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HomeMy WebLinkAbout10-5369c ot 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 pleadings@udren.com ATTORNEY FOR PLAINTIFF ?j c O BAC Home Loan Servicing, LP =COURT OF COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION Servicing LP 475 Getzville, NY 14068 Plaintiff Cumberland County v. Patrick J. Neal Lisa M. Neal 82 Keefer Way Mechanicsburg, PA 17055 Defendant(s) NO. 10 - a-lvil-&M 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. 0 4ga.oo pp ArM Cp IS743 S eaquq6V 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 ti.ene 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 IMIEDIATANENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLANE 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: 82 Keefer Way MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Upper Allen COUNTY: Cumberland DATE EXECUTED: 7/28/04 DATE RECORDED: 7/30/04 BOOK: 1875 PAGE: 2585 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 08/09/10: Principal of debt due $116,357.13 Unpaid Interest at 3.875%* from 02/01/10 to 08/09/10 (the per diem interest accruing on this debt is $12.52 and that sum should be added-each day after 08/09/10) 2,378.80 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $339.00 and that sum should be added on the first of each month after 08/09/10) 0.00 Late Charges (monthly late charge of $30.68 should be added in accordance with the terms of the note each month after 08/09/10) 184.08 Partial Payment Balance (96.96) Uncollected Late Charge Balance 30.68 Attorneys Fees (anticipated and actual to 5% of principal) 5,817.86 TOTAL $125,276.59 *This interest rate is subject to adjustment as more fully described in the note and mortgage. 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 $125,276.59 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN/ LAW OFFICES, P.C. BY: / / A orneys 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 SIEDMAN, ESQUIRE First Anterlcen Idle Insurer== Coatpeny Cann?stitme nt Number 04359 SCL6 C RROPERTY DESCRR: nON The land referred to In this CcavrAment is desorlmd as foloww. 40 ALL THAT CERTAIN PIECE OR PARCEL. cf ground situate in Upper Allan Township, Gums iand County, Perenayhrar ia, heft Lot No. 85 as shown on a plait erect "Phase It. SoeaRnasa VNlager mom prep Ia NX4" as 8cwretWe VINO Upper , Allen Township, Curnbertar3d Cannon, Pannsylv8?fa" rao4rded DeCernber ?i4, 2000. be Plan Book t92 63 and recorded an Jarwary 3.. 200?I Plan ftok 82. Page as, prepared by Dawocrd Engineering, Inc.. more perdprl wW bounded and dtasorlbed as folbovAT-. BEGINNING at a 5W rebar to be set;, said rebeer being on the dividing line betrresen Lot No. 86 Lot No. 87 vvtter+a seAd lima interanseta with the arouthern r? Iine of Keefer Way (5 e1 tt"a€-way dimes eImp Lot No. 87. Soc#h 46 degrees 27 rrlinUlas 15•seaotp 1 East, a distance of 990.00 fast to are 518" cabarr Les beam at the 00, nrn 3n canner of tot No. 64, Lot No. 65, Lot No. a8 and lot No. W; thence along Lott. No. 55, South 43 degrees 32 rrirurtas 45 seconds West, a distance of 37.00 #eet to an 818" reber to be set at fhe corr;mon comer of Lot Not 64 Lot No. 56, Lot No. 85 and Lot No. 8S. 1hance along got No. 86. Nbrth 46 degrees 27 minutes 15 seconds West, -a distance of ei !h sl?a,tp 1110A f t to an gins 6/8 " l? to be set on the southern ftht-ofavMy line of Keefer WiW; theme 37:00 met W an W67 re bar to be sat on the lot am of Lot No. 85 end Lot 3 W. 86, BEGINNING. of CONTAINING 4,070 square feet, mom or Leas. . UNDER AND SUBJECT for a 10 access easernmtt along the vmsisrn side of the lot and to all covenants and agreements of record. ALSO UNDER AND SUBJECT to Deciasation of Protective Covenants, RestrIctionts and Conditions as set forth in Miscellaneous. Book 664, Pagan 862. HAVING thwoon erected a two-story townhouse known as 82 Keefer Way, Mechanicsburg, Pernteylvat9i. 97055. BEING PART OF THE SAME PREMISES which Bc>w ynants VB a Partners a pea?aerahIp, ttyr its deed dated October 28, 2002 and recorded Deownber 10, 2002 In the Office of th$ 62eaoax?er s? ?sds in acrd ic?r ? P0ulY. PO eyhranis, In deed Bo{,ok??254, Page •4473, granted and coranp?;M un a t? {Je a Harms, Ina, a Cbrporatlon, ter he egn. XHIBiT A E. (043&A043Wt2) IllaMtOAM6 408 hoar