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HomeMy WebLinkAbout09-8228Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 ,,,Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 222699 BAC HOME LOANS SERVICING, L.P. 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff V. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. C? ?? Cd v CUMBERLAND COUNTY File #: 222699 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 222699 Plaintiff is BAC HOME LOANS SERVICING, L.P. 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 01/07/2008 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200801309. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified File #: 222699 by written notice sent to Mortgagor, the entire principal balance and all interest due 6. thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance $136,879.18 Interest $4,698.86 05/01/2009 through 11/22/2009 (Per Diem $22.81) Attorney's Fees $1,300.00 Cumulative Late Charges $242.75 01/07/2008 to 11/22/2009 Cost of Suit and Title Search $-5-50-00 Subtotal $143,670.79 Escrow Credit $0.00 Deficit $1,070.12 Subtotal ,0-12 $1_ 70 TOTAL $144,740.91 7 8 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriff s Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 222699 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $144,740.91, together with interest from 11/22/2009 at the rate of $22.81 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLWAN &,SCHMIEG, LLP By: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? P!n cis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 222699 LEGAL DESCRIPTION ALL THAT CERTAIN LOT, TRACT OF LAND, PARCEL, PIECE OF GROUND WITH THE BUILDINGS AND IMPROVEMENTS THEREON ERECTED, SITUATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE CENTERLINE OF CLEVERSBURG ROAD AT CORNER OF LOT NO. 11 ON THE HEREINAFTER MENTIONED PLAN; THENCE ALONG THE CENTERLINE OF CLEVERSBURG ROAD, BY A CURVE TO THE RIGHT HAVING A BEARING OF NORTH 22 DEGREES 56 MINUTES 23 SECONDS WEST, A DISTANCE OF 86.23 FEET TO A POINT; THENCE ALONG LOT NO. 9 OF PLAN FOR JOHN H. BILLAMAN, NORTH 68 DEGREES 05 MINUTES 37 SECONDS EAST, 172.31 FEET TO A POINT AT OTHER LANDS OF JOHN BILLMAN, NORTH 68 DEGREES 05 MINUTES 37 SECONDS EAST, 172.31 FEET TO A POINT AT OTHER LANDS OF JOHN BILLMAN; THENCE ALONG THE LATTER; SOUTH 29 DEGREES 06 MINUTES 56 SECONDS EAST, 80.12 FEET TO A POINT AT CORNER OF LOT NO. 11 ON HEREINAFTER MENTIONED PLAN; THENCE ALONG THE LATTER; SOUTH 66 DEGREES 03 MINUTES 36 SECONDS WEST, 172.58 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 14,357.2 SQUARE FEET AND BEING LOT NO. 10 AS SHOWN ON THE PLAN OF WALNUT GROVE RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 41, PAGE 59. File #: 222699 TAX ID #: 39-13-0102-040 BY FEE SIMPLE DEED FROM JOHN H. BILLMAN AS SET FORTH IN DEED BOOK 182, PAGE 140 AND RECORDED ON 7/28/1988, CUMBERLAND COUNTY RECORDS. PROPERTY BEING; 251 NEIL ROAD File #: 222699 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. Attorney for Plaintiff DATE: ozo S?- File #: 222699 Apy JJ 9 A a-3`/)f7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R A~~derson Sheriff ;: ~ttti~~'` ~~inirfi~~~~~ v lit ~.,. ~; . Jody S Smith Chief Deputy Edward L Schorpp Solicitor i~;~MAY :~~ AN iD~ 21 ~u~.i, ~ r~,- _, t BAC Home Loans Servicing, LP vs. Bazil F. Doyle, Jr. (et al.) Case Number 2009-8228 SHERIFF'S RETURN OF SERVICE 04/06/2010 01:19 PM -Ronald Hoover Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1318 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 Bazil F. Doyle, Jr., and Judith Doyle, located at, 251 Neil Road, Shippensburg, Cumberland County, Pennsylvania according to law. 04/06/2010 01:19 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 a 1318 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Bazil F. Doyle, Jr., by making known unto, Judith Doyle, wife, at, 251 Neil Road, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 04/06/2010 01:19 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 a 1318 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Judith Doyle., by making known unto, Judith Doyle, personally, at, 251 Neil Road, Shippensburg, Cumberland County, Pennsylvania its contents and a' the same time handing to her personally the said true and correct copy of the same. 05/04/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Schmieg on 4/29/10 SHERIFF COST: $645.83 SO ANSWERS, .... May 21, 2010 RON R ANDERSON, SHERIFF ~/~ -~ 7~: / /3 ~ ~ ~~ BAC HOlV1~E LOANS SERVICING, L.P. Plaint?,ff `' v. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION N0.09-8228 CIVIL TERM CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 BAC HOME LOANS SERVICING, L.P., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) BAZIL F. DOYLE, JR A/I{/A BAZIL F. DOYLE JUDITH DOYLE 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Z51 NEIL ROAD SHIPPENSBURG, PA 17257-0000 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate} None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the`sale: Nr~r-e Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. February 9, 2010 By: Att r Plaintif Phelan Hallman &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ F `cis S. Hallman, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. S874S ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 6 ].791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. Na 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 .._, ,_ BAC HOME LOANS SERVICING, L.P. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE Defendant(s) N0.09-8228 CIVIL TERM CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BAZIL F. DOYLE, JR. JUDITH DOYLE A/K/A BAZIL F. DOYLE 251 NEIL ROAD 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 SHIPPENSBURG, PA 17257-0000 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A lliSCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000 is scheduled to be sold at the Sheriff's Sale on Ob102/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $145,972.b5 obtained by BAC HOME LOANS SERVICING, L.P. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. T'he sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-5b3-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your properly will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be al-~~ to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property.' 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 - SHORT DESCRIPTION By virtue of a Writ of Execution NO. 09-8228 CIVIL TERM BAC HOME LOANS SERVICING, L.P. vs. