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Home My WebLink About10-0437UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 n ADAM L. KAYES, ESQUIRE - ID #86408 , MARGUERITE L. THOMAS, ESQUIRE - ID #204460 <. N J WOODCREST CORPORATE CENTER CD 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 - ?? 856-669-5400 z" -- r pleadings@udren.com ' BAC Home Loans Servicing, LP :.COURT OF COMMON PLEAS f/k/a Countrywide Home Loans :CIVIL DIVISION Servicing LP P.O. Box 650070 :Cumberland County Dallas, TX 75265--0070 Plaintiff V. Jeffrey A. Goss 12 Big Horn Avenue NO. Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TP-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. C0' Iwyoy2? ?? a3LSav LAWYERS REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. Plaintiff is the legal holder of the Mortgage that is the subject of this action. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 12 Big Horn Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Upper Allen Township COUNTY: Cumberland DATE EXECUTED: 01/16/09 DATE RECORDED: 01/28/09 INSTR NO.: 200902268 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 01/18/10: Principal of debt due $145,526.97 Unpaid Interest at 5.5W from 07/01/09 to 01/18/10 (the per diem interest accruing on this debt is $22.23 and that sum should be added each day after 01/18/10) 4,490.46 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Late Charges (monthly late charge of $41.56 should be added in accordance with the terms of the note each month after 01/18/10) 249.36 Property Inspection Fee 15.00 Attorneys Fees (anticipated and-actual to 5% of principal) 7,276.35 TOTAL $158,163.14 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $158,163.14 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BY: '--0' i1 Attorneys for 191aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE ALL THAT CERTAIN piece or parcel of land situate in Township, County of Cumberland and Commonwealth of Penns3TlvaniiUpper Allen a, bounded and described as follows, to wit: BEGINNING at a point on the northern line of Big Horn Avenue at the eastern line of Lot NO. 55 as shown on the Plan of Section I$ Mt. Allen Heights; thence along the eaBteril line of Lc'at No. ?i9 North 5 degreest 7 minutes West 116.45 feet to a point, thence along lots in the Plan of Section 2, Mt. Allen Heights, North 84 degrees 53 minutes East 98. feet to a point: thence along the western line of Lot No. 57 as shown an the Plan of Sehtion I, Mt. Allen Heights, South 5 degrees 7 minutes Bast 116.46 feet to a point on the northern side of Big Horn Avenue; thence along the northern line of Big Horn Ave=e South 84 degrees 53 minutes West 98 feet to the place of BEGINNING. BEING Lot No. 56, Plan of Section I, Mt. Allen heights, said Plan ;peing recorded in the Cumberl;inm Counter ReaordcriQ Offioe Pages 14 and 15. ire PlLu Hc,c,k Lis, DELM thft name- Premises which Todd A. Duffi. .aa C11ris N. Wuffie, wife, by their deed dated Febru the Cumberland County Recorder of Deeds Offic20, e on OFebruar recorded in the 24 r Page '2282, 21 2002 in Book grArited and convo d unto Ma ehael K. ClWuaexr and Leslie A. Clouser, his wife, Grantors herein. C, BankofAmefta AW Horse loans _.. _-----•------_... PO Box 9048 TemecWa, CA 92589-9048 Send Payments To. PO Box 850070 Dallas, TX 75265-0070 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 1111111111111111111111 7113 8257 1473 6520 7409 Jeffrey A Goss 12 BIG HORN AVE MECHANICSBURG, PA 17055-5515 091001-7 8LQPA1 PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 1054-36 li Bank of America -4301- Home Loans P. 0, Box 650070 Dallas, TX 75265-0070 Jeffrey A Goss 12 BIG HORN AVE MECHANICSBURG, PA 17055-5515 Send Payments to: P.O. ,fix 650070 Dallas, TX 75265-0070 10/0112009 Certified Mail: 7113 8257 1473 6520 7409 Return Receipt Requested Regular Mail Account No.: 200781434 Property Address: 12 Big Horn Ave Mechanicsburg, PA 17055-5515 Current Servicer: BAC Home Loans Servicing, LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaae on your home is in deft ¦It and he lender intends to for km Specific information about the nature of the default is provided in the attached nag". The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home, This Notice explaina how the a. ram works. To sae If HEM" can hello. you must MEET WITH A CONSUMER CREDIT COUNSELii??