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HomeMy WebLinkAbout10-5302 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP 1800 Tapo Canyon Road Mail Stop #SV-103 Sims Valley, California 93063 v, R. Scott Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 and Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number Jo-5-30d-- CIVIL ACTION/MORTGAGE FORECLOSURE ,ri, oo pd- a47 clc//6 3 ,ems 4Y6 7" NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that ifyou fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar 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 decidir 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. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 41 CIVIL ACTION/MORTGAGE FORECLOSURE Plaintiff is BAC Home Loans Servicing, LP flca Countrywide Home Loans Servicing LP, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is R. Scott Lauffer, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 225 High Mountain Road, Shippensburg, Pennsylvania 17257. 3. The Defendant is Regina Mae Lauffer, who is the mortgagor and real owner ofthe mortgaged property hereinafter described, and his/her last-known address is 225 High Mountain Road, Shippensburg, Pennsylvania 17257. 4. On February 1, 2008, R. Scott Lauffer and Regina Mae Lauffer made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for Countrywide Bank, FSB which mortgage is recorded in the Office of the Recorder of Cumberland County in Instrument 200803791. 5. The aforesaid mortgage was thereafter assigned by Mortgage Electronic Registration Systems, Inc., as nominee for Countrywide Bank, FSB to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP, by Assignment of Mortgage, which will be duly recorded in the Office of the Recorder of Cumberland County. 6. The premises subj ect to said mortgage is described in the legal description attached as Exhibit "A" and is known as 225 High Mountain Road, Shippensburg, Pennsylvania 17257. 7. The mortgage is in default because monthly payments of principal and interest upon said mortgage due December 1, 2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following amounts are due on the mortgage: Principal Balance $ 269 707 24 Interest through August 4, 2010 $ , . 14 525 88 (Plus $52.44 per diem thereafter) , . Attorney's Fee Late Charges $ 1,300.00 Corporate Advance $ $ 730.40 125.50 GRAND TOTAL $ 286,389.02 9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands an in rem Judgment against the Defendants in the sum of $286,389.02, together with interest at the rate of $52.44 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISND CONWAY,P.C. BY: TERRENCE J. McCA , E UIRE MARC S. WEISBE V UIRE EDWARD D. CON WAN, MARGARET GAIRO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiff, who is not available to sign this, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISB ,F,f?D CONWAY,P.C. BY: ?- Attorn s for laintiff TERRENCE J. McCABKESOJA MARC S. WEISBERG, EDWARD D. CONWA MARGARET GAIRO, ESQUIRE exhibit A Commonwealth Land Title Insurance Company Commitment Number: 08-0405 SCHEDULE C PROPERTY DESCRIPTION The land referred to In this Commitment is described as follows: ALL THAT CERTAIN tract of land located In South Newton Township, Cumberland county, Commonwealth of Pennsylvania, bounded and described as follows: Beginning at a point in the center line Township Road T334, which point is 983 feet Southeasterly a center line of Township Road 334, from the center line of the Intersection of Route T321 and T334;long the thence, Northerly 65 degrees 06' East, 400 feet to a point; thence, Easterly 38 degrees 2T 42 East, 199.08 feet to a point, thence southerly 65 degrees 06' West, 400 feet to a point; thence, Westerly 35 degrees North, 30 feet to a point, the place of Beginning. TAX ID/ Parcel No. 41_12-0326-059A Being the same premises which Wayne E. Hawkins and Margaret A. Hawkins, his wife, by Deed dated June 29, 1977 and recorded June 29, 1977, in Cumberland county in Record Book G-27, Page 496, conveyed unto R. Scott Lauffer and Regina Mae Lauffer, his wife, in fee. Property also known as: 225 High Mountain Rd. Shippensburg, PA 17257 ALTA Commitment Schedule C (t AUFFER,ROY.PFD/08-0105/8) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ..~ '•~r~ r.~, S"ILCU 1^y"r~f", ^~T ~ ~; f..r.. T~ (r- ~~'' _ ..: i~'v ,. C Ji'v: ~.i" ~. PEti~vSl'i.:v~PdiA BAC Home Loans Servicing, LP Case Number vs. R. Scott Lauffer (et al.) 2010-5302 SHERIFF'S RETURN OF SERVICE 09/10/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 10, 2010 at 1500 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Regina Mae Lauffer. After several attempts the Complaint in Mortgage Foreclosure has expired. 09!10!2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 10, 2010 at 1500 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: R. Scott Lauffer. After several attempts the Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $80.00 SO ANSWERS, ~~"" September 10, 2010 RON R ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff V. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff Cumberland County r`s Court of Common Pleas r r- tV m G? .;~ C) =,.z . ,. _ ... 4'.? - ... . Number 10-5302 Civil r MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 Plaintiff attempted to personally serve a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Regina Mae Lauffer, at his/her last-known address of 225 High Mountain Road, Shippensburg, Pennsylvania 17257. The process server was not able to serve the Defendant because there was no response after multiple attempts. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendant and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B". As a result of the investigation, a special Order of Court is required permitting service by regular and certified mail at the Defendant last known address and by posting a copy of the original process on the mortgaged premises. 4. No judge has ruled upon any other issue in this matter or in any related matter. No attorney has entered an appearance in this matter on behalf of Defendant and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 6. If service cannot be made on the Defendant, Regina Mae Lauffer, the Plaintiff will be prejudiced. WHEREFORE, Plaintiffprays this Honorable Court grant an Order allowing the Plaintiffto serve the Complaint in Mortgage Foreclosure, and all other subsequent pleadings that require personal service, and the Notice of Sheriff s Sale upon the Defendant Regina Mae Lauffer, by regular mail; certified mail, return receipt requested; and by posting at the last-known address of Defendant and the mortgaged premises wn iVlhieremi as 225 High Mountain Road, Shippensburg, Pennsylvania 17257. T ENCE J. Me E,1 MARC S. WEISBERG, ESQU EDWARD D. CONWAY, ESQ RE MARGARET GAIRO, ESQUI Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP tka Countrywide Home Loans Servicing LP Plaintiff v. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10-5302 Civil MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. TERRENCE J. McCABE, MARC S. WEISBERG, E! EDWARD D. CONWAY, MARGARET GAIRO, ES Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff V. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10-5302 Civil CERTIFICATION OF SERVICE I, Edward Conway, Esquire, attorney for the Plaintiff, hereby certify that I served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 2 l st day of December, 2010, upon the following: Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 TERRENCE J. McCABE, MARC S. WEISBERG, E.' EDWARD D. CONWAY, MARGARET GAIRO, ES Attorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of this jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating t'o unsy/or ,jf'Qlsij6aXonJdauthorities. TERRENCE J. McCABE MARC S. WEISBERG, E EDWARD D. CONWAY, MARGARET GAIRO, E'. Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith .. Chief Deputy ? Richard W Stewart Solicitor OFFICE OF Twj WERIFF SAC Home Loans Servicing, LP vs. Case Number R. Scott Lauffer (et al.) 2010-5302 SHERIFF'S RETURN OF SERVICE 09/10/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that on September 10, 2010 at 1500 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Regina Mae Lauffer. After several attempts the Complaint in Mortgage Foreclosure has expired. 09/10/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that on September 10, 2010 at 1500 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: R. Scott Lauffer. After several attempts the Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $80.00 September 10, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF Ex1fi"bit A M 00 nw$Ae She:Hf, Teieosoll, ime. Attorney Outsourcing Support Services, Inc. Suite 2040 123 S. Broad Street Philadelphia, PA 19109 (215) 790-5964 FAX (215) 320-5770 AFFIDAVIT OF GOOD FAITH INVESTIGATrON SUBJECT OF INVESTIGATION: Regina Mae Lauffer CLIENT: FILE #: 49481 MATTER #: 234-4922 AOSS FILE#: 10-6808 SUBJECT'S LAST-KNOWN ADDRESS: 225 High Mountain Road Shippensburg, PA 17257 1, Ernest Caldwell , being duly sworn according to law, depose and say that Attorney Outsourcing Support Services, Inc. completed a good faith investigation into the whereabouts of the above-named subject and the extent of the investigation and the results are as follows: INQUIRY OF POSTAL AUTHORITY: Postal Authority stated that there is no change in the subject's address. 2. INQUIRY OF LOCAL TELEPHONE COMPANY; A. DIRECTORY ASSISTANCE AND INTERNET SEARCH: The subject has a listed phone number for the above stated last-known address. Said number(s) being: a. (717) 532-4117 Exhibit B Page Two Investigation of Retina Mae Lauffer continued: (subject name) 3. INTERNET SEARCH: Search shows the subject resides at the above stated last-known address.. 