lams P[0 Bax Elm Temeoda, CA 92589-9048 Send Payn"mts Io: P.O. Box 15222 Wilmington. DE. 1198M.6222 Swid Correspondeneo for PO Box 5170, MS SV3148 Simi Valley, CA 93065 PRESORT FM-Claw Mail U.S. Postage and Fens Paid Ws0 7113 8257 1474 2828 0219 20100628-7 lilhlll?l?,??,??itnld.,n?p??????tl,Illll?lf??tt.l?l?lll??l Patrick J Neal 82 KEEFER WAY MECHANIICSBURG, PA 17055-9256 6t.0PA1 11722 U M2010 Sawke#America 'Itw Noah Lsaas P.0 Box 860694 Det/aa, TX 75286-OW14 Stand Payments to: P.O. Box 95222 W#ffW rtan. DE 9 9 9 86-5222 May 27, 2010 Patrick J Neal 82 KEEFER WAY MECHANICSBURG, PA 17055-9256 Certified Mau: 7113 6257 1474 2828 0214 Return Receipt Reauested Regular Mall Account No.: 66039192 Property Address: 82 Keefer Way Mechanicsburg, PA 17055-9256 Current Servicer: BAC Home Loans Servicing, LP ACE 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains Important legal information. K you have any questions, ropres intatlves at the Consumer Credit Counseling Agency may be able to help explain IL You may also want to contact an attomey in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAC16M EN ADJUNTO ES DE SOMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIKIENDO EN SU CASA. III NO COMPRENDE EL CONTENIDO DE ESTA NOTIFtCACI$N OSTENGA UNA TRADUCCION INMEDWTAMENTE LLAMANDO ESTA AGENCiA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRISA, PUEDE SER ELEGIBLE PARA UN PRIkSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL 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 LENDERJSERVICER: Paymut heetnmttontw Mrlayou-d,ad.aayademaac Horne Loans Sarvune. LP • DonYsandosoh Pluses indudm c uipanwllh ywr paymanf Far a1 full marlin Payiorit Perlods, interest is caudoifed on a menOYybade. Ao,ordinoy, internal for W) fUil ma61119e, inalWing Febtuary, is calculated as 30XMD ci annual Interest . mlopeetive of the equal nutrlaer of days in the =nf,. Par cormal rrantts, ktwass to caicumied deity 1}n the taosis W a 305 My year, Patrick J Neal 82 Keefer Way Machenloabure. PA 17o55-9 9 66039/92 13AC home Loans Servicing, LP is a subsicl ary of Be* nof America, N.A. Please wile you stools ru-cer on all checks and al rmm rdencr_ We map chIsMe you a fee liar wry PSYM1`0 rcatrrted ix reiecaed by ysur fiRlOW N irrslwtlcn, VA0011 to awlial*0 law. eLO PA r 11712 aa+oarm10 ceoe N Moro er. OOMI92--1 Patrick J Neal Balance Due for charges fisted above: $2,683.32 as of May 27, 2I11D. 82 Keefer Way Please.stale a-neil rdon„alm on he'-Ma one ofthie -4=. Mechanicsburg, PA 17055-8256 Fifi w 8.APt 11??...Ill?ll?ll n'I1.1.Il?flll'1119??'ll?????l.?lll?l?.lll.?l.l Eaavw ? BAC Home Loans Servicing, LP PO BOX 15222 (i?';nac? Wilmington, DE 19886-51222 TOW 0660139192100000266332000268332 /: 543699005131:66039 19 211' HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH C-AN 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 WITHIN THE NEXT THIRTY 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 desthnated consumer credit couns elina soencies for the county in which the property is located areset 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 ASSIST'sNCE - 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 old, 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 IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established25y the Act. The Pennsylvania Housing Finance Agency has sbay (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. (ff you have tiled 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 82 Keefer Way Mechanicsburg, PA 17055-9256 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 Chames: 03101/2010 Late Charges: 03101/2010 Other Charges: Uncollected Late Charges: Uncollected Casts: Partial Payment Balance: TOTAL DUE: 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: Provift your eynall address below we allow us to serer you Infomurdon on your account. Account Nunber: 08=192 Patrick J Naar E-mail address: $2.857.56 $92.04 $30.88 ($200.00) (S96,9Bl $2,683.32 Now we poet your payma?ts: AN acceplad pmyrnarna of principal and In arest we be applied to the longest ounsiani*q insiabment due, unless ofherwiss expressly prol*jipsd or limited by law, tf you wbr* an amount In adciddu to your sdwdulad monthly amount, Am will apply your payments as follows: {Ii m urtstarudtrrg monthly