HomeMy WebLinkAbout09-262210
McCABE, WEISBERG AND CONWAY, P.C.
BY: /T'ERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Countrywide Home Loans Servicing, L.p.
1800 Tapo Canyon Road
Mail Stop #SV-103
Simi Valley, California 93063
V.
Amber D. Tittle
427 Oak Flat Road
Newville, Pennsylvania 17241
Attorneys for Plaintiff
Cumberland County
Court of Common Pleas
Number 6 '1
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, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A
LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere
defenderse de estas demandas ex-puestas en las paginas
siguientes, usted tiene veinte (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Hace falta
asentar una comparencia escrita o en persona o con un
abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de
su persona. Sea avisado que si usted no se defiende, la
corte tomara medidas y puede continuar la demanda en
contra suya sin previo aviso o notificacion. Ademas, la
corte puede decidir a favor del demandante y requiere
que usted cumpla con todas las provisioner de esta
demanda. Usted puede perder dinero o sus propiedades
u otros derechos importantes para usted.
USTED LE DEBE TOMAR ESTE PAPEL A
SU ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE A UN ABOGADO, VA A O TELEFONEA LA
OFICINA EXPUSO ABAJO. ESTA OFICINA LO
PUEDE PROPORCIONAR CON INFORMATION
ACERCA DE EMPLEAR A UN ABOGADO.
SI USTED NO PUEDE PROPORCIONAR
PARA EMPLEAR UN ABOGADO, ESTA OFICINA
PUEDE SER CAPAZ DE PROPORCIONARLO CON
INFORMACION ACERCA DE LAS AGENCIAS
QUE PUEDEN OFRECER LOS SERVICIOS
LEGALES A PERSONAS ELEGIBLES EN UN
HONORARIO REDUCIDO NI NINGUN
HONORARIO.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
CIVIL ACTION/MORTGAGE FORECLOSURE
Plaintiff is Countrywide Home Loans Servicing, L.P., a corporation duly organized and
doing business at the above captioned address.
2. The Defendant is Amber D. Tittle, who is the mortgagor and real owner of the mortgaged
property hereinafter described, and her last-known address is 427 Oak Flat Road, Newville, Pennsylvania
17241.
3. On August 27, 2003, mortgagor made, executed and delivered a mortgage upon the
premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for America's
Wholesale Lender which mortgage is recorded in the Office of the Recorder of Cumberland County in
Mortgage Book 1834, Page 4676.
4. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration
Systems, Inc., as nominee for America's Wholesale Lender to Countrywide Home Loans Servicing, L.P., by
Assignment of Mortgage, to be duly recorded in the Office of the Recorder of Cumberland County.
5. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A"
and is known as 427 Oak Flat Road, Newville, Pennsylvania 17241.
6. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due November 1, 2008 and each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month, the entire principal balance and all
interest due thereon are collectible forthwith.
7. The following amounts are due on the mortgage:
Principal Balance
Interest through April 20, 2009
(Plus $21.06 per diem thereafter)
Attorney's Fee
Late Charges
Corporate Advance
$ 110,292.62
$ 4254.12
$ 1,300.00
$ 271.11
$ 29.00
GRAND TOTAL $ 116,146.85
8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and
notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter
13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular
mail with a certificate of mailing and by certified mail, return receipt requested.
WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $116,146.85,
together with interest at the rate of $21.06 per diem and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgaged property.
McCABE, WEISBERG AND CONWAY,P.C
BY:
Attdrneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
VERIFICATION
The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the
within action, and that he/she is authorized to make this verification and that the foregoing facts based on
the information from the Plaintiff, who is not available to sign this, are true and correct to the best of
his/her knowledge, information and belief and further states that false statements herein are made subject
to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities.
McCABE, WEISBERG AND CONWAY,P.C.
BY:
Attorneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
' r
F. 495 3?
D '
?T P. ZIEGLER
.1,UO-DER OF DEEDS
II Ll :.RLAND COUNTY-N,
Bf4?KER-S SETTLEMEA"#b*C9S PM 2 29
1501 REEOSDALE STREET SUITE 502
PIT SBURG ,, PA. 15233
After Recording,Ken+'^ Prepared B :
COUNT^° MARY FRATANGELI
I.W- tf Parcel Number:
11 a ?'
?.r [Space Above This Line For Recm*m Data]
TITTLE 00003971299408003
[Escrow/Closing 11 (Doc ID i1
MORTGAGE
MIN 1000157-0002942412-0
DEFIN1'1'lONS
Words used in multiple sections of this document are defined below and other words are defined in Sections 3,
11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in
Section 16.
W "Secm* Iwtr ==Vl means this document, which is dated AUGUST 27, 2003
together with all Riders to this document. '
(B) "Borrower" is
AMBER D TITTLE, AN UNMARRIED WOMAN
Borrower is a mortgagor under this Security Instrument.
PENNSYL A - 3ingla Famly - Fannie Maef raddle Mac UNIFORM INSTRUMENT WITH MERE
Pape 1 of is InIfiak, _ FFN
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(C)"141ERS"is Mortgage ID #; 00003971299408003
gage Electronic Registration Systems, Inc. MFRS is a separate corporation that is acting
solely as a nominee for Lender and Lender's successors and assigns. MERS is the mortgstgee under this
Secant' Iustrtmtent. MGRS is organized and existing under the laws of Delaware, and has an address and
telephone number of P.O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS.
(D) "fin is
AMERICA'S WHOLESALE LENDER
Lender is a CORPORATION
organized and existing under the laws Of NEW YORK
Lenders address is
P.O. Box 660694, Dallas, TX 75266-0694
(E) "Note" means the promissory rote signed by Borrower and dated AUGUST 27, 2003
The Note states that Borrower owes Lender
ONE HUNDRED SEVENTEEN THOUSAND NINE HUNDRED and 00/100
Dollars (U.S. $ 117, 900.00 ) plus interest Borrower has promised to pay this debt in regular
Periodic Payments and to pay the debt in full not latex than SEPTEMBER D1, 2033
(I) "Property" means the property that is described below under the heading "Transfer of Rights in the
Property.*
(G) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges
due under the Note, and all stuns due under this Security Instrument, plus interest
(l) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following
Riders are to be executed by Borrower (check box as applicable]:
Adjustable Rate Rider Condominium Rider Second Home Rider
Balloon Rider Planed Unit Development Rider 14 Family Rider
VA Rider ???JJJ Biweekly Payment Rider L Other(s) [ ]
0
(1) "Applicable Law" means _all controlling applicable federal, state and local statutes, regulations,
ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final,
non-appealablejudicial opinions.
(n "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other
charges that are imposed on Borrower or the Property by a condominium association, homeowners association
or similar organization.
(I) "Bdechude Funds Transfer" means any transfer of funds, other than a transaction originated by check,
draft, or similar paper instrument, which is )nitiaed through an electronic terminal, telephonic instrument,
computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an
account Such teen includes, but is not limited to, point-of-sale transfers, automated teller machine
transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers.
(I ) "Escrow Items" means those items that are described in Section 3.
(1VI) 'Wiscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by
any third party (other than insurance proceeds paid under the coverages described in Section 5) for 0) damage
to, or deslraction of, the Property; Oi) condemnation or other taking of all or any part of the Property; (iii)
conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or
condition of the Property, f A6-
(80,-41A(PA) (0206) CHL (O UM Pepe 2 of 18 NOW&; Form 9038 1101
BK 18.34PG4677
DOC ID M: 00003971299408003
"Mortgage Durance" means insurance protecting Lender against the nonpayment of, or default 014 the
Loan.
