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Home My WebLink About09-8307GULDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 W W W.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased 41 Pine Street Carlisle, PA 17013 Defendant IN THE COURT OF PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Nom. bq - aso7 CNi( CML ACTION: MORTGAGE TerM 1=t1Rle1 F NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRTTA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. ` RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUID USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELIRFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERIR CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, IRSTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homwwners/reaf.Mx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafcd.orz/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention ani. oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 90819FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendant is AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased, 41 Pine Street, Carlisle, PA 17013. AMY J. THRONE, Individually is hereby released from personal liability for the debt secured by the mortgage. GREGORY THRONE died on November 21, 2008. Letters of Testamentary were granted to AMY J. THRONE on January 22, 2009 in the register of wills of Cumberland County. 3. On January 16, 2008 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Instrument #200801997. The mortgage has been assigned to: BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "Al' ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$184,817.84 Interest from 04/01/2009 through 11/12/2009 at 6.0000% .......................$6,865.88 Per Diem interest rate at $30.38 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$9,240.89 Late Charges from 05/01/2009 to 11/12/2009 .............................................$407.26 Monthly late charge amount at $58.18 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $330.35 $202,231.87 7. If the Mortgage is reinstated prior to a Sheriffs Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attomey's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attomey's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose has been sent to Defendant by certified mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $202,231.87, together with interest at the rate of $30.38, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: t - GOLDBECK McCAFFERTY & Mc EVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Michael T. McKeever, Esquire, hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the Verification could not be obtained within the time allowed for the filing of the pleading that he is authorized to make this verification pursuant to Pa.R.C.P 1024(c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon the information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: wink Michael T. McKeever, Esquire PA I.D. #56129 #90819FC AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased 41 Pine Street Carlisle, PA 17013 Prepared By and Return To: Referral Department GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 GMM File Number: 90819FC Parcel ID#: 40-22-0487-133 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORPORATION (Assignor), for and inconsideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer to BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP. BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP. (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed GREGORY THRONE , Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR TAYLOR, BEAN & WHMAKER MORTGAGE CORPORATION. Bearing date of: January 16,2008; Amount Secured: $187,51800; Recorded on January 18, 2008; in Instrument #200801997; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 41 Pine Street, Carlisle,PA 17013 AS FURTHER DESCRIBED IN EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate corporate officers, h s executed and sealed with its corporate seal this Assignment of Mortgage on this day of VW ? 2009. MORTGAGE ELECTRONIC REGIS ION SYSTEMS, INC., ACTING SOL Y AS NOMINEE FOR TAYLOR, BEAN & AKER MORTF6A? A (Affix Corporate Seal) Name: CYle. " Vick Title: V1??WC: ? t *C? (SEAL) Name: Title: wt (in s C ?. l ss: STATE OF?tJ1-,- ) COUNTY OF -) BE IT REMEMBERED, that on this2"0ha of L2&ag?t6 2009, before me, the subscriber, a Notary Public personally appeared _ A officers of Assignor, who I am satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary act and deed of such corporation made by virtue of a Resolution of its Board of Directors. Notary Public My commission expires: -.