` AGEIr ,Y WITHIN 30 DAYS OF THE DATE OF THIS NOTICE Take this Notfc_ with y when you most iron the o¦ -i Amency. The names. addiaasas and ohnras ..o••dr.a s ?...._..?__ ..??:...---__-••- _ This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARll PUEDE SER ELEGIBLE PARA UN PRE'STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Jeffrey A Goss PROPERTY ADDRESS: 99 ai., U-- A- Mechanicsburg. PA 17055-5515 LOAN ACCT. NO.: 200781434 ORIGINAL LENDER: CURRENT LENDER/SERVICER: BAC Home Loans Servicing P HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Please write your account number on all checks and correspondence. We may charge you a tee for any payment returned or rejected by yourfinanaal institution. subject to applicable law. SLOPAI 8323110792 04!18!2008 Payaant atttn,atorlK U Um er: • Make your check payable to BAC Jeffrey A Goss Balance Due for charges listed above: $2,577.12 as of October 1, 2009. More Loans Servicing. LP 12 Big Horn Ave • Don't send cash Mechanicsburg, PA 17055-5515 Please update email iMOrmason on the reverse side of this coupon • Please include coupon with your payment fyhcp7Y/ For all full month payment periods, interest sis! l BLoPAt alated o a monthly ttly basis. A ca Aarordngy, interest for all full months, BAC Home Loans Servicing, LP Aay/dl bnW 1?" including February, is calculated as PO BOX 650070 30mo of annual interest, irrespective of Dallas, TX 75265-0070 . the aclual number of days in the month. For partial months. interest is calculated II III I I II Irl II II Irr III I 111 III rrr k r .n r k ur r w w r m nr roar cnacx Tore' daily on the basis of a 385 day year. 200781434200000257712000257712 EXHIBIT A I: 5B69900551: 200713 L43Le ills YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR wrrl4ut TUP CONSUMER CREDIT COUNSELING- AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The Yiuwnv is ic.,c;aL"u are set Toren at the ena OT MIS Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within Thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you If you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 12 Big Horn Ave Mechanicsburg, PA 17055-5515 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due Monthly Charges: 08/01/2009 Late Charges: 08/01/2009 Other Late Charoes: Total Late Charges: Uncollected Costs: SAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. E-mail use: Providing your a-mail address below will allow us to send you information on your account. Account Number: 810781434 Jeffrey A Goss E-mail address: $2,493.33 $83.12 $0.67 $0.00 How we pat your pwnwds: All accepted payments or principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. M you submit an amount in addition to your scheduled monthly amount, we will apply your payments as fbkYws: (i) to outstanding monthly payments of principal and interest, (1) escrow deficiencies, (tie) late changes and other amounts you owe In connection with your loan and (N) to reduce the ou- .riding principal balance of your loan. Please spedry if you went an addllata[ wmout applied to future payments, ndher than principal reduction. PoMddad Elects: Poskinted checks will be processed on the date received unless a loan courmbr agrees to honor the date written an the check as a corditbn of a repayment plan. Partial Payment Balance: ($0.00) TOTAL DUE: $2,577.12 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION IDo not use if not applicable na+r. ray a:urte rrr r?FFn?n r - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PA8T DUE TO THE LENDER, WHICH IS $2,577.