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Home My WebLink About09-7842GOLDBECK 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 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. KATHRYN M. GEESAMAN Mortgagor and Record Owner 508 East Orange Street Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term `' No. C - %4", V 1 ? Defendant CIVIL AC770N: MORT(;QE r ?r...? ?clJ! 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 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 http://www.phfa.org/consumers/homeowners/real.4Wx. 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.orWforeclosure/ 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 1-866413-2311 or via email at homeretentionggoldbecklaw.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 88886FC. 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 Defendant is KATHRYN M. GEESAMAN, 248 Chestnut Drive, Shippensburg, PA 17257, who is the mortgagor and record owner of the mortgaged premises hereinafter described. JOSIAH E. GEESAMAN JR. died on January 20, 2006 by operation of law title vests solely in KATHRYN M. GEESAMAN and JOSIAH E. GEESAMAN JR. is hereby released of liability pursuant to PA. R.C.P. 1144. 3. On December 30, 2005 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICA'S WHOLESALE LENDER, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#:1937, Page 486. The mortgage has been assigned to: BAC HOME LOANS SERVICING, LP FKA 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 June 01, 2009 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 ..................................................................................$216,765.67 Interest from 05/01/2009 through 09/29/2009 at 6.8750% .......................$6,206.16 Per Diem interest rate at $40.83 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................$10,838.28 Late Charges from 06/01/2009 to 09/29/2009 .............................................$295.60 Monthly late charge amount at $73.90 Costs of suit and Title Search ......................................................................$900.00 $235,005.71 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 Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has 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 Defendant 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 Defendant 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 Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $235,005.71, together with interest at the rate of $40.83, 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: I _PAPA k&A2?? McCA FERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF 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: U 0 Michael T. McKeever, Esquire PA I.D. #56129 #88886FC KATHRYN M. GEESAMAN 508 East Orange Street Shippensburg, PA 17257 Prepared By and Return To: Referral Department GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 GMM File Number: 88886FC Parcel I D#: 32-34-2413-177 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICA'S WHOLESALE LENDER (Assignor), for and inconsideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP. BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed KATHRYN GEESAMAN , Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICA'S WHOLESALE LENDER Bearing date of: December 30,2005; Amount Secured: $225,000.00; Recorded on January 10, 2006; in Book 1937, Page 486; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 508 East Orange Street, Shippensburg, PA 17257 AS FURTHER DESCRIBED IN EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate corporate officers, has executed and sealed with its corporate seal this Assignment of Mortgage on this day of NpVf} S 2009, 2009. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICA'S WHOLESALE LENDER (Affix Corporate Sea]) Name: Sardm W#lWWAgSK VJW Title: ss: STATE OF VIM" ) COUNTY OF CONIN BE IT REMEMBERED, that on this day of NOV O 5 2009, before me, the subscriber, a Notary Public personally appeared I.anca HwzM Vloe president MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.. AS NOMINEE FOR AMERICA'S WHOLESALE LENDER officers of Assignor, who I am satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary act and/?ejee? of escorporation made by virtue of a Resolution of its Board of Directors. /?J 41 Notary Public My commission a ire*10V 1 F loll I hereby certify the address of the Assignee is: Azfat Siddlqui Notary FuW • STATE OF TEXAS My Comm. Exp• r4m.16.2010 Case #: 88886FC ExhibitA ALL THAT CERTAIN lot of ground in the Development known as Haflwood Heights. SITUATE in the Borough of 5hippensburg, Cumberland, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the curb line at corner of East Orange Street and Hollar Avenue; thence by East Orange Street North, 60 degrees 15 minutes East 112.45 feet to a sWw at coma of land, now or formerly of Kenneth Smith and wife; theace by I sad of now or formerly, Kenneth Smith and wife South 43 degrees 45 minutes Host, 150 feet to a stdw at common ooma of now or formerly, Kenneth Smith and Fatatacht; thence by Fasnacht land South 60 degrees 15 minutes Wask 112.45 feat to a stake on curb line of Hour Avenue; thence along Hollar Avenue North 44 degrees 43 minutes West, 150 feet to the phce ofbeghwing. Parcel# 32-32-2413-177 I Certify this to be recorded In Cumberland County PA Recorder of Deeds Bt1937PG0503 T--.... r E.rFidit B ACT 91 NOTICE DATE OF NOTICE: 10/02/2009 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 (IEMAP) mLay 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 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: 10/02/2009 Homeowners Name: KATHRYN GEESAMAN Property Address: 508 East Orange Street, Shippensburg, PA 17257 Loan Account No.: 123236560 Original Lender: BAC HOME LOANS SERVICING, L.P. 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 2 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>BANKRIVTCV-1`THE FOLLOWING PART OF S 1NOTI IS FOR IEI VOOIAT-161 1f'PPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO .C+OiLECT'THE DEBT. (If you have fled bankruptcy, you can Stilt apply; for Emergency Morto e'Assistavee.) 