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HomeMy WebLinkAbout09-529560 BECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagors and Record Owners 133 Sunset Drive Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term (2- No. 09 - 5a4s tv, Defendants CIVIL ACTION: MORTGAGE N0TICLO LGOORF You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. REC[JERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hltp://www.phfa.orv,/consumers/homeowners/real.aox. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: hqp://www. 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(&goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80210FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, 7105 Corporate Drive, PTX C 35 Plano, TX 75024. 2. The names and addresses of the Defendants are LORRIE A. NULTON, 133 Sunset Drive, Mount Holly Springs, PA 17065 and STEPHEN U. NULTON, 133 Sunset Drive, Mount Holly Springs, PA 17065, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On October 05, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR NBANK NA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book# 1926 Page# 1728. The mortgage has been assigned to: COUNTRYWIDE HOME LOANS SERVICING LP which is now known as BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP by assignment of Mortgage May 11, 2009 as Instrument #-200915302. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for December 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance............. ......................................................................$197,660.90 Interest from 11/01/2008 through 07/21/2009 at 6.2500% .... ...................$8,902.55 Per Diem interest rate at $33.85 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$9,883.05 Late Charges from 12/01/2008 to 07/21/2009 ....................... ......................$411.75 Monthly late charge amount at $51.47 Costs of suit and Title Search ................................................ ...................... $900.00 Monthly Escrow amount $328.28 $217,758.25 7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in perso 'judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The date of the postmark on the Notice was the same as the date of the Notice. The Defendants had the required face to face meeting within the required time and Plaintiff has been advised that the Defendants filed an application for mortgage assistance with the Pennsylvania Housing Finance Agency, the Plaintiff has been advised by the Pennsylvania Housing Finance Agency that the Defendants' application has been rejected. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $217,758.25, together with interest at the rate of $33.85, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: ATTORNEY FOR PLAINTIFF BY: MICHAEL T. MCKEEVER, ESQUIRE VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: v Michael T. McKeever, Esquire PA I.D. #56129 #80210FC LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 ExhibitA } -A 0 EMFIIBIT A ALL the following, described real estate lying acid being,; situate in South Middleton Township, Cumberland , County.~ Pennsylvania, more particularly described as follows: BEGIMING at a point on the southern right of way line of Sunset Drive at corner of Lot 51 and Lot 52 on plan of lots hereinafter mentioned; thence along the dividing line between amid lots, South 9 degrees 33 minutes 45 seconds West 136.16 feat to a point] thence along the dividing line between Lot 49 and Lot 50, North 80 degrees 26 minutes 15 seconds West 28.53 feet to a point; thence along the dividing line between Lot 50 and Lot 51, North 80 degrees 26 minutes 15 seconds West 106.47 feet to a point; thence along the southern right of way line of Sunset Drive by a curve to the right having a radius of 175 feet, an are length of 202.92 with a chord bearing North 54 degrees ].9 minutes 3 seconds West 191.74 feet to a point and place of beginning, containing 0.2964 acre. BRING Lot 51 on plan of South View Estates prepared by Statler-Brehm Associates, Inc.,. dated October 15, 1996, recorded in Cumberland County, Pa., Plan Book 76, Page 56. I Certify this to be recorded In Cumberland County PA { e cc-order of Deods ?hidit ? ACT 91 NOTICE DATE OF NOTICE: 03/20/2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose Specific information about the nature of the default is provided to the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to hem to save your home This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com Date: 03/20/2009 Homeowners Name: LORRIE A. NULTON and STEPHEN U. NULTON Property Address: 133 Sunset Drive, Mount Holly Springs, PA 17065 Loan Account No.: 106883570 Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR NBANK NA Current Lender/Servicer: COUNTRYWIDE HOME LOANS SERVICING, L.P. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 133 Sunset Drive, Mount Holly Springs, PA 17065 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 12/01/2008 thru 03/20/2009 (4 mos. at $1,357.76/month) $5,431.04 (b) Late charges from 12/01/2008 thru 03/20/2009 (4 mos. at $51.47/month) $205.88 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $5,636.92 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $5,636.92, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: Attention: Act Letter Department COUNTRYWIDE HOME LOANS INC. c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 HomeRetention@goldbecklaw.com 866-413-2311 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY Period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: COUNTRYWIDE HOME LOANS, INC. Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 972-526-2354 Fax Number: 817-230-6811 Contact Person: Nicole Graves 13 Email: PHFA-Program@countrywide.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Nicole Graves 13 Phone Number: 972-526-2354 HEMAP Consumer Credit Counseling Agencies I Report last updated: 12/2312008 1:52:41 PM I Lycom.Cintn Co Comm fo Comm Action 2138 Lincoln Street P.O. Box 3568 Williamsport, PA 17703 570.326.0587 CCCS of Western PA 2000 L'mglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 COLUMBIA County American Credit Counseling Institute 212 Berwick-Hazelton Hwy Nescopeck, PA 18635 888.468.8847 CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 570.602.2227 600.922.9537 CRAWFORD County Booker T. Wash Iri ton Center 1720 Holland Street Erie, PA 16503 814.453.5744 CCCS of Western PA 4402 Peach Street Erie, PA 16509 888.511.2227 ext 108 888.5112227 ext 108 Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 814.337.8450 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County Adams County Interfaith Housing AuthorNy 40 E High Street Gettysburg, PA 17325 717.334.1518 Community Action Commission of Captial Reglon 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Marsnatha 43 Philadelphia Avenue Waynesboro, PA 17268 717162.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DAUPHIN County CCCS of Western PA 2000 L'rnglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captfal Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Opportunity Inc. 301 East Market Street York, PA 17403 717.424.3645 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DELAWARE County Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 215.765.1221 Page 7 of 19 0 nr ? i ^n - -1 11 1 r, 47$. So AA ATN CCU aR 109O a aslo4 3 Sheriffs Office of Cumberland County R Thomas Kline Sheriff ,' QY Ronny R Anderson Chief Depute?, Jody S Smith Civil Process Sergeant OE r? s"ERIE ' Edward L Schorpp Solicitor BAC Home Loans Servicing, LP Case Number vs. Lorrie A. Nulton 2009-5295 SHERIFF'S RETURN OF SERVICE 08/04/2009 10:59 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Stephen U. Nulton, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Stephen U. Nulton. The Mount Holly Springs Postmaster has advised the defendants new address is P.O. BOX 5402 Harrisburg, PA 17110. 08/04/2009 10:59 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lorrie A. Nulton, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Lorrie A. Nulton. The Mount Holly Springs Postmaster has advised the defendants new address is P.O. BOX 5402 Harrisburg, PA 17110. SHERIFF COST: $60.30 SO ANSWERS, August 05, 2009 R THOMAS KLINE, SHERIFF GOLDBECK MCCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 OF Cumberland COUNTY No. 09-5295 civil term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: Plaintiff is the holder of a first mortgage upon the premises 133 Sunset Drive, Mount Holly Springs, PA, 17065, hereinafter, the "mortgaged premises". 