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE owner(s) of property situate in Southampton Township, Cumberland County, Pennsylvania, being (Municipality) 251 NEIL ROAD SHIPPENSBURG PA 17257-0000 Parcel No. 39130102040 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $145,972.65 Phelan Hallman & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 _•~. LEGAL DESCRIPTION ALL THAT CERTAIN LOT, TRACT OF LAND, PARCEL, PIECE OF GROUND WITH THE BUILDINGS AND IMPROVEMENTS THEREON ERECTED, SITUATE IN SOUTHAMPTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE CENTERLINE OF CLEVERSBURG ROAD AT CORNER OF LOT NO. 11 ON THE HEREINAFTER MENTIONED PLAN; THENCE ALONG THE CENTERLINE OF CLEVERSBURG ROAD, BY A CURVE TO THE RIGHT HAVING A BEARING OF NORTH 22 DEGREES 56 MINUTES 23 SECONDS WEST, A DISTANCE OF 86.23 FEET TO A POINT; THENCE ALONG LOT N0.9 OF PLAN FOR JOHN H. BILLAMAN, NORTH 68 DEGREES OS MINUTES 37 SECONDS EAST, 172.31 FEET TO A POINT AT OTHER LANDS OF JOHN BILLMAN, NORTH 68 DEGREES OS MINUTES 37 SECONDS EAST, 172.31 FEET TO A POINT AT OTHER LANDS OF JOHN BILLMAN; THENCE ALONG THE LATTER; SOUTH 29 DEGREES 06 MINUTES 56 SECONDS EAST, 80.12 FEET TO A POINT AT CORNER OF LOT NO. 11 ON HEREINAFTER MENTIONED PLAN; THENCE ALONG THE LATTER; SOUTH 56 DEGREES 03 MINUTES 36 SECONDS WEST, 172.58 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAIl~IING 14,357.2 SQUARE FEET AND BEING LOT NO. 10 AS SHOWN ON THE PLAN OF WALNUT GROVE RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN PLAN BOOK 41, PAGE 59. Vested by Special Warranty Deed, dated 07/13/1998, given by John H. Billman to Bazil F. Doyle, Jr. and Judith A. Doyle and recorded 7(28/1998 in Book 182 Page 140 Instrument # 1998-025185. PREMISES BEING: 251 NEIL ROAD, SHII'PENSBURG, PA 17257-0000 PARCEL N0.39130102040 WRIT OF EXECUTION and/or ATTACHMENT COMMONV1jEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N009-8228 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, L.P. Plaintiff (s) From BAZIL F. DOYLE, JR. A/K/A BAZIL F. DOYLE AND JUDITH DOYLE (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 $145,972.65 L.L. $.50 Interest FROM 01/16/2010 TO DATE OF SALE ($24.33 PER DIEM) -- $3,357.54 Atty's Comm Atty Paid $181.00 Plaintiff Paid Uate: O'L/17/2010 (Seal) REQUESTING 1-ARTY: Due Prothy $2.00 Other Costs L~/~ J ` David D. Buell, Prothonotary By: Deputy Name: IYIICI-IEi E M. BRADFORD, ESQUIRE Address: '(17 JFK BLVD. SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 69849 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, Known and numbered, 251 Neil Road, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: Real Estate Coordinato~- J a}:; =,;, ~_` ~, ; v _ G'G .~' ~ :. ~~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, Apri123, and Apri130, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. wit xo. zoo9-s228 civ11 BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP vs. Bazil F. Doyle, Jr. a/k/a Bazil F. Doyle, Judith Doyle Atty: Daniel Schmieg By virtue of a Writ of Execution NO. 09-8228 CIVIL, BAC HOME LOANS SERVICING, L.P. vs. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE, JUDITH DOYLE, owners of property situate in Southampton Township, Cumberland County, Pennsylvania, being 251 NEIL ROAD, SHIPPENS- BURG, PA 17257-0000. Parcel No. 39 1 30 1 02040. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $145, 972- .65. ~- Li Marie Coyne, ~ ditor SW TO AND SUBSCRIBED before me this 30 da of Aril 2010 Notary NOTARIAL SEAL DEBORAH A COLLtNS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commisaioa Expires Apr 28, 2014 i `' ~ ~ The Patriot-News Co. 2020 Technology Pkwy . Suife 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c'~I~e ~lahiot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY Writ No. 2009-8228 Civil Term BAC Home Loans Servicing, LP F/IVA Countrywide Home Loans Servicing, LP ~S. Bazll F. Doyle, Jr. alk/a Bazll F. Doyle JudRh Doyle Atty: Danlel Schmieg By virtue of a Writ of Execution N0. 09-8228 CIVIL TERM BAC HOME LOANS SERVICING, L:P. vs. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE owner(s) of property situate in Southampton Township, Cumberland County, Pennsylvania, being (Municipality) 251 NEIL ROAD, SHIIPPENSBURG, PA 1"7257-0000 Parcel No. 39130102040 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $145,972.65 This ad ran on the date(s) shown below: ~i~~i~71%~i-~ Sworn to and,~Ibscribed before me this 1.8~`d _ of May, 2010 A.D. ,..` ,= j' .~'" Notary Public ~'' COMMONWEALTH OF PENNSYLYAN>f~4 Notarial Sail Sherrie L. Klsnar, Notary Publk Lower Paxton Twp., Diuphln Gaunty My Commission Explrai Nov, 26, 2011 Member, Pennsylvania Association of Notaries 04/16/10 04/23/10 04/30/10 rr i T PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 BAC HOME LOANS SERVICING, L.P. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 01/16/2010 to Date of Sale ($24.00 per diem) TOTAL . ~ Po ~~ va. oo e~F l0~5.83 ~~ a f+~.oo ~. 3~}. GD .• 848. ~ •Po A-ny ~a.00 ax~Cp C~a$3$a,S ~~~y~~7 Note: Please attach description of property. PHS # 222699 N0.09-8228 CIVIL TERM CUMBERLAND COUNTY C7 ~ _- v ? i" $14$,972.65 W ~~ 4 r,-" $ 7,848.00 - ~ ~" , .-,... . {s ~ , -., d c_ X153,820.65 ~~ Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 /~ -o a~ a .o c~ N a. L Q~ 3 y b Q W O w a N o o ~ °o Q ~ a ~ Q a V a: ~O~ (7w ~~,y z w Nza Q~ N (n 0 0 0 0 N Q a ~Q~ O x~w ~za ~~-, N V] W N ~ z O~ ar A ~ N ~ r a W ~% W ~ ~ N~~~ ~ o;~~r~~ a N~p~~n ~ Mme, o~p z ~ N V N~ON~p'ct "'l~l~ M ^"cl'.-. O SON ~+ ~ d c+~NN t~~l~r~1M O~~Oz00 ~p ~p p 00 O M N [~ 00 Q~ N O ~a V ~ W ~ C, C ° °z'nzo~o~~n~D O p~N cz ~ Q k. o '~zzZ~z-ci o o °~ ozz o„zzv~ ~F a ~ O % a °bb ~~~zzz~ozb;vw~;o 3 (~~ ~ _ O ~ WW-p"m ~tj.v'vN".C a,WW~WW ~ DA p rW7 W ~ a on ". ~~~ 5•°~~ $ ~W>,W ~ y'~~ a ~' ~ ~~ _ Z W~ ~'',`'a,,b ~ d~io ,c ea ~~m" E.~ > ~ ~W~~a.~ aai~C] c AO ~, W c ~ a,g ~ aC Ll > ~ ~ v ~C7 G~ ~ ~ ~A ~ ~~+ ~--~ ~v~~~ c~ n,•~- c~a v ~ ICJ W (~ ~ O. ~+ Q U ~ ~ x ~ 'v .~ ,~ ~ a~i °~ i a~i GCl~.• ~ ~ v°, ~ a' ~ ".. U ~ > a1 ~ A. w ¢ a ^a^^^^^^^^^^a^^aa r. ~ .1 LEGAL DESCRIPTION ALL THAT CERTAIN lot, tract of land, parcel, piece of ground with the buildings and improvements thereon erected, situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the centerline of Cleversburg Road at corner of Lot No. 11 on the hereinafter mentioned Plan; thence along the centerline of Cleversburg Road, by a curve to the right having a bearing of North 22 degrees 55 minutes 23 seconds West, a distance of 86.23 feet to a point; thence along Lot No. 9 of Plan for John H. Billaman, North 68 degrees OS minutes 37 seconds East, 172.31 feet to a point at other lands of John Billman, North 68 degrees OS minutes 37 seconds East, 172.31 feet to a point at other lands of John Billman; thence along the latter; South 23 degrees 06 minutes 56 seconds East, 80.12 feet to a point at corner of Lot No. 11 on hereinafter mentioned Plan; thence along the latter; South 66 degrees 03 minutes 36 seconds West, 172.58 feet to a point, THE PLACE OF BEGINNING. CONTAINING 14,357.2 square feet and being Lot NO. 10 as shown on the Plan of Walnut Grove recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 41, Page 59. Vested by Special Warranty Deed, dated 07/13/1998, given by JOHN H. BILLMAN to BAZIL F. DOYLE, JR. and JUDITH A. DOYLE and recorded 7/28/1998 in Book 182 Page 140 Instrument # 1998-025185 PREMISES BEING: 251 NEIL ROAD, SIIIPPENSBURG, PA 17257-0000 PARCEL N0.39130102040 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Bk. No. 1:10-bk-03397 MDF BAZIL F. DOYLE, JR JUDITH A. DOYLE Chapter 7 Debtors BAC HOME LOANS SERVICING, L.P. Movant 11 U.S.C. §362 v. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH A. DOYLE A/K/A JUDITH DOYLE Respondents and LEON P. HALLER, ESQUIRE (TRUSTEE) Respondents ORDER MODIFYING §362 AUTOMATIC STAY Upon consideration of Motion of BAC HOME LOANS SERVICING, L.P. (Movant), it is: ORDERED that the Automatic Stay of all proceedings, as provided under 362 of the Bankruptcy Code 11 U.S.C. §362 is modified with respect to premises 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000, as more fully set forth in the legal description attached to said mortgage, as to allow the Movant to foreclose on its mortgage or take any legal or consensual action enforcement of its right to possession of, or title to, said premises (such actions may include but are not limited to the signing of a deed in lieu of foreclosure or entering into a loan modification agreement) and to allow the purchaser of said premises at Sheriffs Sale (or purchaser's assignee) to take any legal or consensual action for enforcement of its right to possession of, or title to, said premises; and it is further; ORDERED that Rule 4001(a)(3) is not applicable and BAC HOME LOANS SERVICING, L.P. may immediately enforce and implement this Order granting relief from the automatic stay. B,y the Court, B ~! ~tld~r~ (JG) Dated: May 26, 2010 This dacumen# is else#ranacally signed and faded on the same da#e. Case 1:10-bk-03397-MDF Doc 17 Filed 05/26/10 Entered 05/26/10 09:59:40 Desc Phelan Hallinan &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Fri F ~~ Philadelphia, PA 19103 `~ 215-563-7000 ~~ 10 i~J ~~ -- 3 ~° -~ BAC HOME LOANS SERVICING, L~~j~4f,J , i~C ~~( Plaintiff ~.~ , , ~ ;, v. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION N0.09-8228 CIVIL TERM CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: (X) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. B /`~J`~G~~4~ Y• Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 BAh HOME LOANS SERVICING, L.P. '' ` Plaintiff v. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION N0.09-8228 CIVIL TERM CUMBERLAND COUNTY PHS # 222699 AFFIDAVIT PURSUANT TO RULE 3129.1 BAC HOME LOANS SERVICING, L.P., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 251 NEIL ~QAD, SHIPPENSBURG, PA 17257-0000. n ~=' ~- G ~~ ,,1.~ i~~. ~~ ~ 1. Name and address of Owner(s) or reputed Owner(s): ~ , :; ~ Name Address (if address cannot be reasonably ~~ ~ ! `~~ ascertained, please so indicate) _ c=~ ._. r_. C. _ ~_ BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 c _ ~.-; ~, ~. ."~ JUDITH DOYLE 251 NEIL ROAD '~ ~~ ~~` SHIPPENSBURG, PA 17257-0000 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. ..,. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. ~' ~~JzyY~y Julv 29, 2010 By: G Attorney for Plaintiff Phelan Hallinan &Schmieg, LLP ^ Lawrence T. Phelan, Esq., Id. No. 32227 ^ Francis S. Hallinan, Esq., Id. No. 62695 ^ Daniel G. Schmieg, Esq., Id. No. 62205 ^ Michele M. Bradford, Esq., Id. No. 69849 ^ Judith T. Romano, Esq., Id. No. 58745 ^ Sheetal R. Shah-Jani, Esq., Id. No. 81760 ^ Jenine R. Davey, Esq., Id. No. 87077 ^ Lauren R. Tabas, Esq., Id. No. 93337 ^ Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 BAC HOME LOANS SERVICING, L.P. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. N0.09-8228 CIVIL TERM BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE CUMBERLAND COUNTY JUDITH DOYLE . Defendant(s) ~~ ~' ,,`~ •- " NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~ t, ~- , ~ _'- ,- f., t TO: BAZIL F. DOYLE, JR A/K/A _ - `" BAZIL F. DOYLE - _ JUDITH DOYLE - T 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 ~ `' * *THIS FIItM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000 is scheduled to be sold at the Sheriff s Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $145,972.65 obtained by BAC HOME LOANS SERVICING, L.P. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) w YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot, tract of land, parcel, piece of ground with the buildings and improvements thereon erected, situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the centerline of Cleversburg Road at corner of Lot No. 11 on the hereinafter mentioned Plan; thence along the centerline of Cleversburg Road, by a curve to the right having a bearing of North 22 degrees 55 minutes 23 seconds West, a distance of 86.23 feet to a point; thence along Lot No. 9 of Plan for John H. Billaman, North 68 degrees OS minutes 37 seconds East, 172.31 feet to a point at other lands of John Billman, North 68 degrees OS minutes 37 seconds East, 172.31 feet to a point at other lands of John Billman; thence along the latter; South 23 degrees 06 minutes 56 seconds East, 80.12 feet to a point at corner of Lot No. 11 on hereinafter mentioned Plan; thence along the latter; South 66 degrees 03 minutes 36 seconds West, 172.58 feet to a point, THE PLACE OF BEGINNING. CONTAINING 14,357.2 square feet and being Lot NO. 10 as shown on the Plan of Walnut Grove recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 41, Page 59. Vested by Special Warranty Deed, dated 07/13/1998, given by JOHN H. BILLMAN to BAZIL F. DOYLE, JR. and JUDITH A. DOYLE and recorded 7/28/1998 in Book 182 Page 140 Instrument # 1998-025185 PREMISES BEING: 251 NEIL ROAD, SIIIPPENSBURG, PA 17257-0000 PARCEL N0.39130102040 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-8228 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP, Plaintiff (s) From BAZIL F. DOYLE, JR a/k/a BAZIL F. DOYLE & JUDITH DOYLE (1) You are directed to lery 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 $145,972.65 L.L. Interest from 1/16/10 to Date of Sale ($24.00 per deim) -- $7,848.00 Atty's Comm Due Prothy $2.00 Atty Paid $848.33 Other Costs Plaintiff Paid Date: 8/3/10 . Buell, Prothonotary (Seal) By; Deputy REQUESTING PARTY: Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BAC HOME LOANS SERVICING, L.P. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. BAZIL F. DOYLE, JR. A/K/A BAZIL F. DOYLE JUDITH DOYLE Defendant(s) CIVIL DIVISION No.: 09-8228 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/her, fled Mail Return Receipt stamped by the U.S. Postal Service is attached here xhib t m __ Date: _ i Lawre e Phelan, Esq., Id. No. 32227 ? Fran S . Hallman, Esq., Id. No. 62695 ? Dane G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford; Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 F-? Sheetal R. Shah-Jani, Esq., Id.. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 Q Lauren Rjabas, Esq., Id. No 93337 r 0 Vivekivastav'a, Esq., Id. No. 202331 ? Jay, . Jones, Esq., Id. No. 86657 ? P er J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq,, Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C, Bramblett' Esq., Id, No. 208375 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 222699 Q C c N C a? N N at p ? 0. O y ? t:1e a ? 0 Q tad ? ? 'v ti z ` o ?o m R ? Ca . . 7 C vvi ? ..,. OLOZ £Osnv 9SZLI.lb004 ' G ea OUT O W G z o o°O X s?nnos ?KUa C G E ,[ i3 O C p,.0y w V 'C' V O ? d? ro r.:ro-.G c7? r? W ; E :b 4 ? . ? 8 g ??oo H y' N ? G ev -H o r sv i?: ' . O C C^ ? 40 . O ° o E ? y U M ' a A ; d w F o ? w o N .? Via,.. u ?R a W ' ? " c Pa C p tT ' . C O ? ? U A W ? t ? ?u:. . ? ? h y C V "C O P +"r v.+ p. U CR ? gy N O Y h C7 ? A vl p a o H "? ..e w y r O .? p ? N 6C) In w .G v,+ ?1r pr i, .?++ o i Y y . ?r ,? G 7. O. .,C p ?~ y py0, ? yam, .,?! A k w ? / ? Q fY W ? ? i t/j f? N x a ? ry ?, i t ? y .C ? y D p y '..c o 0 0 C/] m CG. Wtr, x. O GSM cC ctl d G C N i N ?_ N X X is -Y' ? .. U ? < b ? V z a 00 tv 5 `?GK. ?Jj1) PLAINTIFF BAC HOME LOANS SERVICING, L.P. AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PHS # 222699 ig DEFENDANT BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH A. DOYLE A/K/A JUDITH DOYLE SERVE JUDITH A. DOYLE A/K/A JUDITH DOYLE AT: 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 SERVICE TEAM/ talc COURT NO.: 09-8228 CIVIL TERM TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 12/0812010 1 a? tai M 10, at- SERVED SERVED Served and made known to JUDITH DOYLE , Defendant on the ISTday of 44o Yfit 0R , 20 q-1-19L, o'clock. M., at 105 Rd ST K DA. Silt ~&A& . ??> in the manner described below: _ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is 4?fR3 D _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age -715 S Height 1 0'. Weight ;40 Race W Sex M Other r-3 r? CD 01 321- v ,.Y f I, RowAc& A 4 L L , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. cant - Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at 11-TI Sworn to and subscribed KIMBERLY CURTY before me this I 51' day Co. NOTARY PUBLIC STATE OF NEW JERSEY Of 6kd Not y: MY COMMISSION EXPIRES MARCH 7, 2013 N RVED On e 20_, at- o'clock _. M., Defendant NOT FOUND because: Service Refused Other: Sworn to and subscribed before me this day of _726 By: Notary: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq, Id. No. 32227 Francis S. HaOLm, Esq., X No. 62695 Daniel G. Sckole8, Eaq.. Id. No. 62205 Mkide M. Bradford, Esq., Id. No. 69849 Jadhb T. Rama, Eq., Id. N. 58745 SMeMal R. ShWJaoi, Eeq., Id. No. 81760 Jenine R Davey, Esq., Id. No. 87971 Lauren R Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jaie% Esq, Id. No. 86657 Peter J. Mnlceky, Esq., Id. No. 61791 Andrew L Spivack, Esq, Id. No. 84439 Jaime McGuMness, Esq., Id. No. 90134 Chrisovakude P. FBakos, Esq, Id. No. 94628 Joshua 1. Goldman, Esq, Id. Na 285047 Comusay R Dann, Esq, Id. No. 206779 Andrew C. Brambhty let. No. 208375 1617 JPerms ohn Kenenneat S dy Blvd, nSastation ke 1400 Ftdbde4WWa, PA 19103.1814 (215)563.7000 PLAINTIFF BAC HOME LOANS SERVICING, L.P. AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PHS # 222699 DEFENDANT BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH A. DOYLE A/K/A JUDITH DOYLE SERVE BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE AT: 105 RUSTIC DR SHIPPENSRURG, PA 17257-8750 SERVICE TEAM/ kxc COURT NO.: 09-8228 CIVIL TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 1210812010 r TEljt"' SERVED erved and made known to BAZIL F. DOYL.E. JR , Defendant on the 1I rday of NO YA1tM , 20 ?O , at o'clock 4. M., at It* R uSrC D& gif i pffmsA-Q .IPA , in the manner described below: _ Defendant personally served. - Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. Other: Description: Age -10s Height 51 D Weight 2 40 Race W Sex M Other n..a M 1, D dAtA;- li L4 a competent adult, being duly sworn according to law, depose and state that I personally ---1 w ?;-sue L'. handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed (LIMBERLY CUR t'Y before me this 1&r day NOTARY PUBLIC of Ab 1/, 2016 pftt" STATE OF NEW JERSEY No By: MY C()MMtS W EXPIRES MARCH 1, ?A I3 NOT SERVED 0 the 20_, at - o'clock _. M., Defendant NOT FOUND because: acant - Does Not Exist - Moved - Does Not Reside (Not Vacant) - No Answer on at Service Refused Other: Sworn to and subscribed before me this day of _. By: Notary: ATTORNEY FOR PLAINTIFF Lawrence T. Melon, Fsq, Id No. 32227 Fronds S. HaMoan, Feq, Id. No. 62695 Dmdd G. Schdeg, Eiq, Id. No, 6ZW Mkhde M. BradOord, Fsq., Id. No. 69809 Judith T. Ramona, Esq, Id. No. 58745 Sheetal R Sholijad, Fsq, Id No. 81760 Jesdne R. Davey, Fsq., Id. No. 87877 Laura' R. Tabus, Esq., Id. No. 93337 Vivek Srivastava, Fsq, Id. No. 202331 Jay B. Joins, Fsq, Id. No. 86657 Peter J. Makohy, FBq, Id. No. 61791 Andrew L Spivock, Fsq, Id. No. 84439 Jahm McGuinness, Fsq, Id. No. 90134 Chrisovalan a P. FSukes, FA% Id. No. 94620 Joshae L Goldman, Fwq, Id. No. 205807 Cuurtenay R Down, Esq., Id. No. 206779 Andrew G Branbbt, F?kl. No. 2118375 one Penn Cnna at Station 1617 Jahn F. Kennedy Blvd, Sake 1400 Philadelphia, PA 19103-1814 (215)563.7000 A 4 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor gSt??tp tit ?1t?tiGrr[??j9 -,rFtCE'vf ".li, `•ERIrP H-ED-OFFICE ?I T HE Pi-?0TH0'?OTARY 21311 APR 1 I AM 10: 33 CUMBERLAQ COUPS Y PENNSYl VA NIA BAC Home Loans Servicing, LP vs. Bazil F. Doyle, Jr. (et al.) Case Number 2009-8228 SHERIFF'S RETURN OF SERVICE 10/08/2010 04:32 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1630 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 Bazil F.& Judith Doyle, Jr. , located at, 251 Neil Road, Shippensburg, Cumberland County, Pennsylvania according to law. 10/08/2010 04:32 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Bazil F. Doyle, Jr., but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 251 Neil Road, Shippensburg, PA 17257, address is vacant, defendant did not leave a forwarding with the post office. 10/08/2010 04:32 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Judith Doyle but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 251 Neil Road, Shippensburg, PA 17257, address is vacant, defendant did not leave a forwarding with the post office. 12/03/2010 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011 01/31/2011 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 04/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Schmieg on 4/1/11. SHERIFF COST: $694.93 April 07, 2011 SO ANSWERS, ROW R ANDERSON, SHERIFF co S1378 R-`- -.2srrs7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY (C CountySuite Sheriff . T7eleosoft. Inc. 14 BAC HOME LOANS SERVICING, L.P. Plaintiff V. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE Defendant(s) COURT OF COMMON PLEAS CIVIL, DIVISION NO. 09-8228 CIVIL TERM CUMBERLAND COUNTY PHS # 222699 AFFIDAVIT PURSUANT TO RULE 3129.1 BAC HOME LOANS SERVICING, L.P., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. July 29, 2010 By: 4',ul G" l G?l" Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 R- BAC HOME LOANS SERVICING, L.P. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. : NO. 09-8228 CIVIL TERM BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE CUMBERLAND COUNTY JUDITH DOYLE Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000 is scheduled to be sold at the Sheriff's Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $145,972.65 obtained by BAC HOME LOANS SERVICING, L.P. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS Y BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot, tract of land, parcel, piece of ground with the buildings and improvements thereon erected, situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the centerline of Cleversburg Road at corner of Lot No. 11 on the hereinafter mentioned Plan; thence along the centerline of Cleversburg Road, by a curve to the right having a bearing of North 22 degrees 55 minutes 23 seconds West, a distance of 86.23 feet to a point; thence along Lot No. 9 of Plan for John H. Billaman, North 68 degrees 05 minutes 37 seconds East, 172.31 feet to a point at other lands of John Billman, North 68 degrees 05 minutes 37 seconds East, 172.31 feet to a point at other lands of John Billman; thence along the latter; South 23 degrees 06 minutes 56 seconds East, 80.12 feet to a point at corner of Lot No. 11 on hereinafter mentioned Plan; thence along the latter; South 66 degrees 03 minutes 36 seconds West, 172.58 feet to a point, THE PLACE OF BEGINNING. CONTAINING 14,357.2 square feet and being Lot NO. 10 as shown on the Plan of Walnut Grove recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 41, Page 59. Vested by Special Warranty Deed, dated 07/13/1998, given by JOHN H. BILLMAN to BAZIL F. DOYLE, JR. and JUDITH A. DOYLE and recorded 7/28/1998 in Book 182 Page 140 Instrument # 1998-025185 PREMISES BEING: 251 NEIL ROAD, SIIIPPENSBURG, PA 17257-0000 PARCEL NO. 39130102040 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-8228 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP, Plaintiff (s) From BAZIL F. DOYLE, JR a/k/a BAZIL F. DOYLE & JUDITH DOYLE (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 $145,972.65 L.L. Interest from 1/16/10 to Date of Sale ($24.00 per deim) -- $7,848.00 Atty's Comm % Atty Paid $848.33 Plaintiff Paid Date: 8/3/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs D. Buell, rothonotary By: Deputy Name: JAIME McGUINNESS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 90134 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, Known and numbered as, 251 Neil Road, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: a.,, Real Estate Coordinator Mlkbe Patriot-News Co. 2020 Technology Pkwy Suite 300 ilechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE i4tPatriot•News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Comm nwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisl irg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newsp pers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The P? riot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all hav 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 a J/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interes ?d in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place ? id 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 f The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockh Iders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and )r said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. F JBLICATION COPY This ad ran on the date(s) shown below: '009-8228 Chill Term 10/15/10 BAC tome Loans Servicing, LP vs 10/22/10 Bazi F. Doyle, Jr, a/k/a Bazil F. Doyle 10/29/10 Judith Doyle tty: Danlel Schmieg By virtu of a Writ of Execution NO. 09-8228 • • • • • . CIVILI RM BAC H( 4E LOANS SERVICING, L.P. 1 vs . Sworn to ?dZw scribed b' re me?this 10 cla* of November, 2010 A.D. BAZIL DOYLE DOYLE, JR WA BAZIL F. JUDITI; )OYLE 1 ?• %? owner(s) f property situate in Southampton Townshil Cumberland County, Pennsylvania, Notary Public being (Municip ty) 251 NEI ROAD, SHIPPENSBURG, PA 17257-001 Parcel Nc >9130102040 (Acreage street address) COMMONWEALTH OF =mKirvLVAkn Improverr its thereon: RESIDENTIAL !r DWELLL G Notarial seal JUDGMI +'TAMOLNT. 4145.972.65 j Sherrie L Kisner, Notary public Lower Paxton Twp., Dauphin County My Commisslon Expires Nov. 25, 2011 Merrn a,, Penn_?Mvania Association of Notaries 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. isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 5 da of November, 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2009-8228 civil BAC Home Loans Servicing, LP VS. Bazil F. Doyle Jr a/k/a Bazil F. Doyle Judith Doyle Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 09-8228 CIVIL TERM, BAC HOME LOANS SERVICING, L.P. vs. BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE, JUDITH DOYLE, owners of property situate in Southampton Township, Cumberland County, Pennsylvania, being 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000. Parcel No. 39130102040. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $145,972- .65. 36 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Attorney For Plaintiff One Penn Center Plaza n Philadelphia, PA 19103 G 215-563-7000 Q Zn?-- BAC HOME LOANS SERVICING, Court of Common Pleas L.P. Plaintiff vs BAZIL F. DOYLE, JR A/K/A BAZIL F DOYLE JUDITH DOYLE A/K/A JUDITH A DOYLE Defendant Civil Division • ?O CUMBERLAND County Tpz No. 09-8228 CIVIL TERM PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P., 2352 TO THE PROTHONOTARY: Kindly substitute Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based are as follows: Plaintiff BAC Home Loans Servicing, LP has merged with and into Bank of America, N.A. under the provisions of the National Bank Act. Bank of America, N.A. is successor by merger to BAC Home Loans Servicing, LP and, as a matter of federal law, is deemed to be the same company as BAC Home Loans Servicing, LP and all rights, franchises, and interests of BAC Home Loans Servicing, LP in and to every type of property (real, personal, and mixed) and choses in action are transferred to and vested in Bank of America, N.A., without any deed or other transfer. Accordingly, the name of the plaintiff has changed to Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP. Kindly amend the information on the docket Date: October 11, 2011 24RI-? =NAN & SCHMIEG, LLP Attorneys for Plai Printed Name: Bar Id. No. PHS# 222699 Attorneys for Plamttff Q 'r1 o- ? is y,? ok-0111501'?-f 1,., ?2 aeac?? Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff BAC HOME LOANS SERVICING, L.P. Plaintiff vs BAZIL F. DOYLE, JR A/K/A BAZIL F DOYLE JUDITH DOYLE A/K/A JUDITH A DOYLE Defendant Court of Common Pleas Civil Division CUMBERLAND County No. 09-8228 CIVIL TERM PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please mark the judgment in the above-captioned matter to the use of Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP ?Jc 7105 Corporate Drive, Plano, TX 75024. Date: October 11, 2011 PTML IALLINAN & SCHMIEG, LLP Attorneys for Plat t V, Printed Name: Bar Id. No. PHS# 222699 Attorneys for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Attorney For Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BAC HOME LOANS SERVICING, Court of Common Pleas L.P. Plaintiff Civil Division vs CUMBERLAND County BAZIL F. DOYLE, JR No. 09-8228 CIVIL TERM A/K/A BAZIL F DOYLE . JUDITH DOYLE A/K/A JUDITH A DOYLE Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Bank of America, N successor by merger to BAC Home Loans Servicing, LP. Date: October 11, 2011 INAN&-g-CHMIEG, LLP Attorneys for PlaintPrinted Name: #1 t ?? Bar Id. No. PHS# 222699 Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 BAC HOME LOANS SERVICING, L.P. Plaintiff V. BAZIL F. DOYLE, JR A/K/A BAZIL F DOYLE JUDITH DOYLE A/K/A JUDITH A DOYLE Defendant CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe to mark judgment to Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP and substitution of party plaintiff was served by regular mail to the person(s) on the date listed below: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-8228 CIVIL TERM CUMBERLAND COUNTY BAZIL F. DOYLE, JR A/K/A BAZIL F DOYLE JUDITH DOYLE A/K/A JUDITH A DOYLE 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 Date: 1-?J'741 /1( 1- /11 &1 By: PHS# 222699 & SCHMIEG, LLP Attorneys for Plai? * 11,14.01 _ Printed Name: M- srtj Bar Id. No. Attorneys for Plaint T WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 09-8228 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., as Successor by merger to BAC HOME LOANS SERVICING, LP, Plaintiff (s) From NDITH DOYLE (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: $145,972.6.5 L.L.: Interest from 1/16110 To Date of Sale ($24.00 per diem) -- $25,320.00 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $1,579.66 Other Costs: Plaintiff Paid: Date: 8/3Yf12 (Seai) l David D. Buell, Prothonot Deputy RE~IJEST I~I(~a li'ARTY: Name;: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) I~ P.R.C.P.3180-3183 ', BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff v. JUDITH DOYLE Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 01/16/2010 to Date of Sale ($24.00 per diem) TOTAL COURT OF COM CIVIL DIVISION NO.: 09-8228 CN CUMBERLAND CO G ~1° .,0.3 +.~ ~~ ~ $145,972.65 ~~ ~ $25,320.00 ~~ ~ -< ~ Phi man & Schmi~g; LLP Allison W ,Esq., Id. No.309519 Attorney for Plaintiff Note: Please attach description of property. PHS # 222699 l~J '~ d8.5p PQ a-rt~/ ova. oo C8~' (ow5. g3 -i 104.43 " r/Q $0 11 11l~+. 00 6I~. 0 0 " a1~.00 u 8 0O ., ~ !, 579. ~ ~ - ~o Any ~a.a5 ~ ~ C~ laaa~~ e~asc~8 ,~E ~ ~~-~ PLEAS c~ '+1 --~ ~~ rn -mm ~~ c~ ~~ Ca .~:: -c a~ .o ~` ..., •.. O w a cv c ~' a ~>7 W~ Ua a ~~ ~~ ~~ ~a ~~ o ~~ °~ ~a ~o~ a U~ ~~a ~~ U ~~ ~v aar~ z O w 0 ,-, ~ O ~ xQ ~ W i v a• ~A~ ~'Q ~~a a~ a ~°z "~ a( y 0.Y .~ ~ ~. ~~~° ~; ~ ~° o a¢¢ fnldec (09/09) UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA In re: Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden, and trade): Bazil F Doyle 105 Rustic Drive Shippensburg, PA 17257 Chapter 7 Case No. 1:10-bk-03397-MDF Judith A Doyle 105 Rustic Drive Shippensburg, PA 17257 Last four digits of Social-Security, Individual Taxpayet~Identification, Employer Tax-Identification No(s)(if any): xxx-xx-6698 xxx-xx-6980 FINAL DECREE The estate of the above named debtor(s) has been fully administered. IT IS ORDERED THAT: Leon P. Haller (Trustee) is discharged as trustee of the estate of the above-named debtor(s); and the chapter 7 case of the above named debtor(s) is closed. BY THE COURT Dated: A~tp,tst 30.2010 ~`~~~ Mary D. France United States Bankruptcy Judge This document is electronically signed and filed on the same date. Case 1:10-bk-03397-MDF Doc 23 Filed 08/30/10 Entered 08/30/10 22:01:07 Final Decree Closing Case Page 1 of 1 PHELAN HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO COURT OF COM BAC HOME LOANS SERVICING, LP Plaintiff CIVIL DIVISION v. NO.: 09-8228 CIVI JUDITH DOYLE Defendant(s) CUMBERLAND CERTIFICATION ~ ~ .~~ ~:' The undersigned attorney hereby states that he/she is the attorney for the Plaintiff i ab®e matter and that the premises are not subject to the provisions of Act 91 because: ~~ w ~: -c -_ ~..~ (X) the mortgage is an FHA Mortgage ="~,,° ~ ~: --t, ~; ( ) the premises is non-owner occupied ?~ -- ~ ~' ' ( ) the premises is vacant ( ) Act 91 procedures have been fulfilled -~ ~ ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 39 3 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 unsworn authorities. PLEAS to ieslydt-Schmieg, LLP ells, Esq., Id. No.309519 Plaintiff BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff v. JUDITH DOYLE Defendant(s) COURT OF COMMON CIVIL DIVISION NO.: 09-8228 CIVIL TE CUMBERLAND COU PHS # 222699 AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the folio information concerning the real property located at 251 NEIL ROAD, SHII''PENSBURG, PA 17257-0000. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 BAZIL F. DOYLE, JR A/K/A BAZIL F. DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 2. 3. 4. 5. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE PLEAS in the C e~ ~ N ~ ~ -t~° W "" -- ~~ s~ d Z ~_ ~~ p~ --~ -4 ~ ;~ -a Name and last known address of every judgment creditor whose judgment is a record lien on the real property to sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT BAZIL F. DOYLE, JR COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY UNIT, ESTATE RECOVERY PROGRAM DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 6TH FLOOR, STRAWBERRY SQ. DEPT 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 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 t to the of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. _..~ , Date: lan Hallinan chmieg, LLP Allison a s, Esq., Id. No.309519 Attorney for Plaintiff by the may BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO COURT OF COMMON BAC HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: vs. JUDITH DOYLE CUMBERLAND COUN Defendant(s) c ``' w s -~ M NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ~~ w TO: JUDITH DOYLE p ° 3 ~'`''' 251 NEIL ROAD ~:° -' ~"`? SHIPPENSBURG, PA 17257-0000 -~ ..,.: **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION O TAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BAN UPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT NLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 251 NEIL ROAD, SHIPPENSBURG, PA 17257 '-0000 is scheduled be sold at the Sherii~'s Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hano er Street, Carlisle, PA 17013 to enforce the court judgment of 5145,972.65 obtained by BANK OF AME CA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP (the mortgagee) ainst you. In the event the sale is continued, an announcement will be made at said sale in compliance with a.