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Home My WebLink About10-5317UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 -ADAM L. KAYES, ESQUIRE - ID #86408 , c= C-? , MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 a- _- ` 856-669-5400 . pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS 475 Cross Point Parkway :CIVIL DIVISION Getzville, NY 14068 Plaintiff :Cumberland County V. Keith A. Hench Magdalene M. Hench NO. 10- -S317 234 North 32nd Street Camp Hill, PA 17011 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL ?? SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. ?.b' J 7?1q- '?/ IV 2.66 v tsM4 LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DENANDA A UN ABOGADO INMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page, who is the legal holder of the Mortgage and is in the process of formalizing the Assignment of Mortgage to be sent for recording. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 234 North 32nd Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Camp Hill COUNTY: Cumberland DATE EXECUTED: 10/07/99 DATE RECORDED: 10/11/99 BOOK: 1575 PAGE: 1054 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 08/01/10: Principal of debt due $126,820.01 Unpaid Interest at 8.625% from 04/01/10 to 08/01/10 (the per diem interest accruing on this debt is $30.38 and that sum should be added each day after 08/01/10) 1,120.02 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $258.31 and that sum should be added on the first of each month after 08/01/10) 0.00 Late Charges (monthly late charge of $0.00 should be added in accordance with the terms of the note each month after 08/01/10) 0.00 Uncollected Late Charge 966.18 Attorneys Fees (anticipated and actual to 5% of principal) 6.341.00 TOTAL $135,852.21 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $135,852.21 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFI ES, P.C. BY. Attorneys for iklaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE DANIEL SIEDMAN, ESQUIRE Aus-10-2010 12,13pm From- X.R.E.1.11, LOMAS 328: PAGE 25/25 wets RUXIIIT A ALL TOM CERTA21? SAT OR PIECE OF CROWD. TOO== VM TM TWO AND ORE-BALE BTQR7 MUCK DMELLUC EtOm BRBGTE() T li, B a=G IMOM AS no, 234 NORTH T=ST!-MCM BTR=r, SXTOATB IN =9 NOROUM OF CRMOT IE=, ODLV= OF QUNMZMV AM COMM11=79 OF P>t>mU=VMZ&, JUW B=M ALL OF wr NO. 26 ON TEE PLAN Off' LOTS Moffi A6 "BBLYOIR" , . R8t'ORDEO IN TR8 1>iL"'030MIS OFFSCZ = AND FOR COMM CUM=M IN MW ROOK 1 PADS 1C, HOPE MTICE ARLY SOUNDED A= M= BED AS FOLLOWS, TO iOIT: 2=== M AT A P671iT ON TM NEST IN= OF =MX MM-==M BTRSRT, AT THE S MMU L=E OF UM NO. 27 ON PLAN OF LOTS SPORE P B ==ND, SAID FOS12T ALGO g=po a4m S FORTY--On AND TNZRTS-FIVE QDiH-wilmANDM (141.35) SO= OF TJM SCUTUNUT CCMKMR OF NORM ' R%M-B8C7M '"I IMT AIM A. FXrM= (15) ROOT AGLSYr TAE ASAlt4 SAID LUM T=TY-SV=V STS, g0UM 11 DMES4 51 Di771UM SW, 8YM (501 Tmst TO A 6TA= AT IDM D1ONnM N =M OF LOT ND. 2S, ON TEM MRMUREFORS nma &ZCN + PLAKI Tom= Az4m Rhm IAT Advm 40 DROP= Ob lamme wow, OWE HMMM BIiT1C (160) BEET TO SMM. TIiCS NORTH 11 DEORM 52 HIMMS MOT, gIPTY (SO) PS£T TO A ,877 = AT MM SOUTMIX LIM OF SAT i10. 37 ON SaD PLAN; TFMCE 1iO0LTF3 74 AEMIM 09 MINMSB BUT, Oft RUMORED Sn=Y (160) PIMI: TO A 9== ON TAS WISTM 3nM OF 27M APOR8Ji1R1iTIONSD NO= TS=7ZT1'-6EY= 6TAM AND THE PLACE OF RZODBUNG. ADDPXSSz 232 N 32ND ST_; CANE SILL, PA 17021 TAX MAP OR PARCH ID nm: 01-20-1850-013 Aug 10 2010 12:04vm P009/009 T-600 P.009/009 F-745 9LL10 01 f wmwlw** $$ Aprord?4 nd Ooh °iDwk 3n Ulr.- CmdBR 0011575wdaso ri m=15i nkm rm mrrv Inat.0199937398 - P30C 7 of 7 BankefAmedes -411111'. Nt Loans PO Box 9048 Temecula, CA 92589-9048 Send Payments to: P.O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 7113 82571474 3724 1867 PRESORT First-Class Mall U.S. Postage and Fees Paid WSO 20100701-7 1-11-111 Pd Magdalene Hench 234 N 32ND ST CAMP HILL, PA 17011-2810 EXHIBIT A BLQPAI 11722 03!0812010 BmlkofAmerica .001. Home Loans P.O. Box 660694 Deflas, 7X 75266-0694 Send Payments to. P.O. Box 95222 Wilmington, DE 198W-5222 July 1, 2010 Magdalene Hench 234 N 32ND ST CAMP HILL, PA 17011-2810 Certified Mail: 7113 6257 1474 3724 1867 Return Receipt Requested Regular Mail Account No.: 873404171 Property Address: 234 N 32nd St Camp Hill, PA 17011-2810 Current Servicer: BAC Home Loans Servicing, LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an afficial notice that the mortgage on your home In In defaul t, and the lender In tends foreclose, S pecific information about the nature of the default is provided in the attached Davi es The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be