payments of priodpsl and Intel at, (li) eaaow deficiencies, (NI) late charges and otter amourns you cram In mnecuan with your loan and " to reduys the ou6a1311K iIng prindpsi balance of your loans Flews specify if you went an additional amount appiad to future payments, reAher lhiln prinrJpai reduction- Posadmad checks: Postdstad decks will be pfccesead an the data recervad unless a loan counselor agrees To honor the daft weircen on the check as a condition of a repayment plan, HOW TO CURE THE DEFAULT - You may cure the default wlthinTHIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,683.32 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 oavable and sent to: BAC Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222. You can cure any other default by taking the following action within THIRTY (301 DAYS of the date of this letter. (Do not use If not aoolicablel 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 alts 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 tender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE 1f3 FORECL08ED 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. N you cure the default within the THIRTY (30) DAY period, you wlg 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 NONEXISTENCE 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 underthe mortgage. Curing your default In the manner set forth In this notice will restore your mortgage to the same position as it 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 data 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: Nags of Lender. SAC Nome Loans Servicing, LP Address: P. 0. Sox 660094 Dallas, TX 75266-0664 Phone Number: 1-800-669-6654 FaxNumbers 1-817-230- ail Contact Person: MS TX2-977-01-13 Atteri on: Loan Counselor Email Address. To ensure secure email communications please log on to the BAC Home Loans Servicing, LP Webette at www.bankafamerice.corn and email us by navigating through the Customer Service link provided EFFECT OF SHERIFFS SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy ft. 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 startled 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 (1) 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 BAG Home Loans Servicing, LP is a subsidiary of Bank of America, NAn 7113 6257 1474 2628 0214 valuation services) may be taken. The casts 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 26, 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, L.P. Our basic plan requires that BAG Home Loans Servicing, LP receive, up front, at least 'A of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rater and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. o 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 ft. 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 Notsholder and avoid time foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with BAG 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 June 26, 2010 as outlined alcove 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 1-800-66"654. SAC Home Loans Servicing, LP is a subsidiary of Bark of America, NA 7113 6257 1474 2828 0214 Attachment: Itemization of Charges and Pees Monthly Charges: 03/01/2010 - 05/31/2010 Late Charges: Other Charges: 03/0112010 - 05131/2010 Uncollected Late Charges: Partial Payment Balanoe: Tva,j $952.52 $2.857S6 $30.68 $92.04 $30.68 ($96.961 TOTAL DUE: $2,683.32 BAC Home Loans Sarvidrg. LP is a subsidiary of Banc of America, M.A. C"ONStJMER CRF_D?IT COUNSELING AGENCIES SE.RVTIUG YOUR COUNTY CUMBERLAND COUNTY PHFA Adams Cavity Interfalth Housing Authority loveship, inc. 211 North Front Street 40 E High S~ 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 Commuryfty Action Commission of Cwbai Maranathe 2000 Unglestown Road Region 43 PhiteMph o Avemis Harrisburg, PA 17102 1514 Derry Street Waynesboro, PA 17288 88&5112227 Harrisburg, PA 17104 717.762,3285 88eZl 1 42227 717.232.9757 .?.... &vW^4ei+??. .. 8anlrrf8tas4ri+c? PRESORT FYI' Class Mail PO am 9(7x48 U.S. Postage and Temecula. CA 92589-9046 Foes WSO Pell 7113 825? 1474 2828 0202 Send P. MMWS to. P.O. Box '15222 Wil" gton, DE. 19888.5222 Bond Goureopcosdence to. Po Sox 5170, MS SV3145 22100628 7 Simi Valley, CA 93065 t Iru l?u r?r rtr"Il ?rr nll??l?lr'?'