3 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: 508 East Orange Street, Shippensburg, PA 17257 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 06/01/2009 thru 10/02/2009 (5 mos. at $1,478.09/month) $7,390.45 (b) Late charges from 06/01/2009 thru 10/02/2009 (5 mos. at $73.90/month) $369.50 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $7,759.95 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $7,759.95, 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 866413-2311 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 te up to one hour before the Sheriffs Sale. You may do so by paving 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: BAC HOME LOANS SERVICING LP 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 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. 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 Phone Number: 972-526-2354 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 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 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 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 rcx\ %ZV FILEL, CC OTARY 2009 HIGY 12 Fill'-?: 41 $gg.So Po ATT`F eL* Sb5387 R4 d333`71 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND3COU?NTY CP tNc P,POMHONOTARY Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ??,?rptr of L*utnbrr{??b 2009 NOV 18 PM 2: 0 3 r` `i COUNTY €EI E : '?4 ..c PENNSYLVANIA BAC Home Loans Servicing, LP vs. Kathryn M. Geesaman Case Number 2009-7842 SHERIFF'S RETURN OF SERVICE 11/16/2009 01:15 PM - Jason Vioral, Corporal, who being duly sworn according to law, states that on November 16, 2009 at 1315 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kathryn M. Geesaman, by making known unto Sandra Geesaman, adult it charge at 248 Chestnut Drive Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.44 November 17, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF C04; (C CougtySultP Sherit7_ Teleosoft Inc. BAC HOME LOANS SERVICING, LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff v. KATHRYN M. GEESAMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09-7842 CIVIL TERM IN RE: PLAINTIFF' S MOTION FOR SUMMARY JUDGMENT BEFORE OLER and EBERT, JJ. ORDER OF COURT AND NOW, this 7`" day of July, 2010, upon consideration of the attached letter from Forest N. Myers, Esq., attorney for Defendant, it is hereby ordered and directed that summary judgment in mortgage foreclosure is hereby granted in favor of Plaintiff and against Defendant, with damages assessed in the amount of $235,005.71, together with interest from September 30, 2009, to the date of Sheriff's Sale at the rate of $40.83 per day, and for foreclosure and sale of the mortgaged premises. BY THE COURT, ~mas I. Puled Es . q Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 Attorney for Plaintiff -~ ,. ,~ ~. Wesley O~e~, Jr. J. r `~~ <~ -;~f; ,~ . -~: ~~~ --~ r. a r=_~ r ~.- -- _.,~ ~:: ~; -, o`'''a f1 --~ ~~ :: rest N. Myers, Esq. 137 Park Place West Shippensburg, PA 17257 Attorney for Defendant :rc f. i Es m~ c f 7~7/~~ ~~ °~ ~ r.Aw or~cE -~' ORE ST ~, ~!IYERtS .137 Park Place West, Shlppensburg, Pennsylvania 17257 717.532.9046 Fax 717.532.8879 :July 6, 2010 Nathan C Wolf, Esquire 10 West High Street Carlisle PA 17013 BAC v. Geesaman No. 99-7842 Dear Nathan: This will confirm our telephone conversation earlier today where I indicated that it is not the intention of the Defendant, Kathryn Geesaman, who I represent to contest the entry of an Order of Summary Judgment in the above matter. I appreciate your willingness to convey this to the Court and should there need to be any further information from me in this matter please feel free to contact me. Sincerely, i Forest N Myers GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano. TX 75024 vs. KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 MMrr F?tFS???C ?; ti??Y M3?nYLVAWIAo PEN IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 09-7842 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to Plaintiff s Complaint filed on November 12, 2009 in the above captioned matter. GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF Professional Corporation By: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 09-7842 KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification to Plaintiffs Complaint was served on Defendant(s) via first class mail on August 27, 2010 as follows: KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 GEESAMAN, KATHRYN M. 508 East Orange Street Shippensburg, PA 17257 GOLDBECK McCAFFERTY & McKEEVER 'Michael T. McKeever Attorney for Plaintiff VERIFICATION Gregory J No 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: f-I J Price, Assistant Secretary #88886FC - KATHRYN M. GEESAMAN 508 East Orange Street Shippensburg, PA 17257 dOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 FILED-1;FF1CF, Cr THE PROTHONOT,"k R'i' 2010 Noy 30 AN 11: 29 88886FC CF: 11/12/2009 SD: 12/08/2010 $235,005.71 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICI 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 09-7842 Keith C. Halili, an employee of Goldbeck McCafferty & McKeever, counsel for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/ ompetent s?rlt (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. ( ) Premises was posted by Sheriffs Office/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 AND COU1 i y COURT OF COMMON PLEAS i YLVA N I A of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE m ? fiJ MS Cc, rah,y- "T.C71?? ` G CJ J d ? 4 ? ? C m U0yk Z z Wy mo?O Z a m N V CL. >`- m U1 8 ?c=7 `t h fl wm m- o l m ?'? v = r 'd NY F=- N :r wW4gi tZil? cr `c w m a LL h1i1 ?tA flmSc? mNd U??' flG 4Q (OD m$v$? u ??Q' Oho O Ng wY-00 WU Xw=o ?ab J? F iDO (A. tZ4?. pl m U??o-' woL O p'.ct? v D W c Z E ? J C o N ? O o?Q o A ? ? V U U. ?WC Qs¢?' zW O a o ut, Lb ?L 1d0 1A Id o m z o Lna ?..r? O o m Z '"? p' C? N Dom- 4-0 og d tpY ?,yya,-_ a? mm E a+ ? m$ ? NY ?o N C3 m CO m U3 -z ?1 O 3i c O ?` r2 CD 4c , 0- T 0 OSO D- co 1 U Z W d c°Tn Ul O- m N4 W?pGW? ? pWgd o cv ?- m CO a Y V N a v ca t Q O N Q N z .. t7 o, 4 pa Wad Z?? m All - , 9(k Wow a QQ NNN ? m . $ t ° 3 f,` m r ? o - 0 * U ? 0 o D d m o m m o N a m m ? N r ?5 a 0 oo m O ? m a> t7 m - z o v a Q E W -3 LU V Ch m ~ v i6 " i ' a co d4 - Y 1 n N OD r- cD SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ???? 