4. DEATH RECORDS: Social Security has no death record for the subject. LOCAL TAX RECORD INQUIRY: After inquiry, I was unable to confirm a mailing address for the above stated last-known address.. 6. INQIJIRY OF COUNTY VOTER REGISTRATION: After inquiry, I was unable to confirm a listing with the County Voters Registration Office for this subject.. Page Three Investigation of Regina Mae Lauf1'er continued: (subject name) INQUIRY OF NEIGHBORS: a. Neighbor, Richard C Meily, residing at 226 High Mountain Rd, Shippensburg, 17257 with a phone number (717) 532-7872 stated that the subject is residing at the property address of 225 High Mountain Road,, Shippensburg, PA, 17257 b. Neighbor, Nancy R Wilson, residing at 244 High Mountain Rd, Shippensburg, 17257 with a phone number (717) 532-3659 stated that he/she does not know the subject. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge, information, and belief. BY: NAME: -Ernest Caldwell Print TITLE: Location Specialist DATE: &1411y Notary Public: Sworn to and subscribed before me this "14-h day of _ CCU', 2010 Cmrx% Y\ C"QN410L 13 03. Postmaster Shi ensbur = PA 17257 City, State, 'LIP Code Date September 16, 2010 Request for Change of Address or Boxholder . Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder)for the following: Name: R. Scott Lauffer Address: 225 High Mountain Road Shi ensbur PA 17257 NOTE: The name and last known address are required f'or change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 C1iR 265.6(d)(6)(ii). 't'here is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro so - except a corporation acting pro se must cite statute): Not applicable. .Requester is an attorney 3. The names of all known parties to the litigation:- v. R. Scott Lauffer 4. The court in which the case has been or will be heard: Cumberland, PA. 5. The docket or other identifying number if one has been issued: Nn: 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FAISN INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSh OTHER THAN TIIE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPF.,CTNE LITIGATION COULD RESULT IN CRIMINAL PENAI, fIHS INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEF FOR CHANGE OF ADDRESS INFORMATION OF NOT MORL THAN 5 YEARS, OR BOTI f ('TITLE 18 U.S.C. SECTION 1001). PLEASE PROVIDE TIIE CORRFsCT ADDRESS FOR THE DEFENDANT. I certifyA at the above information is true and that the address information is needed and will be used solely for service of leg ocess in co9pfction with actual or prospective litigation. .f 7 Si I"3 S. Broad Str: ct. Suite 2080 Address Oscar Dun an AOSS V Printed Name Philadelphia. PA 19109 City, State, ZIP Code FOR POST OFFICE USE ONLY NEW ADDRESS or BOXHOLDER'S NAME and No change of address order on file. PHYSICAL STREET ADDRESS Not known at address given. Moved, left no forwarding address. No such address. Good As Addressed 1\ ? .Una Postmaster Date September 16, 2010 SMRRensburg, PA 17257 City, State, ZIP Code Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Regina Mae Lauffer Address: 225 High Mountain Road, Shippensburg, PA 17257 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g. process server, attorney, party representing himself): attorney 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or party acting pro se - except a corporation acting pro se must cite statute): Not applicable. Requester is an attorney 3. The names of all known parties to the litigation: v. Regina Mae Lauffer 4. The court in which the case has been or will be heard: Cumberland, PA 5. The docket or other identifying number if one has been issued: NO: 6. The capacity in which this individual is to be served (e.g, defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTTIER TTIAN THE SERVICE OF LEGAL PROCESS IN CONNF.C 1ON WITH ACTUAL OR PROSPECTIVE LfrfGATION COULD RESULT IN CRIMINAL, PF.NAI:1'IFS INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THH FFF FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (rrrLE 18 U.S.C. SECTION 1001). PLEASE PROVIDE THE CORRECT ADDRESS FOR THE DEFENDANT. I certify that the above information is true and that the address information is needed and will be used solely for service of leF " bcess in con ct on with actual or prospective litigation. 123 S. Brcad Street, Suite 2080 Si ature Address Oscar Dungan, ROSS Philadelphia, PA 19109 Printed Name City, State, ZIP Code FOR POST OFFICE USE ONLY NEW ADDRESS or BOXHOLDER'S NAME and No change of address order on file. PHYSICAL STREET ADDRESS Not known at address given. Moved, left no forwarding address. No such address. Good As Addressed BAC HOME LOAN SERVICING, LP, IN THE COURT OF COMMON PLEAS OF f/k/a COUNTRYWIDE HOME LOANS CUMBERLAND COUNTY, PENNSYLVANIA SERVICING, LP, f ,pt? PLAINTIFF ? p -4 V. Cl) R. SCOTT LAUFFER, 1 co -40 AND REGINA MAE LAUFFER, -CZ ="n DEFENDANTS NO. 10-5302 CIVIL c" p y Z, ORDER OF COURT Z G AND NOW, this 27th day of December, 2010, upon consideration of the Plaintiff's iVVOR for Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, Plaintiff's Motion is GRANTED. IT IS HEREBY ORDERED AND DIRECTED: 1. That the Plaintiff is directed to serve the Complaint upon Defendant by posting a copy of the Complaint upon the premises at 225 High Mountain Road, Shippensburg, PA 17257; 2. That the Plaintiff serve the Complaint by certified and regular mail to the Defendant's last known addresses at 225 High Mountain Road, Shippensburg, PA 17257; 3. All future service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known addresses. By the Court, M. L. Ebert, .Jr., J. ,/ dea David J. Apothaker, Esquire ,,?1'"` Attorney for Plaintiff Cdr ' ? o ,al oa Regina Mae Lauffer Defendant bas McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ED # 16496 MARC S. WEISBERG, ESQUIRE - ED # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff V. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas C' -n C ° -m r c, rn .v ? Nv G7-n ~ C-) 1 `=- Number 10-5302 Civil . r n 7 D SUGGESTION OF DEATH TO THE PROTHONOTARY: It is hereby suggested of record that Defendant, R. Scott Lauffer, departed this life on October 12, 2009. Thus, title to the property being foreclosed upon in the within action, vests solely in Defendant, Regina Mae Lauffer, by rights of survivorship. Attorney for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWITZ, ESQUIRE ?=SLED tlt-??.Pr0T-1' ri 7011 FEB 22 APB 11: CUMBERLANO C0,; McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff V. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10-5302 Civil PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above-captioned matter. ?'A > 3 A EN E J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff 1?f? r:????1<s r.., SHERIFF'S OFFICE OF CUMBERLAND COUIAY :; M iT1 r Ronny R Anderson ' `f._,"'• Sheriff ?.s no Jody S Smith Chief Deputy e Richard W Stewart Solicitor . 'y BAC Home Loans Servicing, LP vs. R. Scott Lauffer (et al.) Case Number 2010-5302 SHERIFF'S RETURN OF SERVICE 02/22/2011 06:00 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2011 at 1800 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Regina Mae Lauffer, pursuant to order of court by posting the premises located at 225 High Mountain Road, Shippensburg, Cumberland County, Pennsylvania 17257 with a true and correct copy according to law. SHERIFF COST: $52.44 February 23, 2011 ROB T BITNER, DEPUTY SO ANSWERS, 11- (;" 24 ? ? RON R ANDERSON, SHERIFF O THE PROTHONUTAR 2011 APR -4 AM II : 5p CUMBERLAND COUNTY PENNSYLVANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorneys for Plaintiff BAC Home Loans Servicing, LP flea Countrywide Cumberland County Home Loans Servicing LP Court of Common Pleas Plaintiff Number 10-5302 Civil V. R. Scott Lauffer and Regina Mae Lauffer Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Terrence J. McCabe, Esquire, being duly sworn according to law, deposes and says that the following is true and correct to the best of his knowledge and belief: That he is counsel for the above-named Plaintiff; 2. That on March 2, 2011, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Regina Mae Lauffer by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last-known address of 225 High Mountain Road, Shippensburg, Pennsylvania 17257. True and correct copies of the letters, certificates of mailing and certified receipts are attached hereto, made a part hereof, and marked as Exhibit "A." That on February 22, 2011, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Regina Mae Lauffer, by posting the same at the mortgage premises of 225 High Mountain Road, Shippensburg, Pennsylvania 17257. True and correct copy of the Affidavit of Service indicating the same is attached hereto, made art hereof, and marked Exhibit "B." TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff SWORN AND SUBS ?D BEFO ME THIS DAY OF /,(_ _ '2011 PUBLIC COMMONWEALTH OF PENNSYLY NOTARIAL SEAL Barbara J. Moyer-Notary Pubilc CRy of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 TERRENCE J. MCCABE••' MARC S. WEISBERG" EDWARD D. CONWAY - MARGARET GAIRO `•' LISA L. WALLACE+t DEBORAH K. CURRAN±- LAURA H.G. O'SULLIVANf, GAYL C. SPIVAK•= FRANK DUBINANDREW L. MARKOWITZ HEIDI R. SPIVAK* SCOTT TAGGART* MARISA COHEN• KATHERINE SANTANGINI- JASON BROOKS f FAITH MIROS `<' ERIN BRADY - KEVIN T MCQUAIL RABIRAH SCOTT •• ALEXANDRA T. GARCIA* CORRIN DEMENT - ABBY K. MOYNIHAN -• CATHLEEN WELKER See www.mw 4aw- for licensing key. Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 2080 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790-1010 FAX (215) 790-1274 March 2, 2011 SUITE 303 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858-7020 SUITE 499 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)-636-8900 FAX (914)-636-8901 Also servicing Connecticut SUITE 100 8101 SANDY SPRING ROAD LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 201 4021 UNIVERSITY DRIVE FAIRFAX, VA 22030 (866) 656-0379 Re: BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP v. R. Scott Lauffer and Regina Mae Lauffer Cumberland County CCP Number 10-5302 Civil Dear Regina Mae Lauffer: Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure, along with a copy of the signed Order dated December 27, 2010, the original of which has been filed against you in regard to the above-captioned matter. Very truly yours, Terrence J. McCabe TJM/mc Enclosures SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7010 1870 0000 09112289 RETURN RECEIPT REQUESTED Fxh1hjt P This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. gCgqg( SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy : ?. Richard W Stewart Solicitor OFFICE OF THE SkERIFF BAC Home Loans Servicing, LP Case Number vs. 2010-5302 R. Scott Lauffer (et al.) SHERIFF'S RETURN OF SERVICE 02/22/2011 06:00 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2011 at 1800 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Regina Mae Lauffer, pursuant to order of court by posting the premises located at 225 High Mountain Road, Shippensburg, Cumberland County, Pennsylvania 17257 with a true and correct copy according to law. SHERIFF COST: $52.44 February 23, 2011 ROB ?TBITNER%, DEPU SO ANSWERS, RON R ANDERSON, SHERIFF t ? {ci Cap:ryciite Shen f. 78taj>,tl, Inc. BAC HOME LOAN SERVICING, LP, IN THE COURT OF COMMON PLEAS OF f/k/a COUNTRYWIDE HOME LOANS CUMBERLAND COUNTY, PENNSYLVANIA SERVICING, LP, PLAINTIFF V. R. SCOTT LAUFFER, AND REGINA MAE LAUFFER, DEFENDANTS NO. 10-5302 CIVIL ORDER OF COURT AND NOW, this 27th day of December, 2010, upon consideration of the Plaintiff's Motion for Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, Plaintiff's Motion is GRANTED. IT IS HEREBY ORDERED AND DIRECTED: 1. That the Plaintiff is directed to serve the Complaint upon Defendant by posting a copy of the Complaint upon the premises at 225 High Mountain Road, Shippensburg, PA 17257; 2. That the Plaintiff serve the Complaint by certified and regular mail to the Defendant's last known addresses at 225 High Mountain Road, Shippensburg, PA 17257; 3. All future service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known addresses. By the Court, M. L. Ebert, Jr., J. David J. Apothaker, Esquire Attorney for Plaintiff Regina Mae Lauffer Defendant bas McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP flea Countrywide Home Loans Servicing LP Plaintiff v. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5302 Civil ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: C -cs =0o rVI :z;U cn r- I- r_ CD C) C-1 r-- Ca C) _T1 fl? Fri Y P-11 s? ts? ZZ c? Kindly enter judgment by default in favor of Plaintiff and against Defendant, Regina Mae Lauffer, (ONLY) in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages ac follows: Principal Interest from 08/05/10 to 04/06/11 Total $ 286,389.02 $ 12,900.24 $ 299,289.26 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff QV{sly.eof' I ow * ??? ?WO?:1ee1 AND NOW, this __? day of 2011, Judgment is entered in favor of Plaintiff, BAC Home Loans Servicir ;, LP flea Countrywide Home Loans Servicing LP, and against Defendant, Regina Mae Lauffer, (ONLY), and damage; are assessed in the amount of $299,289.26, plus interest and costs. BY THE PROTHONOTARY: /'1 47Z McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff V. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-5302 Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Regina Mae Lauffer, (ONLY), 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 Act of Congress of 1940 as amended; and that the Defendant, Regina Mae Lauffer, (ONLY), is over eighteen (18) years of age, and reside as follows: Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 SWORN AND SUBS BEFORE ME THIS WY OF April .2011 NOTARIAL SEAL Barbara J. Moyer- Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES JAN. 12, 2014 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP flea Countrywide Home Loans Servicing LP Plaintiff V. R. Scott Lauffer and Regina Mae Lauffer Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5302 Civil CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant, Regina Mae Lauffer, (ONLY) that judgmer t would be entered against them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND SUBS BEFORE ME THIS TJAY OF April___, 2011 Ad, i -C== v4f? NOTARY PUBLIC "t MM17NWEALTH OF PENNeYLVANiA NOTARIAL SEAL Barbara I Moyer Notary Public ,ft y tj Philade'011 41,sladelphip ?W ©la i y z,??v? DES 12,2 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff 1D OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary March 23, 2011 To: Regina Mae Lauffer 225 High Mountain Road_ Shippensburg, Pennsylvania 17257 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP vs. R. Scott Lauffer Regina Mae Laufer Cumberland County Court of Common Pleas Number 10-5302 Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO DE REBELDIA FOR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOOADO Y POR NO HABER RADICADO FOR ESCRITO CON ESTE TRIBUNAL SUS DEFENSES U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALOUNA, DICTAR SENTENCIA EN SUCONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE A UN ABOOADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LAD PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTEDNO PUEDE PROPORCIONARPARAEMPLEARUN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMAC16N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGMLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. 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 AI FARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPPA TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 00 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 INFORMATIONABOUTAGENCIPS7NATMAYOFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG, AND CONWAY, P.C. BY /1 A ?.?-r _,4 i /S,/A Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE me WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-5302 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. Plaintiff (s) From REGINA MAE LAUFFER (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: $299,289.26 L.L.: $.50 Interest from 4/7/11 $12,004.80 AT $49.20 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $264.94 Other Costs: Plaintiff Paid: Gate: 8/30/11 David D. Buell, rothonotary (Seat) By: Deputy REQUESTING PARTY: Name: MARGARET GAIRO, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 34419 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION FILE NO.: 10-5302 Civil Civil T erm'-= - " BAC Home Loans Servicing, LP fka Countrywide CX1 rnrn - Home Loans Servicing LP AMOUNT DUE: $299 289.26 ty ` v. , . INTEREST: from 04/07/11 - Regina Mae Lauffer $12,004.80 at $49.20 „ ATTY' S COMM.: =C) tv ca COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 225 High Mountain Road, Shippensburg, Pennsylvania 17257 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: August 26, 2011 OLI, vrLl B`o . as SA (44 a a.oo 14.0o u c? 16 aly') MAI Signature: Print Name: argar Gairo, Esquire Firm: MCCABE, EISBERG AND CONWAY Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 34419 s so?c-- k-4k IV gel e1+ ap McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff V. Regina Mae Lauffer Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5302 Civil AFFIDAVIT PURSUANT TO RULE 3129 [ CS -+: c? C-5 - The undersigned, attorney for Plaintiff' in the above action, sets forth the following information concerning the real property located at: 225 High Mountain Road, Shippensburg, Pennsylvania 17257, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owner or Reputed Owner Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 Name and address of Defendant in the judgment: Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. 6. Name and address of every other person who has any record lien on the property: Name Address None Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 225 High Mountain Road Shippensburg, Pennsylvania 17257 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 811 Street Inheritance Tax Office Suite #204 Philadelphia, PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America United States of America c/o Atty General of the United States United States of.America c/o Atty General of the United States c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Name and address of Attorney of record: Name Address None 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. Aueust 26, 2011 M rgaret afro, squire DATE Attorney or Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP flea Countrywide Home Loans Servicing LP Plaintiff V. Regina Mae Lauffer Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5302 Civil AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. t„r CD F^. l C-D -c s?? Co The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 SWORN AND BEFO ME' OF GO NOTARY PUBLIC N0 i= IA b W l_ Barbara J. Moyer - Notary PubIIC Gty Of Philadelphia, Philadelphia County My COMMISSION EXPIRES JAN. 11 , 2014 &,Or Ma garet giro, Esquire Attorney 16r Plaintiff -i; .c; ca McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP V. Regina Mae Lauffer COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5302 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 `' r7i Cu 'J - ; - r tnC c.a CD `. „.. =C) ?G N C ' c:-- :. Your house (real estate) at 225 High Mountain Road, Shippensburg, Pennsylvania 17257 is scheduled to be sold at Sheriffs Sale on December 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $299,289.26 obtained by BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. Attorneys for Plaintiff 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 the following notice 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 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 by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r Jody S Smith Chief Deputy Richard W Stewart J 4`it Solicitor L BAC Home Loans Servicing, LP Case Number vs. R. Scott Lauffer (et al.) 2010-5302 SHERIFF'S RETURN OF SERVICE 09/30/2011 06:10 PM - Deputy Stephen Bender, 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 225 High Mountain Road, Shippensburg, PA 17257, Cumberland County. 