2. Defendants, LORRIE A. NULTON and STEPHEN U. NULTON, are the mortgagors and real owners of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, David Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. IN THE COURT OF COMMON PLEAS The last known address of Defendants is 133 Sunset Drive, Mount Holly Springs, PA, 17065, as set forth in Paragraph 2 of the Complaint. The Sheriff has been unable to effect service of the Complaint upon Defendants, at the last known address after numerous attempts. Per Sheriff, the Defendants moved. Their new address is P.O. Box 5402 Harrisburg, PA, 17110, in which the Sheriff is unable to serve. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendants. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendants, by posting the premises and certified and regular mail to the Defendants" last known address. Respectfully submitted, David B. ein, Esq. ProVest, LLC Affidavit of Good Faith Investigation Client provided information: File Number: 80210FC Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: Stephen U. Nulton Property Address: Street: 133 Sunset Drive City: Mount Holly Springs State: PA Zip 17065 Skip Results: Date of Birth: None Found ProVest File Number: 1819354 Last Known Dates: As of 8/12/2009 Street: 133 Sunset Drive Phone: City: Mount Holly State: PA Zip: 17065 Springs Death Records: As of 8/12/2009, the Social Security Administration has no death record on file for Stephen U. Nulton. Social Security Number Search Completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Stephen U. Nulton as 133 Sunset Drive, Mount Holly Springs, PA 17065. Department of Motor The Pennsylvania Department of Motor Vehicles provided no change for Stephen U. Nulton Vehicle Records: from 133 Sunset Drive, Mount Holly Springs, PA 17065. Public Licenses (Pilot, Search performed provided no information. Real Estate, etc): Voter Registration The County Voters Registration Office has no listing for Stephen U. Nulton. Information: National Postal Has no change for Stephen U. Nulton from 133 Sunset Drive, Mount Holly Springs, PA 17065. Address Search: Military Search: There was no active military status found. Comments: 717-486-3082: Called possible neighbor, Linda Antonishek, answering machine answered, no message left. 717-323-0168: Called possible neighbor, Anita Gelsomino, answering machine answered, no message left. 717486-8062: Number listed to Lorrie and Stephem Nulton at 133 Sunset Drive, Mount Holly Springs, PA 17065, there was no answer. On 8/12/2009, I, Patti Garrett being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investigation. Sub.vcrTbsd A cl5v/v to t;re me. fiaAltbll C7??' - t H Affiant ?: Pi Garrett N(')tClfy F-u-blic Date: 8/12/2009""?° CYNML~ MY COMMISSION E)U'tP'- ProVest, LLC Affidavit of Good Faith Investigation Client provided information: File Number: 80210FC Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: Lorrie A. Nulton Property Address: Street: 133 Sunset Drive City: Mount Holly Springs State: PA Zip 17065 Skip Results: Date of Birth: None Found ProVest File Number: 1819354 Last Known Dates: As of 8/12/2009 Street: 133 Sunset Drive Phone: City: Mount Holly State: PA Zip: 17065 Springs Death Records: As of 8/12/2009, the Social Security Administration has no death record on file for Lorrie A. Nulton. Social Security Number Search Completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Lorrie A. Nulton as 133 Sunset Drive, Mount Holly Springs, PA 17065. Department of Motor The Pennsylvania Department of Motor Vehicles provided no change for Lorrie A. Nulton from Vehicle Records: 133 Sunset Drive, Mount Holly Springs, PA 17065. Public Licenses (Pilot, Search performed provided no information. Real Estate, etc): Voter Registration The County Voters Registration Office has no listing for Lorrie A. Nulton. Information: National Postal Has no change for Lorrie A. Nulton from 133 Sunset Drive, Mount Holly Springs, PA 17065. Address Search: Military Search: There was no active military status found. Comments: 717-486-3082: Called possible neighbor, Linda Antonishek, answering machine answered, no message left. 717-323-0168: Called possible neighbor, Anita Gelsomino, answering machine answered, no message left. 717-486-8062: Number listed to Lorrie and Stephem Nulton at 133 Sunset Drive, Mount Holly Springs, PA 17065, there was no answer. On 8/12/2009, I, Patti Garrett being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investigation. sur>scr;lbec, A d 5WOrn to tare fne, Affiant p i Garrett Date: 8/12/2009 YNMt,AHMM ?¢ MY tvC1101IMMM NWWAWS,2011 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor BAC Home Loans Servicing, LP vs. Lorrie A. Nulton ?4Yttt,, ni ?attaah?rla Case Number 2009-5295 SHERIFF'S RETURN OF SERVICE 08/04/2009 10:59 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Stephen U. Nulton, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Stephen U. Nulton. The Mount Holly Springs Postmaster has advised the defendants new address is P.O. BOX 5402 Harrisburg, PA 17110. 08/04/2009 10:59 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lorrie A. Nulton, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Lorrie A. Nulton. The Mount Holly Springs Postmaster has advised the defendants new address is P.O. BOX 5402 Harrisburg, PA 17110. SHERIFF COST: $60.30 August 05, 2009 SO ANSWERS, - R THOMAS KLINE, SHERIFF GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 VERIFICATION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 09-5295 civil term i I Attorney for Petitioner do hereby verify that the facts set forth l ? in the foregoing Motion for Substitu ed Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. BY: David B. Fein, Esq. GOLDBECK MCCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024" vs. LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 OF Cumberland COUNTY No. 09-5295 civil term MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendants, which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants, by posting the premises and certified mail and regular mail to the Defendants' last known address. Respectfully submitted, IN THE COURT OF COMMON PLEAS J David B. Fein, Esq. GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. LORRIE A. NULTON STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 CERTIFICATE OF SERVICE of Cumberland County No. 09-5295 civil term ? r g does hereby certify that true and correct c9 pies of the f7"2009, Motion fort/ Substituted Service have been served upon the Defendants, thisday of?? TU, , by first class mail, postage prepaid. STEPHEN U. NULTON LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 BY: David B. Fein, Esq IN THE COURT OF COMMON PLEAS OF THE ^' ..? , 7I?Y 7009 Al,iG 19 El !: 44' R. ?w: _ !`f 1 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY VS. LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 09-5295 civil term ORDER AND NOW, this day of 009, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants, by posting a copy of the Complaint upon the premises 133 Sunset Drive, Mount Holly Springs, PA, 17065, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 133 Sunset Drive, Mount Holly Springs, PA, 17065, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants, by sending copies of same to Defendants' last known address by certified and regular mail, and by posting the premise PZ;BY COUR J. stribution list: ?ichael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 ./ L RIE A. NULTON, 133 Sunset Drive Mount Holly Springs, PA 17065 TEPHEN U. NULTON, 133 Sunset Drive Mount Holly Springs, PA 17065 cloa, nA-tAv-cL gg JOL C) 7 VF THE' PF,'OTHI,iNKDTARY 2009 AUG 21 AM 11 w 09 PD4 i V; WIA GOLDBECK McCAFFERTY & McKEEVER B Y. MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. Term LORRIE A. NULTON No. 09-5295 civil term STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) PRAECIPE TO RETNSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER 7-Aa6e,By Michael T. McKeever, Esq. Attorney for Plaintiff C Ft:..i,.±..! OF TH11- P. -NOiARY 2009 A113 31 Ph 12, 08 1.rLikYY?' i'?y;Y 4 (0 . oo PC) ATty CiC.`? 39x55 !) Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant €FFiCE''=' Es"ERIFF Edward L Schorpp Solicitor F;1 i n tU? ? S;EP -3 , is s: ? 