6t +?uanbrx? ' Jody S Smith Chief Deptlly ? ' 41 ti Richard W Stewart Solicitor OF XF DF rkE S LAFF BAC Home Loans Servicing, LP vs. Case Number . I Kathryn M. Geesaman 2009-7842 SHERIFF'S RETURN OF SERVICE 10/08/2010 04:12 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1610 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 Kathryn M. Geesaman, located at, 508 East Orange Street, Shippensburg, Cumberland County, Pennsylvania according to law. SHERIFF COST: $898.92 SO ANSWERS, October 26, 2010 RON R ANDERSON, SHERIFF ic'I GOU,fySA S Shenft, Teleoscft, lid. GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-7842 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: 508 East Orange Street Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 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 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: MCCUNE LUMBER COMPANY INC. 80 West Burd Street Shippensburg, PA 17257 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 508 East Orange Street Shippensburg, PA 17257 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 SANDRA GEESAMAN 248 Chestnut Drive Shippensburg, PA 17257 SANDRA GEESAMAN 20 NORTH FAYETTE STREET SHIPPENSBURG, PA 17257 (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 unworn falsification to authorities. DATED: November 24, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Ii @@-rl 3 f °, Sheriff f Jody S Smith Chief Deputy Richard W Stewart F, 7, Solicitor BAC Home Loans Servicing, LP Case Number vs. Kathryn M. Geesaman 2009-7842 SHERIFF'S RETURN OF SERVICE 10/08/2010 04:12 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1610 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 Kathryn M. Geesaman, located at, 508 East Orange Street, Shippensburg, Cumberland County, Pennsylvania according to law. 12/03/2010 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011 01/31/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 03/01/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 03/02/2011 Property sale removed from 4/6/2011 sale. 03/02/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney on 3/2/11. SHERIFF COST: $777.04 March 02, 2011 SO ANSWERS, RONINN R ANDERSON, SHERIFF ?.DD 'pat- ev- s? LL pd . ek-# `'SG03 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. KATHRYN M. GEESAMAN (Mortgagor(s) and Record Owner(s)) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-7842 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: 508 East Orange Street Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 r. 4. Name and address of the last recorded holder of every mortgage of record: MCCUNE LUMBER COMPANY INC. 80 West Burd Street Shippensburg, PA 17257 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 508 East Orange Street Shippensburg, PA 17257 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 SANDRA GEESAMAN 248 Chestnut Drive Shippensburg, PA 17257 SANDRA GEESAMAN 20 NORTH FAYETTE STREET SHIPPENSBURG, PA 17257 HALLWOOD HEIGHTS PUD AWAITING ADDRESS (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 unswom falsification to authorities. DATED: July 16, 2010 GOLDB C & MCKEEVER BY: Barb Hand 09-7842 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. KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) Term No. 09-7842 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: GEESAMAN, KATHRYN M. KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 Your house at 508 East Orange Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $235,005.71 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 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 09-7842 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: hM://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 09-7842 717-243-9400 09-7842 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 http://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 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 88886FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-7842 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff (s) From KATHRYN M. GEESAMAN (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$235,005.71 L.L.$.50 Interest FROM 9/30/2009 TO DATE OF SALE PER DIEM AT $40.83 Atty's Comm % Atty Paid $165.44 Plaintiff Paid Date: JULY 20, 2010 (Seal) REQUESTING PARTY: Deputy Name DAVID FEIN, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER, SUITE 5000 - MELLON INDEPENDENCE CENTER, 701 MARKET STREET, PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Due Prothy $2.00 Other CostsTO BE ADDED Supreme Court ID No. 82628 Dy. On September 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Borough, Cumberland County, PA, Known and numbered as, 508 East Orange Street, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: _,- T?? Real Estate Coordinator . .. .a. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. - n? ,--- sa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 5 da of November. 201 Notary NOTARIAL SEA DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 ,. CUMBERLAND LAW JOURNAL Writ No. 2009-7842 civil BAC Home Loans Servicing, LP, F/K/A Countrywide Home Loans Servicing, L.P. VS. Kathryn M. Geesaman Atty.: Michael McKeever ALL THAT CERTAIN lot of ground in the Development known as Hall- wood Heights. SITUATE in the Borough of Ship- pensburg, Cumberland, Pennsyl- vania, bounded and described as follows, to wit: BEGINNING at a point in the curb line at corner of East Orange Street and Hollar Avenue; thence by East Orange Street North, 60 degrees 15 minutes East 112.45 feet to a stake at corner of land, now or formerly of Kenneth Smith and wife; thence by land of now or formerly, Kenneth Smith and wife South 43 degrees 45 minutes East, 150 feet to a stake at common comer of now or formerly, Kenneth Smith and Fasnacht; thence by Fasnacht land South 60 degrees 15 minutes West, 112.45 feet to a stake on curb line of Hollar Avenue; thence along Hollar Avenue North 44 degrees 43 minutes West, 150 feet to the place of beginning. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 508 East Orange Street, Shippensburg, PA 17257. SOLD as the property of KATH- RYN M. GEESAMAN. TAX PARCEL #32-34-2413-177. BEING the same premises which Barbara Persun, as personal Repre- sentative of the Estate of Josiah E. Geesaman, Jr., late Dated 5/10/07 and recorded 5/11/07 in Book 279 page 4780 (partial interest) and Deed dated 01/28/82 and Recorded 03/01/82 in book S-29 Page 77 by deed from Josiah E. Geesaman, Sr., widower and single man to Kathryn M. Geesaman and Josiah E. Geesa- man, Jr (deceased) 48 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 the Patr1*0t1WXfW5 Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/15/10 10/22/10 10/29/10 Sworprj ^an?subscribedb ore me thi' 10 day:bf November, 2010 A.D. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Klsner, Notary Public Lower Paxton Twp., Dauphin County f my Commission Expires Nov. 26, 2011 1 Membp,. Ppnnsyivanla Association of Notaries 2909.7943 ChrB Tarm BAC Home Loans Servk kM LA,, ftA Coun ywkdo Horne Loans Semiafp, L.P. Vs Kathryn M. Caea#aman My-. Wheel Mol(sever ALL THAT CERTAIN lot of ground in the Development known as Hallwood Heights. SITUATE in the Borough of Shippensburg, Cumberland, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the curb fine at comer of East Orange Street and Hollar Avenue; thence by East Orange Street North, 60 degrees 15 minutes East 112.45 feet to a stake at corner of land, now or formerly of Kenneth5mith and wife; thence by land of now or formerly, Kenneth Smith and wife South 43 degrees 45 minutes East; 150 feet to a stake at common comer of now or formerly, Kenneth Smith and Fasnacht; thence by Famacht land South 60 degrees 15 minutes West, 112.45 feet to a stake on curb line of Hollar Avenue; thence along Hollar Avenue North 44 degrees 43 minutes West 150 feet to the place of beginning. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 508 East Orange Street- Shippensburg, PA 17257 SOLD as the property of KATHRYN M. GEESAMAN TAX PARCEL #32-34-2413-177 BEING the same premises which Barbara Person, as personal Representative of the Estate of Josiah E. Geesaman, Jr., late Dated 5/10/07 and recorded 5/11/07 in Book 279 page 4780 (partial interest) and Deed dated 01/28/82 and Recorded 03101/82 in book S-29 Page 77 by deed from Josiah E. Geesaman, Sr., widower and single man to Kathryn M. Geesaman and Josiah E. Geesaman, Jr (deceased) KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff r t rr;r, I Z I?:? ?' - ? 4q j t , CoU-ry BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. KATHRYN M. GEESAMAN (Mortgagor(s) and Record Owner(s)) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-7842 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P. 2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP for Voluntary Substitution under Pa.R.C.P. 2352 due to merger and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the new Plaintiff is 7105 Corporate Drive, PTX C-35, Plano TX, 75024. By: ' r-.. - KML R UP, P2 Michael 'IcKee r Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 dill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff C,????R'yy 7/IObS IZE?a'1?-l'-l7b , KML LAW GROUP, P.C. Suite 5000 - BNY 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. KATHRYN M. GEESAMAN (Mortgagor(s) and Record Owner(s)) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-7842 STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P.2352 BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned Action of Mortgage Foreclosure relates to a property located at 508 East Orange Street Shippensburg, PA 17257 ("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Book#:1937, Page 486 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP. 4. BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP is the successor in interest by merger to the Plaintiff and is hereby voluntarily substituted as Plaintiff in the above-ca ioned matter. Respectfully subm By: •C• KMTa Mice Pa. ID 56129 [ 26769 Jay Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 +?Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. SUITE 5000 - BNY 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. KATHRYN M. GEESAMAN (Mortgagor(s) and Record Owner(s)) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) CERTIFICATE OF SERVICE Term No. 09-7842 Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe for Voluntary Substitution and a supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on FOREST N. MYERS, ESQUIRE Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE By: J KML Law Group, P.C. Doris Guzman, Legal Assistant Dguzman@kmilawgroup.com 215-825-6402 (Direct Phone) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 09-7842 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff (s) From KATHRYN M. GEESAMAN (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: $235,005.71 L.L.: Interest FROM 9/30/2009 TO DATE OF SALE PER DIEM AT $40.83 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $977.98 Other Costs: Plaintiff Paid: Date: 5/23/12 1 David D. Buell, olotary (Seal) B : Deputy REQUESTING PARTY: Name: KRISTINA MURTHA, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA. PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 61858 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSUIE) P.R.C.P 3180-3183 zM , •c ., KML Law Group, P.C. ;n z : - Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 . t 215-627-1322 y-,", -: C) ert?v fnr Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. KATHRYN M. GEESAMAN Mort ag®r(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-7842 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 9/30/2009 to Date of Sale per diem at $40.83 (Costs to be added) . 41 ol?).yy ?uF 00 1 v n K a°1 co 01Alt„ `_r"? a l? $235,005.71 By: KML L GR .C. Michael McKee er ,ya. ID 56129 Jay E. Kivitz P . 26769 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff . 7? a3 sa a 0 N O c 0 za 0 U w F 2e x W C7 W ? cn W W z0x ?oA U O i N DC ) w be o a '900 1 9 . U a a U N N M U ? ail RN :2 %A '? pq C ,?. N W) a ALL THAT CERTAIN lot of ground in the Development known as Hallwood Heights. SITUATE in the Borough of Shippensburg, Cumberland, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the curb line at corner of East Orange Street and Hollar Avenue; thence by East Orange Street North, 60 degrees 15 minutes East 112.45 feet to a stake at corner of land, now or formerly of Kenneth Smith and wife; thence by land of now or formerly, Kenneth Smith and wife South 43 degrees 45 minutes East, 150 feet to a stake at common comer of now or formerly, Kenneth Smith and Fasnacht; thence by Fasnacht land South 60 degrees 15 minutes West, 112.45 feet to,a stake on curb line of Hollar Avenue; thence along Hollar Avenue North 44 degrees 43 minutes West, 150 feet to the place of beginning. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 508 East Orange Street Shippensburg, PA 17257 SOLD as the property of KATHRYN M. GEESAMAN TAX PARCEL #32-34-2413-177 BEING the same premises which Barbara Persun, as personal Representative of the Estate of Josiah E. Geesaman, Jr., late Dated 5/10/07 and recorded 5/11/07 in Book 279 page 4780 (partial interest) and Deed dated 01/28/82 and Recorded 03/01/82 in book S-29 Page 77 by deed from Josiah E. Geesaman, Sr., widower and single man to Kathryn M. Geesaman and Josiah E. Geesaman, Jr (deceased) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR I BY MERGER TO BAC HOME LOANS r- SERVICING, LP FKA COUNTRYWIDE _ HOME LOANS SERVICING LP rte Plaintiff NO. 09-7842 - vs. cn r r.) =s KATHRYN M. GEESAMAN Q 461 ? Defendant(s) x ? .. 4 CD EA _.: VERIFICATI N OF N , N- AR VIC VI CIVIL RELIEF ACT AS AA+-NDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, KATHRYN M. GEESAMAN, has a last known residence of c/o Forest N. Myers, Esquire, 137 Park Place West, Shippensburg, PA 17257. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Dale 4Kristina Murtha Pa. 0 ID 61858 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff By: G Michael a ee er . ID 56129 Lisa Lee Pa. ID KNII.David Fein Pa. ID 82628 Results as of : bey-18-2012 09:39:42 Department of Defense Manpower Data Center SCRA 2.1 tt ROPW Punmod to St cmembers Civil Relief Act Last Name: GEESAMAN First Name: KATHRYN Active Duty Status Date May-18-2012 AOW M* &W DOD Sh" Service CanRebent on AGIw Duly on A6. Dray Sias Date NA -- NO NA This response relbch the indWiduais' solve duty shuts based on the Alive Duty Stabs Date WtAdhe 0* Vftbr 367 Ways of Ae&a 0* SWO Wlr NA No NA This response reflects where the individual Wit active duty skips wNhh 397 days pnaosdltnp the Active Duty Stabs Wte The:Man bar or H ,4W lhit Was WOW da Fubaa Celt j* to Adbe aft on A om Mi SM&A Dais . NA No NA This response reflects whather the I dividual or hhftw unit has received early nWM1009on to report for alive duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information mnaf you provtoeu, wu duum w u ns owLr the individual on the active duty status data as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report .for Active Duty. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Marie Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as the Soldiers' and Sail re Civil Relief Ad of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defensefink.mil" URL: httpJ/www.defenselink.niiVfaq/pis/PC0gSLDR.htmi. If you haw evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). If you obtain additional information about the person (e.g., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. in the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun acute duty or actually reported fo induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: Q8AC3PEE6L KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. KATHRYN M. GEESAMAN (Mortgagor(s) and Record Owner(s)) 508 East Orange Street Shippensburg, PA 17257 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-7842 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 508 East Orange Street Shippensburg, PA 17257 I.Name and address of Owner(s) or Reputed Owner(s): KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 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 17105-2675 s i' k D-!.'i t 2012 MAY 23 AM 11: 09 INM ? A U4MON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE' FORECLOSURE 4. Name and address of the last recorded holder of every mortgage of record: MCCUNE LUMBER COMPANY INC. 80 West Burd Street Shippensburg, PA 17257 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 508 East Orange Street Shippensburg, PA 17257 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 SANDRA GEESAMAN 248 Chestnut Drive Shippensburg, PA 17257 SANDRA GEESAMAN 20 NORTH FAYETTE STREET SHIPPENSBURG, PA 17257 I verify that the statements made in this affidavit are true and correct to the best of my 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: 5d], ` By: KML LAW GR UP, .C. Michael McKeev 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 )?[Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 09-7842 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 PROTHONOTAR ",012 MAY 23 AM 11: 10 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 Docket No. 09-7842 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: GEESAMAN, KATMYN M. KATHRYN M. SEESAMAN c% Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 Your house at 508 East Orange Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 05, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $235,005.71 obtained by BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO 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 To prevent this Sheriffs Sale you must take immediate action: 09-7842 1. The sale will be cancelled if you pay to BANK OF AMERICA, N.A., SUCCESSOR BY MERGER 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 1-866413-2311. 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 S ML B ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER fUGHTS EVEN W THE SHEAR'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 die Foreclosure Resource Center: htgtJ/www.nhila kb&AWsiforecl,,? 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 717-243-9400 09-7842 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 717-243-9440. 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 h://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 homeretention@.Wlaw roup.com.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 88886FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 f :,. `~~' ~ti-G1=~1U ~~ ~ ~ sip - ~ a~ io: ~ ~ BANK OF AMERICA, N.A., SUCCESSOR MERGER TO BAC HOME LOANS SERVI LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) YL1 CF: 11/1 SD: 09/0 ~ ~ THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE Term No. 09-7842 CERTIFICATE OF SERVICE PURSUANT TO Pa.RC.P. 3129.2 (cl (2) Amy Gough, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that 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 KML Law Group, P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. (~ Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of maili~l attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment atta ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by KML Law Group, P.C. (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' ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. 