HomeMy WebLinkAbout09-7320,GOLI)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 F/K/A
COUNTRYWIDE HOME LOANS SERVICING LP
7105 Corporate Drive
PTX C-35
Plano, TX 75024 Plaintiff
vs.
AMY C. QUINN
MATTHEW T. QUINN
Mortgagors and Record Owners
2175 Newville Road
Carlisle, PA 17015
Defendants
Term
No. 04 - r1.3a0 C tiV,t l
CIVIL ACTION: MQfiTGAGE Farm
FGRECLC8URE
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
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
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
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
DEMANDA.
' RECUERDE: 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
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: 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 ho://www. hp fa.org,/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http://www.philadelphiafed.orglforeclosure/
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(aDgoldbecklaw.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 8821717C.
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 F/K/A COUNTRYWIDE HOME LOANS
SERVICING LP, 7105 Corporate Drive, PTX C-35 Plano, TX 75024.
2. The names and addresses of the Defendants are AMY C. QUINN, 2706 Turner Street, Apartment 4,
Fairbanks, AK 99701 and MATTHEW T. QUINN, 1460 Market Street, Fairbanks, AK 99709, who are
the mortgagors and record owners of the mortgaged premises hereinafter described.
3. On January 04, 2007 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS
NOMINEE FOR ARK-LA-TEX FINANCIAL SERVICES, LLC, which mortgage is recorded in the
Office of the Recorder of Deeds of Cumberland County as Book#:1978, Page 4488. The mortgage has
been assigned to: BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS
SERVICING LP by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase
or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to
Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course
of business. 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 ..................................................................................$126,657.00
Interest from 11/01/2008 through 09/15/2009 at 7.0000% .......................$7,748.50
Per Diem interest rate at $24.29
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$6,332.85
Late Charges from 12/01/2008 to 09/15/2009 .............................................$413.59
Monthly late charge amount at $41.36
Costs of suit and Title Search ...................................................................... $900.00
Monthly Escrow amount $174.29
$142,051.94
7. If the Mortgage is reinstated prior to a Sheriffs 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 personam" 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 Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $142,051.94,
together with interest at the rate of $24.29, 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: Lhdv-rPr. bwgAj
GOLDBECK McC FFERTY & MCKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Tiaquanda Tumer , 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: DC 1 0 .9 2009
#88217FC - AMY C. QUINN and MATTHEW T. QUINN
2175 Newville Road Carlisle, PA 17015
E.rihibitA
CTA0750
ALL the blowing described real astale, Iytng and being albude in the V pe of West
HM, West Parawboro Township, GwribwkW County, Commonwr a of Pennsylvania,
bounded and described as faltoww.
BEGINNING at a point in the cerMsr of the pubic road leading *mn CwIIMe ID Newvile
at toner of Isnd raw or ihmhehly of Waller W. 8buflsr and wits; thence along said WW.
North 03 degrees 40 minutes F_aet, 203.8 feat, rtpro or ides, to a etatwa: therms slang
land now or farmarly of S.H. Deft acrd wft South 86 degrees 30 nrinules west, 100
feet to a stake: thence Wong the ewe, Sohtlh 03 degrees 40 minules West. 203A teal.
more or lass, to a point in the censer of said public roast thence song the comes of laid
pubic road in an esgwterly direction, 100 feat to a point, the piece of bagir> ft.
BEING inhproaved with a dwaNfng house known and nurberad as 2175 Nam ft Road.
Carisie, Pennsy MkL
Exhibit (B
ACT 91 NOTICE
DATE OF NOTICE: 09/18/2009
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 in
the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP)ay be
able to help 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 A enc.
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 anjr questions, you may call the
Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired
hearing can call (717) 780-1869.1
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: 09/18/2009
Homeowners Name: AMY C. QUINN and MATTHEW T. QUINN
Property Address: 2175 Newville Road, Carlisle, PA 17015
Loan Account No.: 148057248
Original Lender: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING
SOLELY AS NOMINEE FOR ARK-LA-TEX FINANCIAL SERVICES, LLC
Current Lender/Servicer: BAC 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
MORMATION PURPOSES ONLY AND SHOULD' NOT BE CANSWERED AS AN
ATTEMPT TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for
Emergency Mortgage Assistanm)
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: 2175 Newville Road, Carlisle, PA 17015 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 12/01/2008 thru 09/18/2009
(10 mos. at $1,033.99/month) $10,339.90
(b) Late charges from 12/01/2008 thru 09/18/2009
(10 mos. at $41.36/month) $413.60
(c) Other charges; Escrow, Inspec., NSF Checks
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $10,753.50
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 $10,753.50, 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
BAC HOME LOANS SERVICING LP
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 an itme 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 mortaaae. 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: BAC HOME LOANS SERVICING LP
Address: 7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Phone Number: 972-526-6000
Fax Number: 817-230-6811
Contact Person: Christina Squires
Email: PHFA.Program@bankofamerica.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.