(O) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the
Note, Plus (d) any amounts under Section 3 of this Security Instrument.
(P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its
implementing regulfition, Regulation X (24 C.F.R. Part 35001 as they might be amended from time to time, or
any additional or successor legislation or regulation that governs the same subject matter. As used in this
Security Instrument, MESPA" refers to all requirements and restrictions that are imposed in regard to a
"federally related mortgage loan" evert if the Loan does not qualify as a "federally related mortgage loan"
under RESPA.
(Q) "Successor in Interest of Borrower" means any party that has taken title to the
Property, whether or not
that party has assumed Borrower's obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Leader: (i) the repayment of the Lou, and all renewals, extensions and
modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to
MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns
of MFRS, the following described property located in the
COUNTY of CUMBERLAND
[hype or Remdiag Jude ieWn] [Niue dRecording Auisdiction]
SEE EXHIBIT "A" ATTACHED HERETO AND MADE A PART HEREOF.
Which currently has the address of
427 OAK FLAT ROAD, NEWVILLE
tstrewc hy]
Pennsylvania 17241 ("Property Address'):
1VP Code]
TOGETB ER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions mall also
be covered by this Secodty Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property." Borrower understands and agrees that MBRS holds only legal title to the interests granted by
Borrower in this Security Instrument, but, if necessary to comply with law or custom, lVIERS (es nominee for
ftWPA)RM) CHL low; (OB/U2) Pape 3 of to Form 3099 1101
-BK 1834PG4678
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a
DOC ID #: 00003971299400003
Lender and Lande's successors and assigns) has the right: to exercise any or all of those interests, including,
but not limited to, the right to foreclose and cell the Property; and to take any action required of Lender
including, but not limited to, releasing and canceling-this Security Instrument.
BORROWER COVENANTS that Borrower is lawhuy seised of the estate hereby conveyed and has the
right to mortgage, grant and convey the Property and that the Property is unencumbered, except for
encumbrances of record. Boirower warrants and will defend generally the title to the Property against all
claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines mdotm covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a unifoml security instrument covering real
property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment of Pducipal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower
shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment
charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to
Section 3. Payments due under the Note and this Security Instrument shall be made in U.S. currency.
However, if any check or other instrument received by Lender as payment under the Note or this Security
Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under
the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender.
(a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any
such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or
entity; or (d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at such
other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender
may return any payment or partial payment if the payment or partial payments are insufficient to bring the
Loan current. Larder may accept any payment or partial payment insufficient to bring the Loan current,
without waiver of any rights hereunder or preiudiee to its rights to refuse such payment or partial payments in
the future, but Lender is not obligated Lb apply such payments at the time such payments are accepted. N each
Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on unapplied
funds. Lender may hold such unapplied fiords until Borrower stakes payment to bring the Loan current. If
Borrower does not do so• within a reasonable period of time, Lender shall either apply such funds or return
them to Bofrower. If not applied earlier, such funds will be applied to the outstanding principal balance under
the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future
against Leader shall relieve Borrower from making payments due under the Note and this Security Instrument
or pedbrming the covenants and agreements secured by this Security Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments
accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the
Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to
each Periodic Payment in the order in which it became due. Any remaining amounts shall be applied first to
late charges, second to any other amounts due under this Security Instrument, and then to reduce the principal
balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the
i?
48t-M(PA) (a¢oe) CHL (x6102) Page 4 W 16 Form 3088 1101
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DOC ID 1): 00003971299908003
late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from
Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in
W. To the extent that any excess exists after the payment is applied to the full payment of one or more
Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be
applied fins[ to any propsyment charges and then as described in the Note.
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the
Note shall not extend or postpone the due data or change the amount, of the Periodic Payments.
3. Ponds for Facrow Item. Borrower shall pay to Lender on the day Periodic Payments are due under
the Note, until the Note is paid in [fill, a sum (the "Fonds") to provide for payment of amounts due for. (a)
taxes and assessments and other items which can attain priority over this Security Instrument as a lien or
encumbrance on the Property; (b) Leasehold payments or ground rents on the Property, if any; (c) premiums
for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or
any sums payable by Bbrrower to Leader in lieu of the payment of Mortgage Insurance premiums in
accordance with the provisions of Section 10. These items are called "Escrow Items." At origination or at any
time during the term of the Loan, Lender may require that Community Association Dues, Fees, and
Assessments, if any, be escrowed by Borrower, and such does, fees and assessments shall be an Escrow Item.
Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall
pay Lender the Fonds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any
or all Escrow Items. Lender may waive Borrower's obligation to pay to Lender Fonds for any or all Escrow
Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay
directly, when and where payable, the amounts due for any Escrow Items for which payment of Fonds has
been waived by Leader and, if Lender requires, shall famish to Lender receipts evidencing such payment
within such time period as Lender may require. Borrower's obligation to make such payments and to provide
receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security
Instrument, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay
Escrow Items diiectly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item,
Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated
under Section 9 to repay 1A Lender any such amount Lender may revoke the waiver as to any or all Escrow
Items at any time by a notice given in accordance with Section 15 And, upon such revocation, Borrower shall
lay to Lender all Rands, and in such amounts, that are then required under this Section 3.
Lender may, at any time, collect and hold Rands in an amount (a) sufficient to permit Lender to apply the
Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require
under RESPA. Lander shall estimate the amount of Fonds due on the basis of current data and reasonable
estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law.
The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality,
or entity (including Lender, if Lender is an institution whose deposits are so Insured) or in any Federal Home
Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under
RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow
account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Fonds and Applicable
law permits Lender to make such a charge, Unless an agreement is made in writing or Applicable Law
requires interest to be paid on the Ponds, Lender shall not be required to pay Borrower any interest or earnings
on the Funds. Bower and Lender can agree in writing, however, that interest shall be paid on the Funds.
Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA.
InNWa: M
A.GNPA) (ows) CHL (OWM) Page 5 of 16 Form 3038 1101
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DOC ID p: 00003971299408003
If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower
for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined
under RBSPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the
amount necessary to make up the shortage in accordance with RESPA, but in no.more than 12 monthly
payments. If there is a deficiency of Funds M4 in escrow, as defined under RESPA, Lender shall notify
Borrower as required by R.BSPA, and Borrower shall pay to Lender the amount necessary to make up the
deficiency in accordance with RESPA, but in no more than 12 monthly payments.
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to
Borrower any Funds held by Lender.
4. Charges; Lima. Borrower shall pay all taxes, assessments, charges fines, and impositions attributable
to the Property which can attain priority over this Security Instrument, leasehold payments or ground rents on
the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these
items are Escrow Items, Borrower shall pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to
Lender. but only so long as Borrower is performing such agreement; () contests the lien in good faith by, or
defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the
enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded;
or (c) seduce from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this
Security InstrumenL If Lender determines that any part of the Property is subject to a lien which can attain
priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days
of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set
forth above In this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting
service used by Leader in connection with this Loan.
5. Property Insurance. Borrower shall keep the improvemeet6 now existing or hereafter erected on the
Property insured against loss by fire, hazards included within the term "extended coverage," and any other
hazards including but not limited to, earthquakes and floods, for which Lcnder requires )nstuartm This
insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender
requires. What Lender requires pursuant to the preceding sentences can charge during the term of the Loan.