ab le to help to save you r home This Notice explains how the program works To see M HEMAP can help, you must MEET WITH A CONSUMER CREDIT DATE OF THIS NOTICE. Take this Notice with you when you meet with the COUNSELING AGEN (- unfifierina wc___y CY WITHIN 30 DAYS OF THE This Notice contains important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRItSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Payment Instructions: • Make your check payable to BAC Home Loans Servicing, LP • Don't send cash • Please include coupon with your payment For all full month payment periods, interest is colculotedon a monthlybesis. Accordingly, interest for all full months, including February, is calculated as 301380 of annual Imerast, irrespective of the actual nunbar of days in the month. For panel months. interest is calculated rfE?mi??Sr C defy m thebosis beefs of a 385 day year. year. Magdalene Hench 234 N 32nd St Camp Hill. PA 17011-2810 873404171 BAC Home Loans Servicing LP a subsidiary of Bank of America N .A. BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. Passe write your account number on all checks and correspondence. We may change you a fee for any payment returned or rejected by your financial institution, subject to applicable law. SLOPAI 11722 0310812010 Account !Number. 873404171-1 Magdalene Hench Balance Due for charges fisted above: $5,111.17 as of July 1, 2010. 234 N 32nd St Please update email information on the reverse sidsofthis coupon. Camp Hill, PA 17011-2810 AdoR= SLOPAI ?I?Illirrlrl?lll'III1? "'1'I?kl?ll?l'II'1i1'ill'I?„1i11??1'ill? A o a! Escrow BAC Home Loans Servicing, LP PO BOX 15222 check Wilmington, DE 198885222 TOW 873404171100000511117000511117 1: 58 6 9 900 581:8 7 3404 L 7 Lila HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS, IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITI4IN T14F NFXT rurarV CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers of designated consumer credit counseling aaencies for the county in which the mooarty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your Intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the and of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within Thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELYAND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of Its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. NATURE OF TtIE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 234 N 32nd St Camp Hill, PA 17011-2810 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Charaes: 05/01/2010 $4,134.99 Late Charaes: Other Charges. Uncollected Late Charges: $966.18 Uncollected Costs: $10.00 Partial Payment Balance: 1,$0.001 TOTAL DUE: $5,111.17 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not aoolicable) BAC Home Loans Servicing, LP is a subsidiary of Bank of America, NA. E-mail use: Providing your a-mail address below will allow us to send you information on your account. Account Number: 873404171 Magdalene Hanch E-mail address: Now we post your payments: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (1) to outstanding monthly payments of principal and Interest, (II) escrow defldendee, (11) late charges and other amounts you owe in connection with your loan and (iv) to reduce the outstanding principal balance of your loan. Please specify If you want an additional amount applied to future payments, rather than principal reduction. PCOWNed checks: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the date written on the check as a condition of a repayment plan. HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5,111.17 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: BAC Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222. f rr Tvu uo nor cuRE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise Its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly Installments. If full payment of the total amount past due Is not made within THIRTY (30) DAYS, the lender also intends to Instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FOREC )SEE UPON _ The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually Incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth In this notice will restore your mortgage to the same position as If you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: SAC Home Loans Servicing, LP Address: P. O. Box 660694 Dallas, TX 75266-0694 Phone Number; 1-800-669-6654 Fax Number: 1-817-230-6811 Contact Person: MS TX2-977-01-13 Attention: Loan Counselor Email Address: To ensure secure email communications please log on to the BAC Home Loans Servicing, LP Website at www.bankofamerica.com and email us by navigating through the Customer Service link provided EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at anytime. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, BAC Home Loans Servicing, LP may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to(!) observe the physical condition of your property, (ii) verify that the property is occupied and/or (III) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and w1 BAC Home Loans Servicing, LP Is a subsidiary of Bank of America, NA. 7113 8257 1474 3724 1a67 valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before July 31, 2010, BAC Home Loans Servicing, LP wants you to be aware of various options that may be available to you through BAC Home Loans Servicing, LP to prevent a foreclosure sale of your property. For example: • Repayment Plan: It is possible that you may be eligible for some form of payment assistance through BAC Home Loans Servicing, LP. Our basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least 1/2 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, If you are willing to sell your home In order to avoid foreclosure, it Is possible that the sale of your home can be approved through BAC Home Loans Servicing, LP even If your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are Interested in discussing any of these foreclosure alternatives with BAC Home Loans Servicing, LP, you must contact us immediately. If you request assistance, BAC Home Loans Servicing, LP will need to evaluate whetherthat assistancewill be extended to you. In the meantime, BAC Home Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by July 31, 2010 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-600-669-6654. BAC Home Loans Servicing, LP is a subsidiary of Bank of America, NA. 7113 8257 1474 3724 1867 Attachment: Itemization of Charges and Fees Monthly Charges: 05/01/2010 Late Charges: Other Charaes: Its `. 07/31/2010 a $1,378.33 Uncollected Late Charges: MORTPAY BY PHONE EPS Partial Payment Balance: TOTAL DUE: $4,134.99 $966.18 $10.00 ($0.00) $5,111.17 BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY PHFA Adams County Interfaith Housing Authority Loveship, Inc. 211 North Front Street 40 E High Street 2320 North 5th Street Harrisburg, PA 17110 Gettysburg, PA 17325 Harrisburg, PA 17110 717.780.3940 717.334.1518 717.232.2207 800.342.2397 CCCS of Western PA Community Action Commission of Captial Maranatha 2000 Unglestown Road Region 43 Philadelphia Avenue Harrisburg, PA 17102 1514 Deny Street Waynesboro, PA 17268 888.511.2227 Harrisburg, PA 17104 717.762.3285 888.511.2227 717.232.9757 19alnkefArnerk:a PRESORT Iloinwleons First-Class Mail PO Box 9048 U.S. Postage and Temecula, CA 92589-9048 Fees Paid WSO 7113 8257 1474 2123 4684 Send Payments to: P.O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 N 20100504-7 II.I111I.ii.i.illllllillli-1Id111111lllliIN-1111'1"Ill.111-1II Keith Hench 234 N 32ND ST CAMP HILL, PA 17011-2810 BLOPAI 11722 031082010 BmkofAmerica AW ..Bale lases P.O. Box 660694 Dallas, 7X 75266-0694 Send Payments to., P.O. Box 15222 Wilmington, DE 19886-5222 May 3, 2010 Keith Hench 234 N 32ND ST CAMP HILL, PA 17011-2810 Certified Mail: 7113 8257 1474 2123 4684 Return Recejot Rectuested Regular Mail Account No.: 873404171 Property Address: 234 N 32nd St Camp Hill, PA 17011-2810 Current Servicer: BAC Home Loans Servicing, LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaae on your home is in defaul t and the lende r intends t o forecl ose Specifflic Information about the nature of the default is provided in the attached pea es The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROG sM (HEM AP) maybe able to he lp to sav e you r home This Notice explains how the proaram works To see N HEMAP can help you must MEET WITH A CONSUMER CREDIT DATE OF THIS NOTICE, Take this Notice with you when you meet ` fth the COUN r..un SELING AG sellina w__ ENCY WIT ____ HIN 30 D AYS OF THE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAC16N EN ADJUNTO ES DE SOMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRItSTAMO POR EL PROGRAMA LLAMADO HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S) PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERISERVICER: Payment Instructions: - Make your duck payable to BAC Home Loans Servicing, LP - Don't send cash - Please include coupon with your payment For all full month payment periods, interest is caloulatedon a mmthlybesis. Accordingly, interest for all full months, including February, is calculated as 301360 of annual Interest, irrespective of the actual number of days in the month. For partial Vi months, interest is calculated rj= daily on m Via basis of e 385 day year. Keth Hench 234 N 32nd St Camp Hill. PA 17011-2810 873404171 SAC Home Loans Servicina. LP. a subsidiary Bank of America N .A. BAC Home Loans Servicing, LP is a subsidary of Bank of America, N.A. Please write your account number on all checks and correspondence. We may charge you a fee for any payment returned or rejected by your financial institution, subject to applicable law. BLOPA1 11722 03108=10 Account Number. 