BEHALF.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
* 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: Christina Squires
Phone Number: 972-526-6000
HEMAP Consumer Credit Counseling Agencies
Report last updated: 9/1/2009 8:42:35 AM
CCCS of Northeastern PA
401 Laurel Street
Pittston, PA 18640
570.602.2227
800.922.9537
CRAWFORD County
Booker T. Washington 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
888.511.2227 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 Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
DAUPHIN County
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc.
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
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
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Community Action Commission of Captial Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
Acorn Housing Corporation
846 North Broad Street
Philadelphia, PA 19130
215.765.1221
Advocates for Financial Independence
202 East Hinkley Avenue
Ridley Park, PA 19078
215.389.2810
American Credit Counseling Institute
526-528 Dekalb Street
Norristown, PA 19401
610.971.2210
888.212.6741
Page 8 of 21
O
OF THE
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2119 OCT 23 !M 12: f
*,I8. So Po ATM
Ct4t 502(v48
es4 a325o4
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.
Amy C. Quinn
~~a~~t, rt~/,ttt~
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t
Case Number
2009-7320
SHERIFF'S RETURN OF SERVICE
11/13/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Matthew T. Quinn, 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 Matthew T. Quinn. Request for service at 2175 Newville Road Carlisle, PA 17015 is vacant.
The Carlisle Postmaster has advised Matthew T. Quinn has moved and left no forwarding address. An
exact address is not available.
11/13/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Amy C. Quinn, but was unable to locate her in his
bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Amy C. Quinn. Request for service at 2175 Newville Road Carlisle, PA 17015 is vacant. The
Carlisle Postmaster has advised Amy C. Quinn has moved and left no forwarding address. An exact
address is not available.
SHERIFF COST: $59.40
November 13, 2009
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
~- ~ ~,: ~ ', ~'l
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SO ANSWERS,
__
,.. ~::~
_~
r''
R THOMAS KLINE, SHERIFF
t.ci Cnu:~?ty5uite Sner~fi. i~eieosaft. In.c.
SWERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson '~ ~ i:,-~, -
~~y~nct~ nt ~um6r~f~~~~
Jody S Smith ,
Chief Deputy e- ~ ti, ~ ~ , 4 ~ i ~ -, ' ~ ~ ~ ~ „~
~'~~ qm Joao
Richard W Stewart
Solicitor ~~~ G ~ F -~~_ ;~;:~~~~ G~ ~ :-c s~
f! .. .__,',;.L.
BAC Home Loans Servicing, LP
vs.
Amy C. Quinn (et al.)
Case Number
2009-7320
SHERIFF'S RETURN OF SERVICE
04/05/2010 04:55 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 5,
2010 at 1650 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 Amy C. Quinn & Matthew T. Quinn, located at 2175
Newville Road, Carlisle, Cumberland County, Pennsylvania according to law.
04/05/2010 04:55 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 5,
2010 at 1650 hours, he posted a true copy, Pursuant to Court Order, of the within Real Estate Writ,
Notice, Poster and Description, in the above entitled action, upon the property of Matthew T. Quinn,
located at 2175 Newville Road, Carlisle, Cumberland County, Pennsylvania according to law
06/03/2010 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 June 2, 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 Secretary of Veterans
Affairs, 2375 N. Glenville Drive, Building B, Mail Code: TX2-983-01-01, Richardson, TX 75082, being the,
buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 904.30
SHERIFF COST: $904.30 SO ANSWERS,
June 30, 2010 RON R ANDERSON, SHERIFF
a -Dl~ Pd . Co.
s ~ ~- ,~~
~~ 7~d~
{c) Gou,tiy5uite 57en`4_ Telaas~ft. 1r;c.