The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to
disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower
to lay, in connection with this Loan, either. (a) a one-time charge for flood zone detemination, cer ffleadon
and tracking services; or (b) a one-time charge for flood zone determination and certification services and
subsequent charges each time remappings or similar charges occur which reasonably might affect such
determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the
Federal Emergency Management Agency in connection with the review of any flood zone determination
resulting from an objection by Borrower.
If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance
coverage, at Len Ws option and Borrower's expanse. Lender is under no obligation to purchase any particular
type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might not protect
Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or
liability and might provide greater or lesser coverage than was previously in effect Borrower acknowledges
6A(PA) (MOO) CHL (06102) knals `?
m Page 6 of 16 Form 3039 Vol
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that the cost of the insurance coverage so obtained might significantly exceed the coat of insurance that
Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional
debt of Borrower secured by this Security Instnunent. These amounts shall bear interest at the Note rate from
the date of disbumement and shall be payable, with such interest, upon notice from Lender -to Borrower
muesting payment. .
All insurance poBcles.mquired by Lender and renewals of such policies shall be subject to Lander's right
to disapprove such policies, shall include a standard mortgage clause, and shall name Leader as mortgagee
and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If
Lender requires, Bower shall promptly give to Lender all receipts of paid premiums and renewal notices. If
Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or
destruction o4 the Property, such policy shall include a standard mortgage clause and shall name Lender as
mortgagee and/or as an additional loss payee.
In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may
make proof of loss if not made promptly by Burrower. Unless Lender and Borrower otherwise agree in
writing, any Insurance proceeds, whether or not the underlying insua ice was required by Leader, shall be
applied to restoration or repair of the Property, if the restoration or repair is economically feasible and
Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold
such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has
rota meted to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender
may proceeds for the repaint and restoration in a single payment or in a series of progress payments
as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be
paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or
such proceeds. Fees for public adjmstera, or other third earnings
the insurance parties, retained by Borrower shall not be paid out of
of
Proceeds and shall be the role obligation of Borrower. If the restoration or repair is not
economically feasible or Lenders security would be lessened, the insurance proceeds shall be applied to the
sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower.
Such insurance proceeds shall be applied in the order provided for in Section 2.
If Borrower abandons the Property, Leader may file, negotiate and settle any available insurance claim
and related matters. If Borrower does not respond within 30 days to a notice from Tender diet the insurance
carrier has offered to settle a claim, then Lander may negotiate and settle the claim. The 30-day period will
begin when the notice is given. In either event, or if Lender acquires the Property under Section 22 or
otherwise, Borrower hereby "gas to Lender (a) Borrower's rights to any insurance proceeds in an amount
not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's
rights (other than the right to any refund of uneamed premiums paid by Borrower) under all insurance policies
covering the Property, insofar as such lights are applicable to the coverage of the Properly. Larder may use
the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this
Security Instrument, whether or not than due.
6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence
within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as
Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise
agrees in writing, which consent shall not be unreasonably withheld, or unless extemnadug circumstances exist
which are beyond Borrower's control.
Pal 10 1 cwt.(ordo Page 7 of 16
Form aosa trot
BK 1-834PG-4682
DOC ID t: 00003971299408003
7. Preservation, Maintenance and Protection of the Property; Lupedious. Borrower shall not
destroy, damage or impair the Property, allow the Property to deteriorate or commit waste on the Property.
Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent
the Property from deteriorating or using in vahte due to its condition. Unless it is determined pursuant to
Section 5 that repair or restoration Is not economically feasible, Borrower shall promptly repair the Property if
damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in
connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or
restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds
for the repairs and restoration in a single payment or in a series of progress payments as the work is
completed If the insurance or condemnation proceeds are rot sufficient to repair or restore the Property,
Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has
reasonable cause, Lender may inspect the hnteew of the improvements on the Property. Lender shall give
Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process,
Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or
consent gave materially false, misleading, or inaccurate information or statements to Lender (or failed to
provide Lender with material information) in connection with the Loan. Material representations include, but
are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal
residence.
9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If (a)
Borrower fails to perform the covenants and agreements contained in this Security lnatrument, (b) there is a
legal proceeding that might significantly affect Lender's interest m the Property and/or rights under this
Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for
enforcement of a fion which may attain priority over this Security Instrument or to enforce laws or
regulations), or (c) Borrower has abandoned the Property, then Lender may do and pay for whatever is
reasonable or appropriate to protect Lender's interest in the Property and rights under this Security Instrument,
including protecting and/or assessing the value of the Property, and securing and/or repairing the Property.
Lender's actions can include, but are not'limited to: (a) paying any sums secured by a lien which has priority
over this Security Instrument, (b) appearing in court; and (c) paying reasonable attomeys' fees to protect its
interest in the Property and/or rights under this Security Instrument, including its secured position in a
bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make
repairs, change locks; replace or board up doors and windows, drain water from pipes, eliminate building or
other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take
action under this Section 9, Lender does not have to do se and is not under any duty or obligation to do so. It
is agreed that Leander incurs no liability for not taking any or all actions authorized under this Section 9.
Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured
by this Security InstrtunmL These amounts shall bear interest at the Note rate from the date of disbursement
and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment.
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease
If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender
agrees to the merger in writing.
(M"PA) (0209) CHL (06M) Papa a of 16 I ?
Fora1303a 1101
BK 18'34PG 46--83
Doc ID ti: 00003971299408003
10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan,
Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. jr, for any reason, the
Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that
previously provided such insurance and Borrower was required to make separately designated payments
toward the Premiums for Mortgage Insurance, Borrower shall
lurY the premiums required to obtain coverage
substantially equivalent W-the Mortgage hasauance previously in effect, at a cost substantially equivalent to the
cast to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected
by Larder. If substantially equivalent Mortgage Insurance coverage is not available, Borrower shall continue
to pay to Leader the amount of the separately designated payments that were due when the insurance coverage
ceased to be in effect. Lender will accept, use and retain these payments as a non-refndable Ices reserve in
lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that the Loan
is ultimately paid in full, and Lender shall not be required to pay Borrower any interest of earnings on such
loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (m the
amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes
available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage
Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was
required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower
shall pay The premiums required to maintain Mortgage Insurance In effect, or to provide a non-refundable loss
reserve, until Lender's requirement for Mortgage Insmanoe ends in accordance with any written agreement
between Borrower and Lanier providing for each termination or until termination is required by Applicable
Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may
incor if Bower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter
into agreements with other parties that shahs or modify their risk, or reduce losses. These agreements are on
terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these
agreements. These agreements may require the mortgage insurer to make payments using any source of funds
that the mortgage insurer may have available (which may include flmds obtained from Mortgage Insurance
premiums).
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any minsurer, any
other entity, or any affiliate of any of the foregoing, may receive (directly or indirectlY) amounts that derive
from (or might be characterized as) a portion of Borrower's payments for Mortgage Insurance, in exchange for
sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an
affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid to the
insurer, the arrangement is often termed "captive reinsurance," Further:
I's) AM such agreements will not affect the amount that Borrower has agreed to pay for Mortgage
Inearonca, or any other termw of the Loan. Such agreements will not increase the amount Borrower wlQ
owe for Mortgage hlanrance, and they will not =title Borrower to any refund.