•` ?f, '3 I hereby certify the address of the Assignee is: EMYE IOA PAWUS Notary Pubk STATE OF TEXAS Cdnm. Ems. Oi=2413 Case #: 90819FC ExhibitA LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements fluted *MM situate in South Middleton Township, Cumberland county, Pennsylvania, as further descnibed in the Final Subdivision and Land Devel opmeRt Plan for DMM E ttetiprMs dated March 24, 2003, last revised September. 23, 2003, prepared by Haft= and Associates, Inc. and recorded in the Office of the Recorder of Deeds in and for Ctanbecland county, Pennsylvania in Plan Book 88 Page 8, bounded and described as follows: BEGINNING at a point along Pine Street at the dividing line betwwn Lot 13 and Lot 14 as shown on the above referenced plan; thence by said Pine Street, North 50 degrees 45 minutes 00 seconds West 56.00 feet to a point at the dividing lane bwMar Lot 12 and Lot 13 as shown on the above referenced plan; thence by said dividing line North 39 degrees 15 minutes 00 seconds East 120.00 feet to a point at the dividing line between Lot 13 and Lot 19 as shown on the above referenced plan; thence by said dividing line South 50 degrees 45 minutes 00 seconds East 56.00 feet to a point at the dividing line between Lot 13 and Lot 14 as shown on the above referenced plan, thence by said dividing line South 39 degrees 41 minutes 55 seconds West, 120.00 feet, the place of BEGINNING. BEING Lot 13 and containing 0.1543 Acres and being known and numbered 41 Pine Street, Carlisle, PA BEING a portion of the same premises which J. Benson Whitcomb by Deed dated 6/12/03 and recorded 6/13/03 in Cumberland County Deed Book 257-2933, granted and conveyed unto Sterling Trust Company, Custodian F/B/O MahamoW Mohammad, Account Number 064846. ?hibit 0 BaskefAm wka'401' HMO LOOM PO Box 9048 Temecula, CA 92689-9N8 Send Payments ro: PO BOX 650070 Dallas, TX 75265-0070 Send Comesponalmme aa: PO Banc 5170, MS SV314B Simi Valley, CA 93065 11 1 7113 8 7 1473 "1 MOUS8 Gregory Throne 41 PINE ST CARLISLE, PA 17013-3137 20090OW-7 BLOPA2 PRESORT First-Class Mail U.S. Post" and Feas Paid WSO 1128- 29 L 11mikelf America -4W P.O. Box 850070 Send Payrrmft to: Dallas, 7X 75286-0070 P.O. Box 850070 Dallas, 7X 75285-0070 September 8, 2009 Certified Mail 7113 8257 1473 5951 0058 Return Recelot Reauested Gregory Throne Account No.: 22551897 41 PINE ST CARLISLE, PA 17013-3137 Property Address: 41 Pine Street Carlisle, PA FHAA/A Case #: 4418137891703 NOTICE OF INTENTION TO FORECLOSE BAC Home Loans Servicing, LP (hereinafter 'BAC Home Loans Servicing, LP") services the home loan described above on behalf of the holder of the promissory note (the 'Noteholder'). The home loan is In serious default because the required payments have not been made. The total amount now required to reinstate the loan as of the date of this letter is as follows: 05101/2009 $7,273.10 Other Charges: Uncollected Late Charges: $0.00 Uncollected Costs: $0.00 Partial Payment Balance: ($0.00) TOTAL DUE: $7,273.10 You may cure this default within THIRTY-FIVE (35) DAYS of the data of this letter. To cure the default, BAC Home Loans Servicing, LP must receive the amount of $7,273.10, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due during this period. Such payment must be in the form of certified check, cashier's check or money order, and made payable to BAC Home Loans Servicing, LP at P.O. Box 650070, Dallas, TX 75265-0070. If any check (or other payment) Is returned to us for insufficient funds or for any other reason, 'good funds" will not have been received and the default will not have been cured. No extension of time to cure will be granted due to a returned payment if this default is not cured within THIRTY-FIVE (35) DAYS, the mortgage payments will be aacelereed. This means whatever is owing on the original amount borrowed will be considered due Immediately and you may lose the chance to have the original mortgage paid off In monthly installments. If the full payment of the amount of default Is not made within THNtTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. If the mortgage Is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the default is cured before we begin legal proceedings against the collateral involved, BAC Home Loans Servicing, LP and the Notshotder will be entitled to collect the reasonable attorney's fees actually inured, up to $50.00. However, if legal proceedings are started the reasonable attorney's fees will have to be paid even If they are over $50.00. Any attiorrrey's fees will be added to whatever is owed to us, which may also include our reasonable costs. If this default is curled within the Th ft4ive (35) day period, the attorney's fees will riot be required to be paid. YOU HAVE THE RIGHT TO IMOOSTATE AFM ACCELE:RATKM AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON4!XIS1ENCIL OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If the default has not been cured within the TMrtywfive (35) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the elate at any time up to one hour before the foreclosure sate. To do so, the total due, as well as all reasonable attorney's fees and costs incurred in connection with the foreclosure sale (and any other requirements under the mortgage) must be performed. Your loan is in default Pursuant to your loan documents, BAC Home Loans Servicing, LP may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ti) verify that the property is occupied and/or (Ill) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's Interest in the property (including, but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-AeacNbed inspections and property preservation efforts wtN be charged to your account as provided in your security Instrueaerrt. It Is estimated that the earliest date that such a foreclosure sale could be held would be approximately six (6) months from the BAC Hans Loans Servicing, LP is a su bsidary of Bank of Ameriea, N.A. Please writ your accnuad rranbx on al dwoks and mrteapordaim. We may darge you a tee for any payment mtumod or ralecbd by yourfinanGW insiLfon, "ad to applicable law. 9LGPA2 8338110793 00103r2" PglanR IAtOlxlt NuMber 22551SR-6 Bey Due for cimryes fated above: $7,273.10 as or September 8, 2DO9. Make your dtedd payable to RAC """j Throne Nome Loves senddnc. LP 41 Pine Street Pleas updad wmail Womation on m? nveae aide of Bt coupon. • om't sand cash Carlble, PA ?r • Please indude ooupon r.iih your p2r-d 8LQPA2 Far dl full month payment pvioda, I ft st is odolasled on a morally baaia Aoowdh*. unrest for al ItA mantM. indu&V February . le adalaad as 3013e0 of araald intveri, inespedve of to soW maul or of days in fie monk For pvrd mane, invert y odalated daily on the bade of a 3W day yew. X001 SAC Homo Loans Servicing, LP Da BOX 650070 Dallas, TX 75265-0070 11...LL1... LLI l... 1.1.11...11 ...I...HL..I...l ll...... ll l 711W 022551897600000727310000727310 1: 5869900 581;0 2 2 5 5 3689 7N' date of this letter. A notice of the date of the foreclosure sale will be sent to you before the sale. You may find out at any time exactly what the required payment will be by calling us at the following number. 1-800-569-4578. This payment must be In the form of cashier's check, certified check or money order and made payable to us at the address stated above. If this default Is cured, the mortgage will be restored to the same position as if no default had occurred. However, the default may not be cured more than three (3) tines in any calendar year. You should realize that a foreclosure sale will end your ownership of the mortgaged property and your right to remain in It. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. BAC Home Loans Servicing, LP wants you to be aware of various options that may be available to you through BAC Home Loans Servicing, LP to prevent a foreclosure sale of your property. For example: a Repayment Plan: It is possible that you may be eligible for some form of payment assistance through BAC Home Loans Servicing, LP. Our basic plan requires that SAC Home Loans Servicing, LP receive, up front, at least "A of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. a Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the curent loan balance. This foreclosure alternative, however, is limited to•certain loan types. a Sale of Your Property: Or, N you are willing to sell your home in order to avoid foreclosure, it Is possible that the sale of your home can be approved through BAC Home Loans Servicing, LP even if your home is worth less than what is owed on It. a Deed-in-Lieu: Or, if your property Is free from other liens or encumbrances, and if the default Is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure altematives with BAC Home Loans Servicing, LP, you must contact us immediately. If you request assistance, BAC Home Loans Servicing, LP will need to evaluate whether that assistance will be extended to you. In the meantime, BAC Home Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise In writing. Failure to bring your loan current or to enter into a written agreement by October 13, 2009 as outlined above will result in the acceleration of your debt. Time is of the essence. Should you have any questions concerning this notice, please contact Loan Counseling Center Immediately at 1-800-869-4578. BAC Home Loans Servicing, LP is a subsidery of Benin of America, NA AceoW Nunbsr.2MtW E-reai um: Providing your e-rnW address below vA albw us lo send you Iribo voilm on ymr acoourt. Greg Throne E-rrrdl address: How as ped your paytawtik A l a asptsd payraWa of prYrdpar.and itwNt WN be appliad lo rho brtgeaI Waiarrdirg I whit art dus, Wass caaaalss exprssdy pre WAN or Unread by Mw. N YOU artanI an arnnurrt it odrlion lo your sdwdrMd rmid* amount, we wo apply your paynrerts as blows: (n b -ftW4% rrrorrsty payments of plndpd and inbreat, (I) esercw dalklandies, (o) IaH drupes and dhar maouts you owe In aaewdian won yarn loan and pv) b redu:s On ardartfip pMbd bdom or your km. Pbaw apadly I you wed an adMbnal mroaat appW b Mss paym.nts, toga then Pealttrat dfaolz PoatlaMd dada wo be poosesd on Ir dale received union a lour corardor agreaa b honor On d+s wroan an Ire deck as a cooMbn d' a repry.ro t plan. O .. s 'OF' P???'F- : NIOTAFN 209 DEC -2 AM 9:22 ,*.a pp AYM 4, M-# a4 i3,53 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.45612.9 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 FILED-OMICIE OF THr ? r ^ .""TARY P.',UG ZZ Pei 3: 44 CUM : ,? ,. GO.Jim BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-315 Plano, TX 75024 Plaintiff vs. AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased Mortgagor(s) and Record Owner(s) 41 Pine Street Carlisle, PA 17013 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Tenn No. 09-8307 Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office.. Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( } Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached) ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully. sub?mp itted, M> BY: Keith C. Halili 90819FC CF: 12/02/2009 SD: 09/08/2010 $215,231.17 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Legal Secretary I i fN - o 4 11 f 3 _ - .r .xjY3 a 1 N z Q __ > If) U W U cc W LL Z W 7 c`ma W / c.. 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O LL I x v, 1-r r Q ` p D O `J N O A- FO N C p ? C m ? .C_ V C m ?j O _ C d O ' 6/ ? r o m ? m ? U) u m ? m a O ul rr) y O a m E ? S ? N c '- Z W Z 3 cor o mdro nx nc w° 1 d ' ? E cn .U LT- ?? 4 O N In a O uJ, LL C.1 i maw??e N ?o=°' 10 1`4 ui m 0 A _ N T U I i - - d I ! C m W T O ? I T d C3 __ m - ' CA: ? 61 Q? v Q S m Q z D R V O £ 0 L o c? o U c 'CS a C: } mm W o a) ?rK C) a) N En 7 U1 ob CO U Y EN F Z LL o G 1 U3 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.456129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano. TX 75024 Plaintiff vs. AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased Mortgagor(s) and Record Owner(s) 41 Pine Street Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-8307 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praeeipe for the writ of execution was filed the following information concerning the real property located at: 41 Pine Street Carlisle, PA 17013 ].Name and address of Owner(s) or Reputed Owner(s): AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased c/o C.J. Haffner, II Esquire 1224 Hillside Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased c/o C.J. Haffner, 11 Esquire 1224 Hillside Drive Carlisle. PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 41 Pine Street Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1 131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE - SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 CHASE CARDMEMBER SERVICES C/O Phillips & Cohen Associates, LLC 1002 Justison Street Wilimington, DE 19801 BEECH PLACE HOMEOWNERS ASSOCIATION 41 Pine Street Carlisle. PA 17013 BEECH PLACE HOMEOWNERS ASSOCIATION I Irvine Row Carlisle. PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. DATED: August-25,2010 GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~gtti~~tr of ~rriaGC7~l~~~ ~~ ~~'~: F1LE0-~JFF1C~ F ~~-~~ P~:O~~}iOPtt~TARY Jody S Smith Chief Deputy Richard W Stewart Solicitor BAC Home Loans Servicing, LP vs. Amy J. Throne 2~2~ OCT' 20 dal 9~ 45 ~-s~~~~~~~~~~®eouN~Y ~Nl~5YLYA~lA Case Number 2009-8307 SHERIFF'S RETURN OF SERVICE 06/26/2010 08:44 AM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 06-26-2010 at 0844 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Amy J. Throne as Executrix of the Estate of Gregory Throne, Deceased, located at, 41 Pine Street, Cumberland County, Pennsylvania according to law. 09/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever on behalf of BAC Home Loans Servicing, L.P., F/K/A Countrywide Home Loans Servicing LP, 7105 Corporate Drive, PTX C-35, Plano, TX 75024, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 867.96 SHERIFF COST: $867.96 October 11, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF . Sa (~ ~Od~ ~~ ~~~~a lc! CauitySuile Sheriff, Teleoscit. Ific. { I`'roldba~tk McCafferty & McKeever BY: Michael T. McKeever Attorney 1.D. #56129. ' Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVII, ACTION -LAW AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased (Mortgagor(s) and Record Owner(s)) 41 Pine Street Carlisle, PA 17013 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 09-&307 AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 41 Pine Street Carlisle, PA 17013 l .Name and address of Owner(s) or Reputed Owner(s): AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased c/o C.J. Haffner, II Esquire 1224 Hillside Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased c/o C.J. Haffner, II Esquire 1224 Hillside Drive Carlisle, PA 17013 3. Name and Iasi known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bweau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 s- ~ y~ 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 41 Pine Street Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE -SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.Q. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 CHASE CARDMEMBER SERVICES C/O Phillips & Cohen Associates, LLC 1002 Justison Street Wilimington, DE 19801 BEECH PLACE HOMEOWNERS ASSOCIATION 4l Pine Street Carlisle, PA i 7013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infornnation and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: March 12, 2010 c ~_, GOLDBECK McCAFFERTY & McKEEVER BY: Barb Hand 09-8307 GO>~DBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-3 5 Plano, TX 75024 Plaintiff vs. AMY 3. THRONE, as Executrix of the Estate of Gregory Throne, Deceased Mortgagor(s) and Record Owner(s) 41 Pine Street Carlisle, PA 17013 Defendants Term No. 49-8347 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLF,CT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: THRONE, AMYL, as Executrix of the Estate of Gregor}' Throne, Deceased AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased clo C.J. Haffner, II Esquire 1224 Hillside Drive Carlisle, PA 17013 Your house at 4] Pine Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $215,231.17 obtained by BAC HOME LOANS SERVICING. L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 09-8307 1. The sale will be cancelled if you pay to BAC NOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or ]-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid 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 fmd out if this has happened, you may call the Sheriff of 717-240-b390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30} days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money_ The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orQ/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR. LAWYEK 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 IiF.LP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 170]3 ALL THAT CERTAIN tract of land with the improvements erected thereon situate in South Middleton Township, Cumberland county, Pennsylvania, as further described in the Final Subdivision and Land Development Plan for DMM Enterprises dated March 24, 2003, last revised September 23, 2003, prepared by Hartman and Associates, Inc. and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 88 Page 8, bounded and described as follows: BEGINNING at a point along Pine Street at the dividing line between Lot 13 and Lot 14 as shown on the above referenced plan; thence by said Pine Street, North 50 degrees 45 minutes 00 seconds West 56.00 feet to a point at the dividing line between Lot 12 and Lot 13 as shown on the above referenced plan; thence by said dividing line North 39 degrees 15 minutes 00 seconds East 120.00 feet to a point at the dividing line between Lot 13 and Lot 19 as shown on the above referenced plan; thence by said dividing line South 50 degrees 45 minutes 00 seconds East 56.00 feet to a point at the dividing line between Lot 13 and Lot 14 as shown on the above referenced plan; thence by said dividing line South 39 degrees 41 minutes 55 seconds West, 120.00 feet, the Place of BEGINNING. BEING Lot 13 and containing 0.1543 Acres and being known and numbered 41 Pine Street, Carlisle, P A BEING the same premises which Sterling Trust Company, Custodian F/B/O Mahmood Mohammad, Account Number 064846 by Deed dated 1/9/2008 and recorded 1/18/2008 in Instrument #200801996 granted and conveyed unto Gregory D. Thorne (deceased). TAX PARCEL #: 40-22-0487-133 • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-8307 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP, f/k/a/ COUNTRYWIDE HOME LOANS SERVICING, Plaintiff (s) From AMY J. THRONE, as Executrix of the Estate of Gregory Throne, Deceased (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 $215,231.17 L.L.$.50 Interest from 4/1/09 to 9/8/10 Atty's Comm % Due Prothy $2.00 Atty Paid $204.40 Plaintiff Faid Other Costs ` Date: 3115/10 , (Seal) Deputy REQUESTING PARTY: :~?ame: DAVID FEIN, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 82628 On June 14, 2010 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 41 Pine Street, Carlisle ,more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: Real Estate Coordinator Z fi; l~ L i ~~~a (~l~Z ~~ ~, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVAI~TIA 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 Januazy 2, 1952, been regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, viz: July 16, July 23, and July 30, 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 chazacter of publication aze true. Li a Marie Coyne~Editor SWORN TO AND SUBSCRIBED before me this 0 da of Jul 2010 Notary __ NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commiaaion Expires Apr 28, 2014 ~ ito. X10!