Goldbeck NtcCafferty° & McKeever
BY: Michael T.~McKeever
Attorney LD. #56129
Suite 5000 Mellon Independence Center
701 Market Street
Philadelphia, PA ]9106
215-627-1322
Attorney for Plaintiff
BAC HOME LOANS SERVICING, LP F/K/A
COUNTRYWIDE HOME LOANS SERVICING LP
7105 Corporate Drive
PTX C-35
Plano_ "TX 75024
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
AMY C. QUINN
CIVIL ACTION -LAW
MATTHEW T. Qt1INN ACTION OF MORTGAGE FORECLOSURE
(Mortgagor(s) and Record Owner(s))
2175 Newville Road
Carlisle, PA 17015
Defendant(s) ~ No. 09-7320
AFFIDAVIT PURSUANT TO RULE 3129
BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiffin 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 Hmit of execution was filed the following information concerning the real property located at:
2175 Newville Road
Carlisle, PA 17015
1.Name and address of Owner(s) or Reputed Owner(s):
AMY C. QU1NN
2706 Turner Street
Apartment 4
Fairbanks, AK 99701
MATTHEW T. QUINN
2175 Newville Road
Carlisle, PA 17015
2. Name and address of Defendant(s) in the judgment:
AMY C. QUINN
2706 Turner Street
Apartment 4
Fairbanks, AK 99701
MATTHEW T. QUINN
2175 Newville Road
Carlisle, PA 17015
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
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O. Box 2675
Harrisburg, PA 1 7 1 05-2675
4. Name and address of the last recorded holder of every mortgage of record:
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.
TENANTS/OCCUPANTS
2175 Newville Road
Carlisle, PA 17015
(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 2, 2010 j~ -
~_.
GOLD K McCAFFERTY & McKEEV
BY: Barb Hand
~'
09-7320 ~~
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney LD.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA (9106
215-825-6318
Attorney for Plaintiff
BAC HOME LOANS SERVICING, LP F/K/A
COUNTRYWIDE HOME LOANS SERVICING LP
7105 Corporate Drive
PTX C-35
Plano, TX 75024
Plaintiff
vs.
AMY C. QUINN
MATTHEW T. QUINN
Mortgagor(s) and Record Owner(s)
2175 Newville Road
Carlisle, PA 17015
Defendant(s)
Term
No. 09-7320
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: QUINN, AMY C.
AMY C. QUINN
2706 Turner Street
Apartment 4
Fairbanks, AK 99701
Your house at 2175 Newville Road, Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $147,450.85 obtained by BAC HOME LOANS SERVICING, LP F/K/A
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
CIVIL AC1'lON -LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
oy-7~?o
1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FlK/A
COUN'CRY WIDE 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 2l 5-825-6329 or 1-866-4 U-
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 properly 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. 1 f 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 iri 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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
09-7320
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
http://www.nhfa.or~/consumers/homeowners/real aux.
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 homeretentionna 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 88217FC.
Para informacion en espanol puede communicarse con Loretta al 2 ] 5-825-6344.
ALL the following described real estate, lying and being situate in the Village of West Hill, West
Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, bounded and described as
follows:
BEGINNING at a point in the center of the public road leading from Carlisle to Newville at corner of land
now or formerly of Walter W. Stouffer and wife; thence along said land, North 03 degrees 40 minutes East.
203.6 feet, more or less, to a stake; thence along land now or formerly of S.H. Deitch and wife, South 85
degrees 30 minutes West, 100 feet to a stake; thence along the same, South 03 degrees 40 minutes West,
203.6 feet, more or less, to a point in the center of said public road; thence along the center of said public
road in an easterly direction, 100 feet to a point, the place of beginning.
BEING improved with a dwelling house known and numbered as 2175 Newville Road, Carlisle.
Pennsylvania.
BEING the same premises which Bargain & Sale Deed, dated 01/04/2007, given by Raymond L. Landis,
widower by Robert L. Landis, his agent duly constituted by Power of Attorney for real Estate Transaction
to be recorded immediately prior to the recording of this Deed and Robert L. Landis, joined by Darlene J.
Landis, his wife to Matthew T. Quinn and Amy C. Quinn, husband and wife and recorded 1 /9/2007 in
Book 278
Page 1614 Instrument # 2007-001006
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 2175 Newville Road
Carlisle, PA 17015
WEST PENNSBORO TOWNSHIP
SOLD as the property of AMY C. QUINN and MATTHEW T. QUINN
TAX PARCEL #46-18-1400-007
l
i.
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney ].D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
09-7320
BAC HOML LOANS SERVICING, LP F/K/A
COUNTRYWIDE HOME LOANS SERVICING LP
7105 Corporate Drive
PTX C- 35
Plano, l~X 75024
Plaintiff
vs.
AMY C. QUINN
MATTHEW T. QUINN
Mortgagor(s) and Record Owner(s)
2175 Newville Road
Carlisle, PA 170] 5
Defendant(s)
Term
No. 09-7320
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: Ql1INN, MATTHEW T.