00 C BAC Home Loans Servicing, LP vs. Lorrie A. Nulton Case Number 2009-5295 SHERIFF'S RETURN OF SERVICE 09/01/2009 09:03 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 1, 2009 at 2103 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Lorrie A. Nulton, pursuant to order of court by posting the premises located at 133 Sunset Drive Mount Holly Springs, Cumberland County, Pennsylvania 17065 with a true and correct copy according to law. 09/01/2009 09:03 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on September 1, 2009 at 2103 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Stephen U. Nulton, pursuant to order of court by posting the premises located at 133 Sunset Drive Mount Holly Springs, Cumberland County, Pennsylvania 17065 with a true and correct copy according to law. SHERIFF COST: $62.30 September 02, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ByA.2.& WMVb?.?- Depot Sheriff GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. LORRIE A. NULTON and STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 09-5295 civil term PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to Plaintiff's Complaint filed on July 30, 2009 in the above captioned matter. GOLDBECK McCAFFERTY & McKEEVER BY:2 ita.-I - --vil Michael T. McKeever Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6303 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 VS. LORRIE A. NULTON and STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 09-5295 civil term CERTIFICATION OF SERVICE I certify that a true-auf-correct copy of Plaintiff's Praecipe to Substitute Verifsation to Plaintiff's Complaint was served on Defendant(s) via first class mail on September 2, 2009 as follows: LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever Attorney for Plaintiff VERIFICATION David Perez , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: BUG 18 2009 #80210FC - LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 FILED- URCE OF THE PROMIONMARY 2004 SEP -4 Pty 1: S ! ?G'tk, D 6 {JuNTY PENNSYL.VAN A «' .% GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 VS. LORRIE A. NULTON and STEPHEN U. NULTON Mortgagor(s) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5295 civil term CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER ESQUIRE hereby certifies that on he did serve upon Defendant(s) LORRIE A. NULTON and STEPHEN U. NULTON a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated August 21, 2009 The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE RM- ?rICE O H PROTHMTARY 2419 SEP _g AM i i : 03 CILACEI'i?;,4L-., AUNTY PBOSYLVANlA oU, So??/??J r PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Lames Kleinklaus, Advertising Operations Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): September 11, 2009 COPY OF NOTICE OF PUBLICATION Michael T. McKeever, Atty. for Plaintiff Goldbeck McCafferty & McKeever, P.C. Suite 5000, Mallon Independende Center 701 marlm Street Phledelpfda, PA 19104-1532 215427-1322 Affiant further deposes that he/she is not IN HE COURT OF COMMON PLEAS 1L "?''" + --t+er of the CL"SERLAND COUNTY Went, and that CIVIL ACTION - LAW No. 0943295 Civil Term lg statement BAC HOME LOANS SERVICING, LP F/ WA COUNT IN RYW DE HOME LOANS 3ERV ICING LP, Plaintiff vs. LORRIE A. NULTON & STEPHEN U. NULTON, Mortgagors and Real Owners, Defendants T Of TO: LORRIE A. NULTON & STEPHEN U. NULTON, MORTGAGORS AND REAL OWNERS, DEFENDANTS, whose last known address Is 133 Sunset Drive, Mount Holly Springs PA 17065, THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. ' You are hereby notNfed that Plaintiff, BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING LP, has filed q Mortgage Foreclosure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 09-5295 Civil Term, wherein Plaintiff seeks t foreclose on the mottgage secured on youi property located, 133 Sunset Drive, Mount Holly Springs, PA whereupon your property will be sold by the Sheriff of Cumberland County. You have been sued in court. If you wish to defend agims?t theEclaims set forth in #e (oodwing pages, you must fake action within twenty (20) days after the Complaint and notice are served, by enteringa written appearance personally - or by attorney and Filling in writing with the court youidefenses or objections to ft claims eat I" against you. You -ore me this are warned that if you fail to do so the case may proeeed without you and a judgMtart may be ordered aga6lnt you by the Court without further notice for any money claimin the Complaint of for any odw claim or relief requested by ft Plaintiff. You may lose money or property or other rift important to yqu. YOU-6MQU gTAIKE "t&PAPER'TO YOURLAWYIR AT ONCE. IF YOU DO NOtTl)t%%-A LAWYER OR CANNOT t) AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRINGA LAWYER IF NYOU CANNOT FORMA ON ABOUT GENC ES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGALSERVICES INC 401 E. Louther Street Suite 103, Carlisle, PA 17013 COUNTY 71?-243-9400 BA y Public CUMBERLAND COUNTY BAR ASSOCIATION r 32 S. Bedford Sleet, Carlisle, PA 17013 717-5-dQ_41 RR ,;OMMONWEALTH OF PENNS e ? ? A, :., NOTARIAL SEAL BAMBI ANN HECKENDORN; Notwy Puy.,., Camp Hill Boro., Cumberland County My Commission Expires January 27,204,E PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 (Aisa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 11 day of September, 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28. 2010 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz September 11, 2009 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County Civil Action-Law No. 09-5295 Civil Term BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff VS. LORRIE A. NULTON & STEPHEN U. NULTON, Mortgagors and Real Owners, Defendants TO: LORRIE A. NULTON & STEPHEN U. NULTON, MORTGAGORS AND REAL OWNERS, DEFENDANTS, whose last known address is 133 Sunset Drive, Mount Holly Springs, PA 17065. THIS FIRM IS A DEBT COLLEC- TOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OB- TAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECT- ING THE DEBT. You are hereby notified that Plain- tiff, BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING LP, has filed a Mortgage Foreclosure Complaint en- dorsed with a notice to defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 09-5295 Civil Term, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located, 133 Sunset Drive, Mount Holly Springs, PA 17065, whereupon your property will be sold by the Sheriff of Cumberland County. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written ap- pearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint 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 PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. LEGAL SERVICES INC. 401 E. Louther St. Suite 103 Carlisle, PA 17013 (717) 243-9400 or CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 MICHAEL T. McKEEVER, ESQUIRE GOLDBECK McCAFFERTY & McKEEVER, P.C. Attorneys for Plaintiff Suite 5000 Mellon Independence Center CUMBERLAND LAW JOURNAL 701 Market St. Philadelphia, PA 19106-1532 (215) 627-1322 Sept. 11 OF THE 2099 SEP 22 PM 12= ! .I vti In the Court of Common Pleas of Cumberland County BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff VS. LORRIE A. NULTON STEPHEN U. NULTON (Mortgagor(s) and Record Owner(s)) 133 Sunset Drive Mount Holly Springs, PA 17065 No. 09-5295 civil term Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against LORRIE A. NULTON and STEPHEN U. NULTON by default for want of an Answer. Assess damages as follows: $221,842.45 Debt Interest from 10/17/2009 to Date of Sale per diem at $33.85 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED NTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to th arty against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least t d ay prior to thdate of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. cKeever Attorney r Plaintiff I.D. #5 29 AND NOW L/ T pZQ 0200 Judgment is entered in favor of BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP and against LORRIE A. NULTON and STEPHEN U. NULTON by default for want of an Answer and damages assessed in the sum of $221,842.45 as per the above certification. 50 " r thonotary D? • • L BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 09-5295 civil term ORDER AND NOW, this day of 009, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants, by posting a copy of the Complaint upon the premises 133 Sunset Drive, Mount Holly Springs, PA, 17065, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 133 Sunset Drive, Mount Holly Springs, PA, 17065, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants, by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises G'u'?'?C?