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Home My WebLink About10-1545 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 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF C N o C Q z n r5 C om d BAC Home Loans Servicing, LP fka :COURT OF COMMON PLEAS Countrywide Home Loans Servicing CIVIL DIVISION LP P.O. Box 660694 ;Cumberland County Dallas, TX 75266 Plaintiff V. Todd Garman 5 i/ s 1123 Rana Villa Avenue E NO. Camp Hill, PA 17011 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 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ..4v P11 qj/7 ? f 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 County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 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 c , 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. Current assignments of mortgage of record are as follows. Assignor: Mortgage Electronic Registration Systems, Inc. Assignments of Record to: BAC Home Loans Servicing, L.P. fka Countrywide Home Loans Servicing LP Recording Date: 7/20/09 Instrument # 200925239 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: 1123 Rana Villa Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Lower Allen Township COUNTY: Cumberland DATE EXECUTED: 12/19/02 DATE RECORDED: 1/30/03 BOOK: 1794 PAGE: 296 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: C, ( 0 (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 2/15/10: Principal of debt due $83,223.82 Unpaid Interest at 7.125% from 9/1/09 to 2/15/10 (the per diem interest accruing on this debt is $16.47 and that sum should be added each day after 2/15/10) 2,766.96 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $206.82 and that sum should be added on the first of each month after 2/15/10) 0 Late Charges (monthly late charge of $26.25 should be added in accordance with the terms of the note each month after 2/15/10) 131.25 Attorneys Fees (anticipated and actual to 5s of principal) 4,161.19 TOTAL $90,888.22 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. C, I , 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 $90,888.22 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 :k J V4 W ILA A;{AlYd_LllA 2 Attorneys for Plaintiff 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 C, ALL TRAT CERTAIN lot situate in the Township of Lower Alien, County of Cumberland and State of Pennsylvania, being Lot No. 64 on a Plan lmown as Rma Villa Spring Terrace, said Plan beingxecorded in the Recorder's Office at Carlislr., Pennsylvania, in Plan Book 2, page 42, bounded end described as follows, towit: B.EGriNING at a point on the eastern line of Rana. Villa: Avenue, said point being 653 feet to a southerly direction from Rosemont Avenue; thence in an easterly direction along the line of Lot No. 63 of the hereinbefom mentioned Plan of Lots, 166.75 feet to a point; thence in a southerly direcdon along the line of Lot No. 127 hereinbofore intentioned Plan of Lots, 65 feet to a point; thence in a westerly direction along the line of Lot No. 65 of the hereinbeforc mentioned Plan of Lots, 166.75 feet to a point; thence in a northerly direction along the eastern line of Rani, Villa Avenue, 65 feet to the place of BEGINNING. HAVING erected thareon a dwelling house known as No. 1123 Rana Villa Avenue, TOGETHER W the right and privilege of the free and uninterrupted use of the water of Rana Villa Spring, located on Lot No. 33 on said Plan, for domestic purposes only, in common with other owners and, occupiers of lots on said Plan. SUBJECT to coal, oil, gas, mineral. and mining rights as heretofore conveyed or reserved as shown in prior instruments of record. SUBJECT to the rights of way, easements, restrictions, reservations and exceptions as set forth in prior instruments of record. BEING THE SAME PREMISES which John S. Clouser and Doris L. Clouser, his wife, granted and conveyed unto Timothy G. Lao and Christine E. Leo, his wife, by deed dated May 12, 1994, and recorded in the Recorder of Deeds in and for Cumberland, PA in Record Book 105, Page 380, and recorded on May 13, 1994. UNDER cad SUBJECT to restrictions and conditions as now appear of =cord. C 0 BankofAmerica PRESORT ? ns First-Class Mail PO Box 9048 U.S. Postage and Temecula, CA 92589-9048 WSO 111111111111111111111111111111 Fees Paid 7113 8257 1473 7975 611 Send Payments To: PO Box 660694 Dallas, TX 75266-0694 Send Correspondence to. PO Box 5170, MS SV314B Simi Valley. CA 93065 091201-7 BLQPAI III.I.L I,II.I.II.L II1.I•II?IIIIL..IIIII'III?II'illl?ll.lld 111 Todd Garman 1123 RANA VILLA AVE CAMP HILL, PA 17011-6931 1225-3 EXHIBIT A 0 Bankof America .r. Herne Loans P.O. Box 660694 Dallas, TX 75266-0694 Send Payments to: P.O. Box 660694 Dallas, TX 75266-0694 12/01/2009 Certified Mail: 7113 8257 1473 7975 6023 Return Receipt Requested Regular Mail Todd Garman 1123 RANA VILLA AVE CAMP HILL, PA 17011-6931 Account No.: 21332300 Property Address: 1123 Rana Villa Avenue Camp Hill, PA 17011-6931 Current Servicer: BAG Home Loans Servicing, LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in defauR. _and the lender intends to foreclose. Specific information about the nature of the default is Provided in the attached Paaes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home, This Notice exolains how the Program works. To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE, Take this Notice with you when you meet with the Counselina Agency. 