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Home My WebLink About09-8728. GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 VS. AIMEE DEROBBIO Mortgagor and Record Owner 2168 Chestnut Street Camp Hill, PA 17011 Plaintiff Defendant Term 1R - $7ag 0,iVil CIVIL AG1 0 N: M()RT(-%,?r" 7ei°rm, POTECL-0` U7-7 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU.NBOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DiNERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON 1NFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orWconsumers/homeowners/real. 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. hip •ladelphiafed.orp-/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 homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 91890FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendant is AIMEE DEROBBIO, 2138 Market Street Apartment B, Camp Hill, PA 17011, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On December 04, 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 # 200913380. The mortgage has been assigned to: BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for 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 .................................................................... Interest from 04/01/2009 through 12/09/2009 at 6.0000%..... Per Diem interest rate at $27.72 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph. Late Charges from 05/01/2009 to 12/09/2009 ........................ Monthly late charge amount at $51.45 .....$168,651.29 .........$7,013.16 ....$8,432.56 .......$411.60 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $272.05 $185,408.61 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in 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". The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983 or Act 160 of 1998. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $185,408.61, together with interest at the rate of $27.72, 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: GOLDBECK cCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF 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: 91890FC Parcel ID#: 01-21-0271-446 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, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP. BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed AUKEE DEROBBIO, Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORPORATION. Bearing date of. December 04,2008; Amount Secured: $169,159.00; Recorded on April 29,2009; in Instrument # 200913380; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 2168 Chestnut Street, Camp Hill, PA 17011 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 attornFy jp fact, has executed and sealed with its corporate seal this Assignment of Mortgage on this ay of Qew? bt/, 2009. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF PHILADELPHIA CORPORATION By: Gary E. Mc quire of Goldbeck McCafferty & eever as Attorney in Fact for Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America by the Agreement for SS Signing Authority dated November 2, 2009 On this y of .?be 2009, before me, a Notary Public in and for the County and State aforesaid, the undersigned officer, personally appeared Gary E. McCafferty of Goldbeck McCafferty & McKeever, known to me or satisfactorily proven to be the Attorney in Fact on behalf of Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America noted above and acknowledged that, being authorized to do so, executed the foregoing instrument for the purposes therein contained by signing the name of Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America as an Attorney in Fact for Mortgage Electronic Registration Systems, Inc. organized and existing under the laws of the United States of America. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. I hereby certify the address of the Assignee is: 7105 Corporate Drive, PTX C-35, Plano, TX 75024 Case #: 91890FC Notary blic My commission expires: c oHwt?t w OF PlNNaYLVANIA NOTARIAL SEAL CWRTIN S. BAIR, Notary Pv* of Pdaftoilk Courdy C.=* ion EN*n March 3,2013 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: MIIC?'1? ?? ? C Michael T. McKeever, Esquire PA I.D. #56129 #91890FC AIMEE DEROBBIO 2168 Chestnut Street Camp Hill, PA 17011 E.XhibitA EXHIBIT "A" ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey plan of property for Michael S. Trout by D.P. Raffensberger Associates of Camp Hill, Pennsylvania, said plan being dated April 22, 1985 as follows, to wit: BEGINMNG at a point at the northern line of Chestnut Street, three hundred and sixth tenths (300.6) feet east of the northeast corner of 'South Twenty-Sccond Street and Chestnut Street; thence in a northerly direction, North seven (7) degrees zero (00) minutes East, one hundred sixty-seven and twenty-seven one- more or less, to a point in the southern line of a twelve (12) feet wide alley-, thence in a w hundredths (167.2e feet tion North seventy-five (75) degrees and zero (00) minutes West, fifty-five and fifty-four one-hundredths (55.54) feet, more or less, along the southern line of said twelve (12) feet wide alley to a point; thence in a southwardly direction South seven (7) degrees zero (00) minutes West, one hundred seventy-five and zero one-hundredths (175.00) feet to the northern line of Chestnut Street; thence in an eastwardly direction, South eighty-three (83) degrees zero (00) minutes East, fifty-five and zero one-hundredths (55.00) feet along the northern line of Chestnut Street, to a point, the place of 8PGIlVMNG. HAVING 8tr`oet' Borough Of Camp JUL TIRERRON erected a one oand f one-half Cumberland dwelling and detached garage known as 2168 Chestnut Ext..Ohibit 0 Bank ofAmerica Home Loess PO Box 9048 Temecula, CA 92589-9048 Send Payments To: PO Box 650070 Dallas, TX 75265-0070 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 7113 8257 1473 5951 0041 Aimee Derobbio 2168 CHESTNUT ST CAMP HILL, PA 17011-5410 20080908-7 BLOPA2 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1128-v29 ?!lFf?i Bank ofAmerica '10' Home Loans P.O. Box 650070 Dallas, TX 75265-0070 Send Payments to: P.O. Box 650070 Dallas, TX 75265-0070 September 8, 2009 Certified Mail 7113 8257 1473 5951 0041 _Return Receipt Requested Aimee Derobbio 2168 CHESTNUT ST Account No.: 22633225 CAMP HILL, PA 17011-5410 Property Address: 2168 Chestnut Street Camp Hill, PA FHA/VA Case #: 4418655513703 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: Monthly Charoes- 05/01/2009 $6,431.20 Other_ Charges? Uncollected Late Charges: Uncollected Costs: $0.00 Partial Payment Balance: $0'? ($0.00) TOTAL DUE: 66,431.20 You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter. To cure the default, BAC Home Loans Servicing, LP must receive the amount of $6,431.20, 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 accelerated. 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 THIRTY-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 Noteholder will be entitled to collect the reasonable attorney's fees actually incurred, 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 attorney's fees will be added to whatever is owed to us, which may also include our reasonable costs. If this default is cured within the Thirty-five (35) day period, the attorney's fees will not be required to be paid. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE 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 Thirty-five (35) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the foreclosure sale. 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. II verify that the property is occupied and/or (iii) 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-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. It is estimated that the earliest date that such a foreclosure sale could be held would be approximately six (6) months from the BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Please write your account number on all checks and conesponderica. We may charge you a fee for any payment retumed or rejected by your financial institution, subject to apple cable law. Payttwrd trobuctlorr: Account Number. 2263322x2 BLQPA2 8338!70793 06/032006 • Make your check payable to RAC Aimee Derobbio Balance Due for charges listed above: $6,431.20 as of September S, 2009. Home Loans Servicing, LP 2168 Chestnut Street • Don't send cash Please up Dare E-mail irtfonnation on the reverse Side M this coupon Camp • Please include coupon with your Hill, PA payment BLQPA2 Pw For all full month payment periods, interest is calculated on a monthly basis gyq?p,? Accordingly, interest for all full months. BAC Home Loans Servicing, LP including February, is calculated as PO BOX 650070 301360 of annual interest, irrespective of Dallas, TX 75265-0070 the actual umber or days in the monk. C/wck ?,r,s ? For partial months, irneresl is calculated .r. rora? Fo II. LL1..rl.Idl.rdd.ilu.Ilr.rLr.IILrrLr.IIL III M-1 daily on the basis or a 385 day yea. " am 022633225200000643120000643120 1:58 6 9 900 581:0 2 2 633 2 2 5fr' 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. 1-800-669-4578. 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) times 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 Sheriff's 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: • 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 BAC Home Loans Servicing, LP receive, up front, at least '/: 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. • 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 current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if 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. • 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 alternatives 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 1-800-669-4578. BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Account Number: 22633225 E-mail use: Providing your e-mail address below will allow us to send you information on your account. Aimee Derobbio E-mail address: HON' we pod your paymerds: AN accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (i) to outstanding monthly payments of principal and interest, (ii) escrow deficiencies, (ill) late charges and other amounts you owe in connection with yaw pan and (iv) to reduce the outstanding principal balance of your ban. Please specify if you want an additional amount applied to future payments, rather than principal reduction. r'°a°os0 croOm Postdated checks will be processed an the date received unless a loan counselor agrees to honor the date written on the check as a condition are repayment plan. C-S) 7ARY 2059 DEC 13 Pi"i 3: 3 7 v+e: v,.