?rn ter rlrl r'r r?'rr??fl??[????? Lisa M Neal 82 KEEFER'WAY MECHANICSBURG, PA 1 705 5-92 56 M BLOW 11727 C4kCtN2DID BainketAmedm 4,1111110.. hose Leads P.O. Bar 660694 Dellais, TX 75266-0694 Send Payments to. P.O Box 15222 RVirrrungfm, DE 19896-5222 May 27, 2010 Lisa M Neat 82 KEEFER WAY MECHANICSBURG, PA 17055-9256 Certified Mail: 7113 8257 1474 2628 0202 Return Receipt Reauested Regular Mail Account No.: 66039192 Property Address: 82 Keefer Way Mechanicsburg, PA 17055-9258 Current Servicer: BAC Home Loans Servicing, LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains Important legal Information. N you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain IL You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCW, PUES AFECTA SU DERECHO A CONTINUAR VI1/IENDO EN SU CASA. 91 NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16H OSTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRftTAMO 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: f>ay.irrt fnain.aila..? Make your check pnymbs 1D BAC Hems Loam Ssrvone. LP - Don'i sand mah R-a mcludo mupaa Wit. your payrriafd For all ful rtnriat peyrnird: pmad9. Interest is celaieled on a mmlhly bwis. Aoaardingy. nhxesl for ell till months, inoudne Feeifusry, is calculated ss 30mo d arm lie nhxess, /nerd of the actual n fter a( days in the monrti. For carnal monvis, Merest d celcuiaied daily m tae basis of a M day year, Lisa M Neal 82 Keefer Way Mschanicsburo. PA 9705.5-9258 66039192 BAC Horne Loans Servicing, LP is a subsidiary of Be* of America, N.A. Please wrie your anoaurt rumber on all checks well o7ressaardence. We, may ctiafge youa fee lot sny payirieral ieksmed or rejeoled by your ifeerio.0 si91!Ii1Won, sutyea as emlowe law. B"FA111212 a=010 oOWN M ofter. GOMI92-1 Lisa M Neal Balance Due tar charges listed above: 52,683.32 as of May 27.2010- 82 Way fer sileaseupsasretell Momsemonme rsY ma side afmiscoupm. Mechanicsburg, PA 17055 9256 ?- BtAPA4 111111.1.11IN .no111111-1'11111It Ill. vIIII- bl?llltl.11111.11 Ea M BAC Home Loans Servicing, LP PO BOX 15222 Wilmington, DE 19886-5222 Tail 066039192100000268332000268332 t: 51369900513e:660 39 i9 211• HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE E MISLE FOR FINANGLALAaSSISTANCE WHICH C-AN 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 ELIG03LE 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 "lace-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY 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 dessiansted consumer credit counselina aaencies for the county in which the property is located are aft forth at the end of this Notice. It Is only necessary to schedule one face-to-face meeting. Advise your lender jmmedjgtell of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage Is in default for the reasons set forth later in this Notice (sae 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 completer 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 a" (60) days to make a decision after It receives your application. During that time, no foreclosure proceedings will be pursued against you K 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. (it 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 82 Keefer Way Mechanicsburg, PA 1 7 055-9256 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Charges: 03/01/2010 $2,857.56 Late Charges: 03M112010 $92.04 Other Charges: Uncollected Late Charges: $30.68 Uncollected Costs: (5200.00) Partial Payment Balance: (596.96) TOTAL DUE: $2,683.32 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) BAC Horns Loans Servicing, LP is a subsidiary of Bark of America, NA. E-mall use: Providing ywr e-mail address below will allow to to serd you Infomallon on your account, Account Number. 