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HomeMy WebLinkAbout10-3518GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM IN THE COURT OF COMMON PLEAS BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 1299 North Middleton Road Carlisle, PA 17013 Defendants N0TICF. 2?llit:si? I S CUF11 ` OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. OWL ACTION: MOFr-GAGE FORECr OSr j F You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 6 2 Liberty Avenue s ??' Q y Carlisle, PA 17013 GIC ?3/y(?3 ?? rya 7 a G 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 defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner 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 O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, PSTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FHtM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org,/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., 7105 Corporate Drive, PTX C-35 Plano, TX 75024. 2. The names and addresses of the Defendants are The Unknown Heirs of Virginia L. Rupp, Deceased, 1299 N. Middleton Rd, Carlisle, PA 17013, JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, 133 Oak Flat Rd, Newville, PA 17241, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, 53 Strawberry Dr, Carlisle, PA 17013, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, 1026 Centervile Rd, Newville, PA 17241 and SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, 718 Longs Gap Rd, Carlisle, PA 17013. LLOYD L. RUPP died on April 26, 1999. By operation of law title vests solely in VIRGINIA L. RUPP and LLOYD L. RUPP is hereby released of liability pursuant to Pa.R.C.P. 1144. VIRGINIA L. RUPP died on August 17, 2009 Intestate and is survived by her heirs-at-law JAMES A. RUPP, JUDY L. MINNOCH, PATRICIA A. GSELL, SAMUEL E. RUPP. 3. On January 26, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to COUNTRYWIDE HOME LOANS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1938 Page 4206. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for September 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$77,497.62 Interest from 08/01/2009 through 03/23/2010 at 6.2500% .......................$3,118.45 Per Diem interest rate at $13.27 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$3,874.88 Late Charges from 09/01/2009 to 03/23/2010 .............................................$174.79 Monthly late charge amount at $24.97 Costs of suit and Title Search (Estimated) ...................................................$900.00 $85,565.74 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $85,565.74, together with interest at the rate of $13.27, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the,. 4ortgage and Sheriff's Sale of the Property. By: GOLD Michael McKeever Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 VERIFICATION Angelica B. Williams-Asst. Sac*", I, 1 as the representative of the Plaintiff corporation _ t within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: Angelica B. Williams-ASSt. Sacrgtary #96435FC - ESTATE OF VIRGINIA L. RUPP 1299 North Middleton Road Carlisle, PA 17013 EythibitA . SCH EWLIE C LOOAL DESCOMM Fie NurnW.. 5100 7 CommwmM Number 61007 ALL THAT C<'RTM those twv oeW tracte of hard vft the knpru mnents dawn a MAK - she in North WddMon Township, Cumberland Count, Pmw#m*, bounded OW described as DNS: INka-M.-t West 5 2 perches to a 9? at a Post; thence by hard now or fonrrerhr of Jacob Zeigler, Nom A lend noweos OTAn R or ft"* of 9W to the place Ulm* a* thencre South 74 "A degrees West 7 Patches to a P? thence by y? d?eee Fast 9.75 perches to a stare; thanes North 34 % degrees CONTIUt 35 Peldm; aW being improved with o trick dwe k*, TRAM r ? at an iron pin in line of land now or ftlm y of John R. ShM Otienoe by said WAvt North 13 degrees ot jack D~ and pw* 16 IrlirRl? West 117.34 feet to a point; thence by land now orb deescri a South 76 South FA degrees 15 minable E 155.46 feet to an iron Pin; dues 46 minutes West 102 feet to the Puce of WAMPNM- Ex,hibit (B ACT 91 NOTICE DATE OF NOTICE: 03/30/2010 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached ages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM MAP) may be able to help to save your home This Notice explains how the program works To see if HE" can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. _The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869.) 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 any 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, pees afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo 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. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 HomeRetention@goldbecklaw.com Date: 03/30/2010 Homeowners Name: ESTATE OF VIRGINIA L. RUPP Property Address: 1299 North Middleton Road, Carlisle, PA 17013 Loan Account No.: 125904463 Original Lender: BAC HOME LOANS SERVICING, L.P. Current Lender/Servicer: BAC HOME LOANS SERVICING, L.P. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM 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 (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. 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 counseling 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.) 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. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 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 dill apply for Emergency Mortgage Assistance )' HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date)NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1299 North Middleton Road, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 09/01/2009 thru 03/30/2010 (7 mos. at $499.35/month) $3,495.45 (b) Late charges from 09/01/2009 thru 03/30/2010 (7 mos. at $24.97/month) $174.79 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $3,670.24 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 19 670.24 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 to: Attention: Act Letter Department BAC HOME LOANS SERVICING LP c/o Goldbeck McCafferty & McKeever 701 Market Street Suite 5000 Philadelphia, PA 19106 HomeRetention@goldbecklaw.com 866-413-2311 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 brings 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 Sheriffs Sale _You may do so by paving 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 Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: BAC HOME LOANS SERVICING LP Address: 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Phone Number: 972-526-6425 Fax Number: 817-230-6811 Contact Person: Mary Tull Email: PHFA.Program@bankofamerica.