(b) Any an& agreements will not affect the rights Borrower has • if any - with respect to the
Mortgage hrsarance under the Homeowners Protection Act of 1998 or any other law. These rights may
include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage
Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any
Mortgage Insurance premiums that were unearned at the time of such cancellation or termination.
(OkWPA) (0206) CHL (OWN) p m"Wals. ? --
age 9 0116 Form ms9 1/01
8K t 83 4PG4684
00003971299408003
IL to aa of to Lender. s Prmeec?; Forfeiture. All DOC ID #: Miscellaneous Proceeds are hereby
assigned to and nd shall ll b be paid d to eender.
If the Property is damaged' such M WOURneous Proceeds shall be applied to restoration or repair of the
Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such
repair and restoration period, Lender shall have the right to hold-such Idiscellaneous Proceeds until Lender has
had an opparpmity to inspect such Property to ensure the work has been completed to Leader's satisfaction,
provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in
a single disbursement or in a series of progress payments as the work is completed Unless an agreement is
made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall
not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. if the restoration or
repair is not economically feasible or Leader's security would be lessened, the Miscellaneous Proceeds shall
be applied to the sums "secured by this Security Instrument, whether or not then due, with the excess, if any,
paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2.
In the event of a total taking, destruction, or Ions in value of the Property, the Miscellaneous Proceeds
shall be applied to the sums secured by this Security Instrument, whether or not then dun, with the excess, if
any, paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value
of the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than
the amount of the sums secured by this Security Instrument immediately before the partial taking, destruction,
or loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security
Instrument shall be reduced by the amount of the Miscellaneous Pmoeeds multiplied by the following fraction:
(a) the total amount of the am secured immediately before the partial taking, destruction, or loss in value
divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss
in value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value
of the property immediately before the partial taking, destruction, or loss in vahue is lea than the amount of
the am segued immediately before the partial taking, destruction, or loss in value, unless Borrower and
Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sums secured by this
Security Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or i> after notice by Lender to Borrower that the Opposing
Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to
respond to Lander within 30 days after the date the notice is given, Lender is authorized to collect and apply
the Miscellaneous Proceeds either to restoration or repair of the Property or to the stuns secured by this
Security Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower
Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous
Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in
Lender's judgment, could result in for&iture of the Property or other material impairment of Lender's interest
in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration
has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be dismissed with a
ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's
interest in the Property or rights under this Security Instrument. The proceeds of any award or claim for
damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and
shall be paid to Lender.
Mitlab
W PA) (02M
CHL (calm Page 10 W 1e Form 3038 1101
BU 83 4 PG 4 6-aS
DOC ID i~: 00003971299908003
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in
the order provided for in Section 2.
12. Borrower Not Released; Forbearance By Lander Not a Waiver. Extension of the time for
payment or modification of amortization of the an= secured by this Security Instrument granted by Lender to
Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any
Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any
Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of
the same secured by this Security Instrument by reason of any demand made by the original Borrower or any
Successors in Interest of Borrower. Any forbearance by Lender in exorcising any right or remedy including,
without limitation, Lender's acceptance of payments from third persons, entities or Successors in Interest of
Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the exercise of any
right or remedy,
13. Joint and Several Liability; Cosigners; Successors and Assigns Bound. Borrower covenants and
agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who
co-signs this Security Instrument but does not execute the Note (a "co-signet"): (a) is co-signing this Security
Instrument only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this
Security Instt mnent; (b) is not personally obligated to pay the sums secured by this Security Instrument; and
(c) agrees that Leader and any other Borrower can agree to extend, modify, forbear or make any
accommodations with regard to the terms of this Security Instrument or the Note without the co-signer's
consent.
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's
obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's
rights and benefits under this Security Instrumoru. Borrower shall not be released from Bower's obligations
and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and
agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors
and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with
Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this
Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In
regard to any other fees, the absence of express authority in this Security Instrument to charge a specific fee to
Borrower shall not be consumed as a prohibition on the charging of such fee. Lender may not charge fees that
are expressly prohibited by this Security Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law Is finally interpreted so
that the interest or other loan charges collected or to be collected in connection with the Loan exceed the
pemnkW limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge
to the permitted limit; and (b) any sums already collected fkom Borrower which exceeded permitted limits will
be refunded to Borrower. Lender may choose to make this reftmd by redacting the principal owed under the
Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as
a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for
under the Note). Borrowers acceptance of any such refund made by direct payment to Borrower will
constitute a waiver of any right of action Borrower might have arising out of such overcharge.
4-6A(PA) Mile) CHL (OAM2) Papa 11 of to
WIR13; J214
Form 3039 1/01
OK 18 3.4
s
DOC ID $: 00003971299908003
IS. Notices. All notices given by Borrower or Lender in connection with this Security Instrument must
be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have
been given to Borrower when mailed by first class mail or when actually delivered to Bonowees notice
address if not by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless
Applicable Law expressly regair" otherwise. The notice address shall be the Property Address unless
Borrower has designated a substitute notice address by notice to Lander. Borrower shall promptly notify
Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of
address, then Borrower shall only report a change of address through that specified procedure. There may be
only one designated notice address under this Security Instrument at any one time. Any notice to Lander shall
be given by delivering it or by mailing it by first class mail to Lender's address stated herein unless Lender has
designated another address by notice to Borrower. Any notice in connexion with this Security Instrument
shall not be deemed to have been given to Lender until actually received by Lander. If any notice required by
this the Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy
corresponding requirement under this Security Instromea
16. Governing Law; Severabift; Roles of Construction. This Security Instrument shall be governed
by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations
contained in this Security Instrument am subject to any requirements and limitations of Applicable Law.
Applicable Law aright explicitly or implicitly allow the parties to agree by contract or it might be silent, but
such silence shall not be construed as a prohibition against agreement by contract. In the event that any
provision or clause of this Security Instrument or the Note conflicts with Applicable Law, such conflict shall
not affect other provisions of this Security Instrument or the Note which can be given effect without the
conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and include
corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include
the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take any
action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
M Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18,
"Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to,
those beneficial interests transferred in a bond for dead, contract for deed, installment sales contract or escrow
agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not
a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written
consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall
provide a period of not less than 30 days from the date the notice is given in accordance with Section 15
within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these
sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security
Instrument without further notice or demand on Borrower.
19. Bor'rower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower
shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the
earliest of (a) five days before sale of the Property pursuant to any power of sale contained in this Security
-hc
( GA(PA) Mme) CHL (06102) Pape 12 of 16 m
Form 3039 1101
BK f 8.3.4 PG 4.6 87
?? (b) such other DOC ID (k: 00003971299906003
period as Applicable Law might specify for the wimination of Borrower's right to
reinstate; or (c) entry of a judgment enforcing this Security InstrumenL Those conditions are that Borrower.
(a) pays Lender all sums which than would be due under this Security Instrument and the Note as if no
acceleration had occurred; (1)) cures any default of any other covenants or agreements; (c) pays all expenses
incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees,
property inspection and valuation foes, and other fees incurred for the purpose of protecting Lender's interest
in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably
require to assure that Lenders interest in the Property and rights under this Security Instrument, and
Borrower's obligation to pay the Sums sec red by this Security Instrument, shall oontinae unchanged. Lender
may require that Borrower pay such reinstatement sums and expenses in one or more of the following forms,
as selected by Lender. (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's
check, provided any such check is drawn uppn an institution whose deposits am insured by a federal agency,
instrumentality or entity; of (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security
Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred.
However, this right to reinstate shall not apply in the case of acceleration wider Section 18.