09/30/2011 06:10 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Regina Mae Lauffer, pursuant to Order of Court by "Posting" the premises located at 225 High Mountain Road, South Newton Township, Shippensburg, PA 17257, Cumberland County with a true and correct copy according to law. 12/05/2011 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/1/2012 01/30/2012 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/4/2012 04/03/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $784.24 SO ANSWERS, April 03, 2012 RON R ANDERSON, SHERIFF . 5ZII c:--L ??- ?-go 5?'4a?a 3 Si McCABI, WFISBFRG AND CONWAY, P.C. BY: ' TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP Plaintiff V. Regina Mae Lauffer Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10-5302 Civil AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 225 High Mountain Road, Shippensburg, Pennsylvania 17257, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owner or Reputed Owner Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 2. Name and address of Defendant in the judgment: Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein Name and address of every other person who has any record lien on the property: 11 Name None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address Address None Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 225 High Mountain Road Shippensburg, Pennsylvania 17257 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8'h Street Inheritance Tax Office Suite #204 Philadelphia, PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address None 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. August 26, 2011 M rgaret afro, squire DATE Attorney or Plaintiff 01 E :8 d I C e(id iiot v McCABE, XISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP V. Regina Mae Lauffer Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-5302 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 Your house (real estate) at 225 High Mountain Road, Shippensburg, Pennsylvania 17257 is scheduled to be sold at Sheriffs Sale on December 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $299,289.26 obtained by BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing LP the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 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 by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land located in South Newtown Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T334, which point is 983 feet Southeasterly along the center line of Township Road 334 from the center line of the intersection of Route T321 and T324; thence northerly 65 degrees 06 minutes East, 400 feet to a point; thence easterly 38 degrees 27 minutes 42 seconds East, 199.09 feet to a point; thence southerly 65 degrees 06 minutes West, 400 feet to a point; thence westerly 35 degrees north, 30 feet to a point, place of beginning. CONSISTING of 1.793 acres and being improved with a dwelling home. RB5678 225 High Mountain Road, Shippensburg, Pennsylvania 17257. BEING the same premises which WAYNE E. HAWKINS AND MARGARET A. HAWKINS, HUSBAND AND WIFE by deed dated June 29, 1977 and recorded June 29, 1977 in the office of the Recorder in and for Cumberland County in Deed Book G Volume 27, Page 496, granted and conveyed to R. Scott Lauffer and Regina Mae Lauffer, his wife in fee. AND the said R. Scott Lauffer departed this life on October 12, 2009 vesting title solely in Regina Mae Laufer by operation of law. TAX MAP PARCEL NUMBER: 41-12-0326-059A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO10-5302 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, L.P. FKA COUNTRYWIDE HOME LOANS SERVICING, L.P. Plaintiff (s) From REGINA MAE LAUFFER (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: $299,289.26 L. L.: $.50 Interest from 4/7/11 $12,004.80 AT $49.20 Arty's Comm: % Due Prothy: $2.00 Arty Paid: $264.94 Other Costs: Plaintiff Paid: Date: 8/30/11 r4_? k"Cl David D. Buell, Prot onotary (Seal) By: Deputy REQUESTING PARTY: Name: MARGARET GAIRO, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF TRUE COPY FROST RECORDand in Testimony whereof, i here unto set my and the seat of said Court at Carlisle, 0 Pa- day This day of prothonotary Telephone: 215-790-1010 Supreme Court ID No. 34419 On August 31, 2011 the Sheriff levied upon the defendant's interest in the real property situated in South Newton Township, Cumberland County, PA, Known and numbered as, 225 High Mountain Road, Shippensburg, more fully described on Exhibit j "A" filed with this writ and by this reference incorporated herein. Date: August 31, 2011 By: JR"eLk/ Real Estate Coordinator S C .8 c I E qGV i ioi I ]j H CUMBERLAND LAW JOURNAL Writ No. 2010-5302 Civil BAC Home Loans Servicing, LP VS. R. Scott Lauffer Regina Mae Lauffer Atty.: Terrance McCabe ALL THAT CERTAIN tract of land located in South Newtown Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T334, which point is 983 feet Southeasterly along the center line of Township Road 334 from the center line of the intersection of Route T321 and T324; thence northerly 65 degrees 06 minutes East, 400 feet to a point; thence easterly 38 degrees 27 min- utes 42 seconds East, 199.09 feet to a point; thence southerly 65 degrees 06 minutes West, 400 feet to a point; thence westerly 35 degrees north, 30 feet to a point, place of beginning. CONSISTING of 1.793 acres and being improved with a dwelling home. RB5678 225 High Mountain Road, Shippensburg, Pennsylvania 17257. BEING the same premises which WAYNE E. HAWKINS AND MARGA- RET A. HAWKINS, HUSBAND AND WIFE by deed dated June 29, 1977 and recorded June 29, 1977 in the office of the Recorder in and for Cumberland County in Deed Book G Volume 27, Page 496, granted and conveyed to R. Scott Lauffer and Regina Mae Lauffer, his wife in fee. AND the said R. Scott Lauffer de- parted this life on October 12, 2009 vesting title solely in Regina Mae Lauffer by operation of law. TAX MAP PARCEL NUMBER: 41 12 0326 059A. 51 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 21, October 28, and November 4, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 4 day of November, 2011 C Notary F T EAL RAH A COLLINS otary Public UGH, CUMBERLAND COUNTY ion Expires Apr 28, 2014 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 14( Patriot News NOw you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 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 State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ 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 unanirnousiy passed -and adopied severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/21/11 10/28/11 11/04/11 subscribed bef re e t 6Pay of November, 2011 A.D. Notary Public vrEgLTg=TION vaNv? NoSherrie L. Owik . 22015 MEhIBER P... VANIA ASS OF NOTARIES 2(010-5302 Civil Term BAC Home Loans Servicing, LP Vs R. Scott Lauffer Regina Mae Lauffer Atty: Terrance McCabe ALL THAT CERTAIN tract of land located in South Newtown Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T334, which point is 983 feet Southeasterly Tong the center he of Township Road 334 from the center line of the intersection of Route 1321 and T324; thence northerly 65 degrees 06 minutes East, 400 feet to a point; thence easterly 38 degrees 27 minutes 42 seconds East, 199.09 feet to a point; thence southerly 65 degrees 06 minutes West, 400 feet to a point; thence westerly 35 degrees north, 30 feet to a point, place of beginning. CONSISTING of 1.793 acres and being improved with a dwelling home. RB5678 225 High Mountain Road, Shippensburg, Pennsylvania 17257. BEING the same premises which WAYNE E. HAWKINS AND MARGARET A. HAWKINS, HUSBAND AND WIFE by deed dated June 29, 1977 and recorded June 29,1977 in the office of the Recorder in and for Cumberland County in Deed Book G Volume 27, Page 496, granted and conveyed to R. Scott Lauffer and Regina Mae Lauffer, his wife in fee. AND the said R. Scott Lauffer departed this life on October 12, 2009 vesting title solely in Regina Mae Lauffer by operation of law. TAX MAP PARCEL NUMBER: 4112 0326 059A r McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID # 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 = -' HEIDI R. SPIVAK,ESQUIRE-ID#74770 rnM --� MARISA J. COHEN,ESQUIRE-ID#87830 =.,;o -Q . m KEVIN T.MCQUAIL,ESQUIRE-ID#307169 -- �KD CHRISTINE L. GRAHAM,ESQUIRE-ID#309480- `moo BRIAN T.LAMANNA,ESQUIRE-ID#310321 p ED 123 South Broad Street,Suite 1400 D E5 Philadelphia,Pennsylvania 19109 rya _ (215) 790-1010 Bank of America,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number: 10-5302 Civil Regina Mae Lauffer Defendants SUBSTITUTION OF SUCCESSOR PLAINTIFF UNDER RULE 2352(a)PA.R. C.P. TO THE PROTHONOTARY: Kindly substitute Bank of America. National Association, as plaintiff in the above matter, regarding the real property located 225 High Mountain Road, Shippensburg, Pennsylvania 17257, for all purposes in connection with the above captioned matter. The material facts in support of substitution of the Plaintiff are: 1. A Complaint in mortgage foreclosure was filed on 08/20/10 docketed as Number: 10-5302 Civil.The Plaintiff in that action is BAC Home Loans Servicing,LP fka Countrywide Home Loans Servicing LP. 2. Effective July 1,2011,BAC Home Loans Servicing,LP has merged with and into Bank of America,N.A. under the provisions of the National Bank Act. 3. Bank of America,N.A. is successor by merger to BAC Home Loans Servicing,LP and, as C . 