`? lam' BY COUR J. Distribution list: Michael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 LORRIE A. NULTON, 133 Sunset Drive Mount Holly Springs, PA 17065 STEPHEN U. NULTON, 133 Sunset Drive Mount Holly Springs, PA 17065 TRU COPY F+ RECORD ? ? i' tyst? + wherMv f tame unto set my han< 1be am ? said Cox't at Carlisle, M 80210FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: October 2, 2009 TO: LORRIE A. NULTON NULTON, LORRIE A. 133 Sunset Drive Mount Holly Springs, PA 17065 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. LORRIE A. NULTON STEPHEN U. NULTON (Mortgagor(s) and Record Owner(s)) 133 Sunset Drive Mount Holly Springs, PA 17065 TO: LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-5295 civil term 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 AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 80210FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: STEPHEN U. NULTON NULTON, STEPHEN U. 133 Sunset Drive Mount Holly Springs, PA 17065 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON (Mortgagor(s) and Record Owner(s)) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) TO: STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 DATE OF THIS NOTICE: October 2, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-5295 civil term 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 AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE . The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, LORRIE A. NULTON, is about unknown years of age, that Defendant's last known residence is 133 Sunset Drive Mount Holly Springs, PA 17065, and is engaged in the unknown business located at 2. That Defendant is not in the Military Allies, or otherwise within the provisions of the Service of the United States or its ' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, STEPHEN U. NULTON, is about unknown years of age, that Defendant's last known residence is 133 Sunset Drive Mount Holly Springs, PA 17065, and is engaged in the unknown business located /NaService wn address. 2. That Defendant is not in the Military or of the United States or its Allies, or otherwise within the provisions of the SoldSailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON (Mortgagor(s) and Record owner(s)) 133 Sunset Drive Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-5295 civil term Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of BAC HOME LOANS SERVIC HOME LOANS SERVICING LP, and against LORRIE A. NULTON am file an Answer in the above action within (20) days (or sixty (60) days if America) from the date of service of the Complaint, in the sum of $221,;4 Michael McKeever Attornfor Plaintiff I hereby certify that the above names are correct an/that the pr creditor is BAC HOME LOANS SERVICING, LP F OUNTRYW 7105 Corporate Drive PTX C 35 Plano, TX 75024 and that the name(s) Defendant(s) is/are LORRIE A. NULTON, 133 Sunset Drive Mount He NULTON, 133 Sunset Drive Mount Holly Springs, PA 17065; FKA COUNTRYWIDE --N U. NULTON for failure to !$ the United States of ydence address of the judgment VIE LOANS SERVICING LP known address(es) of the igs, PA 1.7065 and STEPHEN U. --CK McCAFFERTY & McKEEVER iael T. McKeever for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $197,660.90 Interest from 11/0 1/2008 through $11,847.50 10/16/2009 Reasonable Attorney's Fee $9,883.05 Late Charges $566.16 Costs of Suit and Title Search $900.00 Escrow Payments Due 3 X $328.28 $984.84 $221,842.45 GOLDBECK BY: Michael Attorney for TY & McKEEVER AND NOW, this JO day of Dd 2009 damages are assessed as above. . /Q . o Prothy 1JK6 2?7J9 Q? r 20 i',? ! : 5 3 ?V 4 I4,oo Po ATT`f a,& W2(04 ot a 3aa7a Loitee ?A? #I& Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON (Mortgagors and Record Owner(s)) 133 Sunset Drive Mount Holly Springs, PA 17065 No. 09-5295 civil term Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonota By: Deputy 4DK$ If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-5295 civil term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 10/17/2009 to Date of Sale per diem at $33.85 $221,842.45 (Costs to be added) .? r A t2 0 L- 1. em.. 1 f N LIJ CD rT` 1 car CU a, a d ?4 z w a a> ?z N 0 ? W > , zo W wQ H x? z ¢? 0 U LL _ ov - =- Q Q. CS 0 °om o r S 0 9 ? v z 0 b ' gz o 00 z? ? ¢ w p l 'd > ? oQ p. C a ao W a M o G ? W o ?" x cmo o? b w a ? ? w w a? x U U 0 ?U a? U ? U ° O cue N u O ? ?, O a b° o ?, .F ALL the following described real estate lying and being situate in South MiddlOten TaMOMP, Cumhezlmd VUWL,y, Pennsylvania, mare particularly described as follows: BRGINNING at a point ota the souther right Of moray line Of Sunset Drive at eoxner of T,ot 51 and Lot 52 on plan Of lots her+einafterr mentioned thence alongr the dividing line bttween said lots. South 9 degrees 33 minutes 45 seconds Nest 136.16 feet to a pout; thence aloz* the dividing line between Lot 4,9 and Lot 50, North 80 degrees 26 minutee is seconds West 28.53 feet to a point: thence along the dividiAg line 'between Lot 50 and Lot $1, North 80 +degreee 26 minutes 15 seconde west 106.x7 feet to a point; thence along the so lithe= right of way line of Sunset prime by a curve to the right having a ra-dius of 175 feet, an arc 1 th of 202.92 with a chord be-artng North .54 degrees 19 m rnutes 3 seconde West 191.74 feet to a point and place of beginning, containing 0.2964 acre. BEING THE SAME PREMISES BY DEED FROM RINE LAND DEVELOPMENT, INC., A PENNSYLVANIA CORPORATION DATED 09/15/2005 AND RECORDED 10/10/2005 IN BOOK 271 PAGE 1910. GRANTED AND CONVEYED UNTO STEPHEN U. NULTON AND LORRIE A. NULTON, HIS WIFE. TAX PARCEL NO: 40-31-2189-107 BEING KNOWN AS 133 SUNSET DRIVE, MOUNT HOLLY SPRINGS PA 17065 Gdidbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP IN THE COURT OF COMMON PLEAS 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. Plaintiff LORRIE A. NULTON of Cumberland County CIVIL ACTION - LAW STEPHEN U. NULTON ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s) and Record Owner(s)) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) No. 09-5295 civil term AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 133 Sunset Drive Mount Holly Springs, PA 17065 I .Name and address of Owner(s) or Reputed Owner(s): LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Fit r 1.0 2OC9GCT 20 53 C?P,h i t Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) NO. 09-5295 civil term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of rec d or the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff haXorlp lied with all the provisions of the Act. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Michael ".cave Attorno for plaintiff - -`F r'NOTARY TpE , . 20(19 OCT 20 Fr, 1:11 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 09-5295 civil term BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s' , of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5295 civil term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NULTON, LORRIE A. LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 Your house at 133 Sunset Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $221,842.45 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 09-5295 civil term 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 09-5295 civil term 717-243-9400 f 09-5295 civil term Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_ov_ for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orp-/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80210FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. r GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 09-5295 civil tenn BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5295 civil term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NULTON, STEPHEN U. STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 Your house at 133 Sunset Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $221,842.45 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: t 09-5295 civil tenn 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 09-5295 civil term 717-243-9400 l .f 09-5295 civil term Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website htlp://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkgoldbecklaw 2 com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80214FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. V ew 09-5295 civil teen GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5295 civil term THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NULTON, STEPHEN U. STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 Your house at 133 Sunset Drive, Mount Holly Springs, PA 17065 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $221,842.45 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County To prevent this Sheriffs Sale you must take immediate action: 09-5295 civil tern-i 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back. if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.or2/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 09-5295 civil term 717-243-9400 09-5295 civil term Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.g_ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.oriz/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention a goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80210FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5295 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff (s) From LORRIE A. NULTON STEPHEN U. NULTON (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 $221,842.45 L.L. $.50 Interest from 10/17/09 to Date of Sale per diem at $33.85 -- to be Determined Atty's Comm % Atty Paid $251.60 Plaintiff Paid Date: 10/20/09 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 - -r -"-? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 80210FC CF: 07!30/2009 SD: 03/03/2010 $221,842.45 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTXC35 Plano, TX 75024 vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) T OF COMMON PLEAS of Cumberland County Plaintiff 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) FlLFD--G~~l~~ cud T~-?~ F'~OT~w1}(NARY 201 Q N~,R -5 A~ E0~ Q 3 CJtY4~'~:; ` 'tit ^°~VtY11 CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5295 civil term CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. (yj Premises was posted by e/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached}. Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, ~'~ - .~' BY: Keith C. Halili Legal Secretary ~~ ° ° p o ~, N n. .AN r ~ ~1 ~ ~ N ~ V i ~ ~ 1~~ a N r O t\9 ~ ~ p N ~ __ ' 0 4 ~i v _ / _ -~ 41 f1S No°~ ~. ~ ,~ ' m 1; , ,O m f`'~ `ti f l .,~0 ~~. ~o .. m y Q ~~ v ¢~ ~ > o 'C a ~, `~~~ Q ~ „ ~ - °' _` a o ~ a ~ n a _ . Z ~ E ;~m Xd~~ _ O ma> ~ ~ rA ,__ 3~ ~ ~~~6~ `OO N ~ N . Z' a U ~ a ~ x ,~ w is '" ~ a~ o, ~- ~L Om , LL- Q ~ U Q lI) m m ~ Q .. >. a h o w~ °~ z ~_ ~ Nto R Q(n ~ ~ a v~a ~~ ~o ~ m c ~ o __ ~ ._ z p ' o m a `€ c o ~~ ~ ~ °m~~ m v~ ~ ~ ~ a W R m u-... W m rN] rn ~ ~ °~ ~ ~ ~ m ~~v i `D ~° U v o $ ~ ~ ~ ~ m ° ~° c ~ a a ~ ~ ~ a w ~ ~ ~' ' .~ o . 4 ~ ~ Z Vi Q ~ Z ~ 0 ~ o ~ N ~ am p S f ~ `o ~ LLI m e W c Q ~ ~ ~ ! a d ? Q J ~ H~~ ~ W ~ „~ ~ o E ~ v~ ~ OO ~ ~om ~ r ' ~a ~~n¢ ~ ~~a a o ~ to ~v ~uow ~ (~ oQ ems u)~~ ~ Z c= z cS ~~ xa V ~ ° ~ a ~' °- a 0 3.. 0~., wz o m ,L ~ m-° ~;'o ~;'o ooo~ ~ a~mQ~ ~ ~ z~~ z.-~ pUac~ am=a= o a N y U ao o p ~a Z~ ~ ~. ~ ~ F~ Z ~ wa `p ~ Q. C Q a, v, a , vYOWaN a QUo1J.r~ ~o mm~~p~ u~i `~ a ~- ~ T ~~~~Q~ Za mm m a c 0 a m 0 .c 3 r _d a E O U N O N m a °o N r 2 ri ti ap M 0 LL _o O N O M 0 0 a~ iv _T C 7 O U C fp N J cs U L.L. _O N z O J Z Z w a w H Z J Z Q _w L :~,~ `tar '~` ~ ~~`~®~ BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C 35 Plano, TX 75024 vs. LORRIE A. NULTON and STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 09-5295 civil term ORDER AND NOW, this ~~ day of 009, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriffand/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendants, by posting a copy of the Complaint upon the premises 133 Sunset Drive, Mount Holly Springs, PA, 17065, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 133 Sunset Drive, Mount Holly Springs, PA, 17065, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 maybe made upon Defendants, by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises ~ ~-• ~~~ 7 "` ~ ~~ BY COUR J. Distribution list: Michael T. McKeever, Esquire, Suite 5000 -Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 LORRIE A. NULTON, 133 Sunset Drive Mount Holly Springs, PA 17065 STEPHEN U. NULTON, 133 Sunset Drive Mount Holly Springs, PA 17065 ~~~3~ GC3l~Y ~RC3~t1 REC®RL° ~~ i est~~ ~• l har8 into set ~I ham t~ 8t # ~t C~tl, P~ 4`1- d Form 3877 Domestic USPS Firm Mailing Book Name and Address of Sender: Permit Number Sequence Number JOSEPH A GOLDBECK JR'~ _ 2841A MELLON INDEPENDENCE CENT 701 MARKET ST STE 5000 Ascent - MAC v7.50.7.70.J PHILADELPHIA, PA 19106 -- ---- -- --------------------------------------------------------- Piece ID Article i' Delivery Address -------- SS -------- Fee ---------- Postage --------------------------------------- Value Sender Charqes Addressee Name Type Insur./Register Due Total 85716T51-08 71114342363000734203 SNOOP, THOMAS A. C 2.80 0.44 4.34 5391 Molly Pitcher Highway ERR 1.10 Chambersburq, PA 17201 65716BS1-08 71119342363000734210 SNOOP, BETH A. C 2.80 0.49 9.34 5391 Molly Pitcher Highway ERR 1.10 Chambersburq, PA 17201 89601BM1-26 71119342363000734227 MORGAN, BRUCE C 2.60 0.44 4.34 6 Deerfield Drive ERR 1.10 .Moscow, PA 18449 64601BM1-26.0171114392363000734239 MORGAN, BRUCE C 2.80 0.49 4.34 125 Deerfield Drive L-4 ERR 1.10 ~ •. Moscow, PA 18444 76370MC3-03 71119342363000739241 CASSELL, MARTIN LESTER C 2.80 0.49 4.34 167 Beetem Hollow Road ERR 1.10 Newville, PA 17241 76310RC3-03 71114342363000734258 CASSELL, RACHELLE ELAINE C 2.60 0.99 4.34 167 Beetem Hollow Road ERR 1.10 r Newville, PA 1 7241 , 6~,r+ .~ •- i 802105N3-03 71114392363000734265 NULTON, STEPHEN U. C 2.80 133 Sunset Drive ERR 1.10 Mount Holly Springs, PA 17065 80210LN3-03 71114342363000734272 NULTON, COARSE A. C 2.80 133 Sunset Drive ERR 1.10 \ Mount Holly Springs, PA 17065 f C16/1!, 'i 0.49 f r.~ ~~~~ 1 r _~ ~_ ~ ` , / ~ 0.99 \\'~ `- # '~ 4.34 4.34 --------------------------------------------------------------------------------------------------------------------------------- Page Totals: 8 31.20 3.52 34.72 Cumulative Totals: 29 93.60 10.56 104.16 Page 3 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP; et seq. Plaintit'f (Petitioner) CASE and/or DOCKET No.: 09-5295 CIVIL TERM Sheri!'Cs Sale Date: 3!3/20!0 V. LORRIE A. NULTON ; et al. Defendant (Respondent) AFFIDAVIT OF SERVICE ~ Complaint ~E Sammons ~/_I Other: NOTICE OF SHERdFF'S SALE OF REAL PROPERTY [, RYAN MARKS, certify that 1 am eighteen years of age or older and that T am not a party to the action nor an empbyee nor relative of a party ,and that 1 served aad made known to the person served, LORRIE A. NULTON; ~ al. the above process on the ] 4 day of February, 2010, at 10:00 o'clock, PM, at 133 Suruei Drive Mount Holly Springs, PA 19065 ,County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: :~ By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dateshimes: 1) _. _... 2) .. -- . --- - .... __ .. _ . _. _...-- 3) ._...._ .. _ Commonwealth of Pennsylvania ) SS: Cowty of Cumberland ) Before me, the undersigned notary public, this day, personally, appeared ~v~(n,Y1 M(I Y`fC. S to me known, who being duly sworn according to l ,deposes the following: J 3 hereby swear or the facts set forth in the foregoing Affidavit of Service are true and correct. Subscribed and sworn to before me (Signatur+e of Affiant} this ~.3 day of 20~. File Number. 80210FC Notary Public CON7Ai0NWFigL F P~NNSY~VANL4 Tema A 1VO~rtal Seal 1Vas•'iisgtpn. ABrks COUttty H'Y CUailn155bri F-rryfrK DeG S, 2Q33 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANJA BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP; et seq. Plaintiff (Petitioner) CASE and/or DOCKET No.: 09-5295 CIVIL TERM ', Sheriffs Sale Date: 3/3/2010 V. LORRIE A. NULTON ; et al. Defendant (Respondent) AFFIDAVIT OF SERVICE Complaint ~Snmmons COther: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY i, RYAN MARKS, certify that 1 am eighteen years of age or older and that 1 am not a party to the action nor an employee nor relative of a party ,and that I served and made known to the person served, STEPHEN U. NULTON; ~ al. the above process on tfie 14 day of February, 2010, at 10:00 o'clock, PM, at 133 Sunset Drive Mount Holly Springs, PA 17065 ,County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: By posting a copy of We original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) -_...._.... _ . _._.....- --- 2) . . -----------. __---- 3) - - -- -- -__ -- Commonwealth of Pennsylvania ) SS: County of Cumberland ) Before me, the undersigned notary public, this day, personally, appeared ! "I,QX` ~-- S~ to me known, who being duly sworn according to law, deposes the following: 1 hereby swear or affi a facts set forth in the foregoing Affidavit of Service are true and correct. Subscribed and sworn to b fors me ( gnature of Affisnt) this ~ day of _~~~ 20 t'b File Number. 80210FC Notary Public -~o ~~-~+ ~lamv~luln Teresa A. t4lnzda, Notary Ptlbtk YYa_lifngton 7wrp., BerkS County ~"~ ~~~ ~PI-es Dec. 5, 2013 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTIi OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz January 29, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ,_ ! Lida Marie Coyne, F~itor :~.