873404171-1 Keith Hench Balance Due for charges listed above: $5,111.17 as of May 3, 2010. 234 N 32nd St Please update e-mail ift mhalion on the reverse side of this coupon. Camp Hill, PA 17011-2810 AdMcnd BLQPAI IIhI??hlhll?lhl?l,r?I111.Illllr??ll?hllklll?'?II1??1"I'll" I11?1 ?onnl BAC Home Loans Servicing, LP PO BOX 15222 a eck Wilmington, DE 19886-5222 rile! 873404171100000511117000511117 1: 5869900 581:8 7 3 404 i 7 ills HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MIKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 19a3 {THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30) days from the date of this Notice. During that time you must arrange and attend a `Face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN TIME NFYT IrUIRTV CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling aaencles for the county in whim the property is located are set forth at the end of this Notice. It Is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your Intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific Information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within Thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELYAND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sbcty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of Its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 234 N 32nd St Camp Hill, PA 17011-2810 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Charaes: 03/01/2010 $4,134,99 Late Charges: Other Charaes: Uncollected Late Charges: $966.18 Uncollected Costs: $10.00 Partial Payment Balance: ($0.00) TOTAL DUE: $5,111.17 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) BAC Home Loans Servicing, LP is a subsidiary of Bank of America, NA. E-mail use: Providing your e-mail address below will slow us to send you information on your account. Account Number: 673404171 Keith Hench E-mail address: How we post your psymente: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (1) to outstanding monthly payments of principal and Intmeat, (ti) escrow deficiencies, (W) late charges and other amounts you owe in connection with your loan and (Iv) to reduce the outstanding principal balance of your loan. Please specify if you want an additional amount applied to future payments, rather than principal reduction. Postdated checks: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the data written on the check as a condition of a repayment plan. HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH 13 $5,111.17 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: BAC Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 18886-5222. You can cure any other default by takina the followina action within THIRTY (30) DAYS of the to of this letter. (Do not use if not aoolrcable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise Its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also Intends to instruct its attomeys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE 13 FORECL O§ZQ Ue - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt If the lender refers your case to Its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually Incurred, up to $50.00. However, If legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as If you had never defaulted EARLIEST POSSIBLE SHERIFF'S SAL DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender. BAC Home Loans Servicing, LP Address: P. O. Box 660694 Dallas, TX 75266-0694 Phone Numbers, 1-800-669-6654 Fax Number: 1-817-230-6811 Contact Person: MS TX2-977-01-13 Attention: Loan Counselor Email Address: To ensure secure email communications please log on to the BAC Home Loans Servicing, LP Website at www.bankofamerica.com and small us by navigating through the Customer Service link provided EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy It. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, BAC Home Loans Servicing, LP may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property Is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and BAC Home Loans Servicing, LP is a subsidiary of Bank of America, NA. 7113 8257 1474 2123 4684 valuation services) may be taken. The costs of the above-described Inspections and property preservation efforts will be charged to your account as provided in your security Instrument. If you are unable to cure the default on or before June 2, 2010, BAC Home Loans Servicing, LP wants you to be aware of various options that may be available to you through BAC Home Loans Servicing, LP to prevent a foreclosure sale of your property. For example: e Repayment Plan: It is possible that you may be eligible for some form of payment assistance through BAC Home Loans Servicing, LP. Our basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least'/.. of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. e Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, It is possible that the sale of your home can be approved through BAC Home Loans Servicing, LP even if your home is worth less than what is owed on it. e Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which Is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with BAC Home Loans Servicing, LP, you must contact us immediately. If you request assistance, BAC Home Loans Servicing, LP will need to evaluate whether that assistanoewill be extended to you. In the meantime, BAC Home Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by June 2, 2010 as outlined above will result in the acceleration of your debt. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-668-6654. BAC Home Loans Servicing, LP is a subsidiary of Bank of America, NA. 7113 8257 1474 2123 4684 Attachment: Itemization of Charges and Fees Monthly Charaes: 03/01/2010 Late Charaes: Other Charaes: wrl- 05/31/2010 0 $1,378.33 Uncollected Late Charges: MORTPAY BY PHONE EPS Partial Payment Balance: TOTAL DUE: $4,134.99 $966.18 $10.00 ($0.00) $5,111.17 BAC Home Loans Servicing, LP is a subsidiary of Bank of America, N.A. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY PHFA Adams County Interfaith Housing Authority Loveship Inc. 211 North Front Street 40 E High Street , 2320 North 5th Street Harrisburg, PA 17110 Gettysburg, PA 17325 Harrisburg PA 17110 717.780.3940 717.334.1518 , 717 232 2207 800.342.2397 . . CCCS of Western PA Community Action Commission or Captial Maranatha 2000 Linglestown Road Region 43 Philadelphia Avenue Harrisburg, PA 17102 1514 Deny Street Waynesboro PA 17268 888.511.2227 Harrisburg, PA 17104 , 717 762 3285 888.511.2227 717.232.9757 . . FROM Sma s"aw payodin V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY: i Attorne s for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE DANIEL S. SIEDMAN, ESQUIRE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~,tr cf ~umbr~,f~~~ ~u;, QFi iGE C ~ THE SwERIFF ~ ~Hl' T/~ Jody S Smith Chief Deputy Richard W Stewart Solicitor ~10 At,IG 3 { AM 8~ 35 ~M$is~rv Bank of America, NA vs. Keith A Hench (et al.) Case Number 2010-5317 SHERIFF'S RETURN OF SERVICE 08/20/2010 07:20 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 20, 2010 at 1920 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Magdalene M. Hench, by making known unto Keith A. Hench, Husband of defendant at 234 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. GE LD WORTHINGT DEPUTY 08/20/2010 07:20 PM -Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 20, 2010 at 1920 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Keith A. Hench, by making known unto himself personally, at 234 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $57.50 August 26, 2010 GE LD WORTHINGT ,DEPUTY SO ANSWERS, .~ RON R ANDERSON, SHERIFF (c} CountySuite Sheriff. TeleosoR, Inc. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. 475 Cross Point Parkway Getzville, NY 14068 Plaintiff V. Keith A. Hench Magdalene M. Hench 234 North 32nd Street Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Keith A. Hench and Magdalene M. Hench for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $135,852.21 Interest Per Complaint 1,640.52 From 08/02/2010 to 09/24/2010 Escrow payment per Complaint 258.31 From 08/02/2010 to 09/24/2010 TOTAL $137,751.04 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LA C. BY: orney or Plaints MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE DAMAGES ARE HEREBY ASSESSED AS INDICA D Ilq.LU ))G_J7 DATE:,G,,-,-i, -2y -,o Cti(? 11oI4.92- PR O c2yg 73A,, 1&.•v%& 1L- ik - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE .:'i { ?