20. Sale of Note; Change of Loan Serricer; Notice of Grievance. The Note or a partial interest in the
Note (together with this Security Instrument) can be sold one or more tunes without prior notice to Borrower.
A sale aright result in a change in the entity pmown as the "Loan Servicer") that oollects Periodic Payments
due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under
the Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan
Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given
written notice of the change which will state the name and address of the new Loan Servicer, the
address to which payments should be made and any other information RESPA requires in connection with a
notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Service- other
than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan
Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless
otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an
individual litigant or the number of a class) that arises from the other party's actions pursuant to this Security
instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of,
this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in
compliance with the requirements of Seetiou 15) of such alleged breech and afforded the other parry hereto a
reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time
period which mind elapse before certain action can be taken, that time period will be deemed to be reasonable
for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pmnrrart
to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to
satisfy the notice and opportunity to take corrective action provisions of this section 20.
21. Hazardous Substances. As used in this Section 21: (a) 'Hazardous Substances" we those substances
defined as toxic or hazardous substances, polk ants, or wastes by Environmental LaW and the following
substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides,
volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b)
Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate
(ft-GA(PA) (OM) CML (06102) Papa 13 of 16
Ideals; 1%
Form 3038 1101
HK 1.83-4PG4688
ti
DOC ID #: 00003971299408003
to health, safety or environmental protection; (c) "Environmental Cleanup" includes any response action,
remedial action, or removal action, as defined in Environmental Lew; and (d) an "Environmental Condition"
means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup.
Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous
Substances, or threaten to release any Hazardous Substances, on or in the property. Borrower shall not do, nor
allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b)
which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous
Substance, creates a condition that adversely affects the value of the Property. The preceding two sentences
shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances
that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property
(kxlWft but not limited to, hazardous substances in consumer products).
Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or
other action by any governmental or regulatory agency or private party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental
Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any
Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance
which adversely affects the value of the Property. If Borrower leans, at Is notified
regulatory authority, or any private party, that by any governmental or
affecting the Property is any ?? or other remediation of any Hazardous Substance
necessary, Borrower shall promptly take all necessary remedial actions in accordance
with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender 11arther covenant and agree as follows:
22. Acceleration; Remedies, Lender shall give notice to Borrower prior to acceleration following
Borrower's breach of any covenant or avvensent in this Security Instrument (but not prior to
acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower
of, among other, f]b*c (a) the default; (b) the action required to cure the default; (c) when the default
must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums
secured by this Security I *Wmnent, foreclosure by Jod(cial pa ng and We of the (Property. Lrynder
shall further inform Borrower of theiight to relpstate after acceleration, and the right to assert irk the
foreelosure proceeding the non-eadstence of a default or any other defense of Borrower to acceleration
and Awedosore. If the default is not cured as specified, Leader at its option may require immediate
payment in fall of all soots secured by this Security Instrument without further demand and may
foreclose this Security Iustromoat by judicial proceeding. Lender shall be esdCM to collect all expenses
incurred in pursuing the remedies provided in do Section A indndiog, but not ]limited to, attorneys'
fees and costs of title evidence to the extent permitted by Apple" Law.
23. Release, Upon payment of all sums secured by this Security Instrment, this Security Instrument and
the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and
satisfy this Security Instrmea Borrower shall pay any recordation costs. Lender may charge Borrower a fee
for releasing this Security Instrument, bat only if the fee is paid to a third party for services rendered and the
charging of the fee is permitted under Applicable Law.
1M-eA(PA) (nos) CHL (oa/oz) Pape U d to
Form 3099 Vet
BK.1834PG4689
8
DOC ID #: 00003971299408003
24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or
defects in proixedings to enforce this security Instrument, and hereby waives the benefit of any present or
'future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and
homestead exemption.
25. Rdnetatement Perlod. Borrower's time to reinstate provided in Section 19 shall extend to one hour
prior to the commencement of bidding at a sherlffB sale or other sale pursuant to this Security InsttumeriL
26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire tide to the Property, this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment, Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under
the Note.
BY SIt3NING BELOW, Borrower accepts and agrees to the terms and covenants contained in this
Security Instrument and in any Rider executed by Borrower and recorded with it.
Witnesses:
7? ?? (Seal)
? TITTLE -Borrower
(Seal)
-Borrower
(Seal)
-Danower
(Seal)
-Bormwer
Qk-SWA) (0200) CHL (OSV2) Pape IS or 18 Form 3038 1/01
8K 1834PG4690
Certificat DOC ID 4: 00003971299408003
the Certificate of e
I, , do hereby certify that
correct a e within-named Mortgagee is P.O. Box 2026, Flint, MI 48501-2026.
Witness my hand this a-I,- day of n, MVf L aKIS
-#A?5tA
Agem of Morigagae
Co117 MONWEALTH OF PENNSYLVANIA, 01,IwR l iwo County 99:
On this, the day of Meundersigned officer, personwly appeared 0. t. T; ,,-der before me, the
bx)wn to me (or satisf) to be
person(s) whose name(s) blare subscribed to the within instrument and aclmow lorilY prothe he eJs sheh ft the
executed the same for the hey
purposes herein contained.
IN WITNESS WHBRHOF, I hereunto set my hand and-official seal
My Commission B44":
B MM HofAtn N Peblk Ave j
MY CenltaNMNI W. Title of OtSc¢
tkS
k Mar„ -
CHL (06/R) Pape 16 of 18 Form 3039 1/01
BK 'I U 4PG-4 631
1 • i V.
A
tee- -va
EXHIBIT C0A"
ALL THAT CERTAIN TRACT OF LAND SITAUTE IN WEST PENNSBORO
TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND
DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD SPIKE IN THE CENTER LINE OF TOWNSHIP
ROAD T-353 (OAK FLAT ROAD), SAID SPIKE BEING 20 MILES EAST OF
THE CENTER LINE OF ROUTE 233 AT THE SOUTHEASTERN CORNER OF
PROPERTY NOW OR FORMERLY OF JOHN C. HEFFERFINGER; THENCE
ALONG SAID PROPERTY, NORTH 09° 03' WEST, 231 FEET TO A PIN;
THENCE ALONG LAND NOW OR FORMERLY OF RONALD M. CALDWELL,
ET UX, NORTH 85° 38' EAST, 150 FEET TO A PIN; THENCE ALONG TRACT
NO.2 HEREIN, SOUTH 9° 03' EAST, 231 FEET TO A NAIL IN THE CENTER
LINED OF TOWNSHIP ROAD T-353; THENCE ALONG LATTER, SOUTH 85°
38' WEST, 150 FEET TO A RAILROAD SPIKE, THE PLACE OF BEGINNING
w
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•lcity this to be recordA
1 ?-?- County P
16
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ARY
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$' 7 ?': s-a f oC a7%y, lo, CMG e
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C/ny-
Sheriffs Office of Cumberland County
R Thomas Kline V?,' Edward L Schorpp
Sheriff Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/30/2009 08:19 PM - Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on April
30, 2009 at 2019 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Amber D. Tittle, by making known unto herself personally, defendant at
427 Oak Flat Drive Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.90
May 04, 2009
2009-2522 B
Countrywide Home Loans Servicing LP
V'S
Amber D. Tittle
!) ._
ch
c_ no
S? RS
R THOMAS KLINE, SHERIFF
Z',// ////i
Y
ep r?eriff
Vi
M'
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
BAC Home Loans Servicing, L.P. f/k/ a Countrywide
Home Loans Servicing, L.p.