~ SWORN TO AND SUBSCRIBED before me this 29 day of January 2010 ~~;~ Notary NOTARUIL SEAL DEBORAH A CCLLINS Nefary PubSic CARLISLE BORO, CUMBERLAt~~D COUNN My Commission Expl~es Apr 28, 2010 CUMBERLAND LAW JOURNAL ACTIOII< OF 1HOIt1YI~A0E ]ErO]iECL09UL2E In the Court of Common Pleas of Cumberland County Civil Action-Law No. 09-5295 Civil Tam BAC HOME LOANS SERVICING, LP FI{A COUNTRYWIDE HOME LOANS SERVICING LP, 7105 Corporate Drive, PTX C 35, Plano, TX 75024, Plaintiff Va. LORRIE A. NULTON and STEPHEN U. NULTON, Mortgagors and Record Owners, 133 Sunset Drive, Mount Holly Springs, PA 17065, Defendants THIS LAW FIRM I3 A DEBT COL- LECTOR AND WE AREATTEMPTING TO COLLECT A DEBT. THi$ NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMA- TION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LORRIE A. NULTON and STE- PHEN U. NULTON, DEFENDANTS, whose last known address is 133 Sunset Drive, Mount Holly Springs, PA 17065. Your house at 133 Sunset Drive, Mount Holly Springs, PA 17065, ie scheduled to be sold at Sheriff's Sale on Wednesday, March 3, 2010, at 10:00 A.M., in Commissioners Hearing Rm., 2nd FL, Courthouse to enforce the court judgment of $221,842.45 obtafned by BAC HOME LOANS SERVICING, LP FICA COUN- TRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE To prevart this sheriff's sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, the ba~c payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at (215) 825-6329 or 1-866-413-2311. 2. You may be able to atop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to post- pone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You map need an attorney to assert your rights. The sooner you contact one, the more chance you wr71 have of stopping the safes (Set notice below on how to obtain an attomeyJ. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAI{E PLACE. 1. If the SheriB's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff at (717) 240-6390.2. You maybe able to peti- tion the Court to set aside the sale if the bid prix was grossly inadequate compared to the value of your prop- erty. 3. The sale will go through o if the buyer pays the Sheriff the ft~ll amount due in the sale. To fmd out if this has happened, you may call the Sheriff at {717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the propertq 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 CUMBERLAND LAW JOURNAL of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheri$'s Sale. Thin schedule witil.state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (rea- sons why the proposed distribution is wrong) are filed with the Sheriff within tea (10) days aRer the sched- ule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your hoax beak, if you act immediately after the sale. 8. You may contact the Foreclosure Resour« Center: http: / /www.philadelphiafed.org/ foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET IEQrAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 or MIDPENN LEGAL SERVICES 401 E. Loather St. Suite 103 Carlisle, PA 17013 {717) 243-9400 MICHAEL T. McKEEVER, ESQUIRTr GOLDBECK McCAFFERTY & McI~EVER, P.C. Attorneys for ~Plainti8' Suite 5000 Mellon Independence Cents 701 Market st. Philadelphia; PA 19106 (215) 825-6318 Jan. 29 10 l PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland fames Kleinklaus, I?irector of Sales and Marketing of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13~, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): January 27, 2010 COPY OF NOTICE OF PUBLICATION 'IN.THE OF s 4 ME LOgNERVI 't: 35, Plentf, TX 75024'i . bn3,13;i Sunset Oii~iv, Moon ~~q ~~W FIRM I A DEe~ T6vou~iw~~,' I t a. FOR THAI';PUl3pOg ' w RIE A. NULTOPI`~1id.'` , MQUnt Hotly Spring98a,. p _ se at t 33 Sunset Drive ~~ may. Mud~i.~0r~9,'.~2Q7~;ry .~~::l:~S:~' ~ ..~:f'NI.I.s.~Cj the ffi?rk.further deposes that he/she is not 1 ~;<.t - ..latter of the ~isement, and that ~'~ ?~:;oing statement as ~~~ ' «~ :er of publication ~~ ~"_ . .. .. ' f f ~4~g.3 '.IdCeever. Any. for Pfaigp~ t?! ~AFFERTY & Mr~l(~~{q~~; ' - . "~' .'* ;{ a;.u.t Greet ~Perttlence~en~la's~'_,. - .. .... - ,.-:mar., -.._.;; PA 19106 y ~{;~ ,~-~~ ~aK I .. PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tames IQeinklaus, Director of Sales and Marketing, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SEl\TITNEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13,18$1, since which date THE SENTIlVEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): January 27, 2010 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all aIlegations in the foregoing statement as to time, place and character of publication are true. ~ Sworn to and sub ed before me this ~~~ l0 ~~, ~ ~~~~ Notary Public My commission expires: cot~n+orswEacrri of ea~tisv~:~-:::: N07ARIAL SEAL I t?AMBI ANN HECKENDORN; Notay i''dt;~c Camp Hip Boro., Cumt>erl~d Coc:~-t• ( My Commission Expires January 21, ~1U j GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTXC35 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN U. NULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount Holly Springs, PA 17065 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5295 civil term AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 133 Sunset Drive Mount Holly Springs, PA 17065 1.Name and address of Owner(s) or Reputed Owner(s): LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 2. Name and address of Defendant(s) in the judgment: LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 STEPHEN U. NULTON 133 Sunset Drive Mount Holly Springs, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: CITIZENS BANK OF PA 1735 Market Street Philadelphia, PA 19103 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTSIOCCUPANTS 133 Sunset Drive Mount Holly Springs, PA 17065 (attach separate sheet if more space is needed) 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. DATED: March 1, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~. •: j-q ~-_ - ,' ^~r Jody S Smith Chief Deputy Edward L Schorpp Solicitor L ~~, , ",~, Zu~~ ~~'fiMAY t0 ~~ (t: ~u BAC Home Loans Servicing, LP Case Number vs. Lorrie A. Nulton (et al.) 2009-5295 SHERIFF'S RETURN OF SERVICE 01/14/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Lorrie A. Nulton and ,but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Lorrie A. Nulton, address provided is vacant, defendant did not leave a forwarding address with the post office. 01/14/2010 Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 12/22/09 at 2015 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 Lorrie A. Nulton and Stephen U. Nulton, located at, 133 Sunset Drive, Mount Holly Springs, Cumberland County, Pennsylvania according to law. 01/14/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Stephen U. Nulton and ,but was unable to locate him it his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Stephen U. Nulton, address provided is vacant, defendant did not leave a fonnrarding address with the post office. 03/01/2010 Property sale postponed to 4/7/2010. 04/07/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on April 7, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of, Fannie Mae, P.O. Box 650043, Dallas, TX, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $882.73 SHERIFF COST: $882.73 SO ANSWERS, May 10, 2010 RON R ANDERSON, SHERIFF ~l~-vU ~,,.~. C~ ~ ~G~> ~,l1. CcF. 5Z' ~~. ~,,.-,~ . ~~ Goldbeck It~cCafi'ei-ty & McKeeyer BY: Michael T. McKeever ,~ Attorney LD. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SI?KVICING LP 7105 Corparate Drive PTX C 35 Plano, TX 75021 Plaintiff vs. LORRIE A. NU ETON STEPI=IEN U. NULTON (Mortgagor(s) and Record Owner(s)) 133 Sunset Drive Mount Holly Springs. PA 17065 Defendant(s) No. 09-5295 civil term AFFIDA~'TT PURSUAN"h TO RULF. 3129 BAC HOME LOANS SERVICING. LP FKA COUNIRYW'IDE HOME- LOANS SERVICING LP. Plaintiff in the above action, by its attorney. ly~lichael ~I~. Iv~lcKeever, Fsyuire. sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 133 Sunset Urive 1~~lount Nol(v Springs. P;1 170(,3 I .Name and address of Owner(s) or Reputed O~~~ner(s): LORRIL ~~. NULTUN 133 Sunset Drive ~-bunt Nolly Springs. P1 1?063 STEPHEN U. Nt;'LI~ON 133 Sunset Drive Mount Holly Springs. PA 170(>i 2. Name and address of Defendant(s) in the judgment LORRIF. A. NUL"IY)N I33 Sunset Drive Mount Holly Springs, PA 1706> STEPHEN U. NLIL~IY)N 133 Sunset Drive Mount Holly Springs, PA 1706 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of CLUilberland County CIVIL. ACTION -LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RF,LATIONS OF CUMBERLAND COUN"PY PO Box 320 ~ • Carlisle. PA ] 7013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Ilea(th and Welfare Bldg. -Room 432 P.O. Box 2675 Ilarrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: CITIZENS BANK OF PA 1735 Market Street Philadelphia, PA 19103 5. Name and address of every other person who has any record interest in or record lien on the property and ~~-hose interest may be affected by the sale: 6. Name and address of e~~ery other person of whom the plaintiff has knowledge ~~~ho has any record interest in the property which may be affected by the sale. Z Name and address oi~everv other person of whom the plaintiff has knowledge ~~~ho has any interest in the property which may be affected by the sale. fEN:'1NfSiOCCUPAN"1 S 1>3 Sunset Drive 1~~lount I[olly Springs, PA 17065 (attach separate sheet if more space is needed) I verify that the statements made m this affidavit are true and correct to the st o my personal kno~~-]Edge or information and belief. 