- ? r zJ - J ' E C NO. 10-5317 acv -?. i C D -1 UDREN LAW OFFICES, P".C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL S. SIEDMAN, ESQUIRE - ID #306534 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pl.eadings@udren.com ATTORNEY FOR PLAINTIFF WOF Bank of America, N.A. :COURT OF COMMON PLEAS 475 Cross Point Parkway :CIVIL DIVISION Getzville, NY 14068 Plaintiff :Cumberland County V. Keith A. Hench Magdalene M. Hench 234 North 32nd Street Camp Hill, PA 17011 Defendant(s) NO. td - S,317 C' COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO 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. ?J SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff?sxtr of GrFracrptt Jody S Smith Chief Deputy - Richard W Stewart Solicitor 43Ap'tC:OP TK fiF.ERIFF Bank of America, NA Case Number vs. 2010-5317 Keith A Hench {et al.} SHERIFF'S RETURN OF SERVICE 08/20/2010 07:20 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 20, 2010 at 1920 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Magdalene M. Hench, by making known unto Keith A. Hench, Husband of defendant at 234 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. -GELD WORTHIN GT DEPUTY 08/20/2010 07:20 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on - August 20, 2010 at 1920 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Keith A. Hench, by making known unto himself personally, at 239 N. 32nd Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. GRTHINGT , DEPUTY SHERIFF COST: $57.50 August 26, 2010 SO ANSWERS, J RON R ANDERSON, SHERIFF Coun7,S st, Sriei t. Teieosn';. Inc, n ++ PS. n 0 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #? 6DS?95?'1 Bank of America, N.A. Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Keith A. Hench Magdalene M. Hench ENO. 10-5317 Defendant(s) TO: Keith A. Hench 234 North 32nd Street Camp Hill, PA 17011 Date of Notice: September 10, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER. IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, STN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SEN'TENCIA EN SU CONTRA, LISTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association: 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL B E. STUART WINNEG "E?9Z LORRAINE DOYLEr, EQL3I' ALAN M. MINATO ESQUIRE CHANDRA M. ARKEMk, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center 111 Woodcrest Load, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID ##204460 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 *i04801a?_? Bank of America, N.A. Plaintiff V. Keith A. Hench Magdalene M. Hench Defendant (s ) TO: Ma dalene M. Hench 23 North 32nd Street Camp Hill, PA 17011 Date of Notice: September 10, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-5317 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE. PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE Y66R PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3266 800-990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCR?R PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE P{UEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9106 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILD-8$ PURPOSE. r ----- - - - .._.._._._.... 8TU7a2T::N?1MEG.,.. ESQUIRE LORRAINE ESQWZRF ALAN M. M-NATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Woodcrest Corporate Center Ill Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 Request fcr 1'v h'arv Status Department of Defense Manpower Data Center aj. Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Sep-22-2010 11:54:48 't, Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service S enc g Y Based on the information you have furnished, the DMDC does not possess HENCH KEITH any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 14 Amt pt. 74(401j4_ A??_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL htti)://www.defenselink.mil/fagtpis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 4??? tin, n Request `or Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members :must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:5H6MC3PEC1 https://www.dmdc.osd.mil/appj/scra/popreport.do 9/2?/?ni n Req,?es` 'i;itary Status Department of Defense Manpower Data Center t Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Sep-22-2010 11:55:25 r Last N First/Middle Begin Date Active Duty Status Active Duty End Date Service ame Agency HENCH MAGDALENE Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). IA. 1A f 110AU, J/014,*j Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL httn://www.defenselink.mil/fag/v-is/PC09SLDR.htrnl. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 912?1?n 1 n Recues` i?itary S`atus Page 2 of 2 More in formation on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:RQESBKOTOR https://www.dmdc.osd.mil/appj/scra/popreport.do 9t??