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent t : BAC Home Loans Servicing, LP at P.O. Box 650070, Dallas, TX 75265-0070. You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE 18 FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will riot be required to pay attorney's fees. OTHER LENDER REMEDIES. - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name or Lender: BAC Home Loans Servicing, LP Address: P. O. Box 650070 Dallas, TX 75265-0070 Phone Number: 1-800-669-6654 Fax Number: 1-8 0 55 7 7-343 2 Contact Person: MS TX2-977-01-06 Attention: Loan Counselor EFFECT OF SHERIFF'S SA F - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HALVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A Muml nLI-L TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. 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. If you are unable to cure the default on or before October 31, 2009, 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 '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. • 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 31, 2009 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-6654. I CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Capital Region 1514 Deny Street Harrisburg, PA 17104 717.232.0757 Adams County Interfaith Housing Authority 40 E High Street Gettysburg , PA 17325 717.334.1518 Loveship, Inc. Maranatha PHFA 2320 North 5th Street 43 Philadelphia Avenue 211 North Front Street Harrisburg, PA 17110 Waynesboro, PA 17268 Harrisburg, PA 17110 717.232.2207 717.762.3285 717.780.3940 800.342.2397 BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. X113 pp Im 6o 10 J D ? 1 Rem IA 9 0. V A . . *60 p, ?sdA J? j Nil to 6 0 Z4 ? . UNIIED $Tp1?s POSIAt SERVE p^??b,G10 T,Cp9?g,9? V E R I FI C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: Attorn eS?s for la ntiff MARK J. UDREN, E UIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson t~-~ T;--~ ~ Sheriff ~ ~' ^~~~ ~~ „~ ~i t~ruribF~~ Jody S Smith ~ (~ Jr.~~ ~; ,F ~ + (o Chief Deputy _ . , ~ _. .. Edward L Schorpp C:. ~ _ ,_ . ,`~:..Y, Solicitor -~" :~r~~ r~ ~ '~~~t~ ,:~~ BAC Home Loans Servicing, LP vs. Jeffrey A. Goss Case Number 2010-437 SHERIFF'S RETURN OF SERVICE 01/21/2010 12:50 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 21, 2010 at 1250 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeffrey A. Goss, by making known unto Sandra Goss, Mother of defendartt' at 12 Big Horn Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 22, 2010 SO ANSWERS, ~` ._ O Y R ANDERSON, SHERIFF gy ~-'~ Deput Sheriff (c; Cc~.i^`ySuitn Shenfi. Te!e.^,eo?t. Inc. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF BAC Home Loans Servicing, LP :COURT OF COMMON PLEAS f/k/a Countrywide Home Loans :CIVIL DIVISION Servicing LP €Cumberland County P.O. Box 650070 Dallas, TX 75265--0070 :MORTGAGE FORECLOSURE Plaintiff v. a Jeffrey A. Gass NO. 2010-437 12-Big Horn Avenue Mechanicsburg, PA 17055 Defendant (s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) Jeffrey A. Goss for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $158,163.14 Interest Per Complaint 800.28 From 1/19/10 to 2/23/10 Late charges per Complaint 41.56 From 1j19/10 to 2/23/10 TOTAL ~; _ , ~ ~ ., - . ~'~' `~ L~ :~ ~~ £Z ~~~'~l~Z ,, X159,004.98 ~z cry ~~os 3 ~~~~~ ~C I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE HEREBY ASSESSED AS DATE : ~~ ~ ' ~ ~ UDREN LAW> S, P.C. BY: , Attorneys laintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ..J.f~3IJIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE. IND GATED P O PROTHY `'° UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHAIVDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADA1~! L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 n1 c~adi n_ cfs(a~~,dren rom BA C Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP Plaintiff v. Jeffrey A. Goss Defendant(s) T0: Jeffrey A. Goss 12 Big Horn Avenue Mechanicsburg, PA 