Plaintiff
V.
Amber D Tittle
Defendant
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 09-2622 civil term
ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter
for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows:
Principal $ 116,146.85
Interest from 04/21/09 to 06/01/09 $ 884.52
Total $ 117,031.37
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
^ J Attorneys for Plaintiff
rl?
AND NOW, this p? day of MAI , 2009, Judgment is entered in favor of Plaintiff, BAC
Home Loans Servicing, L.P. f/k/ a Countrywide Home Loans Servicing, L.p., and against Defendant, Amber D
Tittle, and damages are assessed in the amount of $117,031.37, plus interest and costs.
BY THE PROTHONOT Y:
? "- y
. ?` .??,.
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
BAC Home Loans Servicing, L.P. f/k/ a Countrywide
Home Loans Servicing, L.p.
Plaintiff
V.
Amber D Tittle
Defendant
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 09-2622 civil term
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SS.
The undersigned, being duly sworn according to law, deposes and says that the Defendant, Amber D Tittle,
is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the
Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Amber D Tittle, is
over eighteen (18) years of age, and reside as follows:
Amber D Tittle
427 Oak Flat Road
Newville, Pennsylvania 17241
SWORN AND SUBSCRIBED
BEFORE ME THIS I" DAY
OF JUNE , 2009
OTARY PUBLIC
CiTFAhRO..V1L'lF.J1l.Tff Ci3'??•,'!?S^sYf_VAR.?.',R
NOTARIAL SEAL
GLORIA D. MITCHELL, Notary Public
City of Philadelphia, Phila. County
M Commission Expires June 2, 2011
TERR NCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse, Carlisle, Pennsylvania 17013
Curt Long
Prothonotary
May 21, 2009,
To: Amber D Tittle 7, r 04 L
427 Oak Flat Road
Newville, Pennsylvania 17241
Countrywide Home Loans Servicing, L.P.
vs.
Amber D Tittle
Cumberland County
Court of Common Pleas
Number 09-2622 civil term
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE
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
AGAINSTYOU WITHOUTAHEARING AND YOU MAY LOSEYOURPROPERTY
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
TOPROVIDE YOU WITH INFORMATION ABOUTAGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER
PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA
PERSONALMEI TE O POR ABOGADO Y POR NO HABER RADICADO POR
ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS
RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA
ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA
NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE
COMPARECER LISTED EN CORTE U OIR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS
DERECHOSIMPORTANTES.
USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO
INMEDIATAMENTE. SI LISTED NO TIENE A UN ABOGADO, VA A O
TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE
PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN
ABOGADO.
SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO,
ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON
INFORMAC16N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECERLOS
SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO
REDUCIDO NI NINGON HONORARIO.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
McCABE, WEISBERG, AND CO AY, P.C.
BY:
Attorneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
hm
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
BAC Home Loans Servicing, L.P. f/k/ a Countrywide
Home Loans Servicing, L.p.
Plaintiff
V.
Amber D Tittle
Defendant
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 09-2622 civil term
CERTIFICATION
The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law,
deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be
entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the
Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A".
SWORN AND SUBSCRIBED
BEFORE ME THIS I" DAY
OF JUNE , 2009
c?cQD
)'OTARY PUBLIC
N0T,AR1 L,S? ,- v 7
City Of PhuadCr` r f" .a?C
C? r;Qmcr??Sy€?n ir?tJar 2u
. 2011
r:?Mok' , J C
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
VERIFICATION
The undersigned hereby certifies that he is the attorney for the Plaintiff in the within action and that he is
authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge,
information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S.
Section 4909 relating to unsworn falsification to authorities.
- L-?&V ?"
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
I?I?C?J + r
THt
Apy
tlf u J7
?? o1aC?D39
A
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Prothonotary
To: Amber D Tittle
427 Oak Flat Road
Newville, Pennsylvania 17241
BAC Home Loans Servicing, L.P. f/k/ a Countrywide
Home Loans Servicing, L.p.
Plaintiff
Amber D Tittle
v.
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No. 09-2622 civil term
NOTICE
Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding
as indicated below. (2"52kw
Prothonotary
x Judgment by Default
- Money Judgment
- Judgment in Replevin
- Judgment for Possession
If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conwav
P.C. at (215)790-1010
? ?
? t?
.,
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
BAC Home Loans Servicing, L.P. lka Countrywide
Home Loans Servicing, L.P.
Plaintiff
Amber D Tittle
Defendant
Attorneys for Plaintiff
CUMBERLAND COUNTY e.~
COURT OF COMMON PLEAS C c
5..
~? txr ~
rr.. !~ ~' ' -7l
rl '~:.~ ~
Number 09-2622 civil term ~ i- ~" ~~
'~-'. i> ~ ~ -T i
r
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C+ K
AFFIDAVIT OF SERVICE
I, the undersigned attorney for the Plaintiff in the within matter, hereby certify that on the 24"' day of
February, 2010, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent
lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A."
Copies of the letter and certificates of mailing are also attached hereto, made a part hereof and marked as
Exhibit "B."
SWORN AND SUBSCRIBED
BEFORE ME THIS 24TH DAY
OF FEBRUARY, 2010
NOT RY PUBLIC
~[1MMOMk"d ,~lT~i RF" {'~h~.7.^, i`/^.Pdl~~
Fat.l~ ~'.~ ]b" 1.~ 1. ,.~1 e . r ~_ 1„
Elizabeth C, F~a7.snn~~-Pa~ta~y i'~~':7i~c
Ch`y of Phil~delph+a, F'~tiladeii~i~.i~ C~wrdy
MY COi~AWtI~N{~i~ ~1 EX~!kc S .I~~_:'~::. !~,
ERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARL S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GA1R0, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
215 790-1010
Attorneys for Plaintiff
BAC Home Loans Serv~cmg, L.P. flca Countrywide CUMBERLAND COUNTY COURT OF COMMON
Horne Loans Servicing, L.P. PLEAS
Plaintiff
v
Amber D Tittle
Defendant
NO: 09-2622 civil term
AFFIDAVIT PURSUANT TO RULE 3129
The undet•signed, attorney for 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: 427 Oak Flat Road,
Newville, Pennsylvania 17241, a copy of the description of said property being attached hereto and marked Exhibit
..A ~,
I. Name and address of Owner or Reputed Owner
Name Address
Amber D Tittle 427 Oak Flat Road
Newville, PA 17241
2. Name and address of Defendant in the judgment:
Name Address
Amber D Tittle 427 Oak Flat Road
Newville, Pennsylvania 17241
3
4.
5
Name and last known address of every judgment a•editor whose judgment is a record lien on the
real property to be sold:
Name Address
Plaintiff herein
Name and address of the last recorded holder of every mortgage of record:
Name
Plaintiff herein
Mortgage Electronic Registration
Systems, Inc.
Bank of America Home Loans,
formerly Countrywide Home Loans,
Inc.
Bank of America, formerly
Countrywide Home Loans, Inc.