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, cost and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 xl 30. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the j if the judgment was improperly entered. You may also ask the Court to postpone the sale for good ca 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance ~ou will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPER"1'Y A1Vll Yuu Havr: vrri~x xiuti ~ a EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. ~ 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find ut the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate c pared 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 ut if this has happened, you may ca11215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the prope as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the heriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule f distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) d ys after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection i his office. This schedule will state who will be receiving that money. The money will be paid out in acco dance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with th Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immed ately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA E A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED B LOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE Z LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN LOT, TRACT OF LAND, PARCEL, PIECE OF GROUND WITH THE BUILDINGS AND IMPROVEMENTS THEREON ERECTED, SITUATE IN SOUTHAMPTON TOWNSHII', CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE CENTERLINE OF CLEVERSBURG ROAD AT CORNER OF L NO. 11 ON THE HEREINAFTER MENTIONED PLAN; THENCE ALONG THE CENTERLINE OF CLEVERSBURG ROAD, BY A CURVE TO THE RIGHT HAVING A BEARING OF NORTH 22 DEGREES 56 MINUTES 23 SECONDS WEST, A DISTANCE OF 86.23 FEET TO A POINT; THENC ALONG LOT N0.9 OF PLAN FOR JOHN H. BILLAMAN, NORTH 68 DEGREES OS MINUTES 37 SECONDS EAST, 172.31 FEET TO A POINT AT OTHER LANDS OF JOHN BILLMAN, NORTH 68 DEGREES OS MINUTES 37 SECONDS EAST, 172.31 FEET TO A POINT AT OTHER LANDS OF JOHN BILLMAN; THENCE ALONG THE LATTER; SOUTH 29 DEGREES 06 MINUTES 56 SECONDS EAST, 80.12 FEET TO A POINT AT CORNER OF LOT NO. I 1 ON HEREINAFTER MENTIONED PLAN; THENCE ALONG THE LATTER; SOUTH 66 DEGREES 03 MINUTES 36 SECONDS WEST, 172.58 FEET TO A POINT, THE PLACE OF BEGINNING. CONTAINING 14,357.2 SQUARE FEET AND BEING LOT NO. 10 AS SHOWN ON THE PLAN OF WALNUT GROVE RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNT'' IN PLAN BOOK 41, PAGE 59. TITLE TO SAID PREMISES Vested by Special Warranty Deed, dated 07/13/1998, given by JOHN H. BILLMAN to BAZIL F. DOYLE, JR. and JUDITH A. DOYLE and recorded 7/28/1998 in Book 182 Page 140 Instrument # 1998-025185 By virtue of the death of BAZIL F. DOYLE; JR on 12/08/2011, Judith Doyle became the sole owner of the premises as surviving joint tenant with the right of survivorship. PREMISES BEING: 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000 PARCEL N0.39134102040 SHORT DESCRIPTION .~ By virtue of a Writ of Execution N0.09-8228 CIVIL TERM BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP vs. JUDITH DOYLE owner(s) of property situate in SOUTHAMPTON TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 251 NEIL ROAD, SHIPPENSBURG, PA 17257-0000 Parcel No. 39130102040 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: 5145,972.65 Phelan Hallman & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 w , ~ ~ IN 'FHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA BANK OI~ AMERICA. N.~~. AS SUCCESSOK B~' MERGER TO BAC HOME f,OANS SERVICING, LP Court oT Common Pleas Civil Division Plaintiff v. CUMBERLAND County No.: 09-8228 CIVIL "TERM JUDITH DOYLE Defendant KULE AND NO~~. this~~ _ da~~ o~ ~ 2012, a Rule is entered upon the Defendant to show cause why an Urder should not be entered granting Plaintiffs Motion to Reassess Damages. Defendant shall have t~~~cnt~~ (20} da_y~s from the date of this Order to file a response to Plaintiff s Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Ruie Absolute and no hearing will be scheduled on this mat HE J. ~ ~he~c~~, ~~ ~jrr-QH `~ ~im'~ / Sud, ~ 1jBy/~ C9p~es ~,~l~d rof~~~~a ~~ ~.. ~, ~~_: ~ r - - ; . :.._:, , , _._ -. n y. _~ 222699 ~~Ilison F. Wells. Esq.. [cl. A~c~.309~ L~) Phelan Hallman & Schmie<~. i1,P 1617 JFK Boule~,ard, Suite 1-00 Philadelphia. PA 19103 I'1:L: (`? 15) 563-7000 ':,~~: (215) 563-3459 ~~~ 1tillI"hH DOYL[~ 105 RUSTIC DR >f I(PPFNSBURG. P~'1 l 7257-K7>0 l~ -°I) ~a; ~', ,IUDITH DOYLF. 251 NE1L ROAD SHIPPENSBURG, PA 17257-0000 »~~nn ?22699 _. ~ . ' S. r I _ . 1. ... i .., a. 1 . ~ p, t ~ t v a ., PHF,LAN HALLINAN & SCHMIEG, ILL' ~'~ ~ ~ ~ ~~' ~~, ~-~_~~~ ~~ ~ '~~ by: Allison F. Wells, Esquire, Atty. I.D. No. 309519 1617 John F. Kennedy Boulevard; Suite 1400 Philadelphia, PA 19103-1814 ] 5) 563-7000 _ BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff v. JUDITH DOYLE ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Cumberland County No.: 09-8228 CIVIL TERM Defendants PRAECIPE TO SUBSTITUTE EXHIBIT To the Prothonotary: Please attach the following Concurrence letter and Certificate of Mailing as Exhibit "C" to Plaintiff's Motion to Reassess Damages which was filed with the court on or about October 12, ?012. DATE: ~ v~- Phelan Hallinan &fS~rrrrie~~~;~ ~_ ~.-~_°._~ rte. ,_ ~'~> ~'// Allison F. Wells, Esquire Attorney for Plaintiff EXHIBIT "C" PHELAN F[ALLINAN & SCHMIEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Nallinan & Schmieg, LLP Representing Lenders in Pennsylvania and I~e«• .Jersey October 2, 2012 1UDI'TH DOYLE 105 R(JS~I•IC DR SHIPPENSBIJRG, PA 17257-8750 RE: BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC I~C>.~!1F [.(:>,qNS SERVICING, I~P v. JI7DITH I)OYLE Premises Address: 251 NEIL ROAD SHIPPENSBI7RG, PA 17257 CUMBERLANl7 County CCP, No. 09-8228 CIVIL TERM Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and t)rder. In accordance with Ctunberland Coluzty Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond tip me within ,days, by 10/09/:?012. Should you have further questions or conceals, please do not hesitate to convict r~;~e. C-the--wise, please be guided aceardingly. Very truly yours, =~Ilisoiul~ ~'cl1s., (";~;j-~fr~-t~ezti09519 Attorney for Plaintiff Enclosure ='.?699 ~`it l 7.I.pZ ZQ1~ 9SLLLZbOQQ o£~I~+~~ ~ ~++1t ZO .:y1A09.A)tiA4t ~" ~3,~ •!' !! GT gcuvs '~ ~ ~' 'R G o ~ ~ ~ ~ d ~ R a 'Eb fi .-'? ~ F G =_ D ~ ~ ~ 3 ~ C is W V ~ ~ ~ ~ u 4. a d 3 ~ ~~ u ~~ w O 'o°`~' ~ o E E ~ ~ a . s"$ 4 +c e ppGo." ~ v ~ ~ ~ 3y~N._ x .