1 understand that false statements herein are made subject to he enalties of 1 R Pa. C.S. Section 4904 relating to unsworn F~~Isification to authorities. [)AI~EI~: October 16, ?O09 ~~OLDBfC ~ CAF ~I RI ' ~~ McKFE~'EI2 BY ~Iich~ ~1 ~f. h1c Kcc Esy. Attorney or Plaintiff r~ 09-5295 civil teen GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney LD.#56 (29 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff ~BAC HOME LOANS SERVICING, L.P FKA COUNTRYWIDE HOME LOANS SERVICING LP 710 Corporate Drive PTX C 3 Plano, TX 75024 Plaintiff vs. LORRIE A. NULTON STEPHEN IJ. rdULTON Mortgagor(s) and Record Owner(s) 133 Sunset Drive Mount IIolly Springs, PA 17065 Defendant(s) CIVIL ACTION -LAW ACT10N OF MORTGAGE FORECLOSURE Term No. 09-5295 civil tern? 7`HIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTE~~IPTING TO COLLECT A DEBT. THIS NO"TILE IS SENT TO ~'OU IN AN ATTE1vIPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROiVI YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIhF'S SALE OF REAL PROPERTY TO: NULTO~, LORRIL A. LORRIE A. NULTON 133 Sunset Drive Mount Holly Springs. PA 17065 Your house at 133 Sunset Drive, Mount Ho11y Springs, PA (7065 i~ scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at ]0:00 ,SM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $221,842.45 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU IvIAY BE ABLE TO PREVENT TFIIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County To prevent this Sheriffs Sale you must take immediate action: 09-5295 civil term 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING. LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments. late charges, costs and reasonable attorney's fees due. To find-out~how much you must pay call our office at 215-825-6329 or I-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3: You may also be able to stop the sale throu~~h other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on ho~~~ to obtain an attorney). YOU ih~IAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EDEN IF THE SHERIFF'S SALE DOTS NOT TAKE PLAC>/. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid rice was grossl p y inadequate compared to the value of your property. 3. The sale will go through on]y if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened. you may call the Sheriff of 717-240-6390. 4. If the amount due from Che 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 frill amount due is paid to the Sheriff and Che Sheriff gives a deed to the hover. At that time, the hover may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. 1-his schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You ma~~ also have other rights and defenses. or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: h'ttn:%i ~~~ww.philadelphiafed.ore/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN G>;T LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle. PA 17013 09-5295 civil tern 717-243-9400 09-529j civil teim Resources available for Homeowners in Foreclosure ACT NO~V! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified, attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counszling. 3). Visit HUD'S website ww~~~.hud.~ for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa ors/consumers/homeowners/real aspx. 51_ (Fall the P1aII.tlff ~}'Our lender] at and aS;; i0 Speak io Soiileorte abOiit LOSS Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll flee number at 1-866-413-231 1 or via email at homeretention~~oldbecklaw com. Call Seth at 215-825-6329 or fax 215-525-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of ourfirm's Homeowner Retention Department is David Fein who can be retched at 21 ~-525-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 50210FC. Para information en espanol puede communicarse con Loretta al 215-525-6344. ~L rho ~ollo~~ri.n~ desc.x~il~~d rna~ e~tat~ lyirc~ ~.rztz b~irg ~,~ k1,7.'lt~w x_3'1 ~oU~~ ~ic3c~1~l~~~l ~'c3N;'1~'th~~'i, C~1il~Ll~diic~ ~."i.rtat+.LYr P~'1'7SS~i~'1S:~I2~c~, 3Ylta::."~,' ~}~~"~1Ct1~.?li`7.,y c~e~~z'1b~3 ~3E7 ~C}1~C~T,~: ~~~`~z~2d~1V~' c"2~ ~. ~.1~'S:i.17~ f.~Tw' ~h~ Sdg1~P1~Z'~7 ~d.~~a~ +~~ &fkA~~ 1~.33~' O~ Surl~et ~-rive ~~ enx`~7.~r a~ I.,r~C ,? ~F1c'~ I..~f. ~~ ~n p~.an of its ae~~~ila~~ex a*.~.an~d; the^~:° ~~~ng the r33~,*idir._g line b~~Cwee~ sairi ].oi:~, t~at3a ~ rl,ec~re~:~ ~3 ~n~.FtxC.~s ~~ ~~nor~ds west 13C _ 1.6 ~~~~ toa ~giilt; chance ~I~~1~ ~:~~~ ai^~a.c~.r1g Ii:n~ ~~~weez~ T.,~r ~~ and, Lnt 5Q, ~i~r~:.2~ 8~ de~r~es ~~ m»~~1ut~~ ~~ ~G:~~71Gi~ Wes: 2E~.53 f~~t cc~ ~. pc~.int; th.~rnc~: ~1.r~ng t:f~e ditiidn ling k~tween, i~caG 5G ~~ad Kok. ~1, ~foi:~:n 8C Ca~E'~1:ALS .'~ tit131U~;G'~ ' 3~ €;f'i.~1Z£~F, ~7P~~~ ~()~ .9 % 1~BE~?.~ ~~ ~ ~~ixit; XPaeixce a~ 031 chm ~ta~zth~~n rzghv ~~ way 1.ir1e ~~ S~~.r35~L. ~3-i~r~ ~?~ ~ ~~ z~ try r.~.gY1~. Y1s~.rirlg' a r~.t3ius ~,w X75 !'~~~`, hil ~Y'C -Fng~h ~~ X02.92 w,r?Ch ~ chc~*_'d ~~~~"~I3t~ ~v'bit~ 5~ d~gx~~~~ .19 R~a.rri~tes 3 se~G»1C~S West 3.91. ~g ,~;,atyt La a ~acs~.nz end ~.s.a~~ n~ :~?~"~7.si1~~1t13~, cflnta:f~nia~t 0.~'~#i~ aux~e. BEING THE SAME PREMISES BY DEED FROM RINE LAND DEVELOPMENT, INC., A PENNSYLVANIA CORPORATION DATED 09/15/2005 AND RECORDED I O110/2005 IN BOOK 27l PAGE 1910. GRANTED AND CONVEYED UNTO STEPHEN U. NULTON AND LORRIE A. NUL"1,ON, HIS WIFE. TAX PARCEL NO: 40-31-2 l S9- 107 BEING KNOWN AS 133 SUNSET DRIVE, MOUNT HOLLY SPRINGS PA 1706> i' GOLDBECK N1cC:~FFERTY & ivTcKEEVER BY: Michael T. McKeever ' Attorney LD'.~56129 Suite X000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTXC3> Plano, TX 75024 Plaintift~ vs. LORRIE A. NULTON STEPHEN u. NuLT ON Mortgagor(s) and Record Owner(s) 133 Sunset Drive MOLInI Holly Springs, PA 17065 Defendant(s) Teizn No. 09-529 civil term THIS LAW FIRIVI IS A DEBT COLLECTOR .=1ND WE ARE ATTE11~1NTING TO COLLECT A DEBT. THIS NOTICE IS :SENT TO ~'OU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBT:1lNED FROM YOU WILL BE USED FOR THAI` PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NULTON. ST~PFIFN U. STEPHEN U. NULTON 133 Sunset Drive Mount I-lolly Springs, PA 17065 Your house at 133 Sunset Drive, Mount Holly Springs, PA 1706 is scheduled to be sold at Sheriffs Sale on Wednesday, I~larch 03, 2010, at 10:00 Aid-I, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court jud~~rnent of $221.842.45 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SFIZVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SOLE 09-5295 civil ten~n of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriff's Sale you must take immediate action: 09-5295 civil term 1. The sale will be cancelled if you pay to BAC HO_NIE LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP. the back payments, late charges, costs and reasonable attorney's fees due'. To Lind out how much you must pay call our office at 215-825-6329 or I-866-413- 231 L ?. You may be able to stop the sale by tiling a petition asking the Court to strike or open 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 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance v_ ou will have of stopping die sale. (See notice below on hoer to obtain an attorney). YOCt NIAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU Hr1VE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT 'TAKE PUCE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You ma_v find out die price bid price by calling the Sheriffof717-2-10-6390. 2. You Holy be able to petition the Court to set aside the sale if die bid price was crossly inadequate compared to the ~~alue of your property. 3. The sale ~~-ill go through only if the hover pays the Sheriff the fiill amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due fiom the Buyer is not paid to die Sheriff. you will remain the o~~mer of the property as if die sale never happened. 