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs 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 Sheriffs 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 HAVE 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. * 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. Contact Person: Mary Tull Phone Number: 972-526-6425 HEMAP Consumer Credit Counseling Agencies Report last updated: 3!1/2010 8:47:08 AM CCCS of Western PA 4402 Peach Street DAUPHIN County Erie, PA 16509 CCCS of Western PA 888.511.2227 ext 2000 I..inglestown Road 108 888.511.2227 ext Harrisburg, PA 17102 108 888.511.2227 888.5112227 Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 814.337.8450 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County CCCS of Western PA 2000 Unglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Community Action Commission of Captial Region 1514 Deny Street Harrisburg, PA 17104 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DELAWARE County Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 215.389.2810 American Credit Counseling Institute 175 Strafford Avenue Suite 1 Wayne, PA 19087 610.971.2210 888.212.6741 American Credit Counseling institute 526-528 Dekalb Street Norristown, PA 19401 610.971.2210 888.212.6741 American Financial Counseling Services Inc. 1080 N. Delaware Avenue Suite 200 Philadelphia, PA 19125 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 405 West Germantown Pike Norristown, PA 19403 267.228.7903 800.490.3039 American Financial Counseling Services Inc. 175 Strafford Avenue Suite One Wayne, PA 19087 267.228.7903 800.490.3039 Page 8 of 21 .~ BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased ORDER ?~ zoo IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 10-3518 ~ ~`• L r r= (.h r'; ~._ ~` s=~ ~- _ y ~, 7 L _ ``' C ~C AND NOW, this ~5 ~ day of ~ tsz 62010, upon consideration of the Plaintiffs c.~ c tr! :~ C.3" 4,. Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, The Unknown Heirs of Virginia L. Rupp, Deceased have been unsuccessful, it is hereby ORDERED and DECREED that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant, The Unknown Heirs of Virginia L. Rupp, Deceased by (i) publication as provided in Pa.R.C.P. 430(bx2), (ii) posting a copy of the Complaint upon the subject property, located at 1299 North Middleton Road, Carlisle, PA, 17013 (the "Property"), and (iii) sending a copy of same by certified and regular mail to the Property; and, it is further ORDERED and DECREED that Plaintiff shall serve the Notice of Sheriffls sale upon Defendant, The Unknown Heirs of Virginia L. Rupp, Deceased by (i) posting a copy of the Complaint upon the Property, and (ii) sending a copy of same by certified and regular mail to the Property; and, it is further ORDERED and DECREED that all other legal papers shall be served upon Defendant, The Unknown Heirs of Virginia L. Rupp, Deceased by sending a copy of same by regular mail to the Property. ~ rn~<« L/z4 ~~a ~~ +.:.r -at T '~ FT'1 .r, t~~ ~...~ :~` 7 a'! ` ;;f-~ :~ FILE:--.._. - GOLDBECK McCAFFERTY & McKEEVER .>~. T~ r '- ~ f ` ".r~Y BY: MICHAEL T. MCKEEVER ~~~~ ~`~~ _~ ~~~ ~• ATTORNEY LD. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET ~'~%~~ ~- ~.-' '~'~j~ PHILADELPHIA, PA 19106-1532 ~ ` ~ `~'` ' ~- '~''~ fit, (215)627-1322 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) Term No. 10-3518 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER .--- z / ~~%G~2~ Attorney for Plaintiff By Michael T. McKeever, Esq. Ck'~ S3~T~ l ,~i- d uil~t/3 SHERIFFI'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOllCltOf ~,~~r~ta rat ~'rt~pbrr~~~~ 4 i. F:~~' ~.i QFI'iCE ': '~E Sr'~RIFE ,,r T~ I``~'rf ,_ ~ ~,~~' 210 : nisi a `~~ t!J ,fit; ~_ ~ r~ i ,~ ( V i1 .J r, ;~~ ~,;, z (~ ,-• r- BAC Home Loans Servicing, LP Case Number vs. The Unknown Heirs of Virginia L. R pp, Deceased (et al.) 2010-3518 SHERIFF'S RETURN OF SERVICE 07/14/2010 04:13 PM -Michael 2010 at 1613 hours, within named defenc court by posting the Pennsylvania 17013 rick, Deputy Sheriff, who being duly sworn according to law, states that on July 14, served a true copy of the within Complaint in Mortgage Foreclosure, upon the to wit: The Unknown Heirs of Virginia L. Rupp, Deceased, pursuant to order of mises located at 1299 North Middleton Road, Carlisle, Cumberland County, h a true and correct copy according to law. MI AEL BARR CK, DEPU SHERIFF COST: $39.40 July 15, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheriff, Teleosoft. Inc. r GOLDBECK McC BY: MICHAEL T. McKI ATTORNEY I.D. #56129 SUITE 5000 - MELLON I 701 MARKET STREET PHILADELPHIA, PA 191 (215) 627-1322 ATTORNEY FOR PLAINT BAC HOME LOANS SE. COUNTRYWIDE HOMI F/K/A COUNTRYWIDE 7105 Corporate Drive PTX C-35 Plano, TX 75024 The Unknown Heirs of Vi JAMES A. RUPP, Solely Virginia L. Rupp, Decease Solely in Her Capacity as Deceased, PATRICIA A. ~ Capacity as Heir of Virgin SAMUEL E. RUPP, Soler Virginia L. Rupp, Decease Mortgagor(s) 1299 North Middleton Ro: Carlisle, PA 17013 TY & McKEEVER CENTER 1532 ~f~.CU _ _, 2010 ~IJ!_ ~ 9 P~ ~ ,~: i ~. cu ~9r~ ; ~, ~} ' ,r t/~. VICING, LP FKA LOANS SERVICING LP IOME LOANS, INC. ;inia L. Rupp, Deceased, His Capacity as Heir of JUDY L. MINNOCH, eir of Virginia L. Rupp, SELL, Solely in Her . L. Rupp, Deceased and in His Capacity as Heir of IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVII. ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-3518 Defendant(s) CERTIFICATE OF SERVICE MICHAEL T. he did serve upon Defend copy of the above-caption dated June 25, 2010. The provided by 18 P.S. Sectic %v ESQUIItE hereby certifies that on ~~ ~ 1 The Unknown Heirs of Virginia L. Rupp, Deceased a true and correct Complaint by certified and regular mail in accordance with the Court Order understands that the statements herein and subject to the penalties i 4904. Respectfully submitted, GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE PROOF OF PUBLICATION ~ ~ State of Pennsylvania, County of Cumberland fames Kleinklaus, Director of Sales and Marketing, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspape of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13~, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): Tuly 19, 2010 -z COPY OF NOTICE OF PUBLICATION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , CIVIL ACTION -LAW No. 10-3518 NOTICE OF ACTION IN MORTGAGE FORECLOSURE BAC HOME LOANS SERVICING, LP t/k/a COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased, JAMES A.'RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased & SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, Mortgagors and Real Owners, Defendants TO: The Unknown Heirs of Virginia L. Rupp, Deceased, MORTGAGOR AND REAL OWNER, DEFENDANT(S), whose last known address is 1299 N. Middleton Road, Carlisle, PA 17013. THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIE~T. ANY INFORMATION OBTAINED FROM YOU W ILL BE USED FOR THE PURPOSE OF COLLECTING THE D BT. You are hereby notified that, Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP f/k/a COUNTRYWIDE HOME LOANS, INC., has filed a Mortgage Foreclosure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 10-3518, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located, 1299 North Middleton Road, Carlisle, PA 17013, whereupon your property wilt be sold by the Sheriff of Cumberland County'. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (2Q) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD.TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 401 East Lowther Street, Suite 103, Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street, Carlisle, PA 17013 717-249-3166 Michael T. McKeever, Atty. for Plaintiff Goldbeck McCafferty & McKeever, P.C. Suite 5000, Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 0 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and tha all allegations in the foregoing statement to time, place and character of publication are true. Sworn to and subscribed before me this ~~~ ~~~ r (,U~~'l,~',y~ CLt~a.Jt.~ Notary Public My commission expires: NOTARIAL SE BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commi:afon Expires Jan 27, 2014 ~0- 3sr~ cw;l PROOF OF PUBLICATION ~ ~ ~~ 3 ' State of Pennsylvania, County of Cumberland lames Kleinklaus, Director of Sales and Marketing, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues p# o THE SENTINEL on the following day(s): ~~ July 19, 2010 `' ~ ~ 1 `~ _,~; ;~ -c.. - - ~ ~-~ r:,. .~ < COPY OF NOTICE OF PUBLICATION ~- ' ' ~ y-- _-: o .. .r- - ..;~ c., Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. ~ ~i My commission expires: before me this NOTARIAL 8EAL BAIABI ANN MECKENDORN NeAanr PelDlic CARLISLE BOROIIBH, CUMBERLAND CNTY My ComnMtebn Expire: Jan 27, 2014 Notary Public PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 Lisa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this _23 day of July 2010 Notary NOTARIAL 8EAL DEBORAH A COLONS CARLIBLE BOROU6F1~, CUARLAir~ COUN~ry My Commb~on ExpNq Apr 20.2011 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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 Cazlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since Januazy 2, 1952, been 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 regulaz editions and issues of the said Cumberland Law Journal on the following dates, Viz July 23, 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 aze true. CUMBERLAND LAW JOURNAL xo~cE of Ac~riox nr MORTQAt~E FORECLOSURE In the Court of Common Pleas, Cumberland County Civil Action-Law No. 10-3518 BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING LP f/k/a COUNTRYWIDE HOME LOANS, INC., Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased, JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 8a SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, Mortgagors and Real Owners, Defendants TO: The Unknown Heirs of Vir- ginia L. Rupp, Deceased, MORT- GAGOR AND REAL OWNER, DEFENDANT(S), whose last known address is 1299 N. Middleton Rd., Carlisle, PA 17013 THIS FIRM IS A DEBT COLLEC- TORAND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OB- TAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECT- ING THE DEBT. You are hereby notified that, Plaintiff BAC HOME LOANS SERV- ICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING LP f/k/a COUNTRYWIDE HOME LOANS, INC., has filed a Mortgage Foreclosure Complaint endorsed with a notice to defend against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 10-3518, wherein Plaintiff seeks to foreclose on the mortgage secured on your property located, 1299 North Middleton Road, Carlisle, PA 17013, whereupon your property will be sold by the Sheriff of Cumberland County. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written ap- pearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint 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 PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES INC. 401 East Louther Street Carlisle, PA 17013 CUMBERLAND LAW JOURNAL (717) 243-9400 or CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Ca:'hsle, PA 17013 (717) 249-3166 ESQUIRE T. McKEEVER, GOLDBECK McCAFFERTY ~ McKEEVEl2, P.C. Attorneys for Plaintiff Mellon Independence Center 701 Market St. Suite 5000 Philadelphia PA 19106-1532 (215) 627-1322 In the Court of Common Pleas of Cumberland County BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FFI No. 10-3 ? UNi'Y THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased and SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased in accordance with the signed consent judgment dated 03/23/10. Assess damages as follows: Debt Interest from 03/24/10 to Date of Sale per diem at $13.27 Total (Assessment of Damages attached) $85,565.74 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 MC --,EVER yji &R42386 ? Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW a l s+ { , p , Judgment is entered in favor of BAC HOME LOANS SERVICING, LP FKAL S S hK V-1 E HOME LOANS, INC. and against JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased and SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased in accordance with the signed consent judgment dated 74 as per the above certification. 14.00 PAAlM el 6N& A2Q e,-2q 8 5'13 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: PATRICIA A. GSELL GSELL, PATRICIA A. 1299 North middleton road carlisle, PA 17013 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP FIK/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) TO: PATRICIA A. GSELL 1299 North middleton road carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 IMPORTANT NOTICE 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 (10) 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. LEGAL. SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: MINNOCH L JUDY MINNOCH, JUDY L. 1299 NORTH MIDDLETON ROAD carlisle, pa 17013 In the Court of Common Pleas of Cumberland County BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/KJA COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) TO: MINNOCH L JUDY 1299 NORTH MIDDLETON ROAD carlisle, pa 17013 CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 IMPORTANT NOTICE 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: JAMES A RUPP RUPP, JAMES A. 1299 NORTH MIDDLETON ROAD carlisle, pa 17013 In the Court of Common Pleas of Cumberland County BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) TO: JAMES A RUPP 1299 NORTH MIDDLETON ROAD carlisle, pa 17013 CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 IMPORTANT NOTICE 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: SAMUEL E. RUPP RUPP, SAMUEL E. 1299 north middleton road Carlisle, pa 17013 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) TO: SAMUEL E. RUPP 1299 north middleton road Carlisle, pa 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 IMPORTANT NOTICE 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: The Unknown Heirs of Virginia L. Rupp, Deceased The Unknown Heirs of Virginia L. Rupp, Deceased 1299 N. Middleton Rd Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP FIK/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) TO: The Unknown Heirs of Virginia L. Rupp, Deceased 1299 N. Middleton Rd Carlisle, PA 17013 CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 IMPORTANT NOTICE 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased RUPP, JAMES A. 133 Oak Flat Rd Newville, PA 17241 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 TO: JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 IMPORTANT NOTICE 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased MINNOCH, JUDY L. 53 Strawberry Dr Carlisle, PA 17013 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 TO: JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 53 Strawberry Dr Carlisle, PA 17013 IMPORTANT NOTICE 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased GSELL, PATRICIA A. 1026 Centervile Rd Newville, PA 17241 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 TO: PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newville, PA 17241 IMPORTANT NOTICE 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 96435FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 20, 2010 TO: SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased RUPP, SAMUEL E. 718 Longs Gap Rd Carlisle, PA 17013 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. The Unknown Heirs of Virginia L. Rupp, Deceased JAMES A- RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) TO: SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 IMPORTANT NOTICE In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-3518 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 (10) 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, is about unknown years of age, that Defendant's last known residence is 133 Oak Flat Rd Newville, PA 17241, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 6 ` 10 M/'W Michelle Clarkson VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, is about unknown years of age, that Defendant's last known residence is 718 Longs Gap Rd Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. -NArvuo, co?jkg-N) Date: 1 - / /o Michelle Clarkson IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. Plaintiff VS. CIVIL DIVISION NO. 10-3518 JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Defendant(s) VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, is about unknown years of age, that Defendant's last known residence is 53 Strawberry Dr, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments.. Date: 9/16/2010 JQ oj_?_ Michelle Clarkson IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. Plaintiff VS. CIVIL DIVISION NO. 10-3518 JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Defendant(s) VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, is about unknown years of age, that Defendant's last known residence is 1026 Centervile Rd, Newville, PA 17241, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 9/16/2010 Michelle Clarkson GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 10-3518 Please enter Judgment in favor of BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., and against JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased and SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased in accordance with the signed consent judgment dated 03/23/10, in th ,5-7 F By: LDBEC KEEVER Mi eel Gary LKristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, 133 Oak Flat Rd Newville, PA 17241, JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, 53 Strawberry Dr Carlisle, PA 17013, PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased, 1026 Centervile Rd Newville, an OfLfEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased, 718 Longs Gap Rd Carlisle, PA 1 By: GOL ECK GAFFER & MCKEEVER Michael eever Pa. 129 Gary McCafferty a. ID 42386 Lisa Lee Pa. ID 78020 Kristine Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff a ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $77,497.62 Interest from 08/01/2009 through $3,118.45 03/23/2010 Reasonable Attorney's Fee $3,874.88 Late Charges $174.79 Costs of Suit and Title Search $900.00 Escrow Payments Due 0 X $0.00 $0.00 $85,565.74 By: GOLDB Kaffe CAFFERT & MCKEEVER Michael er Pa. ID 56 9 Gary M6 Lisa L ee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW, this c2l day of o? f- , 2010 damages are assessed as above. '- 3eA/ rothy FILEO-OFFiCE E THE '?C ? ` 0H0TAR`' GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever, Esquire Attorney I.D. #56129 BY: Thomas I. Puleo, Esquire Attorney I.D. #27615 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attomev for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. vs. The Unknown Heirs of Virginia L. Rupp, Deceased, JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 2014 SEP 21 Ali 10.45 CUMBERLAND COUNTY n -9!fI h -iqi f'LVAPl1s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 10-3518 CONSENT JUDGMENT AND NOW, it is hereby stipulated and agreed by and between the undersigned as follows: Defendants are named solely in their capacity as Heirs of the Estate of Virginia L. Rupp, Deceased, and have no personal liability for the payment of the debt secured by the mortgage upon the said premises situate at 1299 North Middleton Road, Carlisle, Pennsylvania. 2. An in rem judgment is entered in favor of the Plaintiff and against the Defendants in the sum of $85,565.74 plus interest from March 23, 2010 at the rate of $13.27 per diem and other costs and charges collectible under the Mortgage, and for the foreclosure and sale of the mortgaged Property. 3. Defendants retain the right to reinstate and/or payoff the mortgage in question at anytime prior to a Sheriffs Sale, if any, in accordance with the mortgage documents. 4. Defendants have no defenses to this action and do not intend to interpose any answer herein and specifically waive the right to do so and any and all defenses that might otherwise have been contained therein. 5. Plaintiff and Defendants agree that any sums advanced by Plaintiff after the entry of this judgment in mortgage foreclosure shall become a part of the judgment lien. 6. Defendants acknowledge and agree that they are the only heirs of Virginia L. Rupp, Deceased. 7. This Consent Judgment represents the whole agreement of the parties who, intending to be legally bound, have executed it bid through the undersigned duly authorized counsel. Date: Date: O /a " /6) - U Date:--,R-- Date: Date: /C e Date: -/0 Michael T. WKeever, Esquire Thomas I. Puleo, Esquire Attorneys for Plaintiff .Ones A. Rupp Defendant Samuel E. Rupp Defendant Ju(fy L. h Defendant Patricia Gsell Defendant 5 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. IN THE COURT OF COM MON PLEAS 7105 Corporate Drive PTX C-35 of Cumberland County Plano, TX 75024 Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of No. 10-3518 Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road ` ^u Carlisle, PA 17013 =y ra Defendant(s) cr) = "+7 r°s .- Cn C _ N --- S IF PRAECIPE FOR WRIT OF EXECUTION r -,= q TO THE PROTHONOTARY: c> ? >C Issue Writ of Execution in the above matter: --? --- taa ? Amount Due Any 00 PO $85,565.74 13q.. +48o0 cBF Interest from 03/24/10 3q q. q. 00 " to Date of Sale per 10.00 diem at $13.27 ? 