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 NOTIFICACION 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 TRADUCCKIN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. 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): Todd Garman PROPERTY ADDRESS: 1123 Rana Villa Avenue Camp Hill. PA 17011.6931 LOAN ACCT. NO.: 21332300 ORIGINAL LENDER: CURRENT LENDER/SERVICER: 13AC Home Loans Servicing. LP HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Please write your aawuni oun,ber on all cheats and corresponde-e. We may change you a fee for any payment rel-ed or rejected by your financial institution, subject to apolicahle law. BLQPA' 832°110792 (W18/2006 Payment tlWrxtlons: Account Number: Todd Garman Balance Due for charges listed above: $5,233.96 as of December 1, 2009. Make your oftcrc payable to BAC 1123 Rana Villa Avenue Home Loans Servicing, LP Please update e-mail information on the reverse side o'this coupon. • Don`; send oas`i Camp Hill, PA 17011$931 • Please irclude coupon w1h your ACd.-I payment 19 iWI / 7/ For al,. fell month payment pens ds. interest cnlot 'I I ated on a r mhy basis. Aoaordingy, interest for all full molnrE, Iincluding February, is oowlatcJ as 30!380-f annual interest, irrespective cf the actual number of days in the month. For partial months, interest is raloulated wily On 1he basis of a 385 pay year. BLQPAI AdUilo k 'Ilrl"Irll'll'I'1111"I'III'rlllllll'lll""II^nr'1111'III ??"" BAC Home Loans Servicing, LID cnk sc PO BOX 660694 - Dallas, TX 75266-0694 021332300900000523396000523396 C 1: 51869900 581:0 2 L 3 3 230011' YOU MAY BE ELIGIBLE FOR_FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND 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 WITHIN THE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counselina agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) 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: 1123 Rana Villa Avenue Camp Hill, PA 17011-6931 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 Charoes: 10101/2009 11/01/2009 Late Charaes: 10101/2009 Other Late Charaes: Total Late Charges: BAC 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: 2133230D Todd Gartman E-mail address: $731.77 $1,872.20 $52.50 $0.00 How we post your paymerris: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. ff 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, (iii) late charges and other amounts you owe in connection with your loan 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. Postdated cheola: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the date written on the check as a condition ore repayment plan. Uncollected Costs: $2,577,49 Partial Payment Balance: ($0.00) TOTAL DUE: $5,233.96 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not aoolicable)) HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,233.96, 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 savable and sent to: BAC Home Loans Servicing, LP at P.O. Box 660694, Dallas, TX 75266-0694. You can cure any other default by takina the followina 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 IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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 not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any 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 of Lender: SAC Home Loans Servicing, LP Address: P. O. Sox 660694 Dallas, TX 75266»0694 Phone Number: 1-800-669-6654 Fax Number: 1-805-577-3432 Contact Person: MS TX2-981-03-03 Attention: Loan Counselor EFFECT OF SHERIFF'S SALE - 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 attorneys fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM BAC Horne Loans Servicing, LP is a subsidiary al Bank of America, N.A. a e?;p C, ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. 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 December 31, 2009, BAC Home Loans Servicing, LP wants you to be aware of various options that may be available to you through BAG 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 BAG Home Loans Servicing. LP. Our basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least '/2 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 December 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. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg , PA 17325 717.334.1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Capital Region 1514 Deny Street Harrisburg. PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 BAC Hone Loans Servicing, LP is a subsidiary of Bank of America, N.A. 0 it r V E R I F I 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 A - n JAA I-AZLZ WAA IX41 U J Attorneys for Plaintiff 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 i C SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson t a f t Sheriff of u,n "- Jody S Smith Chief Deputy Edward L Schorpp Solicitor CrF?I E ???F?=F1(;E,?f BAC Home Loans Servicing, LP VS. Todd Garman Case Number 2010-1545 SHERIFF'S RETURN OF SERVICE 03/12/2010 06:38 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on March 12, 2010 at 1834 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Todd Garman, by making known unto himself personally, at 1123 Rana Villa Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 March 15, 2010 GERALD WORTHINGT DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) GcuniySuite, Shenff. Te eosof't, Inc_ 'UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. IIDREN, ESQIIIRE - ID #04302 STIIART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQIIIRE - ID #34576 `~~~~ _ :j~h, ALAN M. MINATO, ESQIIIRE - ID #75860 ,- , . ,. CHANDRA M. ARKEMA, BSQIIIRE - ID #203437 ADAM L. RAYES, ESQIIIRE - ID #86408 ; . ~; ?' ? ~ ~ ,~ , `; ~~: ~ MARGUERITE L. THOMAS, BSQIIIRE - ID #204460 °" ' V~^ ~~ ~u ~ 3o Pwl a T33 WOODCREST CORPORATE CENTER ,. r .w~ 111 WOODCREST ROAD, SIIITE 200 vti"" CHERRY HILL, NJ 08003-3620 ` 856-669-5400 BAC Home Loans Servicing, LP fka Countrywide :COURT OF COMMON PLEAS Home Loans Servicing LP :CIVIL DIVISION Plaintiff €Cumberland County v. Todd Garman Defendant(s) '_NO. 10-1545civil AFFIDAVIT OF SERVICE PURSIIANT TO Pa.R.C.P.RIILB 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true .and correct copy of which is attached .hereto as Exhibit "A", was sent to every recorded lienholder and every 'other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: July 21, 2010 UDRE / BY: neys or ain i MARK J. UDREN, SQUIRF_ ..__.___- STUART WINNEG;--'ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE UDREN LAW OFFICES, P.C. .MARK J. UDREN, ESQUIRE -1D #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 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff v. Todd Garman Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Cumberland County PLEAS NO. 10-1545civil TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Todd Garman PROPERTY: 1123 Rana Villa Avenue, (Lower Allen Township) Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on September 8. 2010, at 10:00 am, in the Commissioners Hearing Room, 2ND Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 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N 3°-~°oa~o N y = C N ~ ~ O ~~ ~ ° ~ ~ m Ot n x ~~ m J n y' ~ £n m ~ a 7 y ~~ Q t '+~m~c3 m c c ~ N m o m n w ~ J m 3 m .. a m m ~ c m 3a n ~aw3~~ -w0 n~ ~ a+~D ° n X a ~J ' 3 p y ~ y . . ~a~ ~ m 3 o~y v 7 __d N O ~J O.O n N x °-'m3 v ov°~2c ° ~d 'O m m ~ o~,v 4 v ~m - ~ ~ ~ tnm O'~~ fD T ~ _. ~ yd.N .~ m y m m O N O O N J fD N ~1 O '7 fD ~ G p y ~~~-' UJ,3 - w ?O y N C O d ~ m m c m ~ Jo-m'yo~ T(n mb Q ~ _~d o. ~ ~ J m m ~ 3 ~. y .l Z y o i 'J Sj ~ ~ ~ % 3 y~gsW3 ° 3 w N2 m y J n i3 o. y~ ~ mo^m ~3 :U .Zl N n J ~ ~ S a H~B~ I~ ~ ~ M ° ~~o~~ ~ ? ;~ y ~ J c, w m~ m m T W ° - m m o N SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~s```~ Ronny R Anderson Sheriff ~Q~~ca at ~u~nbr~,~~~ Jody S Smith , G Chief Deputy Richard W Stewart -~~- Solicitor mice car - ~sE s~seatrF BAC Home Loans Servicing, LP vs. " Todd Garman Case Number 2010-1545 SHERIFF'S RETURN OF SERVICE 06/23/2010 06:36 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 6-23-201 C at 1833 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Todd Garman, located at, 1123 Rana Villa Avenue, Camp Hill, Cumberland County, Pennsylvania according to law. 06/26/2010 11:55 AM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-201 C at 1155 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: Todd Garman, by making known unto, Todd Garman, personally, at, 1123 Rana Villa Avenue, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $898.92 July 02, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF EXHIBIT B (cy CountySuite Sheriff, Teleosoft, hr. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF cF, ". ,, E -...?