5. You have a riuht 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 drat time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money ~-vhich was paid for your house. A schedule of distribution of the money bid for your house will be tiled by the Sheriff within thirty (30) days Isom the date of the Sheriff's Sale. This schedule will state who ~~iil be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are tiled with the Sheriff within ten (10) days after die schedule of distribution is Bled. %. 1'ou ^u1v also have other rights and defenses. or ways oFgetting your house back. if you act immediately after the sale. 8. Yon may contact the Foreclosure Resource Center: http:i/~,vww.phi]adelphiafed.or~=rforeclosur~% YOU SHOULD FAKE THIS PAPER TO YOUR L.A~~tYLR AT ONCE. IF YOU DO NOT IIAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA ] 7013 09-5295 civil teen 717-2=13-9400' 09-5295 civil term Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage I=oreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a,qualified attorney call either~of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at I-800-959-2227 for free counseling. 3). Visit HUD'S website www.hud.~ for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.or~/consumers/homeowners/real aspx. ~ j. Caii tii% Diainiiff ~y0ilr lender) al arld ask iV speak `tO JVllleolle abUlll Lots Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention ~L~oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Deparhnent is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 80210FC. Para informacion en espanol puede eommunicarse con Loretta al 215-825-6344. ~L C'z~ ~p~~.Q?n*~,.11,v^, ~~StCY'1~@u Z'~c3~ E?,''iLFC"iL? ~.~r1T:~ c3.7"~C:~ ~~3T3.c~ ~'.?.tu+~yfii ~ou•t=~ ~i.!•3t~.1.tY"~'1 ~'.Z+„rwiwh~.~r L'L3tYE~i•!`1'?d.1~~ ~.'~,1uaiLYt Pen.r~~yi~.°ania, wawa partici~l.~r1,y c~e~crb~ as ~oilaws csF;C-:t3+II~2N~; ~4 ~. ~r,~,nt ~~ the S~t3uth~ ~~.g'rt ~~ k7Ftt7 lira cif ~ttTi~~tJT'I.V{-' ~~ COZ2),ET t)L ?,,rjL. ~ ~ ~F1t~ L.>c)t s'? s~I7 p~.~i3 t~~ ~at~ :~~:~~ix~a~~~:~ me~~~ant~d; r..h~~•^~ ~1~~~ ~kae dit~*zdirg 1~ne b~,~~een 3'~1.d 1.rst~, Saat~ ~ r~~cr~'e~:~ ?3 m.~z:ut.~~ 45 s~caud~ w~~t 13~ _ ~7.t; f~~~ to ~ paim~; thez~~z ~.lc~nc~ r_.~za ai~'a.di.~g Ii~~ ~+~~:~~~xa I,+~t ~~ ~z~~ ~~ 5f?, ~or~.t~ $~ ~~gr~~s ?~ til„1,33t1~~~ 1~ E~~G~Y1C~ WE?S~ 2E~.53 ~E'~t CCU ~. pC}~7,1~; ~:~1~T1C~ ~1.c~n~ t:hp ditiid~.~~ lin.~ ~b~tae~n ter 5G 3~d 1vc~G W1, i+Forth ~~ ~~~r~~s ~~ ~t~inu`e~ ~;5 £;ni.C~t2fi ~e~w 1(~6.~7 lea: ~c~ ~~~nL, r.1~~~re c'~C+l~ the st~uth~zr~ right a~ xa~.y l~rz~ at sY~:ns~r~riv'~ ~~ ~ ~.~~,~ ~a tt~ r.~.glxt tai ~rirzg ~ r~.dius a ?5 re~~, ~ arc-~ngts ax x(32.92 x+-~th ~ ch~s°~d ~~~!~zrsc? i.€3I'~iZ~~'+.% G~~~.;'f?~J~a ~~ [T3µ.I,1~<tGat3 j r3PCUXIC~S x$~a~ .'~~? ~ ~4 a:+^t~~ L°C~ racj~rt end z~~.a~r ~~ .~~Q~L3:?i129, ~c~nta:i_ni}~t t~.: ~G~ ~cx~. BEING THE SAME PREMISES BY DEED FROM RIME LAND DEVELOPMENT, INC., A PENNSYLVANIA CORPORATION DATED 09/15/2005 AND RECORDED 10/10/200 IN BOOK 271 PAGE 1910. GRANTED AND CONVEYED UNTO STEPHEN U. NULTON AND LORRIE A. NULTON, HIS WIFE. TAX PARCEL NO: 40-31-2189-] 07 BEING KNOWN AS 133 SUNSET' DRIVE, MOUNT HOLLY SPRINGS PA 17065 - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH O~ PEI~P~SYLVANIA) NO 09-5295 Civil COUNTY OF CUMBERLAND) 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 LORRIE A. NULTON STEPHEN U. NULTON (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 $221,842.45 L.L. $.50 Interest from 10/17/09 to Date of Sale per diem at $33.85 -- to be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $251.60 Other Costs Plaintiff Paid Date: 10/20/09 n -` - f~ l.,(,(.tv-c,~ f~- Curt R. Long, Prothono ary (Seal) gy; ~, Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDE NCE CENTER 70l MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone : 215-627-1322 Supreme Court ID No. 56129 On November 5, 2009 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as 133 Sunset Drive, Mount Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 5, 2009 By: Real Estate Coordinator _>,t '~~. ^. {'.:e ., ~ ,y , c 1;~1~ ~~ ~Y/ ~".~~. U~t PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22 January 29 and February 5 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Coyne, SVt~6~N TO AND SUBSCRIBED before me this 5 day of February. 2010 Notary / ~~ GE;;C?7.~'~ti ~ CGI.LINS n Na1ar~ Puhllc CARLISLE GORO, CL:h~i~~~nU'S,'L} COUPJif My Commis~cn ~xcires F.,~r 2$, 2010 Writ No. 2 09 250 25 95 civil BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP vs. Lorrie A. Nulton Stephen U. Nulton Atty; Michael McKeever ALL THE FOLLOWING described real estate lying and being situate in South Middleton Township, Cum- berland County, Pennsylvania, more particularly described as follows: BEGINNING at a point on the southern right of way line of Sunset Drive at corner of Lot 51 and Lot 52 on plan of lots hereinafter mentioned; thence along the dividing line be- tween said lots, South 9 degrees 33 minutes 45 seconds West 136.16 feet to a point; thence along the dividing line between Lot 49 and Lot 50, North 80 degrees 26 minutes 15 seconds West 28.53 feet to a point; thence along the dividing line between Lot 50 and Lot 51, North 90 degrees 26 minutes 15 seconds West 106.47 feet to a point; thence along the southern right of way line of Sunset Drive by a curve to the right having a radius of 175 feet, an arc length of 202.92 with a chord bearing North 54 degrees 19 minutes 3 seconds West 191.74 feet to a point and place of beginning I containing 0.2964 acre. BEING THE SAME PREMISES by deed from Rine Land Development, Inc., a Pennsylvania Corporation dated 09/ 15/2005 and recorded 10/ 10/2005 in Book 271 Page 1910. Granted and conveyed unto Stephen U. Nulton and Lorrie A. Nulton, his wife. TAX PARCEL NO: 40-31-2189- 107. BEING KNOWN AS 133 SUNSET DRIVE, MOUNT HOLLY SPRINGS PA 17065. PROPERTY ADDRESS: 133 Sun- set Drive, Mount Holly Springs, PA 17065. UPl# --- the Patriot-~IVews Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c~he ~latriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /22/10 01 /29/10 ~~ ~ , ~ 02/05/10 ~~~;~ Swo n to an u scribed before Je is ~ d r~ y of February, 2010 A.D. t ~ ~ ~ ~ ~' i!~ . _ Notary Public ^' COMMONWEgLTp~ OF pEWNSYLVAWIA Nata------ ~ S--_._ Sherrie L. Kigner, N~Py Public ~ ~'~ u~, Dauphin Cou Expires Nov. 2fi, 20 1 Member, Pennsylvania Association of Notaries pocket Number: 2009-5295 Clvl~ Term r, ~ ~C Home Loans Servlcfng, Ld, A FiiVA Countrywide Home Loan~"A Servicing, LP ~ a Vs. ;u Louie A. Nulton Stephep U. Nulton xy Atty: Michael, McK~ever ~T ALL THE FOLLOWING DESCRIBED REAL ESTATE LYING AND BEING SITUATE IN SOUTH MIDDLETON TOWNSHIP CUMBERLAND' COU~ITY~,~ PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING at, a point on the southern right of way line of Sunset Drive at comet of Lot 51 andl Lot 52 on plan of lots hereinafter mentioned; thence along the dividing line between said lots, South 9 degrees 33 minutes 45 seconds West 136.16 feet to a point; thence along the dividin line between Lot 49 and Lot 50, North 8~ degrees 26 minutes 15 seconds West 28.53 feeiB to a ,point; thence along the dividing lin between Lot 50 and Lot 51, Noith 90 degrees 2 minutes 15 seconds West 106.47 feet to a pomt;,~ thence along the southern right of way line o~l Sunset Drive by a curve to the right having aC radius of 175 feet; an azc length of 202.92 wrth ~. chord bearing North 54 degrees'19 minutes 3 seconds West 191.74 feet to a point, and place beginning I containing 0.2960. aae.. BEIN .y THE SAME PREMISES BY DEED FROIv~, RIME. LAND DEVELOPMENT, INC., AEI PENNSYLVANIA CORPORATION DATED 09/15f2005 AND RECORDED lO/1Of2005_11N't BOOK 271 PAGE 1910. GRANTED ANUa CONVEYED UNTO STEPHEN 1J. NULTOIV' AND LORRIE A. NULTON, HIS WIFE. TA7~ PARCEL NOi40-31-2189-107. BEING KNOWN AS 133 SUNSET DRIVE MOUNT HOLLY SPRINGS PA 17065 ~ PROPERTY ADDRESS:. 133 Sunset Drive; Mount Holly Springs, PA 17065 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which FANNIE MAE is the grantee the same having been sold to said grantee on the 7TH day of APRIL A.D., 2010, under and by virtue of a writ Execution issued on the 20TH day of OCT, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 5295, at the suit of BAC HOME LOANS SERVICING LP against LORRIE A NULTON & STEPHEN U is duly recorded as Instrument Number 201011847. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~~ ~~' day of r ~, ~ `~ ~"' ` ~ l~ ~~ .,~. ~ f , -~ ecorder of Deeds '' ~ ~" ~L Re°°rdercr e, a.M,e~,aCanM ~a PA ~_ f ~:" .':l~~, ~+1Y Expbss tbs Fist librrley d Jsa 2014 -- +~at i~3 c` cv