MATTHEW T. QUINN
2175 Newville Road
Carlisle, PA 17015
Your house at 2 ] 75 Newville Road, Carlisle, PA 17015 is scheduled to be sold at Sheriffs Sale on
Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the
court judgment of $147,450.85 obtained by BAC HOME LOANS SERVICING, LP F/K/A
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
CIVIL ACTION -LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
f
U9-7~~~
1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FIKIA
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: htt~://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.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
09-7320
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
http://www.phfa.or~/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 2l 5-825-6429. 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 88217FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
ALL the following described real estate, lying and being situate in the Village of West Hill, West
Pennsboro Township, Cumberland County, Commomvealth of Pennsylvania, bounded and described as
follows:
BEGINNING at a point in the center of the public road leading from Carlisle to Newville at corner of land
now or formerly of Walter W. Stouffer and wife; thence along said land, North 03 degrees 40 minutes East,
203.6 feet, more or less, to a stake; thence along land now or formerly of S.H. Deitch and wife, South 85
degrees 30 minutes West, ] 00 feet to a stake; thence along the same, South 03 degrees 40 minutes West,
203.6 feet, more or less, to a point in the center of said public road; thence along the center of said public
road in an easterly direction. 100 feet to a point, the place of beginning.
BEING improved with a dwelling house known and numbered as 2175 Newville Road, Carlisle,
Pennsylvania.
BEING the same premises which Bargain & Sale Deed, dated 0]/04/2007, given by Raymond L. Landis,
widower by Robert L. Landis, his agent duly constituted by Power of Attorney for real Estate Transaction
to be recorded immediately prior to the recording of this Deed and Robert L. Landis, joined by Darlene J.
Landis, his wife to Matthew T. Quinn and Amy C. Quinn, husband and wife and recorded 1/9/2007 in
Book 278
Page 1614 Instrument # 2007-001006
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 2175 Newville Road
Carlisle, PA 17015
WEST PENNSBORO 'TOWNSHIP
SOLD as the property of AMY C. QUINN and MATTHEW T. QUINN
TAX PARCEL #46-18-1400-007
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) N009-7320 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/k/a Countrywide Home
Loans Servicing LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff (s)
From Amy C. Quinn
Matthew T. Quinn
(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 $147450.85 L.L. $.50
Interest from 3/4/2010 to Date of Sale per diem at $24.29
Atty's Comm % Due Prothy $2.00
Atty Paid $231.30 Other Costs
Plaintiff Paid
Date: 3/5/2010
~~
David D. Buell, Prothon tart'
(Seal) gy;
REQUESTING PARTY:
Deputy
Name David Fein, Esq.
Address: Goldbeck McCafferty & McKeever
Suite 5000 -Mellon Independence Center
701 Market St.
Philadelphia, PA 19106
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court ID No. 82628
On March 22, 2010 the Sheriff levied upon the
defendant's interest in the real property situated in
West Pennsboro Township, Cumberland County, PA,
Known and numbered as, 2175 Newville Road, Carlisle,
more fully described on Exhibit "A" filed with this writ and
by this reference incorporated herein.
Date: March 22, 2010
By:
rnz~-4~L~Q(_
Real Estate Coordinator
Z..
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 16, Apri123, and Apri130, 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.
sa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
30 da of Aril 2010
L~• ~
Notary
.....
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBEALAND COUNTY
My Commission Expires Apr 28, 2014
qHt I(o. 9009-7390 Civil
PAC Home Loans Servicing,
LP F/K/A Countrywide
Home Loans Servicing, LP
vs.
Amy C. Quinn
Matthew T. Quinn
Atty: Michael McKeever
ALL the following described real
estate, lying and being situate in the
Village of West Hill, West Pennsboro
Township, Cumberland County,
Commonwealth of Pennsylvania,
bounded and described as follows:
BEGINNING at a point in the cen-
ter of the public road leading from
Carlisle to Newville at corner of land
now or formerly of Walter W. Stouffer
and wife; thence along said land,
North 03 degrees 40 minutes East,
203.6 feet, more or less, to a stake;
thence along lard now or formerly
of S.H. Deitch and wife. South 85
degrees 30 minutes West, 100 feet
to a stake; thence along the same,
South 03 degrees 40 minutes West,
203.6 feet, more or less, to a point in
the center of said public road; thence
along the center of said public road
in an easterly direction, 100 feet to a
point, the place of beginning.