/?n? n UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU ATTORNEY FOR PLAINTIFF - ID #04302 - ID #45362 - ID #34576 - ID #75860 IRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 nleadings@udren.com Bank of America, N.A. Plaintiff v. Keith A. Hench Magdalene M. Hench Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 10-5317 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted H.R. 100), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age. Residence: Employment: Defendant : Age. Residence: Employment: Keith A. Hench Over 18 As captioned above Unknown Magdalene M. Over 18 As captioned Unknown Sworn to and subscribed before me this 24 day 9k September. 2010. or1 Pmnt ' CARA 5TEAR5 NOTARY PUIX OF NEWJEftSEY CwmLrdon hpW" 10/15/2013 Hench above = Tame Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. UDREN LAS? OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. L'DREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v• =Cumberland County :MORTGAGE FORECLOSURE Keith A. Hench Magdalene M. Hench NO. 10-5317 Defendant(s) TO: Magdalene M. Hench 234 North 32nd Street Camp Hill, PA 17011 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Px onotary X Judgment by Default Money Judgment Judgment in Replevin Q?o?yf tU Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsGudren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. :Cumberland County MORTGAGE FORECLOSURE Keith A. Hench =NO. 10-5317 Magdalene M. Hench De f endant (s) TO: Keith A. Hench 234 North 32nd Street Camp Hill, PA 17011 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Pr onotary x Judgment by Default Money Judgment Judgment in Replevin Q/ay/Id Judgment for Possession l j Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL: ATTORNEY Mark J. Udren, Esquire At this telephone number: 856-669-5400 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Keith A. Hench :NO. 10-5317 Magdalene M. Hench De f endant (s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $137,751.04 Interest From 09/25/2010 4,830.42 to Date of Sale March 2, 2011 Ongoing Per Diem of 30.38 to actual date of sale including if sale is held at a later date (Costs to be added) ,?fZZk.vv ?? A?- 517.5o CBF 9x•00 14.00 " " (2.50 4 JQ0.00 - PO A'n'y/ UDREN C. Y: ` ne s for Plaintiff MARK J. UDR RE STUART WINNPU,-EUE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 4 4-0o bcv-- lA 50 l-L 12.E Loth 4wuad- Ccc?f 11,11.13( o--AA-- 2.`f813a t-? r -o ?- c,?)r _< .?, UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 20 0 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Keith A. Hench -:NO. 10-5317 Magdalene M. Hench ?' x? Defendant (s) c c-a - ¢ , C E R T I F I C A T E ?- ? I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. Y: _ aintiff MARK J. UDREN, ESQ E STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE c UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. €COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Keith A. Hench :NO. 10-5317 Magdalene M. Hench Defendant(s) ?- cm C7 -r? ma c, r. C) -., Q AFFIDAVIT PURSUANT TO RULE 3129.1 Bank of America, N.A., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 234 North 32nd Street, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Keith A. Hench Magdalene M. Hench 234 North 32nd Street Camp Hill, PA 17011 234 North 32nd Street Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of of record: Name Bank of America, N.A the last recorded holder of every mortgage Address 475 Cross Point Parkway Getzville, NY 14068 e !c 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 234 North 32nd Street Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: September 24, 2010 UDREN LAW BY: aintiff MARK J. , STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. =COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION :Cumberland County V. Keith A. Hench Magdalene M. Hench :NO. 10-5317 Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Keith A. Hench Magdalene M. Hench PROPERTY: 234 North 32nd Street Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March 2, 2011, at 10:00AM, at the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF •` MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff =CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Keith A. Hench :NO. 10-5317 Magdalene M. Hench Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Keith A. Hench 234 North 32nd Street Camp Hill, PA 17011 Your house (real estate) at 234 North 32nd