BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 09-2218 CIVIL CUMBERLAND COUNTY PHS # 198645 AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) ,: STEPHEN M. KNIGHT 32 DOGWOOD LANE j ; r DILLSBURG, PA 17019 M ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 =an C., -,- 77 '? t 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) r • TENANT/OCCUPANT Domestic Relations of Cumberland County 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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 ma he penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities vl Date: < :2 V11 llinan & Schmieg, LLP Allison F. e ls, Esq., Id. No.309519 Attorney for Plaintiff BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER COURT OF COMMON PLEAS TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: 09-2218 CIVIL VS. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT : CUMBERLAND COUNTY Defendant(s) a f r? , p , NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT 32 DOGWOOD LANE 71 SHERWOOD CIRCLE c i DILLSBURG, PA 17019 ENOLA, PA 17025-1838` "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838 is scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $231,257.74 obtained by BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to tlw value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 09-2218 CIVIL BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP VS. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT owner(s) of property situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, being (Municipality) 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838 Parcel No. 09-15-1288-118 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $231,257.74 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE LYING AND BEING IN THE TOWNSHIP OF EAST PENNSBORO IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA MORE PARTICULARLY DESCRIBED IN DEED DATED JULY 27, 2000 IN DEED BOOK 225 PAGE 278 GRANTED AND CONVEYED BY WILLIAM E BROUGHER AND NICOLE M BROUGHER UNTO ANNIE A KROL-KNIGHT SINGLE INDIVIDUAL BEING IN LOT NO 66 OF FINALSUBDIVISION PLAN NO 3 OF SHERWOOD PARK AS RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFFICE ON OCTOBER 4, 1988 IN PLAN BOOK 56 PAGE 63. UNDER AND SUBJECT TO ACTS OF ASSEMBLY AND TOWNSHIP ORDINANCES, RIGHTS OF PUBLIC UTILITY AND PUBLIC SERVICES COMPANIES, EXISTING RESTRICTIONS AND EASEMENTS, VISIBLE OR OF THE RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED LEGAL RIGHTS THEREOF. TITLE TO SAID PREMISES IS VESTED IN Annie A. Krol-Knight and Stephen M. Knight, by Deed from Annie A. Krol-Knight, dated 12/19/2002, recorded 02/28/2003 in Book 255, Page 4564. PREMISES BEING: 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838 PARCEL NO. 09-15-1288-118 PLAINTIFF BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP DEFENDANT STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT SERVE ANNIE A. KROL-KNIGHT AT: 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 **DIVORCED- One cannot accept service for the other** PHS # 198645 a SERVICE TEAM/ lxh :C COURT NO.: 09-2218 CIVIL r TYPE OF ACTION ?t XX Notice of Sheriff's Sale SALE DATE: March 7, 2012 _ -C 0 C-1 f9l W d SERVED ?` Served and made known to ANNIE A. KROL-KNIGHT, Defendant on the `7 day of to 20?C at ( •'t3 'clock t . M., at -71 5*e0&-czPD PNW `' , in the manner described below: efendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. -1 t i't 1.... :Op d? -n ?C _ Other: Description: Age 50 Height 5 Sd Weight !(---) Race'-W Sex --F Other(3f"i°` a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: N (? Af1A'7 PRINTED NAME: I Q> TITLE: ?qe(t?> SFFZUQ? NOT SERVED On the day of 20-, at _ o'clock - M., Defendant NOT FOUND because: _ Vacant Does Not Exist - Moved - Does Not Reside (Not Vacant) _ No Answer on at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 AFFIDAVIT OF SERVICE (FHLMC) CUMBERLAND COUNTY CUMBERLAND CC`(JN'TY f E}'1' INSYL O1 A i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT Defendants Court of Common Pleas Civil Division CUMBERLAND County No.: 09-2218 CIVIL RULE -?' day of LA l 204a Rule is entered upon the Defendants AND NOW, this to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendants shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. B E COU J. 3 198645 it f Robert W. Cusick, Esq., Id. No.80193 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 