},s, *9a.Co po ATTY 0, a35d'4S GOLDBECK McCAFFERTY ~ McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. AIMEE DEROBBIO 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) ,1~ rr~ ~ i ll~, i , _ "r;~~f 2t7fD,~~JL 27 Ff,f ~; ~,~ CUPS - , .~ I~ , r~l..i It~a~? {(,i r ~~l'~ ~ ~1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 09-8728 CIVIL TERM PRAECIPE TO VACATE JUDQ~:NT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. t ICHAEL T. MCKEEVER, ESQUIRE ~ ~ 4D ~ ~ °~-~7 Cx~s3y38"G ~ ~~~~ GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. AIMEE DEROBBIO Mortgagor(s) and Record Owner(s) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) 91890FC FILED- CF: 12/18/2009 OF rf,E FROTH " 0jA, ,,$194,40 3.92 2910 NOV 30 IN ifMTi OF, COMMON PLEAS of Cum er unty CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-8728 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Keith C. Halili, an employee of Goldbeck McCafferty & McKeever, counselfor Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (Y) Personal Service by the Sheriffs Office/sompeteokdvit`(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. Respectfu ly submitted, ?<-l BY: Keith C. alili Legal Secretary O V/b i 0 ' G3 u o ino t m L m ul a ,` Q La > OC o n q C w S fp N _ .? ly F I J`J ? ? ? a. a ?d 00, 58 ?-' xu Cl) Z_ N E _ w U ts Xs p = 40 -. d W p W t 6 0 Q 0 o Z Z 0D W CD ome a w F N is E B IE _ Z o ? v° c? Q oC a w m E m m if Ix Kin U U 7M r c 0 3 5 L IL m m am 0 m m E a Z ( ` ° o m 'E U v ll! '17 - = : t0 W 4' o .n-- gi O O? j ? ? C) C N _ U O C Q d a a D?DD? w:3 0 O m! co wzo g Z °-' o xa aL)a L a L) . CLW Q O E? 2 m j ro G W Z LLj< CC d v h= Lu CL om c?o- Q 3.t _j W. O 33 ' F J o 2Q5oZCrf e- N M v t6 cfl t.. 06 c ro 0. c 0 Qe m 0 Y F a m a U C) N O N_ N m O ar c? N ?r O C O m C) a ? N m O N N m E O 2 M U m 0 ti W rll LU M c)o a rn Q SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Ktr of barf? Jody S Smith ?. Chief Deputy" , a Richard W Stewart Solicitor OFFICE OF Tµ8 SKFAFP BAC Home Loans Servicing, LP vs. Case Number Aimee Derobbio 2009-8728 SHERIFF'S RETURN OF SERVICE 10/11/2010 05:10 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at-1710 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Aimee Derobbio, located at, 2168 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania according to law. 10/11/2010 05:05 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on 10/21/10 at 2030 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: Aimee Derrobbio, by making known unto, Aimee Derrobbio, personally, at, 2109 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same SHERIFF COST: $899.42 October 26, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ,Cr Coth*Su.f8 Sheriff. teieosoR. Inc. 'GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. AR\4EE DEROBBIO Mortgagor(s) and Record Owner(s) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-8728 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2168 Chestnut Street Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): AIlVIEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: AIMEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 2168 Chestnut Street Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: November 24, 2010 GOLDBECK MCCAFF RTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r, . Jody S Smith ' - LL Chief Deputy Richard W Stewart Solicitor ,. ? r BAC Home Loans Servicing, LP vs. Aimee Derobbio Case Number 2009-8728 SHERIFF'S RETURN OF SERVICE 10/11/2010 05:10 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on 10-11-10 at 1710 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Aimee Derobbio, located at, 2168 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania according to law. 10/11/2010 05:05 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on 10/21/10 at 2030 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: Aimee Derrobbio, by making known unto, Aimee Derrobbio, personally, at, 2109 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same 12/08/2010 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/2/2011 02/02/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 03/01/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney on 3/1/11. SHERIFF COST: $814.27 