~ .~ E ~ ~'at'c- ~ ~ ~ "C '~ a u p E ~~ zo ~ ~ Q v"a Q ~ r ~ G >- .~.) ° ..]°v ~ °° ° ° ~' ~ ~ ~ ~ a~ v i ~ N N ~. r ~"' ~~' 0 ~ `i' a a s rn 'o _, a, ~ ¢ ni ..~ a ,.~ CG ~. G a ~ ~ ~o ~~ ~v ~ ''° ~ U n ~~c~n F ~ ° o ~ a ~ a, ~" AG 0, -~ ~ a "s ~ a'°oa z ~°v~ ~N~ a ~~ .~ s ~ z * * ~ * ,~ ~ ~~ .~ ¢ o ~ ~~ ~~~ t b C .+ N z~ t.... a . B 57 1 ,,~-'"~p t~ 1 L ~~ ~ ~~ ~ ~ '. .~, ,o J, r ti o ~' ^' •,, w~ W N ~'`~ By; Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS St1CCESSOR BY MERGER TO BAC HOME LOANS SERVICING, I~P Plaintiff v. JUDITH DOYLE Defendants ATTORNEY FOR P1..^~iN"CIFF Court of Common Pleas Civil Division Cumberland County No.: 09-8228 CNIL TERM CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of Plaintiff s Praecipe to Substitute Exhibit was sent to the following individuals on the date indicated below. JUDITH DOYLE 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 DATE: /I ~ ~ /' ~-~'"~ JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 ~..._. Phelan Hallman &~ ..p w ~~ _.. .. R_ s:..._ y' - - _ Allison F. Wells, Esq., Id. No. 309519 ATTORNEY FOR PLAINTIFF Phelan Hallinan & Schmieg, LLP Allison F'. Wells, Esq., Id. No.309519 ~ ~~~ ~ ~ ~'' ~~~`' ~`TTORNEY FOR PLAINTIFF 161.7 .iFK Boulevard; Suite 1400 ~ -~ ~; ~.1 lV1 i e„ One Penn Center Plaza ~~~ ~~ ~.+~~, E ~:~~, Philadelphia. PA 19'103 215-~63-7000 BANK OI~ AMERICA, N.A. AS SIICCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff vs. JUDITH DOYLE Defendant Phelan CERTIFICATION OF SERVICE I ]hereby certify that a true and correct copy of the Court's October 17, 2012 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated belo~~~. JUDITH DOYLE 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 1 1257-0000 DATE: Court of Common }'leas Civil Division CUMBERLAND County No.: 09-8228 CIVIL "I~ERM LLP ~~ Allison ~. ells, Esq., Id. No.309519 Attorney for Plaintiff 222699 ~ I ~ e i~' ~'' dL.t... Phelan Hallinan & Schmieg, LLP ~ ~ 2 ~~~ ~' ~ ~~ (0 ~ 2 3 Melissa J. Cantwell, Esq., Id. No.30891~,s4,~ly~~ f~L~al~D ~~~~ORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 ~.~,~iSYL~At~lA One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP Civil Division Plaintiff CUMBERLAND County vs. No.: 09-8228 CIVIL TERM JUDITH DOYLE Defendant MOTION TO MAKE RULE ABSOLUTE BANK OF AMERICA, N.A. A5 SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, by and through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. A Motion to Reassess Damages was filed with the Court on October 12, 2012. 2. In accordance with Cumberland County Local Rule 208.3(9}, Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on October 2, 2012 and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit "A". 3. A Rule was issued by the Honorable Edward E. Guido on or about October 17, 2012 directing the Defendant to show cause by November 6, 2012 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit "B". 4. The Rule to Show Cause was timely served upon all parties on October 31, 2012 in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit "C". 222699 5. Defendant failed to respond or otherwise plead by the Rule Returnable date of November 6, 2012. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff s Motion to Reassess Damages. Phelan H linan & Schmieg, LLP NOV 08 2012 DATE: By: Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff 222699 Exhibit "A" 222699 PHELAN HALLINAN & SCHMIEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215} 563-7000 FAX#: (215) 563-3459 Phelan Hallinan & Schmieg, LLP Representing Lenders in Pennsylvania and New Jersey October 2, 2012 JUDITH DOYLE 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 RE: BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP v. JUDITH DOYLE Premises Address: 251 NEIL ROAD SHIPPENSBURG, PA 17257 CUMBERLAND County CCP, No. 09-8228 CIVIL TERM Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by 10/09/2012. Should you have further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. ..~-~ Very truly yours, v ~ , Atli sn~~1"~~.~~ic~t,09519 Attorney for Plaintiff Enclosure 222699 ~ i ~~~ ~~ .f~~ .o N N N A~ 0 n, ,~1~ Exhibit "B" 222699 t..~ '~,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA, N.A. AS SUCCESSOR BY Court of Common fleas MERGER TO BAC HOME LOANS SERVICING, LP Civil Division Plaintiff , CUMBERLAND County v. : No.: 09-8228 CIVIL TERM JUDITH DOYLE Defendant RULE AND NOW, this~~+ .day ofL~~~-O©2012, a Rule is entered upon the Defendant to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this,m '' ~~.~ f ~`°1'I-ll -~ J. 4' ? r-.x ~~~~ _:.3 ... %J7 i__ _ ~~ F,. ~ _ ~ ~ ::. ""L% ~_~ ~._Y ~'. _~ 222699 Exhibit "C" 222699 I ' . ~. ' . ~ 4, i t 1 Y~. t!fl£R .. _. a r & V . a , Phelan Hallinan & Schmieg, LLP ~ ~ ; , Allison F. Wells, Esq., Id. No.309519 w ~ `~~~~1`{~S1~Ey FOR PLAINTIFF 1617 JFKBoulevard, Suite 1400 ~ '` ~~~~ 1'~~I}~.~; t= One Penn Center Plaza. ~'~` ~',~,`~ P Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff vs. JUDITH DOYLE Defendant Court of Common Pleas Civil Division CUMBERLAND County No.: 09-8228 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's October 17, 2012 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. JUDITH DOYLE 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 ~. A DATE: . .`__ JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 yam, . _ . Phelan I-l~~lii:t»~ c~.~cltn~ie~, LLP IIu: _~_ _ 1~,lfi~rii"T`:`tWelis, Esq., Id. No.309519 Attorney for l'l~untiff 222699 M Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff vs. JUDITH DOYLE ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 09-8228 CIVIL TERM Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Motion to Make Rule Absolute was served upon the following individual on the date indicated below. JUDITH DOYLE 105 RUSTIC DR SHIPPENSBURG, PA 17257-8750 DATE: JUDITH DOYLE 251 NEIL ROAD SHIPPENSBURG, PA 17257-0000 Phelan H linan & ieg, LLP NOV 0 8 1012 By: issa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff 222699 PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Meredith Wooters, Esq., Id. No.307207 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ~ ~~ Philadelphia, PA 19103 -•~ ~ N 215-563-7000 ~r~;,.~,~ ~~w' C"3 IN THE COURT OF COMMON PLEAS -<~' c~ OF CUMBERLAND COUNTY, PENNSYLVANIA ~ c BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff, v. JUDITH DOYLE Defendant(s) ~~ ~ CUMBERLAND COUNTS ~ ;~ << COURT OF COMMON PLE?~S CIVIL DIVISION No.: 09-8228 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: -~' -. rrl _.~ P" ~ ~: c~ °-+o -~~ ~~ -,~.; .A. +.., ~- ~~ As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". Meredith Wooters, Esq., Id. No.307207 j} i l Attorney for Plaintiff Date: _ V / O~ IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 222699 'r ~. CD .1 to U A W !J ~* r'. ~~ ~ ~ a'4 i~ k • lF 4 4 Y ll! 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