TEL: (215) 563-7000 FAX: (215) 563-3459 VSTEPHEN M. KNIGHT 32 DOGWOOD LANE DILLSBURG, PA 17019 STEPHEN M. KNIGHT 56 MAIN STREET WHITESBORO, NY 13492 f s?ia 4,e-5 Ma .Ted )0-)VY STEPHEN M. KNIGHT V ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 198645 198645 -t i r1 ... r. 7Pw ?.V ,I1}, r 11?Y 2012 j4S 19 AM 11-- 36 CUMBE NSYLVAN A TY PEN PHELAN HALLINAN & SCHMIEG, LLP Lawrence T Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Robert W. Cusick, Esq., Id. No. 80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS CIVIL DIVISION SERVICING, LP No. 09-2218 CIVIL V. CUMBERLAND COUNTY STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT SUGGESTION OF DEATH RE: DEFENDANT STEPHEN M. KNIGHT COMMONWEALTH OF PENNSYLVANIA: Plaintiff, BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, by its counsel, Phelan Hallinan & Schmieg, LLP, hereby certifies that, to the best of its knowledge, information and belief, the Defendant Stephen M. Knight is deceased -- date of death January 14, 2011. As the property is owned by defendants Stephen M. Knight and Annie A. Krol-Knight as tenants b) the entireties, upon the death of Stephen M. Knight, Annie A. Krol-Knight became sole owner of the mortgaged premises as surviving tenant by the entireties. PHELA SCHMIEG, LLP Dated: By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 ` Melissa J. Cantwell, Esq., Id. No. 308912 YRobert W. Cusick, Esq., Id. No. 80193 Fit"ED-G' i iCL E= HE P, ROTHONOTAR 2012 JAN 19 AM 11: 3 6 CUMBERLSAND COUNTY PHELAN HALLINAN & SCHMIEG, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Robert W. Cusick, Esq., Id. No. 80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS CIVIL DIVISION SERVICING, LP No. 09-2218 CIVIL V. CUMBERLAND COUNTY STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Suggestion of Death Re: Stephen M. Knight was sent via first class mail to the following on the date listed below: Annie A. Krol-Knight 71 Sherwood Circle Enola, PA 17025 PHE HAL INAN SCHMIEG, LLP Dated: ?- By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Robert W. Cusick, Esq., Id. No. 80193 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR Court of Common Pleas BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME Civil Division c-a LOANS SERVICING, LP Plaintiff m' CUMBERLAND Co ? vs. No.: 09-2218 CIVIL ANNIE A. KROL-KNIGHT - f STEPHEN M. KNIGHT (DECEASED) _ Defendant ORDER AND NOW, this ?t day of *AT?,2012, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendant shall be and is hereby made absolute and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance Interest Through March 7, 2012 Per Diem $43.54 Late Charges Legal fees Cost of Suit and Title Property Inspections Suspense/Misc. Credits Escrow Deficit $211,872.48 $58,525.30 $223.41 $1,325.00 $1,301.50 $410.00 ($27.50) $14,431.64 TOTAL $288,061.83 Plus interest from March 7, 2012 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. ?A! l; s o h ? Gc.?lfs, ?s?. 17 BY TH RT: J. 198645 A cf- C PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Melissa J. Cantwell, Esq., Id. No.308912 rTzf f-" 1617 JFK Boulevard, Suite 1400 " "r- One Penn Center Plaza ? cr `' Philadelphia., PA 19103 215-563-7000 _._ } ° IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION V. ANNIE A. KROL-KNIGHT Defendant(s) No.: 09-2218 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY 1 SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817 and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attaclJred here o Exhibit "A". Melissa J. Cantwell, Esquire `-' Attorney for Plaintiff Date: IMPORTA T OTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 1986,45 e)(" 1gIT tc x I w N O' M O N Q ? o 00 ? N1 ro ? ? a G O ? emu ??a-c a `O O U ? N "C7 N W o, b 'n Q p .+1 it f ?r M V O r- a a W ? O G u ? t ? q O u x F 2 u? b ? 'O u C 0. O n G T n ? G O o E ?s_ 00 3 G F m ? W ? y a x E x v W E ? A ? w ?? N 0 G U O G O ? ?r V u ra P a? L o 0 V 4 09 C O Y. C V• W ? W G O ? ? O I? o.E o? Y Q r V F '° a F cc i CU Q? v ' ? E ^u L o W O O ^y, ? ? V d ° v p b I i L y Nr 44 ? ? A ,> ? w a`? t^o t- 00 W W ? V7 ? O ++ A r.r 00 tn 6. O 00 ?GLUv' A O C C s,M O 'O O r. w o? l- ( O .. CIO C,'N 6J d tn p'. F+ t- a" Lou v "'q 0 y V O ? ca V C .ri O W d 4 . O 7 Ty V] Pr W o Iv p toy c' x S co) ''+? G G L F 0. 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R 4, o w n w c u ?y 9 $ 4 ? ? ? ? a?