14-66 a`' 50 (Costs to be added) 31(.70 - Po 141-ty By: n/? GOLD CCAFFE TY & MCKEEVER 0o a toe ID 56129 a i h l M * . eever a. . M c c ae .5D LL- Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 C !f 5?foao? al Thomas Puleo Pa. ID 27615 e aK857 Attorneys for Plaintiff D? 1?1..4- ti. ? ? dUa ° O d W C.7 W p, ? ? ? x l y ? `? ? p? M W p .? U ca U o x (? v U r W fop r ) o° oG d R ?. -o x A° o w un? Wd0 x? ?UAo? a OD C4 z? 003 w aA? ?px a a O VU a 4 U d x ? o ti O O d y ALL those two certain tracts of 1 and with the improvements thereon erected, situate in North Middleton Township, Cumberland County, Pennsylvania. bounded and described as follows: TRACT NO. 1: BEGINNING at a post; thence by land now or formerly of Jacob Zeigler, North 45 degrees West 5.2 perches to a black oak; thence South 74.5 degrees West 7 perches to a post; thence by land now or formerly of Benjamin F. Nickey, South 65 degrees East 9.75 perches to a stone; thence North 34.5 degrees East 3 perches to the Place of BEGINNING. CONTAINING 35 Perches; and being improved with a brick dwelling. TRACT NO.2: BEGINNING at an iron pin in line of land new or formerly of John R. Stum; thence by said land, North 13 degrees 15 minutes West 117.34 feet to a point: thence by lan d now or formerly of Jack DeHart and partly through a run, South 54 degrees 15 minutes East 155.48 feet to an iron pin; thence by Tract No. 1 herein described, South 76 degrees 45 minutes West 102 feet to the Place of BEGINNING. Parcel# 29-05-0427-051 Property address: 1299 North Middleton Road, Carlisle, PA 17013 Goldbeck, McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 10-3518 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. By: GOLDBEC CCAFF TY & MCKEEVER Michael eever Pa. ID 56129 Gary McCafferty Pa. ID 42386 ? Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 , !LED-OFFICE CE THE P"ON?THONOTARY 2010 SEE 21 10: 43 GLfM8ERLANQ COUNTY @«SYLVANI A IN THE COURT OF COMMON PLEAS David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff GoldbeSk McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Fl'LED-OFFICE , O TI-I . -,O : ONOTAM IQ Sc, 21 NJ 10: 43 r;4 9EERL +I D C0UNT)' IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1299 North Middleton Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): ACTION OF MORTGAGE FORECLOSURE No. 10-3518 JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 53 Strawberry Dr Carlisle, PA 17013 PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newville, PA 17241 SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: JAMES A- RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 53 Strawberry Dr Carlisle, PA 17013 PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newville, PA 17241 SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1299 North Middleton Road Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA, DEPT. OF REVENUE INHERITANCE, TAX DIVISION 1131 Strawberry Sq., 6th Floor Harrisburg, PA 17128 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 INTERNAL REVENUE SERVICE- SPECIAL PROCEDURES BRANCH 1001 LIBERTY AVENUE, 13TH FL SUITE 1300 PITTSBURGH, PA 15222 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: September 16, 2010 GOLDBE K McCAFFERTY & McKE R BY: Michelle Clarkson 10-3518 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s' , ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 Ca GO cn ? "n -? cn r r.> Ca-n 2-' CD c C) tC-)n - 4 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUPP, JAMES A. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orwforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 10-3518 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http•//www phfa orv,/consumers/homeowners/real.Mx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&jzoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 10-3518 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP IN THE COURT OF COMMON PLEA S F/KIA COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive of Cumberland County PTX C-35 Plano, TX 75024 CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAG E FORECLOSURE JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased Docket No. 10-3518 PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased ?, --t SAMUEL E. RUPP, Solely in His Capacity as Heir e ico cn rn- of Virginia L. Rupp, Deceased N rri Mortgagor(s) and Record Owner(s) _ 1299 North Middleton Road 0 Carlisle, PA 17013 _ q C:) .z: Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MWNOCH, JUDY L. JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 53 Strawberry Dr Carlisle, PA 17013 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hM://www.philadelphiafed.orgJforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 10-3518 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aWx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&Roldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 9643517C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 10-3518 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MI NOCH, Solely in Her Capacity as Hei: of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 G') p -n - c -n ?? , ice; -- t... ? :I- o -n c -= c=) e ??o rn THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GSELL, PATRICIA A. PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newville, PA 17241 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orwforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 10-3518 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/bomeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkRoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 10-3518 ,+ 0 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as He]' of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s r QD 'Tt o rn L? C -c - ) 4c ? c-7 = 1 c=) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUPP, SAMUEL E. SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hM://www.philade!P-hiafed.orP,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 10-3518 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.asp . 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. 10-3518 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.956129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Hei of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 c"> 1299 North Middleton Road Carlisle, PA 17013 T cn 3s Defendant(s ?- c-) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO Q COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GSELL, PATRICIA A. PATRICIA A. GSELL 1299 North middleton road carlisle, PA 17013 r? cn 0 c.3 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. C:) M r ? -rt °M A 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-3518 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals-to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff 10-3518 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Hei of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 c? c? © -? r M ? t r - .. CJ C:? 3 -n o o c3 - c a om --t THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MINNOCH, JUDY L. MINNOCH L JUDY 1299 NORTH MIDDLETON ROAD carlisle, pa 17013 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courtjudgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. agamst you. 