SO ANSWERS, March 01, 2011 RON ? R ANDERSON, SHERIFF eA * 5a?o") W a543a;t- 4 I Goldbeck Mt;Cafferi y & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000-- Mellon IndependenceCenter - 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County AINIEE DEROBBIO (Mortgagor(s) and Record Owner(s)) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) No. 09-8728 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2168 Chestnut Street Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): AR%4EE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: AIMEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 2168 Chestnut Street Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: July 30, 2010 GOLDBE McCAFFERTY & McKEEVER BY: Michelle Clarkson r + 09-8728 CIVIL TERM GOLDBECK WCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS Plaintiff vs. AIMEE DEROBBIO Mortgagor(s) and Record Owner(s) 2168 Chestnut Street of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Camp Hill, PA 17011 Docket No. 09-8728 CIVIL TERM Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DEROBBIO, AIMEE AIMEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 Your house at 2168 Chestnut Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $194,403.92 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: e` 1 09-8728 CIVIL TERM 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 09-8728 CIVIL TERM Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orv,/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkgoldbecklaw.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 91890FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey plan of property for Michael S. Trout by D.P. Raffensberger Associates of Camp Hill, Pennsylvania, said plan being dated April 22, 1985 as follows, to wit; BEGINNING at a point at the northern line of Chestnut Street, three hundred and sixth tenths (300.6) feet east of the northeast comer of South Twenty-Second Street and Chestnut Street; thence in a northerly direction, North seven (7) degrees zero (00) minutes East, one hundred sixty-seven and twenty-seven one-hundredths (167.27) fee; more or less, to a point in the southern line of a twelve (12) feet wide alley; thence in a westwardly direction North seventy-five (75) degrees and zero (00) minutes West, fifty-five and fifty-four one-hundredths (55.54) feet, more or jess, along the southern line of said twelve (11) feet wide alley to a point; thence in a southwardly direction South seven (7) degrees zero (00) minutes West, one hundred seventy-five and zero one-hundredths (175.00) fcer to the northern line of Chestnut Street; thence in an eastwardly direction, South eighty-three (83) degrees zero (00) minutes East, fifty-five and zero one-hundredths (55.00) feet. along the northern line of Chestnut Street, [0 a point, the place of BEGINNING. Parcel# 01-21-0271-446 Property address: 2168 Chestnut Street, Camp Hill, PA 17011 Being the same premises which Shelly Capozzi and Lou Capozzi, her husband, by deed dated 02/26/07 and recorded 02/28/07 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 278 Page 4619, granted and conveyed unto Aimee Derobbio. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-8728 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff (s) From AIMEE DEROBBIO (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 $194,403.92 L.L. Interest from 8/2/10 to Date of Sale per diem at $27.72 Atty's Comm % Due Prothy $2.00 Arty Paid $ 9,33.50 Plaintiff Paid Date: 8/5/10 (Seal) Other Costs avi uell, ?rothonotary By: Deputy REQUESTING PARTY: Name: 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 September 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, PA, Known and numbered as, 2168 Chestnut Street, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 B: Real Estate Coordinator 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. v isa Marie Coyne, ,ditor SWORN TO AND SUBSCRIBED before me this 5 da of November, 2010 O? Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2009-8728 Civil BAC Home Loans Servicing, LP, f/k/a Countrywide Home Loans Servicing, LP VS. Aimee Derobbio Atty.: Michael McKeever ALL THAT CERTAIN tract or par- cel of land situate in the Borough of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and de- scribed in accordance with a survey plan of property for Michael S. Trout by D.P. Raffensberger Associates of Camp Hill, Pennsylvania, said plan being dated April 22, 1985 as fol- lows, to wit; BEGINNING at a point at the northern line of Chestnut Street, three hundred and sixth tenths (300.6) feet east of the northeast corner of South Twenty-Second Street and Chestnut Street; thence in a northerly direction, North seven (7) degrees zero (00) minutes East, one hundred sixty-seven and twenty- seven one-hundredths (I 67.27) fee; more or less, to a point in the south- ern line of a twelve (12) feet wide alley; thence in a westwardly direc- tion North seventy-five (75) degrees and zero (00) minutes West, fifty- five and fifty-four one-hundredths (55.54) feet, more or jess, along the southern line of said twelve (11) feet wide alley to a point; thence in a southwardly direction South seven (7) degrees zero (00) minutes West, one hundred seventy-five and zero one-hundredths (175.00) fcer to the northern line of Chestnut Street; thence in an eastwardly direction, South eighty-three (83) degrees zero (00) minutes East, fifty-five and zero one-hundredths (55.00) feet. along the northern line of Chestnut Street, [0 a point, the place of BEGINNING. Parcel# 01-21-0271-446. Property address: 2168 Chestnut Street, Camp Hill, PA 17011. Being the same premises which Shelly Capozzi and Lou Capozzi, her husband, by deed dated 02/26/07 and recorded 02/28/07 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 278 Page 4619, granted and con- veyed unto Aimee Derobbio. 34 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the Patti* ot 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 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, C,Dunty and State aforesaid; that The Patriot-News and The Sunday Patriot-News were, established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of' this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/15/10 10/22/10 10/29/10 Sworn to and,sbscribed be?rne me this 10 day of Nov-ember, 2010 A.D. Notary Public COMMONWEALTH OF PENNSYU/ANL Notarial Seal Sherri' L Kisner, Notary Public Lower Paxton TYW., Dauphin County MY Commissbn Expires Nov. 26, 2011 Member. Pennsylvania Association of Notaries 2009-875 Chris Term SAC Hoaae LOOM $WvftW4 LA t*/a Cour ywMe A M4-0 L"M Servicing, LP Vs Aimee Dwobblo Atty: ilAkMW McKeever ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey plan of property for Michael S. 'Imut by D.P. Raffensberger Associates of Camp Hill, Pennsylvania, said plan being dated April 2Z 1985 as follows, to wit; BEGINNING at a point at the northern line of Chestnut Street, three hundred and sixth tenths (300.6) feet east of the northeast comer of South Twenty-Second Street and Chestnut Street; thence in a northerly direction, North seven (7) degrees zero (00) minutes East, one hundred sixty-seven and twenty-seven one- hundredths (167.27) fee; more or less, to a point in the southern he of -a twelve (12) feet wide alley; thence in a westwardly direction North seventy«five (75) degrees and zero (00) minutes West; fifty-five and fifty-four one- hundredths (55.54) feet, more or jess, along the southern be of said twelve (11) feet wide alley to a point; thence in-a southwardly'direction South seven '(7):degrees zero (00) minutes West; one hundred seventy-five and zero one- hundredths (175.00) fear to the northern be of Chestnut Street; thence in an eastwardly direction, South ei a (83) degrees zero (00) =now East, fd![ and mo one. hundrcdd s (550) int. r tfae notdKrtt titre of Chestnut Street, to a poitti, the place of BEGINNING. Parcels 01-21-0271.446 Property address: 2168 Chestnut Street, Camp Hill, PA 1701E Being the same premises which Shelly Capozzi and Lou Capo22i, her husband, by deed dated 02/26/07 and recorded 02!28/07 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 278 Page 4619, granted and conveyed unto Aimee Derobbio. w• KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. AIMEE DEROBBIO (Mortgagor(s) and Record Owner(s)) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-8728 CIVIL TERM PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P. 2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP for Voluntary Substitution under Pa.R.C.P. 2352 due to merger and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the new Plaintiff is 7105 Corporate Drive, PTX C-35, Plano TX, 75024. By: LAW GROUP, P.C. M hael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KMLL LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. AIMEE DEROBBIO (Mortgagor(s) and Record Owner(s)) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-8728 CIVIL TERM STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P. 2352 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned Action of Mortgage Foreclosure relates to a property located at 2168 Chestnut Street Camp Hill, PA 17011 ("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Instrument # 200913380 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP. 4. BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP is the successor in interest by merger to the Plaintiff and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. Respectfully submitte? By: L LAW GR UP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 215-627-1322 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. AIMEE DEROBBIO (Mortgagor(s) and Record Owner(s)) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-8728 CIVIL TERM CERTIFICATE OF SERVICE Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on AIMEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 