1g��Sl a matter of federal law,is deemed to be the same company as BAC Home Loans Servicing, LP and all rights, franchises, and interests of BAC Home Loans Servicing, LP in and to every type of property(real, personal, and mixed)and chooses in action are transferred to and vested in Bank of America,N.A.,without any deed or other transfer. 4. Accordingly,the name of the plaintiff has changed to Bank of America,N.A. as successor by merger to BAC Home Loans Servicing,L.P. Based on the material facts set out above,kindly substitute Bank of America,National Association pursuant to Pennsylvania Rule of Civil Procedure 2352(a). McCabe,Weisberg and Conway,P.C. BY: [ ] Te rence J McCabe, Esq. [ ] Marc S. Weisberg,Esq. [ ] Edward D. Conway,Esq. [,i] Margaret Gairo,Esq. [ ] Andrew L. Markowitz,Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen,Esq. [ ] Kevin T. McQuail,Esq. [ ] Christine L. Graham,Esq. [ j Brian T. LaManna, Esq. [ ] Ann E. Swartz,Esq. [ ] Joseph F. Riga,Esq. [ ] Joseph I. Foley,Esq. [ ] Celine P. DerKrikorian,Esq. Attorneys for Plaintiff MCCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T. MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 BAC Home Loans Servicing, LP fka Countrywide CUMBERLAND COUNTY Home Loans Servicing LP COURT OF COMMON PLEAS Plaintiff Number: 10-5302 Civil V. Regina Mae Lauffer Defendants CERTIFICATION OF SERVICE The undersigned attorney for Plaintiff hereby certifies that a true and correct copy of the SUBSTITUTION OF SUCCESSOR PLAINTIFF UNDER RULE 2352(a)PA. R. C. P.pertaining to the above-captioned matter was served on Twelfth day of September, 2013, by first-class mail, postage prepaid,upon the following: Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 McCabe,Weisberg and Conway,P.C. BY: jkaktl [ ] Te ence J cCabe,Esq. [ ] Marc S. Weisberg,Esq. [ ] Edward D. Conway,Esq. f,,-T largaret Gairo,Esq. [ ] Andrew L. Markowitz,Esq. [ ] Heidi R. Spivak,Esq. [ ] Marisa J. Cohen,Esq. [ ] Kevin T. McQuail,Esq. [ ] Christine L. Graham,Esq. [ ] Brian T. LaManna,Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph F. Riga,Esq. [ ] Joseph I. Foley,Esq. [ ] Celine P. DerKrikorian,Esq. Attorneys for Plaintiff Delaware PAGE 1 2fie First State 1, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT COPY OF THE CERTIFICATE OF MERGER, WHICH MERGES: "CHASE HOME FINANCE LLC", A DELAWARE LIMITED LIABILITY COMPANY, WITH AND INTO "JPMORGAN CHASE BANK, NATIONAL ASSOCIATION" UNDER THE NAME OF "JPMORGAN CHASE BANK, NATIONAL ASSOCIATION", A CORPORATION ORGANIZED AND EXISTING UNDER THE LAWS OF THE COUNTRY OF UNITED STATES, AS RECEIVED AND FILED IN THIS OFFICE THE TWENTY-SEVENTH DAY OF APRIL, A.D. 2011, AT 6:04 O'CLOCK P.M. AND I DO HEREBY FURTHER CERTIFY THAT THE EFFECTIVE DATE OF THE AFORESAID CERTIFICATE OF MERGER IS THE FIRST DAY OF MAY, A.D. 2011, AT 12:02 O'CLOCK A.M. 4974675 8100M ;� qP? AUTHEN C TION Bu��8723r645 of 110463889 d 7AW`, DATE: 04-28-11 You may verify this certificate online at corp.delaware.gov/authver.shtml State of Delaware Secretary of State Division o f Corporations Delivered 06.*03 PM 0412712011 F7= 06:04 PM 0412712011 SRV 110463889 - 3881786 F= STATE OF DELAWARE CERTIFICATE OF MERGER OF CHASE HOME FINANCE LLC (a Delaware Limited Liability Company) WITH AND INTO JPMORGAN CHASE BANK, NATIONAL ASSOCIATION (a national banking association organized under the laws of the United States of America) Pursuant to Title 6, Section 18-209 of the Delaware Limited Liability Act and pursuant to the laws of the United States of America, the undersigned national association executes the following Certificate of Merger: FIRST: The name of the surviving entity is JPMorgan Chase Bank,National Association,a national banking association organized and existing under the laws of the United States of America,and the name of the limited liability company being merged n into the surviving entity is Chase Home Finance LLC, a Delaware limited liability company, SECOND: The Plan and Agreement of Merger has been approved,adopted.certified, executed and acknowledged by each of the constituent entities. THIRD: The name of the surviving entity is JPMorgan Chase Bank, National Association,a national banking association organized and existing under the laws of the United States of America. FOURTH: The Charter of JPMorgan Chase Bank,National Association shall continue to be the Charter of the surviving entity. FIFTH: The merger is to become effective at 12:02 A.M. on May 1,2011. SIXTH: The Plan and Agreement of Merger is on file at 194 Wood Avenue South, Iselin.,New Jersey 088)0,a place of business of the surviving entity. SEVENTH: A copy of the Plan and Agreement of Merger will be furnished by the surviving entity,upon request and without cost., to any member of any domestic limited liability company or any person holding an interest in any other business entity which is to merge or consolidate. EIGHTH: JPMorgan Chase Bank, National Association,the surviving entity,agrees that it may be served with process in the State of Delaware in any action,suit or proceeding for the enforcement of any obligation of any domestic limited liability company which is to merge or consolidate,irrevocably appointing the Delaware Secretary of State as its agent to accept service of process in any such action, suit or proceeding,and specifies that a copy of such process shall be mailed by the Secretary of State to the surviving entity at 194 Wood Avenue South,2'd Floor, Iselin.New Jersey 08830. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.: 10-5302 Civil Civil Term Bank of America,National Association V. AMOUNT DUE: $299,289.26 Regina Mae Lauffer INTEREST: from 04/07/11 C-) $52,348.80 at$49.20 C= C= "I' ATTY'S COMM.: Z= rn UM COSTS: r ;:0 M _< TO THE PROTHONOTARY OF SAID COURT: >C-) C :Z(--> :.= The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,5,=oUE5 based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed AuatZ;o Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. 70 PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s) 225 High Mountain Road, Shil2pensburg,Pennsylvania 17257 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said gamishee(s). (Indicate)Index this writ against the garnishee(s)as a hs pendens against real estate of the defendant(s) described in the attached exhibit. DATE: BY: T Aence . McCabe,Esq. ],�4arc S. Weisberg,Esq. Edward D.Conway,Esq. Margaret Gairo,Esq. Andrew L.Markowitz,Esq. Heidi R. Spivak,Esq. Marisa J.Cohen,Esq. Kevin T. McQuail,Esq. Christine L. Graham,Esq. Brian T.LaManna,Esq. Ann E. Swartz,Esq. Joseph F.Riga,Esq. Joseph I.Foley,Esq. Celine P.DerKrikorian,Esq. Attorneys for Plaintiff CW-1 so oo Finn:MCCABE,WEISBERG AND CONWAY S.d.q q Address:123 S.Broad Street, Suite 1400 77LI. a q I 14 Philadelphia,PA 19109 Attorney for:Plaintiff 00 Telephone:(215)790 1010 co ti t SURZ4UCourt ID No. N.00 LA. 0,C) C4 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land located in South Newtown Township,Cumberland County,Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T334,which point is 983 feet Southeasterly along the center line of Township Road 334 from the center line of the intersection of Route T321 and T324;thence northerly 65 degrees 06 minutes East,400 feet to a point;thence easterly 38 degrees 27 minutes 42 seconds East, 199.09 feet to a point;thence southerly 65 degrees 06 minutes West,400 feet to a point;thence westerly 35 degrees north, 30 feet to a point,place of beginning. CONSISTING of 1.793 acres and being improved with a dwelling home. 225 High Mountain Road,Shippensburg,Pennsylvania 17257. BEING the same premises which WAYNE E.HAWKINS AND MARGARET A.HAWKINS,HUSBAND AND WIFE by deed dated June 29, 1977 and recorded June 29, 1977 in the office of the Recorder in and for Cumberland County in Deed Book G Volume 27,Page 496,granted and conveyed to R. Scott Lauffer and Regina Mae Lauffer,his wife in fee. AND the said R. Scott Lauffer departed this life on October 12,2009 vesting title solely in Regina Mae Lauffer by operation of law. TAX MAP PARCEL NUMBER: 41-12-0326-059A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 10-5302 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due BANK OF AMERICA,NATIONAL ASSOCIATION Plaintiff(s) From REGINA MAE LAUFFER (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: $299,289.26 L.L.: Interest from 4/7/11 -$52,348.80 AT$49.20 Atty's Comm: Due Prothy:$2.25 Atty Paid: $1094.68 Other Costs: Plaintiff Paid: Date: 9/19/13 David D.Buell,Prothonota Deputy REQUESTING PARTY: Name: MARGARET GAIRO,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1.400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone:215-790-1010 Supreme Court ID No.34419 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-11)# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-1D# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 c KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T. LaMANNA,ESQUIRE-ID#310321 =C7j ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 ; JOSEPH 1.FOLEY,ESQUIRE-ID#314675 >C-) = CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 ' o � 123 South Broad Street,Suite 1400 2' Philadelphia,Pennsylvania 19109 215 790-1010 Bank of America,National Association CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 10-5302 Civil Regina Mae Lauffer Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 225 High Mountain Road, Shippensburg,Pennsylvania 17257,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 2. Name and address of Defendant in the judgment: Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 225 High Mountain Road Shippensburg,Pennsylvania 17257 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`"Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Western District of PA Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 and U.S. Post Office and Courthouse 700 Grant Street, Suite 400 Pittsburgh,PA 15219 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None 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. BY: September 12,2013 [ ] Terrence JPM cCabe,Esq. [ ] Marc S.Weisberg,Esq. DATE [ ] Edward D.Conway,Esq. I.1-Margaret Gairo,Esq. [ ] Andrew L.Markowitz,Esq. [ )Heidi R. Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T. McQuail,Esq. I ] Christine L.Graham,Esq. [ ] Brian T. LaManna,Esq. I ] Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN tract of land located in South Newtown Township,Cumberland County,Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T334,which point is 983 feet Southeasterly along the center line of Township Road 334 from the center line of the intersection of Route T321 and T324;thence northerly 65 degrees 06 minutes East,400 feet to a point;thence easterly 38 degrees 27 minutes 42 seconds East, 199.09 feet to a point;thence southerly 65 degrees 06 minutes West,400 feet to a point;thence westerly 35 degrees north,30 feet to a point,place of beginning. CONSISTING of 1.793 acres and being improved with a dwelling home. 225 High Mountain Road, Shippensburg,Pennsylvania 17257. 41- BEING the same premises which WAYNE E.HAWKINS AND MARGARET A.HAWKINS,HUSBAND AND WIFE by deed dated June 29, 1977 and recorded June 29, 1977 in the office of the Recorder in and for Cumberland County in Deed Book G Volume,27,Page 496,granted and conveyed to R. Scott Lauffer and Regina Mae Lauffer,his wife in.fee. AND the said R. Scott Lauffer departed this life on October 12,2009 vesting title solely in Regina Mae Lauffer by operation of law. TAX MAP PARCEL NUMBER: 41-12-0326-059A 4, McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 M KEVIN T.McQUAIL,ESQUIRE-ID ft 307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 7-J� BRIAN T.LaM ANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 CD JOSEPH F.RIGA,ESQUIRE-ID#57716 =- =cD CD rT, JOSEPH 1.FOLEY,ESQUIRE-ID#314675 Cz CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 4 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW Bank of America,National Association COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Regina Mae Lauffer Number 10-5302 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 Your house(real estate)at 225 High Mountain Road,Shippensburg,Pennsylvania 17257 is scheduled to be sold at Sheriffs Sale on March 5,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$299,289.26 obtained by Bank of America,National Association against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Bank of America,National Association the back payments, late charges,costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice 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 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 by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 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 on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C. at(215)790-1010. 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate 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,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 a LEGAL DESCRIPTION ALL THAT CERTAIN tract of land located in South Newtown Township,Cumberland County,Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T334,which point is 983 feet Southeasterly along the center line of Township Road 334 from the center line of the intersection of Route T321 and T324;thence northerly 65 degrees 06 minutes East,400 feet to a point;thence easterly 38 degrees 27 minutes 42 seconds East, 199.09 feet to a point;thence southerly 65 degrees 06 minutes West,400 feet to a point;thence westerly 35 degrees north,30 feet to a point,place of Beginning. ` CONSISTING of 1.793 acres and being improved with a dwelling home. 225 High Mountain Road,Shippensburg,Pennsylvania 17257. BEING the same premises which WAYNE E.HAWKINS AND MARGARET A.HAWKINS,HUSBAND AND WIFE by deed dated June 29, 1977 and recorded June 29, 1977 in the office of the Recorder in and for Cumberland County in Deed Book G Volume.27,Page 496,granted and conveyed to R. Scott Lauffer and Regina Mae Lauffer,his wife in fee. AND the said R. Scott Lauffer departed this life on October 12,2009 vesting title solely in Regina Mae Lauffer by operation of law. TAX MAP PARCEL NUMBER:41-12-0326-059A at, s - McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE, ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ, ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN, ESQUIRE-ID# 87830 -'`') ` " CHRISTINE L. GRAHAM, ESQUIRE-ID#309480 -'_`- BRIAN T. LAMANNA, ESQUIRE-ID#310321 �° s"" ANN E. SWARTZ, ESQUIRE-ID#201926 —0'1c.)11 - JOSEPH F. RIGA, ESQUIRE-ID# 57716 --- JOSEPH I. FOLEY,ESQUIRE-ID#314675 tau ^ =`P-. CELINE P. DERKRIKORIAN,ESQUIRE-ID# 313673 ;; , JENNIFER L. WUNDER,ESQUIRE-ID#315954 %G ''� s'. LENA KRAVETS,ESQUIRE-ID#316421 v `=! co 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bank of America,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 10-5302 Civil Regina Mae Lauffer Defendant AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 4th day of February,2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE,WE RG& CONWAY,P.C. BEFORE ME THIS J DAY By: /14,1 C (/„(2 [ ] Terrence J.McCabe,Esquire [ arc S. berg,Esquire OF reLrVotrj 2014 [ ]Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire / 400110.°9-_, [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ] Christine L.Graham,Esquire — [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire NO ARY PUBLIC [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L. Wunder,Esquire [ ]Lena Kravets,Esquire COMMONWEALTH OF PENNSYLVANIA NOTARIAL.SEAL ANDREW SWITK Y,Notary Public City of Philadelphia,Phila. County My Commission Expires March 15,2017 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID# 34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK, ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA, ESQUIRE-ID# 57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER, ESQUIRE-ID# 315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215) 790-1010 Bank of America,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. NO: 10-5302 Civil Regina Mae Lauffer Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 225 High Mountain Road,Shippensburg,Pennsylvania 17257,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 2. Name and address of Defendant in the judgment: Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein File#49481 Page 1 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein MERS PO Box 2026 Flint MI 48501-2026 Countrywide Bank FSB 1199 North Fairfax St STE 500 Alexandria VA 22314 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 225 High Mountain Road Shippensburg,Pennsylvania 17257 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section File#49481 Page 2 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept. of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None 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. /'' McCABE,WEISBERG& CONWAY,P.C. DATE /� BY: (( `� L UI `" [ ] Terrence J.McCabe,Esquire [, Marc .Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaMarma,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ] Celine P.DerKrikorian,Esquire [ ]Jennifer L.Wunder,Esquire [ ]Lena Kravets,Esquire Re:Bank of America,National Association v.Regina Mae Lauffer.et al. Cumberland County;Number: 10-5302 Civil File#49481 Page 3 McCABE,WEISBERG AND CONWAY, P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Bank of America,National Association COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Regina Mae Lauffer Number 10-5302 Civil Defendant DATE: February 4,2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Regina Mae Lauffer PROPERTY:225 High Mountain Road, Shippensburg,Pennsylvania 17257 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $299,289.26 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on March 12,2014 at 10:00 a.m.in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. OD• �1 01 V, A W N M.+ y m m 9 eD •.'to to .., , AtiyAm m c eo.a ° byy a eeD s p�+ o g o - r '7 ejj .Nan 0 . . 4 " A'T eD 00 < O '3 e.' = •-■ 70 aa O 2. S. 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N N • =: n� C°o, elE.y °°t YAO.`A.p..a i-+Z..so -AM o A'S. ° 0G .-” ON VI xJo W '� '' °gab° w� °.�'-°c =°s a ..1 IV n- o CAG A� OpC �N...�pA Cn • D\ Cori 00 9a� oz3 ° � �o te �' �" �e °' GdneDm C° A CA O =t!.-r M O A oQ O t7 td O " C+ °,,?t- .r C, RD R It' d `� D CS tc,O y ~y A e CI) 0' a va co = �D O ca O o r 7- C 1... tn eD fr SW1ON ' 1.'(5'y:;' a O P. �i�q %cLPN1P • McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY, ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 r7 ' MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 c. ANN E. SWARTZ,ESQUIRE-ID#201926 `.