11192 Lion M Neal E-mail a " sz: Hrwr we post your paynrits: N accepted payments of plahdpet and worest wo be applied to the longest wtsuirkmV installment due, u . a otherwise expressly peddled cr limited bylaw. tr you submit an amount in addtkrh to ycor scheduled monthly amount; we vA apply your payments as fdiows: (l) to ou meadsV monthly payments of prredpal and i nterset, (11) ascow deAcienciee, (lil) late charges and other amounts you awe In mrhecffan with your loan and (to to reduce the outstanding pthdW balance or your loaf. Pieria specify if you want an additional amount appied W future paynhwm rather than principal re uction- Postttaud cihadra: Postdated checks wall be procasaed an the date raceirad unless a loan counselor agnaes to honor the daft mitten an the check as a canMon of a rarmyment plan HOW TO CURE THE DEFAULT - You may cure the default withinTHIRTY (30) DAYS of the slate of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,683.32 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 19866-5222. You can cure any other default by takino the folbwino action within THIRTY I= DAYS of the date of this letter. (Do not use If not apoiirabiel 1F YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise Its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due Immediately and you may lose the chance to pay the mortgage In monthly Installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. 1F THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to Its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney"s fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even If they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. E 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 Sake. 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 sake and any other costs oonneabed with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements underthe mortgage. Curing your default In the manner set forth In this notice will restore your mortgage to the same position se If you had never defaulted EARLIEST POSSIBLE SHERFF'S SALE DATE - It Is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sake will be sent to you before the sale. Of course, the amount needed to cure the default will incre ase the longer you walk 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 Dollars, TX 75266-0694 Phone Number: 1-800-66"654 Fax Number, 1-817-230.6817 Contact Person: MS TX2-977-01-13 Attention: Loan Counselor Emalf Address: To ensure secure email communications please log on to the BAC Home Loans Servicing, LP Websfte at www.bankolemerice.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 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 attomey's fees and coats 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 (1) 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 0-0 BAC Horne Loans Servicing, LP is a subsidiary of Bank of America, NA 7113 8257 1474 2626 0202 valuation services) maybe taken. The costs of the above-described inspections and property preservation efforts wNl be charged to your account as provided in your security instrument. If you are unable to cure the default on or before June 26, 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/ 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, in is possible that the regular monthly payments can be Icwered 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 BAG Home Loans Servicing, LP even If your home is worth less than what is owed on ft. 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 assistanoe, BAC Home Loans Servicing, LP will need to evaluate whetherthat assistaneewill be erdended 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 ft agrees otherwise in writing. Failure to bring your loan current or to enter Into a written agreement by June 26, 2010 as outlined above will result in the acceleration of your debt. Time is of the essence. tf you have any questions concerning this notice. please contact Loan Counseling Center immediately at 1-800-669-6654. BAG Horne Loans Servicing, LP is a subsidiary cf Bank of America, NA 7113 6257 1474 2828 0202 Attachment: Itemization of Charges and Fees Monthly Charoes: 0310112010 - 05/3112010 Late Charaes- Other Ch roes: 03/0112010 - 0513112010 Uncollected Late Charges: Partial Payment Balance: I?ZA $952.52 $2.857.56 $30.68 $92.04 $30.68 (596.961 TOTAL DUE: $2,1683.32 RAC Horne Loans SeNdng. LP Is a subsidary of Bank of America, W.A. CONSUMER CREDIT COUNSELING AGENCIES SERVTNCT YOUR COUNTY CUMBERLAND COUNTY PHFA Adonis County Intertatth Housing Authority t owreship, 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 800.3422357 CCCS of Westem PA Community Action Commission of Caphot Maranethe 2000 Ungtestovyn Rood Region 43 Philadelphia Awtenue Harrisburg, PA 17,102 1514 Derry Street Waynesboro, PA 17288 888.511.2227 Harrisburg, PA 17104 717.762.3285 888.511.2227 717.232.9757 r _. ?.. a.?ar-r?