-fiQ7 CMl BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP Va. Amy J. Throne, as Executrix of the Estate of Gregory Throne, Deceased Atty.: Michael McKeever ALL THAT CERTAIN tract of land with the improvements erected thereon situate in South Middleton Township, Cumberland County, ' Pennsylvania, as further described in 1 the Final Subdivision and Land De- velopment Plan for DMM Enterprises dated March 24, 2003, last revised September 23, 2003, prepared by Hartman and Associates, Inc. and recorded in the Olftoe of the Recorder of Deeds in and for Cumberland County, laennsylvarssa in Pfau 19oo1c 88 Pale 8, bounded and described as follows: BEGINNING at a point along Pine Street at the dividing line between Lot 13 and Lot 14 as shown on the above referenced plan; thence by said Pine Street, North 50 degrees 45 minutes 00 seconds Weat 56.00 feet to a point at the dividing line between Lot 12 and Lot 13 as shown on the above referenced plan; thence by said dividing line North 39 degrees 15 minutes 00 seconds East 120.00 feet to a point at the dividing line between Lot 13 and Lot 19 as shown on the above referenced plan; thence by said dividing line South 50 degrees 45 minutes 00 seconds East 56.00 feet to a point at the dividing line between Lot 13 and Lot 14 as shown on the above referenced plan; thence by said dividing line South 39 degrees 41 minutes 55 seconds West, 120.00 feet, the Place of BEGINNING. BEING Lot 13 and containing 0.1543 Acres and being lozown and numbered 41 Pine Street, Carlisle, PA. BEING the same premises which Sterling Trust Company, Custodian F/B/O Mahmood Mohammad, Ac- count Number 064846 by Deed dated 1/9/2008 and recorded 1/18/2008 in Instrument #200801996 granted and conveyed unto Gregory D. .Thorne (deceased). The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c'~e~latriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: ` 07/09/10 07/16/10 07/23/10 Sworn to afid~bscribed before me~thi~d of August, 2010 A.D. i Notary Public ~" COMMONWEAL'; Pi Vii= r'ENNSYLVANli4 Notarial SeaE Shen'Ie L Kisner, Notary Public Lower Paxton 1'wp., Dauphin County My Commission Expires Nov.,?6, 2011 Member, Pennsylvania Association of Notaries Writ No. 2009-8307 Civil Term Bad Home Loans Servicing, LP !~/K/A Countrywide Home Loans Servicing, LP Vs Amy J. Throne, as Executrix of the Estate of Gregory Throne, Deceased Atty: Michael McKeever ALL THAT CERTAIN tract of land with the improvements erected thereon situate in South Middleton Township, Cumberland county, Pennsylvania, as further described in the Final Subdivision and Land Development Plan for DMM Enterprises dated Mazch 24, 2003, last revised September 23, 2003, prepared by Hartrnan and Associates, Inc. and recorded in the Office of the Recorder of Deeds in and fot Cumberland County, Pennsylvania in Plan Book 88 Page 8, bounded aad described as follows: BEGINNING at a point along Pine Street at the dividing line between Lot 13 and Lot 14 as shown on the above referenced'plan; thence by said Pine Street, North 50 degrees 45 minutes 00 seconds West 56.00 feet to a point at the dividing line between Lot 12 and Lot 13 as shown on the above. referenced plan; thence by said dividing line North 39 degrees 15 minutes QO seconds East 120.00 feet to a point at the dividing line between Lot 13 and Lot 19 as shown on the above referenced plan; thence by said dividing line South 50 degrees 45 minutes 00 seconds East 56.00 feet to a point at the dividing line between. Lot 13 and .Lot 14 as shown on the above referenced plan; thence by said dividing line South 39 degrees 41 minutes 55 seconds West,120.01)feet, tha Place ofiBEGINNING. BEING Lot 13-and containing 0.1543 Acres and being known and numbered 4] Pine Street, Cazlisle, P A BEING the same premises which Sterling Trust Company, Custodian FBlO Mahmood Mohammad, Account Number 064846 by Deed dated 1!9!2008 and recorded 1/182008 in Instrument #200801996 granted and conveyed unto Gregory D: Thorne (deceased). COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which BAC Home Loans Ser L P flca Countrywide Home Loans Ser L P is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 15th day of March, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 09 Number 8307, at the suit of BAC Home Loans Ser L P fka Countrywide Home Loans Ser L P against Gregory Throne extrix is duly recorded as Instrument Number 201030012. IN TESTIMONY WHEREOF, I have h reunto set my hand ~. and seal of said office this ~ day of ___ . of Deeds