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-3518 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud._ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkgoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 10-3518 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 ? a - --, rn C:) 4 'C= p ?rn THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUPP, JAMES A. JAMES A RUPP 1299 NORTH MIDDLETON ROAD carlisle, pa 17013 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-3518 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: http•//www phfa orp/consumers/homeowners/real.gVx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention ckyoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 10-3518 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Hey of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 Defendant(s CD - ° -4 'r- -n ca ? rn ? cl = ?°- o °rn THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUPP, SAMUEL E. SAMUEL E. RUPP 1299 north middleton road carlisle, pa 17013 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. i 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-825-6329 or 1-866413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-3518 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 r? 10-3518 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website: hilp://www.phfa.org/consumers/homeowners/real.asipx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionkgoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 96435FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3518 Civil 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 f/k/a COUNTRYWIDE HOME LOANS, INC., Plaintiff (s) From JAMES A. RUPP, solely in his capacity as Heir of Virginia L. Rupp, Deceased; JUDY L. MINNOCH, solely in her capacity as heir of Virginia L. Rupp, Deceased; PATRICIA A. GSELL, solely in her capacity as Heir of Virginia L. Rupp, Deceased; SAMUEL E. RUPP, solely in his capacity as heir of Virginia L. Rupp, Deceased (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $85,565.74 L.L.$.50 Interest from 3/24/10 to Date of Sale per diem at $13.27 -- to be added Atty's Comm % Atty Paid $311.70 Plaintiff Paid Date: 9/21/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Dav. . Buell, Pro onotary By: Name: GARY McCAFFERTY, ESQUIRE Address: GOLDBECK McCAFFERTY & MCKEEVER Attorney for: PLAINTIFF Deputy Telephone: 215-627-1322 Supreme Court ID No. 42386 GOLDBECK McCAFFERTY & McKEEVER Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 THt: PROTHONOTARY 2011 FEB 24 AM 11:32 CUMBERLAND, COUNTY BAC HOME LOANS SERVICING, LP FKA? COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 10-3518 ERIC KEENAN, an employee of Goldbeck McCafferty & McKeever, counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/ Y -(copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. 96435FC CF: 05/26/2010 SD: 03/02/2011 $85,565.74 COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Resp lly submi ed BY: ERIC KEENAN Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor BAG Home Loans Servicing, LP vs. Virginia L Rupp let al.) ?q???ty a4 turnLrr/,?d r. OFFICE OF '4i SK:-MrF Case Number 2010-3518 SHERIFF'S RETURN OF SERVICE 01/06/2011 03:45 PM - Deputy Shawn Gutshall, being duly sworn.according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1299 North Middleton Road, Carlisle, PA 17013, Cumberland County. Tract 1 and 2- 01/06/2011 03:27 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: ar uel E. Run° at 718 Longs Gap Road, North Middleton Township, Carlisle, PA 17013, Cumberland County. 01/06/2011 09:47 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: J, uggl, Minnoch Minnich) at 53 Strawberry Drive, South Middleton Township, Carlisle, PA 17013, Cumberland oun 01/06/2011 05:30 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Patricia Se j at 1026 Centerville Road, Penn Township, Newville, PA 17241, Cumberland County. 01/06/2011 05:10 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: James A_ Rupp at 133 Oak Flat Road, West Pennsboro Township, Newville, PA 17241, Cumberland County. SHERIFF COST: $1,283.94 SO ANSWERS, January 20, 2011 RON R ANDERSON, SHERIFF (c) wu,fY3010 Srwct. T912a.5M, Inc. c, ,` Cl Ol U ? $ ? ? " yyy??? c[? O r r p E i7 lL. ` rry, ?? „ '? .,,: c.a of a o ' rxt?t rr ..` 4) ._ Z ?_. .... W U LLF a Uj Q J z Q ?? J O C Uj J LL U R 0 z > M O U) z LL, W z o LL t CO CO 00 N m ch N W m m ? _ F-- w z u. O co ` a g U O? N Z N c w -00 ? m $ ?? rL A y - - ?z r ;z > Q es b ;6.0 W? yy 0 L) > O F-? ti W Sr ? Q H E 6 $G a N IL C-) C W W Z 0) a LZ E6 a w ,^ O Q) $ V) = LL ai of -? W o v Zz uuc m n LC F E CE x-0 Z J'-m _ 0) Z CN W m O W r CL = m` W ~ z F` a H U a 2 0 M z V) d. c r3 m c U ? ty t t Q n W W iJ v a < .r I a R w ac) M m ?n *? U c? o C?7 $ ???? 55? m O 0 C o F i d W O am O I T= ? 1- 7 N Z ? _ g o 02 o W a-6 Lo W n W 'aN Q U ; Q U U L7 0 a, cp x0 . 7 vj ???? W N-F; m Ll2 a y W z E 2Z) cc' H v m gy ' o 0? Q m = a U g a N FL 00 z v 91 4) w z W F- M W Q $ Of 4- ?Yowa..cv a <(..)02-j m,°nX0 8y c, 0 z Z v O a CV M v (O t? co N N N O i a 7 J ro .c O N N N U N Q m U m .c W O cn a+ p IL z C z Q g ? J m } O t1 i O V H N ? Q Q CL 3 U J O M N C b+ M 0 o D ? m = U 3 y O cA ? U a v ? C p M > O Z E U) Ll. C LL Q Co o ltl U- a m ? GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff VS. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-3518 AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1299 North Middleton Road Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 53 Strawberry Dr Carlisle, PA 17013 PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newville, PA 17241 SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 53 Strawberry Dr Carlisle, PA 17013 PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newville, PA 17241 SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1299 North Middleton Road Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA, DEPT. OF REVENUE INHERITANCE, TAX DIVISION 1131 Strawberry Sq., 6th Floor Harrisburg, PA 17128 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 INTERNAL REVENUE SERVICE- SPECIAL PROCEDURES BRANCH 1001 LIBERTY AVENUE, 13TH FL SUITE 1300 PITTSBURGH, PA 15222 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: February 17, 2011 ------- ?? .? GOLDBECK McCAFFERTY & McKEEVER BY: ERIC KEENAN Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff F'i ED-;0 i E it' E Jody S Smith Chief Deputy Richard W Stewart Solicitor 4C1 i 1 JlulL 13 P?°' ?: 11 L2 r•l"MBERLA iD CCE;?'' a''?' P ENN'SYLVA I BAC Home Loans Servicing, LP vs. Virginia L Rupp (et al.) Case Number 2010-3518 SHERIFF'S RETURN OF SERVICE 01/06/2011 03:45 PM -Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1299 North Middleton Road, Carlisle, PA 17013, Cumberland County. Tract 1 and 2. 01/06/2011 03:27 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Samuel E. Rupp at 718 Longs Gap Road, North Middleton Township, Carlisle, PA 17013, Cumberland County. 01/06/2011 09:47 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Judy L. Minnoch (Minnich) at 53 Strawberry Drive, South Middleton Township, Carlisle, PA 17013, Cumberland County. 01/06/2011 05:30 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Patricia A. Gsell at 1026 Centerville Road, Penn Township, Newville, PA 17241, Cumberland County. 01/06/2011 05:10 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: James A Rupp at 133 Oak Flat Road, West Pennsboro Township, Newville, PA 17241, Cumberland County. 