4904. 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Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. KATHRYN M. GEESAMAN Mortgagor(s) and Record Owner(s) 508 East Orange Street Shippensburg, PA 17257 Defendant(s) Term No. 09-7842 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FK, COUNTRYWIDE HOME LOANS SERVICING LP, Amy Gough, an employee of KML Law Group, P.C., counsel o Plaintiff, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning real property located at: 508 East Orange Street Shippensburg, PA 17257 I .Name and address of Owners} or Reputed Owner(s): KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place. West Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE 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 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: MCCUNE LUMBER COMPANY INC. 80 West Burd Street Shippensburg, PA 17257 5. Name and address of every other person who has any record interest in or record lien on the property and whose 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 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 may be affected by the sale. TENANTS/OCCUPANTS 508 East Orange Street Shippensburg, PA 17257 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERIT TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE -SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 SANDRA GEESAMAN 248 Chestnut Drive Shippensburg, PA 17257 SANDRA GEESAMAN 20 NORTH FAYETTE STREET SHIPPENSBURG, PA 17257 DEPARTMENT OF PUBLIC WELFARE c/o Forest N. Myers 137 Park Place West Shipperisburg, PA 17257 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. Sectio 4904 relating to unsworn falsification to authorities. DATED: August 31, 2012 aw Groin?, P.C. B :Amy Gough Legal Assistant Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLANC) COUNTI( -,, .- , , ~~~~ ~~ ~ ?OCt 22 P~f I2~ .'~ ~~~~~ Y ~~ ; Bank of America. NA Case Number vs. Kathryn M. Ueesaman 2009-7842 SHERIFF'S RETURN OF SERVICE 06/25/2012 08:01 PM -Deputy Robert Bitner, being duly sworn according to law, stai:es service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 508 East Orange Street, Shippensburg, PA 17257, Cumberland County. 09/G6/2012 Ronny R. Andersen, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue car outcry at the Cumberland County Courthouse, Carlisle, PA on Septemk~er 5, 2012 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Micheal McKeever, on behalf of Federal National Mortgage ,Association, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST. $721.94 SO ANSWERS, ~~ ~~.. ~- October 22, 2012 RONN R ANDERSON. SHERIFF ~.~ ~~~9~ ~? a~~~GG KML Lam Group., P.C. Spite 5000 - Bl~Y Independency Center 701 Market Stree.~ ~ , Philadelphia, PA 19106-15;42 215-627-12'2 Attorney fir Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOM)=; LOANS SERVICING, LP FKA COUNTRYVVIDF. HOME LOANS SERVICING I_,P '7105 Corporab: Drive PTX C-35 Plano, TX 7502'1 Plaintiff vs. KATHR~'N N[. GEESAMAN (Mortgagor(s) and Record Owner(s)) 508 East Orange Street Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - JLAW ACTION OF MORTGAGE 1+ORECLOSURE Defendant(s) No. 09-7842 AFFIDAVIT PURSUANT TO RULE 3129 BANK: OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWI:flE HOME LOANS SERVICING LP, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 508 East Orange Street Shippensburg, PA 17257 LName and address of Owners} or Reputed Owner(s): KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire L 7 Park Place West Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: KATHRYN M. GEESAMAN c/o Forest N. Myers., Esquire 137 Park Place West Shippensburg, PA 17257 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 $ox 320 Carlisle, PA 17013 P.A DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Roam 432 P.O. Box 2675 Harrisburg, PA 17105-2675 i 4. Name anti address of the, last recorded holder of every mortgage of record: MCCUNE LUMBER COMPANY INC. 80 `3Jest Btud Street Shippensbtug, PA 17257 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 ha; 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 508 East Orange Street Shippensburg, PA 17257 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 11:31 Strawberry Square 6tt~ Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE -SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building H~ut-isburg, PA 17105-8486 SANDRA GEESAMAN 24S Chestnut Drive Srdppensburg, PA 17257 SANDRA GEESAMAN 20 NORTH FAYETTE STREET SHIPPENSBURG, PA 17257 l verify that the statements made in this affidavit are true and correct to the best of my 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. KML LAW GR UP, .C. Michael McKeev 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 ~Kristina Mcutha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 2761.5 __Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML Law Group., P.C. Suite 5000 - I3NY Independence Center 701 Market Street ~ , Philadelphia,'PA 19106-1_`.32 215-627-1322- Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MEKGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-3 Plana TX 750:'_4 IN THE COURT OF COMMON PLEAS Plaintiff vs. KATHRYN M. GEESAMAN (Mortgagor(s) and Record Owner(s)) 508 East Orange Street Shippensburg, PA 17257 of Cumberland C:'ounty CIVIL ACTION ~- LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-784' BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by counsel, KML La~,~ Group, P.C., sets forth as of the date the praec.ipe for the writ. of execution was filed the following information concerning the real property located at 508 East Orange Street Sluppensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 1'7257 2. Name and address of Defendant(s) in the judgment: KATHRYN M. GEESAMAN cio Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 3. Name and last }mown 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 