17055 Date of Notice: February 11, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2010-437 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland Count Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND TH IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE U~IS'gAT PURPOSE. STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE .,LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Load, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com ATTORNEY FOR PLAINTIFF BAC Home Loans Servicing, LP :COURT OF COMMON PLEAS f/k/a Countrywide Home Loans 'CIVIL DIVISION Servicing LP :Cumberland County Plaintiff v. :MORTGAGE FORECLOSURE Jeffrey A. Goss Defendant (s) : NO. 2010-437 STATE OF NEW JERSEY AFFIDAVIT OF NON-MILITARY SERVICE COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Jeffrey A. Goss Age: Over 18 Residence: As captioned above Employment: Unknown Defendant: Age. Residence: Employment: Jeffrey A. Goss Over 18 As captioned Unknown Sworn to and subscribed before me this 23rd day o February 2010. y u lic above Name : "` /l~-Q,vr Title: ATTORNEY OR PLAINTIFF Company: UDREN LAW OFFICES, P.C. CARN 5TEARS NCYI ARY P4~L1C OF NEVVA~Y Canm~£10~15C.101~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~ ~, ~a ; ck€ai:~ ~~ ;:~~ s:~~Ri~€ BAC Home Loans Servicing, LP vs. Case Number Jeffrey A. Goss 2010-437 SHERIFF'S RETURN OF SERVICE 01/21/2010 12:50 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to [aw, states that on January 21, 2010 at 1250 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeffrey A. Goss, by making known unto Sandra Goss, Mother of defendarl` at 12 Big Hom Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 22, 2010 .~ SO ANSWERS, ~'" O Y R ANDERSON, SHERIFF 13y ~~ --~- Deput eriff ;r Cov;i='ySute Sirs*i°. 7~•iansrlt, d•~.. ir~ii,iil~! UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - TD #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 AZAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARREMA, ESQUIRE - ID #203437 LaUIS A. SIMONI, ESQUIRE - ID #200869 ADAM L. KAYES, ESQUIRE - ID #86408 WQODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP 'COURT OF COMMON PLEAS f/k/a Countrywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff v. -'MORTGAGE FORECLOSURE Jeffrey A. Goss NO. 201,0-437 Defendant (s) T0: Jeffrey A. Goss 12 Big Horn Avenue Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Ju Judgment Judgment Judgment Judgment Judgment 3gment in Replevin for Possession on Award of Arbitration on Verdict on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren Esquire At this telephone number: 856-669-5400 C~.~~~~ a/aa/cv On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered, 12 Big Horn Avenue, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: Rea state Coordinator r ~ ~~ C PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, Apri123, and Apri130, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~_ L' a Marie Coyn ,Editor SWORN TO AND SUBSCRIBED before me this 30 da of Aril 2010 ~[ . Notary NOTARIAL SEAL DE80RAH A COLLINS Notary Public CARLISLE 80ROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 Writ No. 2010-437 Civil BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP vs. Jeffrey A. Goss Atty: Mark J. Udren ALL THAT CERTAIN piece or par- cel of land situate in the Upper Allen Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northern line of Big Horn Avenue at the eastern line of Lot No. 55 as shown on the plan of Section I, Mt. Allen Heights; thence along the eastern line of Lot No. 55 North 5 degrees 7 minutes West 116.46 feet to a point; thence along lots in the plan of Section 2, Mt. Allen Heights, North 84 degrees 53 minutes East 98 feet to a point; thence along the western line of Lot No. 57 as shown on the plan of Section I, Mt. Allen Heights, South 5 degrees 7 minutes East 116.46 feet to a point on the northern side of Big Horn Avenue; thence along the northern line of