AIMEE DEROBBIO 2168 Chestnut Street Camp Hill, PA 17011 By: _MP KM*L?awGroup, . C. Doris Guzman, Legal Assistant Dguzman@kmllawgroup.com 215-825-6402 (Direct Phone) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 09-8728 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From AIMEE DEROBBIO (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: $194,403.92 L. L.: Interest from 7/31/2010 to Date of Sale per diem at $27.72 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $1,083.27 Plaintiff Paid: Other Costs: Date: 6/26/12 (Seal) REQUESTING PARTY: Name: DAVID FEIN, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 David D. Buell, By: _ Deputy Supreme Court ID No. 82628 r PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) r P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 L u 215-627-1322 ! e, : "'1 °r`'k N I BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. AIMEE DEROBBIO Mortgagor(s) and Record Owner(s) 2168 Chestnut Street Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-8728 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 7/31/2010 to Date of Sale per diem at $27.72 (Costs to be added) cs_? 55.00 ?; $14 . 410 a? C ? c ? t qa? utt ?y, ov 00 a tt 8-.00 14 4 . Op tt r? tt k ay. ° 0 t, C? !so ti $194,403.92 By. ?. KML LAW GROUP, P.C. Michael McKeever Pa. ID.56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ---David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ?. PS -?>Oc 6. 30, 7/q 006 v 4c?77J9$ ??r ?k of I? .?'veo? V) d W a ?z 0 w? ?o ?U O° O N a I ,a o? 00 z? w x H 4 w a a wz ?aU > OZ? Utz ?D a zoo fax wiz ca z o U i w 00 ?? w ?ab?o w c?a o v? r. O ?? ca Q cz ? oc C a o d b N U W to 0 ? w ., a a 3 cC a a x c C.) M N i N c 15. w) U a N .4 04 Q+ N ?o xo a ALL THAT CERTAIN tract or parcel of land situate in the Borough of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described in accordance with a survey plan of property for Michael S. Trout by D.P. Raffensberger Associates of Camp Hill, Pennsylvania, said plan being dated April 22, 1985 as follows, to wit; BEGINNING at a point at the northern line of Chestnut Street, three hundred and sixth tenths (300.6) feet east of the northeast corner of South Twenty-Second Street and Chestnut Street; thence in a northerly direction, North seven (7) degrees zero (00) minutes East, one hundred sixty-seven and twenty-seven one-hundredths (167.27) feet; more or less, to a point in the southern line of a twelve (12) feet wide alley; thence in a westwardly direction North seventy-five (75) degrees and zero (00) minutes West, fifty-five and fifty-four one-hundredths (55.54) feet, more or less, along the southern line of said twelve (12) feet wide alley to a point; thence in a southwardly direction South seven (7) degrees zero (00) minutes West, one hundred seventy-five and zero one-hundredths (175.00) feet to the northern line of Chestnut Street; thence in an eastwardly direction, South eighty-three (83) degrees zero (00) minutes East, fifty-five and zero one-hundredths (55.00) feet along the northern line of Chestnut Street, to a point, the place of BEGINNING. Parcel# 01-21-0271-446 Property address: 2168 Chestnut Street, Camp Hill, PA 17011 Municipality: Borough of Camp Hill Being the same premises which Shelly L. Krosnowski, now known as Shelly L. Capozzi and Lou Capozzi, husband and wife, by deed dated 02/26/07 and recorded 02/28/07 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 278 Page 4619, granted and conveyed unto Aimee Derobbio. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO I _ BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff vs. AIMEE DEROBBIO Defendant(s) NO. 09-8728 CIVIL TER VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (httpss://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): AIMEE DEROBBIO, has a last known residence of 2138 Market Street Apartment B, Camp Hill, PA 17011. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date *;? By: /c KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 10. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY ' MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. of Cumberland County CIVIL. ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AIMEE DEROBBIO (Mortgagor(s) and Record Owner(s)) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-8728 CIVIL TERM BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2168 Chestnut Street Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): AIMEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: AIMEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 ' W IN THE COURT OF COMMON PLEAS DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 -. 4. Name and address of the last recorded holder of every mortgage of record: 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 2168 Chestnut Street Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: f? ?2 By: .t _. KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 _David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua 1. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 09-8728 CIVIL TERM KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attornev for Plaintiff 7 at?? J4tI lplt•.m BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 vs. Plaintiff AIMEE DEROBBIO Mortgagor(s) and Record Owner(s) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 09-8728 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DEROBBIO, AIMEE AIMEE DEROBBIO 2138 Market Street Apartment B Camp Hill, PA 17011 Your house at 2168 Chestnut Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 05, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $194,403.92 obtained by BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 09-8728 CIVIL TERM 1. The sale will be cancelled if you pay to BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: htti)://www.philadelphiafed.orerjforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 09-8728 CIVIL TERM Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website bt!p://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 91890FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. I~VII~ LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 -:; ; i. _ f '~~- ~! ;'. i s _. ~ T~ (~ _ ~°, BANK OF AMERICA, N.A., SUCCESSOR B~:. ~'r° MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. AIMEE DEROBBIO Mortgagor(s) and Record Owner(s) 2168 Chestnut Street Camp Hill, PA 17011 91890FC CF: 12/18/2009 SD: 12/05/2012 $194,403.92 i n ",` f' ~ ~IiV THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE Term No. 09-8728 CNIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.RC.P. 3129.2 (c) (2) Keith C. Halili, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sli~ee/competent adult (copy of return attached). ( ) Certified mail by KML Law Group, P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by KML Law Group, P.C. (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfull su mitt~e~d3, ~ ~ =zit ~r 1~?..1L~ ) BY: Keith C. Halili ~ Legal Assistant __.. _._.. __. N ~ O O ~ N _ ~ O V ~ y N ~ tt w~ e~l ~ ~ ~ ~ N ~ ~~`,~, NO ~ O O Q d 3(~'1[1 ~ I ' O G t C m ~ ~,. O , d ~ I I , -~-- ~ V ------ - - 4 .~ ~ L a ., m m ~$ _ ~ ~ ~ z o ~ m v _ e ~ x =mE vm ~ ~ ~ c ~n ~~ x e ,~ ~ o ~ ~ U ~. O c ~ a~ `o'S ao ~ c 0 ~ a a d Z ~ m F- N ~ c O 4 m g t ~ m ~ ~ O .E c S m ~p ~ ¢ Z g ~ U ~ ~ ~ ~ ~ ., E" R m J C N W m~ m m - m o. a.. U o U c ~ ^~~^ ~ m ~ a 11.. m s ~ W ~~~ O ~ ' a u N c .4 ~ m a5 O am Z O y ~ ~ o o ~~ ~.~ m~, ~ ~ ~ a ~v ~Q~ QUvN ~ U Q ° v°ow_ d°~x o ~ E- fq~ a m m is ^~O^ ~ o m w m tO `~ ~~ i ~' ~ o N p ~ O E 1'o ~ dtnSa. DU U a°O t~ N a `O C ~ 7 '~ 0 0 -a O ~ ~ ~v ~ C m m .~ ~ w \~~~ o ~ N _ r 2 ~-- ~ ~ ~ O n w ¢ m ~\0 y ~ U [~ c0 ~ ~ Q Q ,yyvyQ7 ~ " ~' ~ ~ m (A N3p~1 ~ -`" ^' ~YoWdc a ~ U ~ ~ ~w°~w ~ ~~, ~ o w ~ (/~ T O~ p 2 rn T tV c~ v ~ti co t~ ao o f a rn Q fR rn .~ n _ IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO ;CASE and/or DOCKET No.: 09-8728 Cl[VIL TERM BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP; et seq. ~ Sheriff's Sale Date: 12/5lZ012 Plaintiff (Petitioner} V. AIMEE DEROBBIO; et al Defendant (Respondent) AFFIDAVIT OF SERVICE ~J Complaint ~ Sammons ~ Other: NOTICE OF SALE [, RYAN MARKS, certify that t am eighteen yews of age or older and that 1 aro not a party to the action nor an employee nor relative of a party ,and that I served A[MEE DEROBBIO the above process on the 31 day of October, 2012, at 4:05 o'clock, PM, at 2109 Princeton Ave Apt 6 Camp Hill, PA 17011 5446 ,County of Cumberland. Commonwealth of Pennsylvania: Manner of Service: By handmg a copy to the Defendant(s) Description: Approximate Age ~, ~0 Height S'¢ Weight X65 Race WRITE Sex FEMALE Hair BROWN Military Status: ~No Yes Branch: Commonwealth/State of !h ) } SS: County of f~j,,K f ) Before me, the undersigned notary public, this day, personally. aPl~ed _ I~ yww MNKJ to me known, who being duly sworn accordmg aw, deposes the following. I hereby swear or affirm fads set forth in the foregoing Affidavit of Service are true and cortect. Affiam) File Number.91890FC Case ID #:3439220 Subscribed and to ore me this,(~dayof / ,20~ i, ~.;i,,t_.;~ Notary Public .. ,_ ~~.iniy :3, 2013 KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. AIlVIEE DEROBBIO Mortgagor(s) and Record Owner(s) 2168 Chestnut Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-8728 CIVII, TERM AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2168 Chestnut Street Camp Hill, PA 17011 LName and address of Owner(s) or Reputed Owner(s): AIMEE DEROBBIO 2109 Princeton Ave Apt.6 ~' Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: AIMEE DEROBBIO 2109 Princeton Ave Apt.6 Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 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 2168 Chestnut Street Camp Hill, PA 17011 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: November 21, 2012 --, KML Law Group, P.C. BY: Keith C. Halili Legal Assistant