+ d C .M+ 3 ? ! R u R 'O N C? Vi d G C C 41 R d d 7 R d R ? h ? C L •O •R o w o yap ?E-? ?? E QL, V V A E ?) a ` ? O u d R a?i E m ?• - eta y $ F C h I 6L7 W ??,• C i i ? ? d d d$ $ H M `G v S.G iCyGm c y d s ? FF t?esus C ._ o C7 ro o, W ? F+ ? ? 4 M N d .'S L i ^. 1 4 y 'C O C } Er ow y^ v o `) c w R 4 a E ++ L ? L1: ? OA Qw ? 'IL W R •C k p'a ! ai ' a p as ?, v' i , x w L.' N M bq a ?, a, c. .C 4 C L O ` y X O 0i a E? a a E °N; G> O L CO O y a 'V N N O Oi a.zU?oA.?:Qa:3? ? ? a Fx 3 ° a Z a .r+ Ci E M rh VI ? n 00 CT ? BANK OF AMERICA, N.A., AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, LP FWA COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: 09-2218 CIVIL V. CUMBERLAND COUNTY STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT PHS # 198645 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838. Name and address of Owner(s) or reputed Owner(s): Name STEPHEN M. KNIGHT 2 3 ANNIE A. KROL-KNIGHT Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 32 DOGWOOD LANE DILLSBURG, PA 17019 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) CAPITAL ONE Capital One Bank, USA, NA C/o Patenaude and Felix, APC C/o Gregg Lawrence Morris, Esquire F1A Card Services, NA FIA Card Services, NA C/o James C. Warmbrodt, Esquire Unifund Corporation NCO Financial Systems P.O. BOX 30285 SALT LAKE CITY, UT 84130-0285 213 East Main Street Carnegie, PA 15106 2727 Paces Perry Road #1400 Atlanta, GA 30339 Weltman, Weinberg & Reis, Co., L.P.A. 436 SEVENTH AVE STE 1400 PITTSBURGH, PA 15219 10625 Techwds Circle Cincinnati, OR 45249 507 Prudential Road Horsham, PA 19044 Unifund Corporation C/O Michael F. Ratchford, Esquire NCO Financial Systems C/O Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 120 N KEYSER AVE SCRANTON, PA 18504-9701 Edwin A. Abrahamsen & Associates, P.C. 120 N KEYSER AVE SCRANTON, PA 18504-9701 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) East Pennsboro Township 98 South Enola Drive Enola, PA 17025 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attornev for the Middle District of PA Commonwealth of Pennsylvania Bureau of Individual Taxes Inheritance Tax Division Department of Public Welfare, TPL Casualty Unit, Estate Recovery Program P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 6th Floor, Strawberry Sq. Dept 280601 Harrisburg, PA 17128 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. Date: By: Phelan Hallinan & Schmieg, LLP` i Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff s !i ??, !1r "" I Cf'yy? Jody S Smith Chief Deputy Richard W Stewart Solicitor 7i'" APR 26 AN 8: v CUMBERLPM COUNTY PENNSYLVANIA BAC Home Loans Servicing, L.P. vs. Stephen M. Knight (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2009-2218 12/29/2011 06:40 PM - Deputy Gerald Worthington, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action upon the property located at 71 Sherwood Circle, Enola, Cumberland CountyPA 17025, Cumberland County. 12/29/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Stephen M. Knight, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 12/29/2011 06:40 PM - Deputy Gerald Worthington, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Annie A. Krol-Knight at 71 Sherwood Circle, East Pennsboro Township, Enola, Cumberland County, PA 17025. 02/02/2012 The requested Real Estate Writ, Notice and Description, in the above titled action, returned by the Sheriff of York County, the within named Defendant Stephen M. Knight, not found. So Answers: Richard Keuerleber, Sheriff. Per Post Office check the defendant resides at 71 Sherwood Circle, Enola, PA 17025-1838-71. 02/21/2012 Affidavit of Service to Lien holders Filed in Sheriffs Office 03/15/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on March 7, 2012 at 10:00 AM. He sold the same for the sum of $166,700.00 to Jeremy Hess on behalf of CJD Group, LLC at 1770 Oregon Pike, Lancaster, PA 17601. CJD Group, LLC being the buyer in this execution, paid to the Sheriff the sum of $177,056.00. SHERIFF COST: $4,482.18 SO ANSWERS, April 10, 2012 RON R ANDERSON, SHERIFF - et? Proposed Schedule of Distribution Posted March 26, 2012 Writ No. 2009-2218 Civil Term BAC Home Loans Servicing, L.P. VS Stephen M. Knight and Annie A. Krol-Knight 71 Sherwood Circle Enola, PA 17025 Sale Date: March 7, 2012 Bid Price: $166,700.00 Buyer: CJD Group, LLC 1770 Oregon Pike, Lancaster, PA 