Big Horn Avenue South 84 degrees 53 minutes West 98 feet to the place of BEGINNING. BEING Lot No. 56, Plan of Section I, Mt. Allen Heights, said plan being recorded in the Cumberland County Recorder's Office in Plan Book 18, Pages 14 and 15. BEING the same premises which Todd A. Duffie and Chris K. Duffie, his wife, by their deed dated February 20, 2002 and recorded in the Cum- berland County Recorder of Deeds Office on February 21, 2002 in Book 250, Page 2282, granted and con- veyed unto Michael K. Clouser and Leslie A. Clouser, his wife, grantors herein. BEING KNOWN AS: 12 Big Horn Avenue, Mechanicsburg, PA 17055. PROPERTY ID NO.: 42-29-2454- 011. TITLE TO SAID PREMISES IS VESTED IN Jeffrey A. Goss, single person by deed from Michael K. Clouser and Leslie A. Clouser, his wife dated 7/29/04 recorded 8/4/04 in Deed Book 264 Page 2620. .. :4 .. The Patriot-News Co. 2020 Technology Pkwy Suite 3Q0 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 c'rl~e ~lahiot News Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has persona! 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: 04/16/10 ;~~~c~< Sworn to and~subscribed beforeme this-~ day of May, 2010 A.D. ~ ~I~ G Notary Public _ COMMONWEALTH OF PENNSYWANL4 Notarial Seal Sherrie L. Klsr-er, Notary Publk Lower Paxton 1Wp., DauphM County My Commisslon F~IreS Nov. 26, 2011 Member, Pennsylvania assodatlon of Notaries 04/23/10 04/30/10 Writ Wo. 201037 Clvll Term ~}AC Home Loans Servk:ltt~, LP F/fVA Countrywi~ Home Loans Servlcing, LP Vs. . Jeitrey A. Goss. Atly: Mark J Udren ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE UPPER ALLEN TOWNSHIP, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERN LIIVE OF BIG HORN AVENUE AT THE EASTERN LINE OF LOT N0.55 AS SHOWN ON THE PLAN OF SECTION I, MT. ALLEN HEIGHTS; THENCE ALONG THE' EASTERN LINE OF LOT N0.55 NORTH 5 DEGREES 7 MINUTES WEST 116.46 FEET TO A POINT; THINCEALONG LOTS IN THE PLAN OF SECTION 2, MT. ALLIN HEIGHTS, NORTH 84 DEGREES 53 MBVi)TES EAST 98 FEET TO A POINT; THENCE ALONG '1`IIE WESTERN LINE OF LOT N0.57 AS SHOWN ON THE PLAN OF SECTION I, MT. ALLIN HEIGHTS, 50UTH 5 DEGREES 7 MINUTES EAST 116.46 FEET TO A POINT ON THE NORTHERN SIDE OF BIG HORN AVENUE; THENCEALONG THE NORTHERN LINE OF BIGHORN AVENUE SOUTH 84 DEGREES 53 MINUTES WEST 98 FEETTOTHE PLACE OF BEGINNING. BEING LOT N0: 56, PLAN OF SECTION I, MT. ALLEN HEIGHTS, SAID PLAN BEING RECORDED. IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK I8, PAGES 14 AND 15. BEINGTHE SAME PREMISES WHICHTODD A. DUFFIEAND CHRIS R DUFPIE, HLS WIFE, BYTHEIl2DEET~DATEDFEBRUARY20,2002 AND RECORDED IN THE CUMBERLAND COUNTY RECORDER OF DEEDS OFFICE ONFEBRUARY 21, 2002IN BOOK 250, PAGE 2282, GRANTED AND CONVEYED UNTO MICHAEL K. CLOUSER AND LE~,S,L,~I,E~ Ar. CLOUSER, HIS WIFE, GRANTORS Liract~,. BEB3C KNOWN AS: 12 Big. Hots Aveaue Mechaoicslwrg, PA 17055 PkOPERTY ID NO:: 42-29-2454-011 Title to saidpremises isvestedin Je6reyA. Goss, single person by deed fiom'Michael K. Clouser Leslie dA~.~Ctlonuser, his wife dNed 7!29104 Fl~ea~ _"~_.~.. Deed Book 264 Page 2620. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM KAYES, ESQUIRE - ID #86408 MARGUERITE THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 in1O0DCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadiags@udren.com BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP P.O. Box 650070 Dallas, TX 75265--0070 Plaintiff v. Jeffrey A. Goss 12 Big Horn Avenue Mechanicsburg, PA 1705.5 Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2010-437 PRAECIPE TO MARK SETTLED, DISCONTINUED AND ENDED AND SATISFY JUDGMENT TO THE PROTHONOTARY: ca ~v "' t'3 { - ~ . Kindly mark the above captioned matter SETTLED, DISCONTINUED AND ENDED AND JUDGMENT SATISFIED. DATED: June 2, 2010 Id01U111~-1 ICES, P.C. B At y for Plaintiff K UDREN, ESQUIRE TUAR WINNEG, ESQUIRE L NE DOYLE, ESQUIRE . MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM KAYES, ESQUIRE MARGUERITE THOMAS, ESQUIRE