03/02/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/6/2011 04/06/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/4/2011 05/04/2011 Ronny R Anderson, Sheriff, 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on May 04, 2011 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of Fannie Mae, P.O. Box 650043, Dallas, TX 75265, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $948.62 May 24 2011 SO ANSWERS, 2,2z"-------? . RON R ANDERSON, SHERIFF 00 , [f L /y Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-35 Plano, TX 75024 Plaintiff vs. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased (Mortgagor(s) and Record Owner(s)) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s) of Cumberland County CIVIL ACTION -- LAW ACTION OF MORTGAGE FORECLOSURE No. 10-3518 AFFIDAVIT PURSUANT TO RULE 3129 BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1299 North Middleton Road Carlisle, PA 17013 1.Name and address of Ovmer(s) or Reputed Owner(s): JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased. 53 Strawberry Dr Carlisle, PA 17013 PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newville, PA 17241 SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS 2.'lame and 9ddress of Defendant(s) in the judgment: JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 JUDY L. MINNOCH, Solely in Her Capacity as Heir of Virginia L. Rupp. Deceased 53 Strawberry Dr Carlisle. PA 17013 PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased 1026 Centervile Rd Newviile, PA 17241 SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 718 Longs Gap Rd Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every, other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale- TENANTS/OCCUPANTS 1299 North Middleton Road Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA, DEPT. OF REVENUE INHERITANCE, TAX DIVISION 1131 Strawberry Sq., 6th Floor Harrisburg, PA 17128 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM PO Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 INTERNAL REVENUE SERVICE- SPECIAL PROCEDURES BRANCH 1001 LIBERTY AVENUE, 13TH FL SUITE 1300 PITTSBURGH, PA 15222 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. DATED: S?tember 16 2010 W I P hd- i?? C 0 0'4k? GOLDBE K McCAFFERTY & MCKEEVER BY: Michelle Clarkson 10-3518 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.456129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. 7105 Corporate Drive PTX C-3 5 Plano, TX 75024 Plaintiff VS. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased JUDY L. MINNOCH, Solely in Her Capacity as Hei of V irginia L. Rupp, Deceased PATRICIA A. GSELL, Solely in Her Capacity as Heir of Virginia L. Rupp, Deceased SAMUEL E. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased Mortgagor(s) and Record Owner(s) 1299 North Middleton Road Carlisle, PA 17013 Defendant(s; IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 10-3518 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUPP, JAMES A. JAMES A. RUPP, Solely in His Capacity as Heir of Virginia L. Rupp, Deceased 133 Oak Flat Rd Newville, PA 17241 Your house at 1299 North Middleton Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2011, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $85,565.74 obtained by BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC. against you. 10-3518 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP F/K/A COUNTRYWIDE HOME LOANS, INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must: pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. I. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hM2://www.philadelphiafed.ory/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 10-3518 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ALL those two certain tracts of land with the improvements thereon erected, situate in North Middleton Township, Cumberland County, Pennsylvania. bounded and described as follows: TRACT NO. 1: BEGINNING at a post; thence by land now or formerly of Jacob Zeigler, North 45 degrees West 5.2 perches to a black oak; thence South 74.5 degrees West 7 perches to a post; thence by land now or formerly of Benjamin F. Nickey, South 65 degrees East 9.75 perches to a stone; thence North 34.5 degrees East 3 perches to the Place of BEGINNING. CONTAINING 35 Perches; and being improved with a brick dwelling. TRACT NIO.2: BEGINNING at an iron pin in line of land new or formerly of John R. Stum; thence by said land, North 13 degrees 15 minutes West 117.34 feet to a point: thence by land now or formerly of Jack Deflart and partly through a run, South 54 degrees 15 minutes East 155.48 feet to an iron pin; thence by Tract No. 1 herein described, South 76 degrees 45 minutes West 102 feet to the Place of BEGINNING. Parcel# 2.9-05-0427-051 Property address: 1299 North Middleton Road, Carlisle, PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3518 Civil CIVIL ACTION - LAW FO 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 Uk/a COUNTRYWIDE HOME LOANS, INC., Plaintiff (s) From JAMES A. RUPP, solely in his capacity as Heir of Virginia L. Rupp, Deceased; JUDY L. MINNOCH, solely in her capacity as heir of Virginia L. Rupp, Deceased; PATRICIA A. GSELL, solely in her capacity as Heir of Virginia L. Rupp, Deceased; SAMUEL E. RUPP, solely in his capacity as heir of Virginia L. Rupp, Deceased (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due 585,565.74 L. L.S.50 Interest from 3/24/10 to Date of Sale per diem at $13.27 -- to be added Atty's Comm % Atty Paid 5311.70 Plaintiff Paid Date: 9/21/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Name: GARY McCAFFERTY, ESQUIRE Address: GOLDBECK McCAFFERTY & MCKEEVER Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 42386 TRUE COPY FROM RECORD M Testimony whereof, I here unto set my hand and the seal of said C"d at Carlisle, Pa. This _rat:t da+1? of 20 IQ ??. lop Prothonotary V t)n November ?, 'ti lU the :sheriff levied upon the defendant's interest lii the real property situated in North Middletown I OWIIShtp, (_ umberiand County, PA_ Known and numbered as. c)() North Middleton Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein Cate: November '-'. )() ; (? l?eal Estate Coordinator PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), R 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 .Iournal, 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: .January 28, February 4, and February 11, 2011 Aff ant further deposes that he is authorized to verify this statement by the Cumberland Law Iournal, 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 staternents as to time, place and character of publication are true. L L a Marie Coyne, E ttor SWORN TO AND SUBSCRIBED before me this 11 day of February, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 26, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-3515 Civil BAC Home Loans Servicing, LP VS. Virginia L Rupp, James A. Rupp, Samuel E. Rupp, Judy L. Minnoch, Patricia A. Gsell Atty.: Michael McKeever ALL those two certain tracts of land with the improvements thereon erected, situate in North Middleton Township, Cumberland County, Pennsylvania. bounded and described as follows: TRACT NO. 1: BEGINNING at a post; thence by land now or formerly of Jacob Zeigler, North 45 degrees West 5.2 perches to a black oak; thence South 74.5 degrees West 7 perches to a post; thence by land now or formerly of Benjamin F. Nickey, South 65 degrees East 9.75 perches to a stone; thence North 34.5 degrees East 3 perches to the Place of BEGINNING. CONTAINING 35 Perches; and be- ing improved with a brick dwelling. TRACT NO.2: BEGINNING at an iron pin in line of land new or former- ly of John R. Stum; thence by said land, North 13 degrees 15 minutes West 117.34 feet to a point: thence by land now or formerly of Jack DeHart and partly through a run, South 54 degrees 15 minutes East 155.48 feet to an iron pin; thence by Tract No. 1 herein described, South 76 degrees 45 minutes West 102 feet to the Place of BEGINNING. Parcel# 29-05-0427-051. Property address: 1299 North Middleton Road, Carlisle, PA 17013. 