-Rtcf FILED-OFFICE c111 OCT 12 lrr: r'"MSERLAND COLIHTY BAC Home Loans Servicing, LP Case Number vs. 2010-1545 Todd Garman SHERIFF'S RETURN OF SERVICE 06/23/2010 06:36 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 6-23-201C at 1833 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Todd Garman, located at, 1123 Rana Villa Avenue, Camp Hill, Cumberland County, Pennsylvania according to law. 06/26/2010 11:55 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on 6-26-201 C at 1155 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: Todd Garman, by making known unto, Todd Garman, personally, at, 1123 Rana Villa Avenue, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 09/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on 9/8/10 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Alan M. Minato on behalf of Federal National Mortgage Association, 1900 Market Street, Ste 800, Phila, PA 19103 being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 1,172.43 SHERIFF COST: $1,172.43 October 11, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF qf.Dj) p,4, 04, .-2-00 Cie, ,s5 Pd, (c) GountySuite Sheriff. TeleoBOft, InC. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. ;JDREN, 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP fka :COURT OF COMMON PLEAS Countrywide Home Loans Servicing LP :CIVIL DIVISION Plaintiff :"Cumberland County V. :MORTGAGE FORECLOSURE Todd Garman NO. 10-1545civil Defendant (s) AFFIDAVIT PURSUANT TO RULE 3129.1 BAC Home Loans Servicing, LP, Plaintiff in the above Udren, ESQ., sets forth as of Execution was filed the real property located at: 17011 LP fka Countrywide Home Loans Servicing action, by its attorney, Mark J. of the date the Praecipe for the Writ following information concerning the 1123 Rana Villa Avenue, Camp Hill, PA 1. Name and address of Owner(s) or reputed Owner(s): Name Address Todd Garman 1123 Rana Villa Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Ammerman Devey 4661 Trindle Road Endodontics Ltd Camp Hill, PA 17011 4. Name and address of the last recorded holder of every mortgage of recorld Name Address BAC Home Loans Servicing, P.O. Box 660694 LP fka Countrywide Home Dallas, TX 75266 Loans Servicing LP Mortgage Electronic Registration Systems, Inc. Members 1st Federal Credit Union 1800 Tapo Canyon Road Mail Stop #SV-103 Simi Valley, CA 93063 C/O Terrence J. McCabe, Esq. 123 South Broad Street Suite 2080 Philadelphia, PA 19109 P.O. Box 2026 Flint, MI 4851-2026 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 1123 Rana Villa Avenue Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and,cor;-ect'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. sec. 4904 relating to unsworn falsification to authorities. DATED: April 13, 2010 LAW OFFICES P.C. C BY: ?Attorne-ys-. - f-ox -.Plaint i f f MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF MARK J.fUDREN, 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP fka -COURT OF COMMON PLEAS Countrywide Home Loans Servicing LP :CIVIL DIVISION Plaintiff :Cumberland County V. :MORTGAGE FORECLOSURE Todd Garman -NO. 10-1545civil Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Todd Garman 1123 Rana Villa Avenue Camp Hill, PA 17011 Your house (real estate) at 1123 Rana Villa Avenue, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on September 8, 2010, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $92,266.90, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY-STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAPE 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ALL THAT CERTAIN lot situate in the Township of Lower Aden, County of Cumberland and State of Pennsylvania, being Lot No. 64 on a Plan Imown as Tuna Villa Spring Terrace, said Plan being.recorded in the Recorder's Office at. Carlisle, Pennsylvania, in Plan Book 2, page 42, bounded and described as follows, towit: BEGINNING at a point on the eastern line of Rana Villa Avenue, said point being 653 feet to a southerly direction from Rosemont Avenue; thence in an easterly direction along the line of Lot No. 63 of the hercirnbefore mentioned Plan of Lots, 166.75 feet to a point; thence in a southerly direction along the line of Lot No. 127 hereinbefore mentioned Plan of Lots, 65 feet to a point; thence in a westerly direction along the line of Lot No. 65 of the hereinbefore mentioned Plan of Lots, 166.75 feet to a point; thence in a northerly direction along the eastern line of Rana Villa Avenue, 65 feet to the place 'of BF-GDRqlNG, HAVING erected thereon a dwelling house known as No. 1123 Rana Villa Avenue. 'T'OGETHER WITH the right and privilege of the free and uninterrupted use of the water of Rana Villa Spring, located on Lot No. 33 on said Plan, for domestic purposes only, in common with other owners and occupiers of lots an said Flan. SUBJECT to coal, oil, gas, mineral, and mining rights as heretofore conveyed or reserved as show, in prior instruments of record. SUBJECT to the rights of way, easements, restrictions, reservations and exceptions as set forth in prior instruments of record. BEING THE SAME PkEMISES which John S. Clouser and Doris L. Clouser, his wife, granted and conveyed unto Timothy 0. Leo and Christine E. Leo, his wife, by deed dated May 12, 1994, and recorded in the Recorder of Deeds in and for Cumberland, PA in Record Book 105, Page 380, and recorded on May 13, 1994. UNDER sad SUBJEC'T' to restrictions and conditions as now appear of record. BEING KNOWN AS: 1123 Rana Villa Avenue Camp Hill, PA 17011 PROPERTY ID NO.: 13-24-0799-209 TITLE TO SAID PREMISES IS VESTED IN TODD GARMAN, A SINGLE MAN BY DEED FROM TIMOTHY G. LEO, JOINED BY CHRISTINE E. LEO, HIS WIFE DATED 12/19/02 RECORDED 01/30/03 IN DEED BOOK 255 PAGE 2763. .The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Z4( patriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin), ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th. 