Street, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:00AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $137,751.04, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ., •, YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsCudren.com FOR PIAINTIFF Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Keith A. Hench :NO. 10-5317 Magdalene M. Hench Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Keith A. Hench 234 North 32nd Street Camp Hill, PA 17011 C 7 Your house (real estate) at 234 North 32nd Street, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:00AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $137,751.04, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N.A. :COURT OF COMMON PLEAS Plaintiff :CIVIL DIVISION V. :Cumberland County :MORTGAGE FORECLOSURE Keith A. Hench :NO. 10-5317 Magdalene M. Hench Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Magdalene M. Hench 234 North 32nd Street Camp Hill, PA 17011 Your house (real estate) at 234 North 32nd Street, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:00AM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $137,751.04, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: _(856)-669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5317 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., Plaintiff (s) From KEITH A. HENCH and MAGDALENE M. HENCH (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 $137,751.04 L.1-3.50 Interest from 9/25/10 to Date of Sale 3/2/11 ongoing per diem of $30.38 to actual date of sale including if sale is held at a later date -- $4,830.42 Atty's Comm % Due Prothy $2.00 Atty Paid $190.00 Other Costs Plaintiff Paid Date: 9/24/10 David D. Buell, P othonotary (Seal) By: REQUESTING PARTY: Name: ALAN M. MINATO, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Deputy Supreme Court ID No. 75860 I UDREN LAW OFFICES P.C. ATTORNEY FOR PLAINTIFF VbODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America, N.A. :COURT OF COMMON PLEAS :CIVIL DIVISION Plaintiff :Cumberland County v. t? ev Keith A. Hench C50 Magdalene M. Hench :NO. 10-5317 xr7l rn ca r- Defendant (s) ?? ?M, -..r a AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129. -a = C X F3 y !v ?r" Plaintiff, by its/his/her Attorney hereby verifies that: w 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is at hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: teQys.y 2011 UDREN LAW OFFICES, P.C. BY. Attorneys for Plaintiff Daniel S. Siedman, Esquire PA ID 306534 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America, N.A. Plaintiff V. Keith A. Hench Magdalene M. Hench Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON CIVIL DIVISION Cumberland County NO. 10-5317 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Keith A. Hench and Magdalene M. Hench PROPERTY: 234 North 32nd Street, Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING PLEAS The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 2. 2011, at 10:OOAM, in the Commissioners Hearing Room, Courthouse, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7 CD D CD 7 n C1 v C2 sy m m K 2 CD n 0 O QJ O_ O c 3 a- CD C1 Cn -n O 3 w r CD CT c v ('o A 0 3 3 w eD 0 0 eo CL cr 3 Cl 3 7 r --4 ? - CT - A - W - N - ? p CO co -I m CT A W N -+ ? Z n 'c CD > O ) cn CL CD CL O ` ° CD CD m m 46 m w o o t ca 3 n Nara C. 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' ?r y y N Q 3°• 0? 0 _ y N = ' m'oom3? .. 7 o Cn m m aye ya f i -: G O_ 7 N y 7 0 r 0 O ?O w c 3 ... _ _ CD 3m? °' O , m c v. a y3 oo 0 C) am D . m °, o.' m 3 0? D.;& 9 =B0) 00 ?n?.3-^ ?0Fr & 7 a ?1 OD)N x D_'m3 o? OoQ? d N m 000 o? mom Q 3 m , 9 d .3 0? 1:3 CD fD p) ?? m .? m a m ?p -n CD N y 0 7 ?` O y J O G. j'F mm' 3 '' M .m N ?• ?O c ? w d a y O d ? d -i si n J j y 0 N T(n CD CD .0 D Q f f?D 53 o m y d I ? N d _9%'3 m 3 -n (n m g - 0 3 y?coRg a c H 3 m2 m °1 m ain? m o ..v M y7 y 3 y °o c ? o 3 ?n a 0 om? m is y O m a v ° m m CD o SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Bank of America, NA vs. Keith A Hench (et al.) Case Number 2010-5317 SHERIFF'S RETURN OF SERVICE 12/29/2010 08:56 PM - Deputy Dennis Fry, 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 234 North 32nd Street, Camp Hill, PA 17011, Cumberland County. 12/29/2010 08:56 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Keith A Hench at 234 N. 32nd Street, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County. 12/29/2010 08:56 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Keith A. Hench, husband of defendant, who accepted as "Adult Person in Charge" for Magdalene M. Hench at 234 N. 32nd Street, Camp Hill, PA 17011, Cumberland County. SHERIFF COST: $908.94 January 21, 2011 SO ANSWERS, ? Y RON R ANDERSON, SHERIFF y :XHIE3IT ?