< JOSEPH F. RIGA,ESQUIRE-ID# 57716 rte' c_ -T JOSEPH I. FOLEY, ESQUIRE-ID#314675 �=K CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID# 315954 = LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Penns j'lvania 19109 (215)790-1010 Bank of America,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 10-5302 Civil Regina Mae Lauffer Defendant AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 7th day of February,2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED McCABE, ISBERG& CONWAY,P.C. BEFORE ME THIS id/ DAY By: 7/4dA [ ]Terrence J.McCabe,Esquire [ c S.Weisberg,Esquire OF II1Q V '014 [ ]Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ] Christine L.Graham,Esquire ��, ` [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire NOTA' PUBLI [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire • [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L.Wunder,Esquire Commove,, �=TH or PENNSYLVANIA [ ]Lena Kravets,Esquire NOTARIAL SEAL RHONDCISHA SMITH, aCounty Public City of Philadelphia. ,201 1 Commission hres us5 File#49481 Page 5 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-11)# 57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Bank of America,National Association CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. NO: 10-5302 Civil Regina Mae Lauffer Defendant AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 225 High Mountain Road,Shippensburg,Pennsylvania 17257,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 2. Name and address of Defendant in the judgment: Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg,Pennsylvania 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein File#49481 Page 1 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein MERS PO Box 2026 Flint MI 48501-2026 Countrywide Bank FSB 1199 North Fairfax St STE 500 Alexandria VA 22314 5. Name and address of every other person who has any record lien on the property: Name Address Tax Claim Bureau 1 Courthouse Square, Carlise,PA 17013 Discover Bank 6500 New Albany Road New Albany OH 43054 James C.Warmbrodt 436 Seventh Avenue Suite 1400 Weltman,Weinberg&Reis Co. Pittsburgh PA 15219 L.P.A. 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 225 High Mountain Road Shippensburg,Pennsylvania 17257 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor,Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 File#49481 Page 2 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America do United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America do U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America do U.S.Dept. of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None File#49481 Page 3 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. (>97/0 //'f McCABE,WEISBERG& CONWAY,P.C. DATE 4A/1:6(--BY: C /,!l/�dA. t [ ] Terrence J.McCabe,Esquire [-1"K arc . Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L. Wunder,Esquire [ ]Lena Kravets,Esquire Re:Bank of America,National Association v.Regina Mae Lauffer. et al. Cumberland County;Number: 10-5302 Civil McCABE, WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Bank of America,National Association COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Regina Mae Lauffer Number 10-5302 Civil Defendant DATE:February 7,2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Regina Mae Lauffer PROPERTY:225 High Mountain Road,Shippensburg,Pennsylvania 17257 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT:$299,289.26 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on March 12,2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. o y wW m rW W N ~ uA my• WCr 0.a g 70 eD m.� .-<g a o. c o. CA, d no ■■• .04y 0. Z "' "+ : V C' o y 0n, L' A O7 "9 "V a �'9 Ao et. MC A » . rte...cr ▪A O, y .•ro A O V . A y 0 D �A fD VI aco = °da ° ��• A� .5n 2.& ao co ifD �py10 r YY:°. c: O'er D - f~!1D A cr 2 co 0 0 0„," Wy C . NC •7 ..t v g� 2 AC. C Ro.n• 1r8I:R 4. nR d CD .W E» �. 1..k y g c 1 r 0. I. r G 7 • r ? i v . • r�T�4••i. '?5 i"aS ti '? .L• O O N r C ONE o_ CO O (!) v i A co .OA 0 m T � IO (A m N O V• O � O A O N McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Bank of America, National Association Plaintiff v. Regina Mae Lauffer Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 10 -5302 Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF PHILADELPHIA The undersigned attorney, being duly sworn according to law, deposes and says that the following is true and correct to the best of his/her knowledge and belief: 1. That he /she is counsel for the above -named Plaintiff; 2. That on March 4, 2014, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Regina Mae Lauffer, by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to his/her last -known address of 225 High Mountain Road, Shippensburg, Pennsylvania 17257. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A ". 3. That on January 3, 2014, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Regina Mae Lauffer, by posting the same at the mortgaged premises of 225 I-Iigh Mountain Road, Shippensburg, Pennsylvania 17257. A true and correct copy of the Sheriff's Returns of Service indicating same is attached hereto, made a part hereof, and marked as Exhibit "13". SWORN AND SUBSCRIBED BEFORE ME THIS `MPAY OF McCABE, WEISBERG AND GONWAY, P.C. BY: [ ] Terrence J. Mc abe, Esq. [ arc S. Weisb rg, Esq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff NOTARY PUBLIC COMMONWEALTH OF PEf SYLVAN!A NOTARIAL SEAL VICTORIA V. SHEGAI, Notary Public City of Philadelphia, Phila. County My Commission Expires October 15, 2016 .' BAC HOME LOAN SERVICING, LP, f /k /a COUNTRYWIDE HOME LOANS SERVICING, LP, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA R. SCOTT LAUFFER, AND REGINA MAE LAUFFER, DEFENDANTS : NO. 10 -5302 CIVIL ORDER OF COURT AND NOW, this 27th day of December, 2010, upon consideration of the Plaintiff's Motion for Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, Plaintiff's Motion is GRANTED. IT IS HEREBY ORDERED AND DIRECTED: 1. That the Plaintiff is directed to serve the Complaint upon Defendant by posting a copy of the Complaint upon the premises at 225 High Mountain Road, Shippensburg, PA 17257; 2. That the Plaintiff serve the Complaint by certified and regular mail to the Defendant's last known addresses at 225 High Mountain Road, Shippensburg, PA 17257; 3. All future service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known addresses. By the Court, David J. Apothaker, Esquire Attorney for Plaintiff Regina Mae Lauffer Defendant bas EXHIBIT A 2250 0001 9489 4065 m rR C:1 N U.S. Postal .Service TM CERTIFIED MAILTM RECEIPT (Domestic Ma Only; No insurance Coverage: Provided) For delivery information visit our website at wwwiusps:com� Postage Certified Fee Return Receipt Fee (Endorsement Required Restricted Delivery Fee (Endorsement Required Total Postage & Fe '1/011 tl � R$ Fdrm 3000,.1 {ugusf 2006 See Reverse for feel: Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 1400 Philadelphia, PA 19109 Attn: Richard Daugherty Check type of mail or service: ❑ Certified COD 0 Delivery Confirmation 0 Express Mail ❑ Insured ❑ Recorded Delivery (International) 0 Registered ❑ Return Receipt for Merchandise Signature Confirmation U.S. POSTAGE » » PITNEY BOWES ti ! .=sdr ; 02 ZIP iV $ 001020° `"! 0001377494 MAR 04 9n i n Line Article Number Addressee Name, Street and PO Address Postas.. _ xa.as.. — ee ee SC Fee SH Fee RD Fee RR Fee 1 Bank of America, National Association v. Regina Mae Lauffer 49481 Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 2 3 4 5 6 7 8 9 10 Total Number of Pieces Listed by Sender Total Number of Pieces Rrceiued "at Post Office = , �'— �' Postmaster, Per (Name of employee) The full declaration of sa!ue is required on all domestic and international registered mail The maximum indemnity payabl nonnegotiable documents under Express Mail document reconstruction =trance is 5500 per piece subject to add'tioral limitations lost or damages in a single catastrophic occurrence. The maximum indemnity payable on E. Mail merchandise insurance Express Mail Service merchandise is available for up to S3.000 to some but not all countries. The maximum indemnity payable mail. See Domestic Mail Alan., R900. S9tS. and 592! for lim m itatio s of on insured and CCD mail. Sec Anernntin, a limitations of color:Tr or t tcrnatfoaat mai:. Sp acit :I handling charges apply only to Standard Matt (At e..d Stand:re Mail (B) of for for the raonstruaion for multiple pi<ar is $500. but optional is 5?5.000 for registered !.trail Iranaal patrols. i=orr. 3877. Augu;t 26 -Do Ccmpictc ;i� "I peWritcr. Ink, or Bali Point Pen EXHIBIT B Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY - -tell.fltriTOtry *Frif".,E r TPE it,F,R1PF Bank of America NA vs. R. Scott Lauffer (Deceased) (et al. Case Number 2010-5302 SHERIFF'S RETURN OF SERVICE 01/03/2014 02:40 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Regina Mae Lauffer, pursuant to Order of Court by "Posting" the premises located at 225 High Mountain Road, South Newton Township, Shippensburg, PA 17257, Cumberland County with a true and correct copy according to law. 01/03/2014 02:41 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 225 High Mountain Road, South Newton - Township, Shippensburg, PA 17257, Cumberland County. SHERIFF COST: $953.71 SO ANSWERS, Y.Y January 29, 2014 RONW R ANDERSON, SHERIFF (c) CountySuite Shenfl, Teleosoft, Inc McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Bank of America, National Association, Plaintiff v. Regina Mae Lauffer Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10 -5302 Civil AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 4th day of March, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THI DAY 2014 NOTARY PU t'0;A`Fi .SEA,L B RE ARA.J. MOYER, Nobr ° Public Qty of Philadelphia, Phila. County It Commission Expires,ta;waiy I2, 2(118 McCABE, WEISBE : & C t WAY, BY [ ] Terrence J. McCabe, squire [ ] Edward D. Conway, Esquire drew L. Markowitz, Esquire ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Marc S. Weisberg, Esquire Margaret Gairo, Esquire Heidi R. Spivak, Esquire Christine L. Graham, Esquire Ann E. Swartz, Esquire Joseph I. Foley, Esquire Jennifer L. Wunder, Esquire File #49481 Page 5 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Bank of America, National Association Plaintiff v. Regina Mae Lauffer Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 10 -5302 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 12 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 225 High Mountain Road, Shippensburg, Pennsylvania 17257, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 2. Name and address of Defendant in the judgment: Name Address Regina Mae Lauffer 225 High Mountain Road Shippensburg, Pennsylvania 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein File #49481 Page 1 West Asset Management, Inc. 7171 Mercy Road PO Box 6183 Omaha, Nebraska 68106 -0183 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein MERS PO Box 2026 Flint MI 48501 -2026 Countrywide Bank FSB 1199 North Fairfax St STE 500 Alexandria VA 22314 5. Name and address of every other person who has any record lien on the property: Name Address Tax Claim Bureau 1 Courthouse Square, Carlise, PA 17013 Discover Bank 6500 New Albany Road New Albany OH 43054 James C. Warmbrodt 436 Seventh Avenue Suite 1400 Weltman, Weinberg & Reis Co. Pittsburgh PA 15219 L.P.A. 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants /Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office- Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 225 High Mountain Road Shippensburg, Pennsylvania 17257 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 File #49481 Page 2 Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name None Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105 -8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 PO BOX 280948 Harrisburg PA 17128 -0948 Clearance Support Department 281230 Harrisburg, PA 17128 -1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 U.S. Dept. of Justice, Rm 4400 950 Pennsylvania Avenue, NW Washington, DC 20530 U.S. Dept. of Justice, Rm 5111 950 Pennsylvania Avenue, NW Washington, DC 20530 Address File #49481 Page 3 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 of18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE MCCABE, WEISBERG & C BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire drew L. Markowitz, Esquire Marisa J. Cohen, Esquire [ Brian T. LaManna, Esquire [ J Joseph F. Riga, Esquire [ 1 Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Y, P.C. Re: Bank of America, National Association v. Regina Mae Lauffer. et al. Cumberland County; Number: 10-5302 Civil c S. Weisberg, Esquire garet Gairo, Esquire Heidi R. Spivak, Esquire ] Christine L. Graham, Esquire 1 Ann E. Swartz, Esquire ] Joseph I. Foley, Esquire ] Jennifer L. Wunder, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE -"ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bank of America, National Association Plaintiff v. Regina Mae Lauffer Defendant DATE: March 4, 2014 Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10 -5302 Civil TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Regina Mae Lauffer PROPERTY: 225 High Mountain Road, Shippensburg, Pennsylvania 17257 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $299,289.26 The above - captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on April 9, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthbuse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriff's Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY'as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 2080 Philadelphia, PA 19109 ATTN: S. W iltban ks -49481 Check type of mail o Certified o COD o Delivery Confirmation 0 Express Mail o Insured or service: Recorded Delivery (International) Registered O Return Receipt for Merchandise o Signature Confirmation Line Article Number Postage ank of America, National Association Plaintiff v. Regina Mae Lauffer Defendant West Asset Management, Inc. 7171 Mercy Road PO Box 6183 Omaha, Nebraska 68106 -0183 U.S. POSTAGE» PITNEY BOWES •L 1' -r ZIP 19109 $ 00120° 02 1V 0001377494 MAR. 04. 2014. Total Number of Pieces Listed by Sender 1 Total Number of /Pieces Received at Posto vie 9'' A -v -p 9110 -99 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith '�' " v Chief Deputy _ i t C fi ND Richard W Stewart Solicitor s <�, P S V,f r Bank of America NA Case Number vs. R. Scott Lauffer(Deceased) (et al.) 2010-5302 SHERIFF'S RETURN OF SERVICE 01/03/2014 02:40 PM-Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Regina Mae Lauffer, pursuant to Order of Court by"Posting"the premises located at 225 High Mountain Road, South Newton Township, Shippensburg, PA 17257, Cumberland County with a true and correct copy according to law. 01/03/2014 02:41 PM -Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 225 High Mountain Road, South Newton -Township, Shippensburg, PA 17257, Cumberland County. 03/11/2014 As directed by Terrance McCabe,Attorney for the Plaintiff, Sheriffs Sale Continued to 4/9/2014 04/09/2014 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, 1 Courthouse Square, Carlisle, PA 17013, on April 9, 2014 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Terrance McCabe, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,005.24 SO ANSWERS, May 13, 2014 RbNW R ANDERSON, SHERIFF / � x.77 y/ i + On November 19, 2013 the Sheriff levied upon the defendant's interest in the real property situated in South Newton Township, Cumberland County, PA, Known and numbered as, 225 High Mountain Road, Shippensburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: November 19, 2013 Ln ,__ t-- e La..!c..._. Li,.,tiff„ By. W ti l C': Ci3 C.?Lc R CC L� C-4 \ 1 Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2010-5302 Civil Term Bank of America NA vs. R. Scott Lauffer(Deceased) Regina Mae Lauffer Atty.:Terrance McCabe ALL THAT CERTAIN tract of land located in South Newtown Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T334, which point is 983 feet Southeasterly along the center line of Township Road 334 from the center line of the intersection of Route T321 and T324; thence northerly 65 degrees 06 minutes East,400 feet to a point; thence easterly 38 degrees 27 min- utes 42 seconds East, 199.09 feet to a point;thence southerly 65 degrees 06 minutes West,400 feet to a point; thence westerly 35 degrees north,30 feet to a point,place of beginning. CONSISTING of 1.793 acres and being improved with a dwelling home. 225 High Mountain Road, Ship- pensburg,Pennsylvania 17257 . BEING the same premises which WAYNE E. HAWKINS AND MARGA- RET A. HAWKINS, HUSBAND AND WIFE by deed dated June 29, 1977 and recorded June 29, 1977 in the office of the Recorder in and for Cumberland County in Deed Book G VolumeZ7,Page 496,granted and conveyed to R. Scott Laufer and Regina Mae Lauffer,his wife in fee. AND the said R. Scott Lauffer de- parted this life on October 12, 2009 vesting title solely in Regina Mae Lauffer by operation of law. TAX MAP PARCEL NUMBER:41- 12-0326-059A. 49 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 24, January 31, and February 7, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this -7 day of February, 2014 Notary IniAL d A`0)� -u - "'-ISLE y tq Ap _,Zl 7,i 1. - " The Patriot-News Co. 2020 Technology Pkwy e a rio � ews Suite 300 Mechanicsburg, PA 17050 NOW you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 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 State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/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: 01/19/14 01/26/14 02/02/14 Swor to nd subscribed befo me this 18 day of February, 2014 A.D. otary Pub t MEM inF dN ti wA!4a 4,A a , 204043M CtATOW sank of V NA (Dweased Reona Mae LAu"Or Atty:.Terrance McCabe ALL_THAT CERTAIN tract of land located ro South Newtown Tbwnship, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road 7334,which point is 983 feet Southeasterly 334 Road the:center line of Tbwnshig from the center lim.of the intersection of Route 7321 .and 7324; thence northerly 65 degrees 06 minutes East, 400 feet toa point; thence easterly 38 degrees,27,minutes 42 seconds East, 199.09-feet to a point;thence southerly 65 degrees 06mioutes.West, 400 feet to a point;thence westerly 35 degrees north,30 feet to a pout,place of beginning. being'fINGe owf 4din Rand home. Mr I twa ShippensbbUrg,Pennsylvania 11251 BEING the same pce*!es•=which WAyNE E. HAWMS AND MARGARET A. HAWKINS, HUSBAND AND WIFE by deed r dated June 29, 1977 and recorded June 29, 1977 in the office of the Recorder in and for Cumberland county in Deed I B� 7, Page 496, granted R, Scott Lauffer and Regina Mae, Lauffer,his wife in fee. AND the said It.Sett Laft departed this life on October 12, jesfing IRegi Mae im ffer.by TAR Mt#P MRRCEL NUMBER:41- 12.032W9A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 9th day of April A.D., 2014, under and by virtue of a writ Execution issued on the 19th day of September, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Tenn, 2010 Number 5302, at the suit of Bank of America National Association against Regina Mae Lauffer is duly recorded as Instrument Number 201413642. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of Recorder of Deeds eft OIL,Cumberland County,Car",PA My Commission Expires the First Monday of Jan.2818