Address
P.O. Box 2026
Flint, Michigan 48501-2026
4500 Park Granada
Calabasas, California 91302-1613
400 Countrywide Way
Simi Valley, California 93065-6298
Name and address of every other person who has any record lien on the property:
Name
Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name
West Pennsboro Township
Address
20 Bears Rd
Carlisle, Pennsylvania 17015
Name and address of every other person of who-n the plaintiff has knowledge who Itas any interest
in the property which may be affected by the sale:
Name Address
Tenants/Occupants 427 Oak Flat Road
Newville, Pennsylvania 17241
Commonwealth of Pennsylvania Department of Public Welfare
P.O. Box 2675
Harrisburg, PA 17105
Commonwealth of Pennsylvania 110 North 8"' Street
Inheritance Tax Office Suite #204
Philadelphia, PA ]9107
Commonwealth of Pennsylvania 6th Floor, Strawberry Square
Bureau of Individual Tax Department #280601
Inheritance Tax Division Harrisburg, PA 17128
Department of Public Welfare Willow Oak Building
TPL Casualty Unit Estate P.O. Box 8486
Recovery Program Harrisburg, PA ] 7105-8486
PA Department of Revenue Bm•eau of Compliance
P.O. Box 281230
Harrisburg, PA ]7128-1230
Commonwealth of Pennsylvania Clearance Support Department 281230
Department of Revenue Bureau of Harrisburg, PA 17128-1230
Compliance ATTN; Sheriff's Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
Domestic Relations P.O. Box 320
Cumberland County Carlisle, PA 17013
United States of America c/o United States Attorney for the
Middle District of PA
235 North Washington Street
Scranton, PA ] 8503
and
Federal Building
228 Wahlut Sheet
P.O. Box 1 1754
Harrisburg, PA 17108
Name and address of Attorney of record:
Name Address
None
verity t]iat the statements made in this Affidavit are true and correct to the best of my personal knowledge
or information and belief 1 understand that false statements herein are made subject to the penalties of I& Pa.C:.S.
Section 4904 relating to unsworn falsification to authorities.
__~_ ~ _ L..GG_~--'
November 17.2009 TE RENC ~ J. McCABE, ESQUIRE
DATI MARC S. EISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, F,SQUIRE
Attorneys for Plaintiff
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
BAC Home Loans Servicing, L.P. fka Countrywide
Home Loans Servicing, L.P.
Plaintiff
v.
Amber D Tittle
Defendant
DATE: February 24, 2010
TO: ALL PARTIES TN INTEREST AND CLAIMANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Number 09-2622 civil term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
OWNERS: Amber D Tittle
PROPERTY: 427 Oak Flat Road, Newville, Pennsylvania 17241
IMPROVEMENTS: Residential Dwelling
The above-captioned property is scheduled to be sold at the Sheriffs Sale on June 2, 2010 at 10:00 a.m. in the
Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse
Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on,
and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to
protect your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days
after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten
(10) days after the filing of the schedule.
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
~~~tixip of tariu~,t.r/~~~~
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Countrywide Home Loans Servicing LP I Case Number
vs.
Amber D. Tittle 2009-2622
SHERIFF'S RETURN OF SERVICE
12/28/2009 11:18 AM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 12-28-09
at 1115 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 Amber D. Tittle, located at, 427 Oak Flat Road, Newville,
Cumberland County, Pennsylvania according to law.
02/01/2010 05:45 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 2/1/10 at
1742 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: Amber D. Tittle, by making known unto, Kris
Crammer, roomate and adult in charge,at, 427 Oak Flat Road, Newville, Cumberland County,
Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1
the same
02/09/2010 Property sale postponed to 6/2/2010.
05/27/2010 Property sale postponed to 7/7/2010.
07/06/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned
STAYED, per letter of instruction from Attorney Terrance McCabe on 7/6/10
SHERIFF COST: $793.64 SO ANSWERS,
July 06, 2010 RON R ANDERSON, SHERIFF
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Attorneys for Plaintiff
BAC Home Loans Servicing, L.P. fka Countrywide CUMBERLAND COUNTY COURT OF COMMON
Home Loans Servicing, L.P. PLEAS
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
215 790-1010
Plaintiff
v.
Amber D Tittle
Defendant
NO: 09-2622 civil term
AFFIDAVIT PURSUANT TO RULE 3129
The undersigned, attorney for 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: 427 Oak Flat Road,
Newville, Pennsylvania 17241, a copy of the description of said property being attached hereto and marked Exhibit
..A ~~
1. Name and address of Owner or Reputed Owner
Name Address
Amber D Tittle 427 Oak Flat Road
Newville, PA 17241
2. Name and address of Defendant in the judgment:
Name Address
Amber D Tittle 427 Oak Flat Road
Newville, Pennsylvania 17241
~ ,
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real properly to be sold:
Name Address
Plaintiff herein
4. Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
5
6
Mortgage Electronic Registration P.O. Box 2026
Systems, Inc. Flint, Michigan 48501-2026
Bank of America Home Loans, 4500 Park Granada
formerly Countrywide Home Loans, Calabasas, California 91302-1613
Inc.
Bank of America, formerly 400 Countrywide Way
Countrywide Home Loans, Inc. Simi Valley, California 93065-6298
Name and address of every other person who has any record lien on the property:
Name Address
None
Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name
West Pennsboro Township
Address
20 Bears Rd
Cazlisle, Pennsylvania 17015
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
Tenants/Occupants 427 Oak Flat Road
Newville, Pennsylvania 17241
Commonwealth of Pennsylvania Department of Public Welfare
P.O. Box 2675
Harrisburg, PA 17105
Commonwealth of Pennsylvania 110 North 8`h Street
Inheritance Tax Office Suite #204
Philadelphia, PA 19107
Commonwealth of Pennsylvania 6th Floor, Strawberry Square
Bureau of Individual Tax Department #280601
Inheritance Tax Division Harrisburg, PA 17128
Department of Public Welfare Willow Oak Building
TPL Casualty Unit Estate P.O. Box 8486
Recovery Program Harrisburg, PA 17105-8486
PA Department of Revenue Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Commonwealth of Pennsylvania Clearance Support Department 281230
Department of Revenue Bureau of Harrisburg, PA 17128-1230
Compliance ATTN: Sheriffs Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
Domestic Relations P.O. Box 320
Cumberland County Carlisle, PA 17013
United States of America c/o United States Attorney for the
Middle District of PA
235 North Washington Street
Scranton, PA 18503
and
Federal Building
228 Walnut Street
P.O. Box 1 1754
Harrisburg, PA 17108
Name and address of Attorney of record:
Name Address
None
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.
November 17, 2009 TE ENC J. McCABE, ESQUIRE
DATE MARC S. EISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD SPIKE IN THE CENTER LINE OF TOWNSHIP ROAD T-353 (OAK FLAT
ROAD), SAID SPIKE BEING .20 MILES EAST OF THE CENTER LINE OF ROUTE 233 AT THE
SOUTHEASTERN CORNER OF PROPERTY NOW OR FORMERLY OF JOHN C. HEFFLEFINGER
(ERRONOEUSLY STATED AS JOHN C. HEFFERFINGER IN CURRENT TITLE DEED); THENCE ALONG
SAID PROPERTY, NORTH 09° 03' WEST, 231 FEET TO A PIN; THENCE ALONG LAND NOW OR
FORMERLY OF RONALD M. CALDWELL, ET UX, NORTH 85° 38' EAST, 150 FEET TO A PIN; THENCE
ALONG TRACT NO.2 HEREIN, SOUTH 9° 03' EAST, 231 FEET TO A NAIL IN THE CENTER LINE OF
TOWNSHIP ROAD T-353; THENCE ALONG LATTER, SOUTH 85° 38' WEST, 150 FEET TO A RAILROAD
SPIKE, THE PLACE OF BEGINNING.