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: MCCUNE LUMBER COMPANY INC. 80 West Burd Street Sluppensburg, PA 17257 5. Name and address of every other person who has any record interest in or record lien on the properly 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 5(18 East Orange Street Shippensburg, PA 17257 COMMONWEALTH OF PENNSYLVANLA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 11.31 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPEC]AL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 SANDRA GEESAMAN 248 Chestnut Drive Shippensburg, PA 17257 SANDRA GEESAMAN 20 NORTH FAYETTE STREET SHIPPENSBURG, PA 17257 I verify that the state;ments made in this affidavit are true and correct to the best of my 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 authoritiles. DATED:. ~__~1 ` ~ ~~ ~/~ By. ----- KML LAV4' GR UP, .C. Michael McKeev D 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa ID 78020 ~Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua L Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ~`~~-7842 IiNll, Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (?_15) 627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, I.P FKA COUNTRYWIDE HOME LOANS SERVICING LP i 105 Corporate Drive PTX C 35 Plano. TX 75024 vs. KATHRYN M. GEESAMAN Mortgagor(s) anti Record Owner(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland Count~a C'NIL ACTION - LA~~V' ACTION OF MORTGAGE FORECLOSURE Docket No. 09-784? Defendants THIS LA~'V FIRM IS A DEBT COLLECTOR Al\fD WE ARE A7CTEMPTING T'O COLLEC'C A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROPvI YOU WIl,L B1 USED FO R THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY 508 East Orange Street Slrippensburg, PA 17257 `['O: GEESAMAN, KA'I'HItYN M. KATHRYN M. GEESAMAN c/o Forest N. Myers, Esquire 137 Park Place West Shippensburg, PA 17257 Your house at 508 East Orange Street, Shippensburg„ PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September O5, 2012, at 10:00 AM, in Co:mrnissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $235,005.71 obtained by BAf~1K OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC. HOME LOANS SERVICING, LP FKA COUNTRYWIh>E HOME LOA.~IS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: i n9-7842 1. The sale will be cancelled if you pay to BANK OF ~'~MERICA, N.A., SUCCESSOR ;BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOA.1'dS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. Tc~ {7nd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. __ You may he 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 goo~~ 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 you will have of stopping the sale. (See notice below on how to obtain an attorneyj. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. l . 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. "{'o 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 propeny as if the sale never happened. ~. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff dives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict vou. 6. You may be entitled to a share of the. money which was paid for your house. A schedule of distribution of the monev 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 ufio will be receiving that money. The money will be paid out in accordance with this scihedule unless exceprions (reasons why tlae proposed distribution Ls wrong) aze filed with the Sheriff within ten (10) days after the schedule of distribution is filed. ~. 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. httpalwww.philadelphiafed.ornJforerlosure/ YOU SHOTILD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR C/U'JNOT AFFORD ONE, GO TO OR TELEPHONE T'HE OFFICE LISTED BELOW TO FIND OUT WHEF,E YOU CAN GET LECSAL HELP. CUMBEF.I_AND COUNTY BAR ASSOCLATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES 1NC S Irvine Row Carlisle, PA 17013 717-243-9400 (~9-7842 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 F[OME FROM: FORECLOSURI~. 1). Call an attorney. For referrals to a qualified attorney call either of thy; following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling A€;ency at 1-80O-989-2227 fo~~~ free counseling. 3). Visit FIUD'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 defau]t. Please See the P1=1FA website http:/iwww.phfa.or~/consumers/homeowners/real ash. 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 ~;.urrent, or payoff the mortgage or request a Loan Workout /Home Retention Package. (;'all our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-63:29 or fax 215 ~325- 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 ? 15- 825-63 18 ar Fax: 215-825-6418. Please. reference our Attorney Fille Number of 88886FC. Para infonnacion en espanol puede communicarse con Loretta x1215-82`i-6344. SHORT DESCRII?TION IMPROVEMENTS consist: of a residential dwelling. BEING PREMISF.,S: 508 East Orange Street Shippensburg, PA 17257 SOLD as the property of KATHRYN M. GEESAMAN TAX PAR('EL #32-34-241.3-177 ALL THA-i' CERTAIN lot of ground in the Development known as Haliwood Heights. SITUATE in the Borough of Shippensburg, Cumberland, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point: in the curb line at corner of East Orange Street and Hol{ar Avenue,; thence by East Orange Street North, 60 degrees !5 minutes East 112.45 feet to a stake at corner of land, now or formerly of Kenneth Smith and wife; thence by land of now or formerly, Kenneth Smith <~nd wife South 43 degrees 45 minutes East, 150 feet to a stake at common comer of now or formerly, KE:>nneth Smith and Fasnac:ht; thence by Fasnacht land South 60 degrees 15 minutes West:, 112.45 feet to a stake on curb line of Hollar Avenue; thence along Hollar Avenue North 44 degrees 43 minutes West, 150 feet to the place of beginning.. IMPROVEMENTS consist of a residential dwelling. BEING PftEM1SES: 508 East Orange Street Shippensburg, PA 17257 SOLD as the property of KATHRYN M. GEESAMAN TAX PARCE: L #32-34- 2413-]_77 BEING the same premises which Barbara Persun, as personal Representative of the Estate of Josiah E. Geesaman, Jr., late Dated 5/10/07 and recorded 5/11/07 in Book 279 page 4780 (partial interest) and Deed dated 01/28/82 and Recorded 03/01/82 in book 5-29 Page 77 by deed from Josiah E~. Geesaman, Sr., widower and singe man to Kathryn M. Geesaman and Josiah E. Geesaman, Jr (deceased) WRIT OF EXECUTION and/or ATTACHMENT COMV]ONW.EAL~'H OF PENNSYLVANIA) NO. 09-7842 Civil COUNT' OF ~L"MBERLAND) CIVIL ACT10'~~ - LP.W ICS THI SHERIFF OF CUMBERLAND COUNTY; To satisfy the debt, interest and costs due BANK OF AMERICA, N.A. SUCCESSOR B1' MERGER TO BAC HOME LOANS SERVICING, LP FKA. COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff (s) Fr,~m KATHRYN iVl. GF,ESAMAN ~1) You are di--~ected to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . ("? i Yore are also directed to attach the property of the defendant(s) not levied upon in the possession of G ~RN[SHEE(S} as follows: and to >>~~tify the garnishee(s) that: (a) an attachment has been issued: (b) the. garnishee(s) is enjoined from paying ar~~.