17601 Real Debt: $231,257.74 Interest: $ 37,325.82 Atty Paid: $ 206.92 Total: $268,790.48 RECEIPTS: Received on December 15, 2011 (check 1133391) $ 1,500.00 Received on March 7, 2012 (check 1000080872) $ 16,670.00 Received on March 15, 2012 (check 1000087395) $160,386.00 TOTAL RECEIPTS $178,556.00 DISTRIBUTION: Sheriff's Costs: $ 4,522.71 State Transfer Tax: $ 3,361.00 Local Transfer Tax: $ 3,361.00 Deb Lupold- Local Tax Collector: $ 988.79 East Pennsboro Township (to include Lien No. 2011-9156) $ 1,514.50 Refund of advance costs to Attorney Daniel Schmieg $ 1,500.00 Paid to Bank of America, N.A. for Writ No. 2009-2218 Civil Term $163,308.00 Total Distribution: ($178,556.00) Balance 0.00 So e R. Anderson Sheriff SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2009-2218 Held March 7, 2012 EFFECTIVE DATE: March 7, 2012 PREMISES: 71 Sherwood Circle, East Pennsboro Township, Cumberland County, Pennsylvania, Tax Parcel No. 09-15-1288-118 (the "Premises") RECITAL: Being the same Premises which Annie A. Krol-Knight, by her deed dated December 19, 2002 and recorded February 28, 2003 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 255, Page 4564, granted and conveyed unto Annie A. Krol-Knight and Stephen M. Knight, husband and wife. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. 3. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2012. 20. Subject to the legal operation and effect of the absence of a legal description pertaining to the Premises in the Sheriffs Notice of Sale. -2- 21. Mortgage in the amount of $213,000.00 from Annie A. Krol-Knight and Stephen M. Knight to Bayrock Mortgage Corp. dated November 5, 2007 and recorded December 3, 2007 at Instrument No. 200744814, assigned March 23, 2009 at Instrument No. 200908601 to Countrywide Home Loans. 22. Judgment against Stephen M. Knight and Annie A. Krol-Knight in the amount of $231,257.74 entered June 30, 2009 in favor of Bank of America, N.A. and Countrywide Home Loans Servicing, LP to No. 2009-2218, amended to $288,061.83 by Order of Court entered February 2, 2012. 23. Judgment against Annie A. Krol-Knight and Stephen M. Knight in the amount of $1,194.70 entered December 9, 2011 in favor of the Township of East Pennsboro in the form of a municipal lien to No. 2011-9156. 24. Judgment against Annie A. Krol-Knight in the amount of $10,689.91 entered January 29, 2010 in favor of NCO Financial Systems to No. 2009-7166. 25. Judgment against Annie A. Krol-Knight in the amount of $7,910.74 entered June 5, 2009 in favor of FIA Card Services, N.A. to No. 2009-1746. 26. Judgment against Annie A. Krol-Knight in the amount of $693.24 entered March 7, 2011 in favor of Capital One Bank (USA), N.A. to No. 2009-0034. 27. Subject to all setback lines, easements, notes and all other matters appearing on Plan No. 3 of Sherwood Park recorded in Plan Book 56, Page 63. 28. Subject to the Agreement recorded in Misc. Book 372, Page 1154. 29. Subject to the rights granted Pennsylvania American Water Co. in Misc. Book 356, Page 974. 30. Subject to the rights granted Sammons Communications in Misc. Book 383, Page 281 and in Misc. Book 357, Page 234. 31. Subject to the rights granted PPL and Bell or Bell of Pennsylvania in Misc. Book 355, Page 708. 32. Subject to the legal operation and effect of the ejectment action filed March 13, 2012 to No. 2012-1608. 33. Subject to the rights of others in and to any portion of the Premises within or adjoining Sherwood Circle. -3- F The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By. I kL-, Keith O. Brenneman -4- Writ No. 2009-2218 Civil Term Bank of America, N.A., As Successor by Merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP VS. Stephen M. Knight and Annie A. Krol-Knight Atty.: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 09-2218 CIVIL, BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP f/k/a COUNTRY- WIDE HOME LOANS SERVICING, LP vs. STEPHEN M. KNIGHT, ANNIE A. KROL-KNIGHT owner(s) of prop- erty situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, being 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838. Parcel No. 09-15-1288-118. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $231,- 257.74. PREMISES BEING: 71 SHER- WOOD CIRCLE, ENOLA, PA 17025- 1838. PARCEL NO. 09-15-1288-118. EXHIBIT A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson' Sheriff Jody S Smith " Chief Deputy Richard W Stewart Solicitor BAC Home Loans Servicing, L.P. vs. Stephen M. Knight (et al.) Case Number 2009-2218 SHERIFF'S RETURN OF SERVICE 12/29/2011 06:40 PM - Deputy Gerald Worthington, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action upon the property located at 71 Sherwood Circle, Enola, Cumberland CountyPA 17025, Cumberland County. 12/29/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Stephen M. Knight, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 12/29/2011 06:40 PM - Deputy Gerald Worthington, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Annie A. Krol-Knight at 71 Sherwood Circle, East Pennsboro Township, Enola, Cumberland County, PA 17025. 02/02/2012 The requested Real Estate Writ, Notice and Description, in the above titled action, returned by the Sheriff of York County, the within named Defendant Stephen M. Knight, not found. So Answers: Richard Keuerleber, Sheriff. Per Post Office check the defendant resides at 71 Sherwood Circle, Enola, PA 17025-1838-71. 02/21/2012 Affidavit of Service to Lienholders Filed in Sheriffs Office 03/15/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on March 7, 2012 at 10:00 AM. He sold the same for the sum of $166,700.00 to Jeremy Hess on behalf of CJD Group, LLC at 1770 Oregon Pike, Lancaster, PA 17601. CJD Group, LLC being the buyer in this execution, paid to the Sheriff the sum of $177,056.00. SHERIFF COST: March 15, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySui, , Sherif` I-,*eosoft !^c If BANK OF AMERICA, N.A., AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: 09-2218 CIVIL V. CUMBERLAND COUNTY STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT PHS # 198645 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was fled, the following information concerning the real property located at 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838. 1. Name and address of Owner(s) or reputed Owner(s): Name STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 32 DOGWOOD LANE DILLSBURG, PA 17019 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. t - N.unc ,ins! ;u{clr?:> ??1 ???r? ??thcr pcrsc?n +hu hits an- rrrwd inicrr<I W the I)]opcrty and who" interest 111;lr be allected by the sale. - Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name TENANVOCCUPANT Address (if address cannot be reasonably ascertained, please indicate) 71 SHERWOOD CHICLE ENOLA, PA 17025-1838 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 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 ma he penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities Date: Y t Ilinan & Schmieg, LLP Allison F. Tells, Esq., Id. No.309519 Attorney for Plaintiff BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER COURT OF COMMON PLEAS TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: 09-2218 CIVIL STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT VS. Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STEPHEN M. KNIGHT 32 DOGWOOD LANE DILLSBURG, PA 17019 ANNIE A. KROL-KNIGHT 71 SHERWOOD CIRCLE ENOLA, PA 17025-1838 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838 is scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $231,257.74 obtained by BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. you may need an attorney to assert your rights. 7 he sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I . If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may 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 go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 1 -1 1 , SHORT DESCRIPTION By virtue of a Writ of Execution NO. 09-2218 CIVIL BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP vs. STEPHEN M. KNIGHT ANNIE A. KROL-KNIGHT owner(s) of property situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, being (Municipality) 71 SHERWOOD CIRCLE ENOLA PA 17025-1838 Parcel No. 09-15-1288-118 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $231,257.74 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE LYING AND BEING IN THE TOWNSHIP OF EAST PENNSBORO IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA MORE PARTICULARLY DESCRIBED IN DEED DATED JULY 27, 2000 IN DEED BOOK 225 PAGE 278 GRANTED AND CONVEYED BY WILLIAM E BROUGHER AND NICOLE M BROUGHER UNTO ANNIE A KROL-KNIGHT SINGLE INDIVIDUAL BEING IN LOT NO 66 OF FINALSUBDIVISION PLAN NO 3 OF SHERWOOD PARK AS RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFFICE ON OCTOBER 4, 1988 IN PLAN BOOK 56 PAGE 63. UNDER AND SUBJECT TO ACTS OF ASSEMBLY AND TOWNSHIP ORDINANCES, RIGHTS OF PUBLIC UTILITY AND PUBLIC SERVICES COMPANIES, EXISTING RESTRICTIONS AND EASEMENTS, VISIBLE OR OF THE RECORD, TO THE EXTENT THAT ANY PERSONS OR ENTITIES HAVE ACQUIRED LEGAL RIGHTS THEREOF. TITLE TO SAID PREMISES IS VESTED IN Annie A. Krol-Knight and Stephen M. Knight, by Deed from Annie A. Krol-Knight, dated 12/19/2002, recorded 02/28/2003 in Book 255, Page 4564. PREMISES BEING: 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838 PARCEL NO. 09-15-1288-118 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N009-2218 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From STEPHEN M. KNIGHT AND ANNIE A. KROL-KNIGHT (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: $231,257.74 L.L.: $.50 Interest FROM 6/30/2009 TO DATE OF SALE ($38.01 PER DIEM) - $37,325.82 Atty's Comm: % Atty Paid: $206.92 Plaintiff Paid: Date: DECEMBER 1, 2011 (Seal) Due Prothy: $2.00 Other Costs: David D. Buell, rothonotary -J??4 By: Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 In T? t4 on Copy FROM RECORD and the s Y whereof. ! here unto set m yet of sard ?adisle, pa ? arb This„`` day of rt , 20 Prothonota 1 On December 15, 2011 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as, 71 Sherwood Circle, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date December 15, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2009-2218 Civil Term Bank of America, N.A., As Successor by Merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP vs. Stephen M. Knight and Annie A. Krol-Knight Atty.: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 09-2218 CIVIL, BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP f/k/a COUNTRY- WIDE HOME LOANS SERVICING, LP vs. STEPHEN M. KNIGHT, ANNIE A. KROL-KNIGHT owner(s) of prop- erty situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, being 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838. Parcel No. 09-15-1288-118. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $231,- 257.74. PREMISES BEING: 71 SHER- WOOD CIRCLE, ENOLA, PA 17025- 1838. PARCEL NO. 09-15-1288-118. 54 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: January 27, February 3, and February 10, 2012 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. Marie Coyne, SWORN TO AND SUBSCRIBED before me this C10 day of February. 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 Y The Patriot-News Co. 2020 Technolopy Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE This ad ran on the date(s) shown below: CARLISLE PA 17013 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly 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 'rhe 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 01/27/12 nd subscribed 02/03/12 02/10/12 Notary Public 14( Patriot News Now you know V)of February, 2012 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Owens, Notary Pubk Lower Paxton Twp., Dauphin County My Commission Expires Nov. 25, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Ba2 nk 0'4" OW2218 CIWI Term a Successor by e? H ome Loans SergOr geNr to'@AC a Countrywide Home LP Loans servicing, g, LP Stephen M. Knight and Anne A. 1(l-Knlqht Any. Dante! Schmleg virtue L a Writ of 221 218 CIVIL Execution so. 09. Op AWRI SUCCESSOR By CA, N.A AS MERGER TO BAC $JME COUNIKy D Ho LOANS SERVICING, Lp vs. ANNIIE-IEN M, XMGHT A "OL-If G Owner(s) of property situate Township of East Pe in the nnsboro, Cumbe and d (Mu niciality) bama, being i; 71 SHERWOOD CIRCLE ENOLA PA 17025-1838 Parcel No. 09-15-1288-118 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENTAA40UNT. $231,257.74 PREMISES BEING: 71 SHERWOOD CIRCLE, ENOLA, PA 17025-1838 PARCEL NO. 09-15-1288-118 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which CJD Group LLC is the grantee the same having been sold to said grantee on the 7 day of March A.D., 2012, under and by virtue of a writ Execution issued on the 1 day of December, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 2218, at the suit of BAC Home Loans Servicing L P against Stephen M. Knight and Annie M. Krol-Knight is duly recorded as Instrument Number 201212108. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D. 7© i-kecorder of Deeds My Carmiss = the W 0Mft fib. PA Fkd lbndW Of AFL 2014