BEING PARCEL NUMBER 46-09-0517-037
BEING KNOWN AS 427 Oak Flat Road, Newville, Pennsylvania 17241.
BEING the same premises which Ryan E. Tittle Sr. and Amber D. Tittle, Husband and Wife, by deed dated
August 27, 2003 and recorded September 9, 2003 in the office of the Recorder in and for Cumberland County in Deed
Book 259, Page 921, granted and conveyed to Amber D Tittle in fee.
Ea~itA
McCABE, WEISBERG AND CONWAY, P.C. ,
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
.MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
CIVIL ACTION LAW
BAC Home Loans Servicing, L.P. flca Countrywide
Home Loans Servicing, L.P.
v.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Amber D Tittle
Number 09-2622 civil term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Amber D Tittle
427 Oak Flat Road
Newville, Pennsylvania 17241
Your house (real estate) at 427 Oak Flat Road, Newville, Pennsylvania 17241 is scheduled to be sold at
Sheriffs Sale on March 3, 2010 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment
of $117,031.37 obtained by BAC Home Loans Servicing, L.P. fka Countrywide Home Loans Servicing, L.P. 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 canceled if you pay to BAC Home Loans Servicing, L.P. fka Countrywide Home
Loans Servicing, L.P. the back payments, late charges, costs, and reasonable attorney's fees due.
To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire
at (215) 790-1010.
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.
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 the following notice 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
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 on the sale. To find
out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.
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.
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.
You may be entitled to a share of the money which was paid for your real estate. A schedule of
distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days
of the sale. 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 schedule of
distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the
schedule of distribution.
You may also have other rights and defenses, or ways of getting your real estate 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, 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD SPIKE IN THE CENTER LINE OF TOWNSHIP ROAD T-353 (OAK FLAT
ROAD), SAID SPIKE BEING .20 MILES EAST OF THE CENTER LINE OF ROUTE 233 AT THE
SOUTHEASTERN CORNER OF PROPERTY NOW OR FORMERLY OF JOHN C. HEFFLEFINGER
(ERRONOEUSLY STATED AS JOHN C. HEFFERFINGER IN CURRENT TITLE DEED); THENCE ALONG
SAID PROPERTY, NORTH 09° 03' WEST, 231 FEET TO A PIN; THENCE ALONG LAND NOW OR
FORMERLY OF RONALD M. CALDWELL, ET UX, NORTH 85° 38' EAST, 150 FEET TO A PIN; THENCE
ALONG TRACT NO. 2 HEREIN, SOUTH 9° 03' EAST, 231 FEET TO A NAIL IN THE CENTER LINE OF
TOWNSHIP ROAD T-353; THENCE ALONG LATTER, SOUTH 85° 38' WEST, 150 FEET TO A RAILROAD
SPIKE, THE PLACE OF BEGINNING.
BEING PARCEL NUMBER 46-09-0517-037
BEING KNOWN AS 427 Oak Flat Road, Newville, Pennsylvania 17241.
BEING the same premises which Ryan E. Tittle Sr. and Amber D. Tittle, Husband and Wife, by deed dated
August 27, 2003 and recorded September 9, 2003 in the office of the Recorder in and for Cumberland County in Deed
Book 259, Page 921, granted and conveyed to Amber D Tittle in fee.
McCABE, WEI'SBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET CAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Attorneys-for Plaintiff
CIVIL ACTION LAW
BAC Home Loans Servicing, L. P. fka Countrywide
Home Loans Servicing, L.P.
v.
COURT~OF COMMON PLEAS
CUMBERLAND. COUNTY
Amber D Tittle
Number 09-2622 civil term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Amber D Tittle
427 Oak Flat Road
Newville, Pennsylvania 17241
Your house (real estate) at 427 Oak Flat Road, Newville, Pennsylvania 17241 is scheduled to be sold at
Sheriffs Sale on March 3, 2010 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, t Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment
of $117,031.37 obtained by BAC Home Loans Servicing, L.P. fka Countrywide Home Loans Servicing, L.l'. 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 canceled if you pay to BAC Home Loans Servicing, L.P. fka Countrywide Home
Loans Servicing, L.P. the back payments, late charges, costs, and reasonable attorney's fees due.
To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire
at (215) 790-1010.
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.
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 the following notice 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
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 on the sale. To find
out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.
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 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.
6. You may be entitled to a share of the money which was paid for your real estate. A schedule of
distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days
of the sale. 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 schedule of
distribution is wrong) are filed with the Sheriff within ten (] 0) days after the posting of the
schedule of distribution.
7. You may also have other rights and defenses, or ways of getting your real estate 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, 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800)990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800)990-9108
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND SITUATE IN WEST PENNSBORO TOWNSHIP, CUMBERLAND
COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A RAILROAD SPIKE IN THE CENTER LINE OF TOWNSHIP ROAD T-353 (OAK FLAT
ROAD), SAID SPIKE BEING .20 MILES EAST OF THE CENTER LINE OF ROUTE 233 AT THE
SOUTHEASTERN CORNER OF PROPERTY NOW OR FORMERLY OF JOHN C. HEFFLEFINGER
(ERRONOEUSLY STATED AS JOHN C. HEFFERFINGER IN CURRENT TITLE DEED); THENCE ALONG
SAID PROPERTY, NORTH 09° 03' WEST, 231 FEET TO A PIN; THENCE ALONG LAND NOW OR
FORMERLY OF RONALD M. CALDWELL, ET UX, NORTH 85° 38' EAST, 150 FEET TO A PIN; THENCE
ALONG TRACT NO.2 HEREIN, SOUTH 9° 03' EAST, 231 FEET TO A NAIL IN THE CENTER LINE OF
TOWNSHIP ROAD T-353; THENCE ALONG LATTER, SOUTH 85° 38' WEST, 150 FEET TO A RAILROAD
SPIKE, THE PLACE OF BEGINNING.
BEING PARCEL NUMBER 46-09-0517-037
BEING KNOWN AS 427 Oak Flat Road, Newville, Pennsylvania 17241.
BEING the same premises which Ryan E. Tittle Sr. and Amber D. Tittle, Husband and Wife, by deed dated
August 27, 2003 and recorded September 9, 2003 in the office of the Recorder in and for Cumberland County in Deed
Book 259, Page 921, granted and conveyed to Amber D Tittle in fee.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY ~ F CUPVIBERLAND)
NO 09-2622 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP, f/Wa
COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff (s)
From AMBER D. TITTLE
(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 $117,031.37 L.L. $.50
Interest from 6/2/09 to 3/3/10 at $19.23 -- $5,288.25
Atty's Comm % Due Prothy $2.00
Atty Paid $164.90
Plaintiff Paid
Date: 11/20/09
Other Costs
(Seal)
REQUESTING PARTY:
Name: MARGARET GAIRO, ESQUIRE
Address: MCCABE, WEISBERG AND CONWAY
123 S BROAD STREET, SUITE 2080
PHILADELPHIA, PA 19109
Deputy
Attorney for: PLAINTIFF
Telephone: 215-790-1010
Supreme Court ID No. 34419
On November 25 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
West Pennsboro Township, Cumberland County, PA,
Known and numbered 427 Oak Flat Road, Newville,
more fully described on Exhibit "A" filed with this
writ and by this reference incorporated herein.
Date: November 25, 2009
B
~~
Real Estate Coordinator
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