+r?r-? V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. BY?°- -(::3, e -A Attorneys 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 Jody S Smith Chief Deputy Richard W Stewart Solicitor BAC Home Loans Servicing, LP vs. Patrick J. Neal (et al.) Case Number 2010-5369 Fllr SCI T} ,1,GARY ^?' .. f1? -Ir dS P-9 AM 8.45 CUME ?;O-UNTY PEVKSib NSA SHERIFF'S RETURN OF SERVICE 09/02/2010 11:33 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1133 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Patrick J. Neal, by making known unto Vivian Smith, Mother in Law at 82 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. ?XA ROB RT BITNER, DEPUTY 09/02/2010 11:33 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on September 2, 2010 at 1133 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Lisa M. Neal, by making known unto herself personally, at 82 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $53.00 September 03, 2010 e/ K ROB R BITNER, DEPUTY SO ANSWERS, (?z C RON R ANDERSON, SHERIFF ,c CcuntySuite Sherff, leleo5oft. Inc. UDREN LAW OFFICES, P.C. MARK J. iTDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQU; - ID #04302 - ID #45362 - ID #34576 - ID #75860 LRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITS 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ~leadings@udren.com BAC Home Loan Servicing, LP fjk/a Countywide Home Loans Servicing LP 475 Getzville, NY 14068 Plaintiff v. Patrick J. Neal Lisa M. Neal 82 Keefer Way Mechanicsburg, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 10-5369 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and Defendant(s) Patrick J. Neal and Lisa M. Neal for failure Answer to Plaintiff's Complaint within 20 days from service for foreclosure and sale of the mortgaged premises, Plaintiff's damages as follows: As set forth in Complaint $125,276.59 against the to file an thereof and and assess Interest Per Complaint 713.64 From 08/10/2010 to 10/05/2010 Late charges per Complaint 61.36 From 08/10/2010 to 10/05/2010 Escrow payment per Complaint 678.00 From 08/10/2010 to 10/05/2010 TOTAL $126,729.59 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 LAW OFFICES, P.C. BY: Attorneys or Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE ~ (~, ~ PD p~ LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE (~~ 1(001533 CHANDRA M . ARKEMA, ESQUIRE 2~6t~ X98 DAMAGES ARE HEREBY ASSESSED AS ICATED y~' t_~ t ~,~ _ p,_,~ DATE : /0~5~l0 ~ ~. qY-8' I VOTE M~s'`~ -T PRO PROTHY UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNIFG, ESQUIRB - TD #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKBMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 DANIEL 5. SIEDMAN, ESQUIRE - ID #306534 ,; ,fir"".:. , z~x._ WOODCREST CORPORATE CENTER , 111 WOODCREST ROAD, SUITE 200 Y~~ ~ . _ '; Y.,;~r ,. ~. ~ CHERRY HILL, NJ 08003-3620 -- ~""•= ,:~, ~' .~ 856-669-5400 --: - --.. pleadings(~udrexi. com ., .. BAC Home Loan Servicing, LP '=COURT OE COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION _ - -. Servicing LP ~_ 475 Getzville, NY 14068 :Cumberland County r• , Plaintiff ~" v. Patrick J. Neal Lisa M. Neal ~ NO. to --.~' 3(09 ~,tiVi1 ~rH $2 Keefer Way Mechanicsburg, PA 17055 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. Tf 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 IBIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTB BELOW. THIS OFFICE CAN PROVIDE YOII WITH INFORMATION ABOUT HIRING A LAWYER. IF YOII CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY SE ABLE TO PROVIDE YOII WITB INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDTJCED FEE OR NO FEE. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~ fa¢ ~u~rb~~.