~ debt to or for the account of the defendant (s) and from delivering any property of the° defendant (s} or otherwise disposing thereof; (~) If property of the defendant(s) not levied upon an subject to attachment is found in the possession o anyone. other than a named garnishee, you are directed to no~:ify hinr!her that he/she has been added as a garnishe,~ and is enjoined as above stated. ~.rlou~lt Due: 5235,005.71 L.L.: I~?tere~t FRO_VI 9/30/2009 'TO DATE OF SALE PER DIEM AT 540.83 Am~'s Comm: °,b Due Prothl:: 52.25 ^:m Paid: 5977.98 Oth~°; Costs: Plaintifi~ Paid: L1ate; ; 33; l 2 ~~Zi~~~e.~%____ _- David D Buell. Prothonotary Deputy REQUESTING PARTY: Name: KRIST[NA MUR'CHA, ESQUIRE :\ddres, : KML LA'W GROUP, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 70l MARKET STREET PHILADELPHIA. PA 19106-1532 ~ttornev for: PLAINTIFF ?~elephone: 215-62 ; -1322 Suprerr~e Court fD iJo. 61858 TRI.lE COPY FROAJi RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ~ day of ~. 2fl ~ Q ~ .~~ On May 22, 2012 the Sheriff levie;d upon the defendant's interest in the real property situated in Shippensburg Borough, Cumberland County, PA, Known and numbered as, 508 East Orange >treet, Shippensburg, more fully described on Exhibit ``A" filed with this writ and by this reference incorporated herein. Date: 1V[ay 22, 201.2 By: ~~ ~~~~z ~_ ~~~~~~~ ~4~~' Real :Estate Coordinator ri'R1~f Og~ i_:~h'~~ ~ gat ,~'i4~o-If,'~, COMMONWE:AL~i'}{ OI= PFVti,`~'; _' COUNTY OF CUMB>/RLA"~D? `~{_ ~ ,. "I0 THE. SHERIFF OI~ CliMBERL:~w1~ -::'~ ~_ ~~ To satisfy The debt, inrerE>t .. _ , ,, ~~3. €~:~~~I~ ~;a~~ ,~, tI6~;}~.I~ ,. °~_;~a. ~&~t~~ 4 *~~Cala 3`z MERGER TO BAC HOME LOA\~ SEI~.L Ic I~vt,, }_,P FR ~ t t)I ~~TRYW'917E I}t)i4~1E, 10,~~~u~ SERVICING L,P Plaintiff ~s) From KATHRh'N M. GEESAii,7r1_~'~ (1) 'y'ou arc Jire~[t'U tc'~ e~~, :ar',. _ ;~,.srz7Ck~i .p~r~. ~, ~#~~~ h.a n ,~. DESCRIPT(t)~' , (-1 ~ ou are a~so direct~~t r;~ it~,ic ~ : ~ ,~~ ~ , i> i GARNISHEE(S) as 1ul(o<<, and to uotifv the garnishee(s) th ~~ ~ ~ ... paying anv debt to or tier the a. ~ ~t,n~~ : ,. (s) or otherwise disposin<r thereon (3) If propene- of the defendan~, :, i n,~ ~ _. of anyone other than a ~7amed ~~arnis%.~t ; ,,~ _. , ,_ garnishee and is enjoined as ah~+~.: ~~<~~_! Amount Due: 5235,005.^ i Interest FROM 9/30/2009 "TCJ I?AT"}~. O}~ SAE f~ }'1~;1,. }?t l=:~~1 s i~ ~~-t3~,~S~~ .Atty's Comm. Attu Paid: S9"'.98 Other Gists: Plaintiff Pali±: Date: 5/23/12 a f 0 r.. sear' ~~-~~ . REQU1/s7~ING PAR~r~~. Name: KRISTIIYA N[URTHA, }:SQL~1R}~ Address: KML LAW GROUP, P.C' SUITE 5000 - I3N~' INDENI~.VU1,\t'i t { ,0"I E I~ 701 MARKET STREE'}~ PHILADELPHIA. PA 19[06-~53 Attorney for: PLA[NT[FF~ Telephone: 215-627-1322 Supreme Court iD No. 61858 T~2IaE ~C?Pl' FRC~:~'9 RI°G~~'C~ T ~ ~~ ~~~;r~Fre~f, I f E ~_~ ~,!r?r ..~~-_, ___~ day ~" __ ~''_ - - `~~ ~~.- CUMBERLAND LAW J~~URNAL Vfirit No. 2009-7842 Civil Term Bank of America, NA vs. Kathryn M. Geesaman Atty.: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 508 East Or- ange Street. Shippensburg, PA 17257. SOLD as the property of kATH- RYN M. GEESAMAN. 'TAX PARCEL #32-34-2413-177. 47 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAIL (Under Act No. 587, approved May 16, 1929),1'. 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 h;~s, 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: July 27, August 3, and August 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, aild 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. ~---- .y .------ L' a Marie Coyne, itor .. SWORN TO AND SUBSCRIBED befc-re me this 10 day of August, 2,012 ~' '` / Notary NOTANIAL SEAL DEBORAH A COI_LINS No±ary PubUc CARLISLE BOROUGH, CUtviBERLAND COUNTI' INy Commission Expires Apr 2B, 2111 V COMMONWF_,ALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Zie~le~r, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal National Mortga emaciation is the grantee the same having been sold to said grantee on the 5 day of September A.D., 2012, under and by virtue of a writ Execution issued on the '?> day of Mme, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 784, at the suit of Bank of America N.A. against Kathryn M. Ueesaman is duly recorded as Instrument Number 201232520. IN TESTIMOI~fY WHEREOF, I ha~,vle~hereunto set my hand and seal of said office this '"' day of 1 ~ - Recorder of Deeds { ~ laDtalty, Cerllsle, PA ~ ~;~ ~ the First Monday of Jan. 2D14 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFF=S OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~e ~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 Holly Blain. being duly sworn according to iaw, deposes and says: That she is a Staff Accountant of The Patriot News Co.. a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949 respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of 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: 07/27!12 08!03/12 2009-7842 Clvll Term NA erica f A 08/10/12 , m Bank o Vs aman r ~ . , _-__..__ ~ ,__ ~ 1 ees Kathryn M. , . . w`-' . ~__ __ s = •~ .. ... .:` .. .. . Atly: Michael McKeever .. ~ . , IMPROVEMENTS consist of a residential dweuing. BEING PREMISES: 508 East Orange Sworn to and subscribed before m~ is ~'7 da}~of August, 2012 A.D. Street Shippensburg, PA 17257 SOLD as the property of KATHRYN M. ti_X, -, . GEESAMAN ~~ TAX PARCEL#32-34-241~rr~'--' '~ NOtarJ/ PUbIIC LC4P"-`~~f~;~`~ ~-'T,i i3~ ~F~ryr:cy~ p,th ~.~ C,tW fi3,' `k.!2i x... ~ ham.-. .... ~~i-. ~v,¢. , ' i ^ i {'•„ ' r ~. ~ _