BEING improved with a dwell-
ing house known and numbered as
2175 Newville Road, Carlisle, Penn-
sylvania.
BEING the same premises
which Bargain & Sale Deed, dated
01/04/2007, given by Raymond L.
Landis, widower by Robert L. Landis,
his agent duly constituted by Power
of Attorney for real Estate Transac-
tion to be recorded immediately prior
to the recording of this Deed and
Robert L. Landis, joined by Darlene
J. Landis, his wife to Matthew T.
Quinn and Amy C. Quinn, husband
and wife and recorded 1/9/2007 in
Book 278
Page 1614 Instrument # 2007-
001006
IMPROVEMENTS consist of a
residential dwelling.
BEING PREMISES: 2175 Newville
Road, Carlisle, PA 17015, WEST
PENNSBORO TOWNSHIP.
SOLD as the property of AMY C.
QUINN and MATTHEW T. QUINN.
TAX PARCEL #46-18-1400-007.
-"The Patriot-News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
c'~I~e~lahiot 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
. -. /~ 4 /~ // . .1l .
This ad ran on the date(s) shown below:
Sworn to and Stab~ribed before me
Notary
04/16110
04/23/10
04/30/10
2010 A. D.
COMM6NWPJ1 '1'H, AF INNS LVANU
Nota~l SNI
Sherrie L. KIN1M, Notary Publk
Lower Paxton TvVp., Dauphin County
My Comml~lon Explr~u Nov, 26, 2011
Member, Penns/Manla Assoclatlon of Notaries
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ALL tLe follaring desc:ribod real auate, lying,T
and.being situate in the Yillage,of West T~T11,H;~
West i?eansboro 7bwrnsdip, Cumberltmd Cou~yq;
Comma-wealth o~`pemayI~ania, bounded a4d~, a
dascdbed as followsi ~ILI
BF.6@1NING ~ a poim m ~e ' ~'tlte pultlic «s
road 1Wdiog from Catdiak uo,Hewvitle si camaC Z
of litp~now orfa~rlypR! $tou~rat~i.!
wifie; tlxnce alo®g srd lm~.d, North 03 degree 4f~~,;
minotes,East, 293.6 feet; mare a less, to a stnlor,t.~f
t}u;nce atggg landnow otfY of S.H. Deitch;ia
and wife. South, 85 ,degrees 36 minutes Weat,~,i
100. , ~~
feet to a state; thaxe sloog the same, SotRh, 03.T 0
degiees 40 minutes Wes{, 203;6. feet, more or,~A
less, tq a point iB ire center of saxl pablic cA
thence a~Ong the center of said,;road ip Ory,-~ ,
easterly ditecbon, ltp~foet to a~~oint,'~ p~'ntl
ofbegimring. l
BEfNI'3' fm~red with a dwdriag bo~ae #npwn 1;~,
andtuiuotwred ~ 2i75 I~evvville~Road, Catl~le,~~~
BEl?~thesam~' wbicbBatgstln & Se{a~T
A~~.o~ed~j,jdid 01~1V?007, given by Lr r•i
1.61R~i~ ~ bjrRobat J~ l.aa~hsf ~~A4)
duly COnattuted-1>g°Power of Attorney for ~
Esta6e'ldibp ~ be teCdldtd irtl,
prier b.the bf flds Deed and Rubeet I.,~,:.i
I.en~; joitted~917t~ie I. Lihdis, hie wife ,' ~
MatttiarT. ~itm tmd Amy C. 0
andwB'e`endreEwededl~9i'~0071$Hoolt27g' , ,,;,
lraga 16141i~ieut ~;ZOfA•901OOb ~ 9sr
IMp9RpVir,M~4'f$! copsist of a reeideetia~~g
~, ~ zi.! .
BEII1G PR~QS~ES: 2175 Newvill'e Road,Af
Carl3ale,FA 17015 "'_ ~J~fi
WB~'I':~BNItiSBORd'lbYr .
St~LD 'the prb~aty of A>IdY C. Q1JJ~1N`ttrg
1i10'i~lY?'@~!U
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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 BAC HOME LOANS SERV LP is the grantee the same having been sold to
said grantee on the 2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on the
5TH day of MARCH, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term,
2009 Number 7320, at the suit of BAC HOME LOANS SERV L P against AMY C OUINN &
MATTHEW T QUINN is duly recorded as Instrument Number 201018335.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this ~ day of
A.D. ~ l o
of Deeds
try cam, ~ Caety~ PYl
MarcJey d Jen. 2014