51 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 e?a r.o Itws Novi yoL snow 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 cf the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot--News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and Slate 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/ Community Weekly 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: 1128111 2/4/11 - 2111/11 ,l ! Sworn to ed subscribed b?f e me this 2 day of February, 2011 A.D. Notary Public .00M HONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L aisner, Notary Public %otiver Paxton T%vp., Dauphin County My Commission IE)Ores Nov., 26, 2011 ?!Fmbr-r PlnnsAvanla As.sociation, 4Nota0w; 2010-3618 Civil Term BAC "am Lewis Swvief1p, LP Vs Virginia L Rupp James A. Rupp Samuel E. Rupp Judy L. Mlmmch Patricia A. GaWl Atty: Michael Makeover ALL those two certain tracts of land with the improvements thereon erected, situate in North Middleton Toamship, Cumberland County, Pennsylvania. bounded and described as follows: TRACT` No.1: BEGINNING at a post; thence by land now or formerly of Jacob Zeigler, North 45 degrees West 5.2 perches to a black oak; thence South 74.5 degrees West 7 perches to a post; thence by land now or formerly of Benjamin E Nickey, South 65 degrees East 9.75 perches to a stone; thence North 34.5 degrees East, 3 perches to the Place of BEGINNING. CONTAINING 35 Perches; and being improved with a bnck dwelling. TRACT-NO.2: BEGINNING at an iron pin in fine of land new or formerly of John R. Stum; thence by saidlandx,North 13 degrees 15 minutes West 117.34 feet to a point: thence by land now or formerly of Jack DeHart and partly through a run, South 54 degrees 15 minutes East 155.48 feet to an iron pin; thence by 'pact No. 1 herein described, South 76 degrees 45 minutes West 102 feet to the Pace of BEGINNING. Parcel# 29-05-0427-051 Pror-,;rty address: 1299 North Middleton Road, CzWe. PA 17013 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Fannie Mae is the grantee the same having been sold to said grantee on the 4 day of May A.D., 2011, under and by virtue of a writ Execution issued on the 21 day of September, A.D., 201.0, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 3518, at the suit of BAC Home Loans Servicing LP F/K/A Countrywide Home Loans Servicing LP F/K/A Countrywide Home Loans Inc. against Heirs of Virginia L. Rupp, Deceased is duly recorded as Instrument Number 201119414. IN TESTIMONY WHEREOF, I have eunto set my hand and eal of said office this /.J day of L , A.D. t ' / J, Re rder of Deeds .% Oanix dAMM, NI My Cam"BWu #* Fat Mondq dJa 2014 r ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r Jody S Smith Chief Deputy 2311 JILL 13 Pr 2: 1? Richard W Stewart Solicitor l UM1??RLt;(@ i,?'' ?i? ? '• Surgical Care Affiliates, LLC vs. Brandon A Rott Case Number 2011-4200 SHERIFF'S RETURN OF SERVICE 05/25/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Brandon A Rott, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Execution as "Not Found" at 102 Lincoln Street, East Pennsboro Township, Enola, PA 17025. This writ of execution is returned STAYED. SHERIFF COST: $61.71 SO ANSWERS, July 13, 2011 RON ? R ANDERSON, SHERIFF r' e 1 Cumberland County Sheriffs Office One Courthouse Sq., Room 303 Carlisle, PA 17013 717.240.6390 If this writ of execution is not_ settlo d quest twenty days from service then up be taken. of the plaintiff further action may ° dedPto the lease There are additiona? sof execution costs listed on this Sheriff s contact the Cumberland ?ff mount. Office for a full pay A full payoff of the writ s She df? s mad ceo the Cumberland County thee should Payment plans and/or a h the Plaintiff. be made directly ` You may not sell, trade, give away, destroy, dispose of or move property under Sheriff' s levy. s r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) ETC., LOCATED AT 102 LINCOLN STREET ENOLA, PA 17025. L.L. $.50 TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SURGICAL CARE AFFILIATES, LLC Plaintiff' (s) From BRANDON A. ROTT AT 102 LINCOLN STREET ENOLA, PA 17025 {1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PERSONAL PROPERTY, INCLUDING FURNITURE, APPLIANCES, TELEVISIONS, VCR'S, DVD PLAYERS, ENTERTAINMENT EQUIPMENT, JEWELRY, COMPUTERS, (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 5425.51 Interest AL LEGAL RATE OF 6% FROM 3/2/2011 @ $.06 PER DAY Atty's Comm °o Atty Paid 553.75 Plaintiff Paid Date: 5/9/11 (Seal) REQUESTING PARTY: Name KIMBERLY A. BONNER, ESQUIRE Address: JAMES, SMITH, DIETTERICK & CONNELLY, LLP PO BOX 650 HERSHEY, PA 17033 Attorne} for: PLAINTIFF Telephone: 717-533-3280 Supreme Court ID No. 89705 Due Prothy $2.00 Other Costs av' u Protho otarv By: NO 11-4200 Civil CIVIL ACTION - LAW Deputy h1'P§st!"' 3 se: my hwid and the, Pa. "is :inotWy : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. ZJQ I I - 4 LOU CIVIL TERM WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300.00. There are other exemptions which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (2) Deliver the form or mail it to the Sheriff's Office at the address noted. You should come to court ready to explain your exemption. If you do not come to court and prove your exemption, you may lose some of your property. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL. HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-(800)-990-9108 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 Statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain Insurance proceeds 8. Such other exemptions as may be provided by law IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO. yO CIVIL TERM To the Sheriff: CLAIM FOR EXEMPTION I, the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): 2. From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: El in cash ? in kind (specify property): (b) Social Security benefits on deposit in the amount of $ (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing of the hearing should be given to me at: Address Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa. C.S. 4904 relating to unworn falsification to authorities. Date: THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390