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true, and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/09/10 Sworn to and-)!!ubscribed before me this 05 day of August, 2010 A. D_ r - Notary Public-- --°-MrvioNw--r__ o`??N?arurA f Notarial Seal i Sherrie L. Klsner, Notary Public Lower Paxton Twp. Dauphin County I_ ?1y Comr issio_n Expires Nov. 26, 20] 1 1 '!ember op? -- ira AsSOOatirn of Noi.aries 07/16/10 07/23/10 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, EsgUire, 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: July 16, July 23,' and July 30, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 30 day of July 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Con missioa Exp1m Apr 28.201 Wit 50.2010.26" C1r11 BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP VS. Todd Garman Atty.: Alan M. Minato ALL THAT CERTAIN lot situate in the Township of Lower Allen,, County of Cumberland and State of Pennsylvania, being Lot No. 64 on a plan known as Rana Villa Spring Terrace, said plan being recorded in the Recorder's Office at Carlisle, Pennsylvania, in Plan Book 2 Page 42, bounded and described as fol- lows, to wit: BEGINNING at a point on the eastern line of Rana Villa Avenue, said point being 653 feet to a south- erly direction from Rosemont Avenue; thence in an easterly direction along the line of Lot No. 63 of the herein- before mentioned plan of lots, 166.75 feet to a point; thence in a southerly direction along the line of Lot No. 127 hereinbefore mentioned plan of lots, 65 feet to a point; thence in a westerly direction along the line of Lot No. 65 of the hereinbefore mentioned plan of lots, 166.75 feet to a point; thence in a northerly direction along the east- ern line of Rana Villa Avenue, 65 feet to the place of BEGINNING. HAVING ERECTED THEREON a dwelling house known as No. 1123 Villa Avenue, together with the right and privilege of the free and uninter- rupted use of the water of Rana Villa Spring, located on Lot No. 33 on said plan, ilex donna is purposes only, in eo a v th other owners and oc- c upien of Iota on said plan. SUBJECT to coal, oil, gas, mineral and mining ri&ts as heretofore con- veyed or reserved as shown in prior instruments of record. SUBJECT to the rights of way, easements, restrictions, reservations, and exceptions as set forth in prior instruments of record. BEING the same premises which John S. Clouser and Doris L. Clouser; his wife, granted and conveyed unto Timothy G. Lee and Christine E. Leo, his wife, by deed dated may 12, 1994, and recorded in the Recorder of Deeds in and for Cumberland, PA in Record Book 105, Page 380, and recorded on May 13, 1994. UNDER AND SUBJECT to restric- tions and conditions as now appear of record. BEING KNOWN AS: 1123 Rana Villa Avenue, Camp Hill, PA 17011. PROPERTY ID NO.: 13-24-0799- 209. TITLE TO SAID PREMISES IS ^ '"'" `VESTED IN Todd Garman a sin le y??UC.t J , g man by deed from Timothy G. Leo, joined by Christine E. Leo, his wife dated 12/19/02 recorded 01/30/03 r"ifs in Deed Book 255 Page 2763. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-1545 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 TODD GARMAN (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 $92,266.90 L.L.$.50 Interest from 4/14/10 to Date of Sale 9/8/10 Ongoing Per Diem of $16.47 to actual date of sale including if sale is held at a later date Atty's Comm % Due Prothy $2.00 Atty Paid $174.00 Other Costs Plaintiff Paid Date: 4/22/10 (Seal) David D. Buell, By: Deputy REQUESTING PARTY: Name: ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 75860 On June 14, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 1123 Rana Villa Avenue, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 14, 2010 By: eal Estate Coordinator COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mty Assoc is the grantee the same having been sold to said grantee on the 8th day of September A.D., 2010, under and by virtue of a writ Execution issued on the 22nd day of April, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 10 Number 1545, at the suit of BAC Home Loans Ser LP fka Countrywide Home Loans Ser LP against Todd Garman is duly recorded as Instrument Number 201029294. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this f 3 day of A.D. D /iO I-Recorder of Deeds d-CoW FA EaIrFWWndydis2M