~ Jody S Smith ~~ ~ ~ ~ ~~,.. Chief Deputy ~ ~'`''~ ~~* Richard W Stewart ~~~~~~'~~~~" Solicitor +~ ~' ~ BAC Home Loans Servicing, LP Case Number vs. 2010-5369 Patrick J. Neal (et al.) SHERIFF`S RETURN OF SERVICE 09/02/2010 11:33 AM -Robert Bitner, Deputy Sheriff, who being duty swom according to law, states that on September 2, 2010 at 1133 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Patrick J. Neal, by making -known unto Vivian Smith, Mather in Law at 82 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 i#s contents and at the same time handing to her personally the said true and correct copy of the same. ROB RT BiTNER, DEPUTY 09/02/2010 11:33 AM -Robert Bitner, Deputy Sheriff, who being defy swom according to iaw, states that on September 2, 2010 at 1133 hours, he served a true copy of the within Complaint in Mortgage. Foreclosure, upon the within named defendant, to wi#: Lisa M, Neal, by making known unto herself personally, at 82 Keefer Way, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said Prue and correct copy of the same. 1 RO R BtTNER, DEPUTY SHERIFF COST: $53.00 SO ANSWERS, September 03, 2010 RON R ANDERSON, SHERIFF {c) CEnmfy3uite Sheriff, Teleosoff, Inc, UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART CPINNSG, ESQUIRE - ID #45362 LORRAINS DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 ADAM L. KAYES, ESQUIRE - ID #Sb408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCR:EST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #1.0080927-] BAC Home Loan Servicin LP f/k/a Countywide Home Loans ~ervicing LP Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Patrick J. Neal - Lisa M. Neal NO. 10-5369 Defendant(s) TO: Patrick J. Neal 82 Keefer Way Mechanicsburg, PA 17055 Date of Notice: September 23, 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 YO{JR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YQU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE XOU 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 AGENC'2ES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVTCE 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 DENTRQ DE UN TERMING DE DTEZ (30) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, STN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCTA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR T_AI, SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION 5E ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICTO DE REFERENCIA LEGAL LAWYER REFERRAL SERV2CE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE: PIIRSUANT TO T8E FAIR DEBT COLL$CTION 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 BE USED.. SE_ M. )UIRE 111 Woodcrest Fcoad, Suite 200 Cherry Hill, I3ew 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. ARRSMA, ESQUIRE - ID #203437 ADAM L. RAYES, ESQUIRE - ID #85408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCRBST CORPORATE CENTER i11 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #~nnso~ ~-1 BAC Home Loan Servicin LP f/k/a Countywide Home Loans ~ervicing LP Plaintiff v. Patrick J. Neal Lisa M. Neal Defendants? _ TO: Lisa M. Neal 62 Keefer Way Mechanicsburg, PA 17055 Date of Notice: September 23, 2010 IMPORTANT NOTICE ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-5369 YOU ARE 2N 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 DAY5 FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOLT 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, THZS 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 NOTIFICACTON 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 NOTIFICACTON, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O 5I NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL, SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 $00-990-9108 NOTICE: PURSUANT TO THE PAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO SE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CHANDRA M . ARKENfP~, E~ ADAM L. ICAYES, ESQU MARGUERITE L. THOMAS, E Woodcrest Co orate C, 111 Woodcrest E~oad, 5u~ Cherry Hi11, New 3ersey 0 3 3620 UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLS, 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 ATTORNEY FOR PLAINTIFF BAC Home Loan Servicing, LP :COURT OF COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff v. :MORTGAGE FORECLOSURE Patrick J. Neal Lisa M. Neal NO. 10-5369 Defendant(s) STATE OF NEW JERSEY AFFIDAVIT OF NON-MILITARY SERVICE COUNTY OF CAMDEN SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Servicemembers' Civil Relief Act (108 P.L. 189; 117 Stat. 2835; 2003 Enacted x.R. l00), and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age: Residence: Employment: Defendant: Age: Residence: Employment: Patrick J. Neal Over 18 As captioned Unknown Lisa M. Neal Over 18 As captioned Unknown Sworn to and subscribed before me this 05 day ~f Octgber,~ 2Q10. above above ~i ~. Name: Title: ATTORNEY FOR PLAINTIFF Company: UDREN LAW OFFICES, P.C. ry ~~'EAR~ NOGI®IEL~JCOF t+EWJHi~Y Com~~sioalQfIS~013 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loan Servicing, LP f/k/a Countywide Home Loans Servicing LP Plaintiff v. Patrick J. Neal Lisa M. Neal Defendant(s) TO: Patrick J. Neal 82 Keefer Way Mechanicsburg, PA 17055 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE €NO. 10-5369 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. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings !d l5/~ ~ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL; ATTORNEY Mark J. Udren, Esquire Prothonotary ~ ~!! P 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 pleadingsC~udren.com BAC Home Loan Servicing, LP =COURT OF COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff v. =MORTGAGE FORECLOSURE Patrick J. Neal Lisa M. Neal €NO. 10-5369 Defendant (s ) TO: Lisa M. Neal 82 Keefer Way Mechanicsburg, PA 17055 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment C~~~Q,crc.0~, J5^ ~ Judgment in Replevin !O 1511 D 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. 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 I~'~ ~~ -~~ IRE - ID #203437 ~s' ~~ ~` ~ `'~~ ~ °F~~ti~' ~~~ WOODCREST CORPORATE CENTER n~ ~ „,., _ ~t, ~,4 ~: ! 9 111 WOODCREST ROAD, SUITE 200 ~_`'>; `~ CHERRY HILL, NJ 08003-3620 '" 856-669-5400 pleadings@udren. com ~ '- ` ' `~ ' " ~ ~ "~ BAC Home Loan Servicing, LP :COURT OF COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff v. =MORTGAGE FORECLOSURE Patrick J. Neal €NO. 10-5369 Lisa M. Neal Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Please issue Writ of Execution in the above matter: Amount due $126,729.59 Interest From 10/0612010 1,852.96 to Date of Sale March 2, 2011 Ongoing Per Diem of 12.52 to actual date of sale including if sale is held at a Later date (Costs to be added) ~c~1~•00 P O p~'Y 53.00 C6F go'~.00 " i~. oo •. a..~ „ x$5.50 ' PA A'rrY •6o t.t. ~rr~a~~{ ~~' a~ iq8 RE lit--e/ UDREN LAW OFFICES, P.C. BY: Attorneys fo'r Plaintiff -' MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 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 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loan Servicing, LP f/k/a Countywide Home Loans Servicing LP Plaintiff ATTORNEY FOR PLAINTIFF n _..9 t°7 . c--.? ~ i ~_ . ~s :,~ •s ~. i i . ~._ , fir.. - t.J i .,. ... y~~1 '. '~~ - ~ _ ,, ,. .-~ "`' COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. :MORTGAGE FORECLOSURE Patrick J. Neal @NO. 10-5369 Lisa M. Neal Defendant (s ) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X C. In Mortgage Foreclosure D. On a Note accompanying a purchase money. mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. BY: Attorneys far Plaintiff MARK J. UDREN, ESQUIRE STUART WTNNEG, 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 pleadingsC~udren.com BAC Home Loan Servicing, LP 'COURT OF COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff v. :MORTGAGE FORECLOSURE Patrick J. Neal ?NO. 10-5369 Lisa M. Neal Defendant (s ) C E R T I F I C A T E c-~ ~ -n ~,_~ ~__~ 4'..9 _.~. ~ ~ i~ y -.~ .7 - ~ 7 .~~ ~ '. _ ~ 5 ~ ~~~ ` ~` i ~ ~ 1 : :. _~ . ;~ ~. •`~ ~ :y 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: ( ) ( ) ( ) ( X ) ( ) An FHA insured mortgage Non-owner occupied Vacant 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. BY: ~ i~ Attorneys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. 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 #20343? WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loan Servicing, LP COURT OF COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff v. :MORTGAGE FORECLOSURE Patrick J. Neal €NO. 10-5369 Lisa M. Neal Defendant (s ) AFFIDAVIT PURSUANT TO RULE 3129.1 c "° a ~'~~ ,7 7 ~._ S _~,{ ~~ -; .-a ~:., _;~~ - _._ ~, ~.y r > c V~c,~t . .- yr _. BAC Home Loan Servicing, LP f/k/a Countywide Home Loans Servicing LP, 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: 82 Keefer Way, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Patrick J. Neal 82 Keefer inlay Mechanicsburg, PA 17055 Lisa M. Neal 82 Keefer Way Mechanicsburg, PA 17055 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 the last recorded holder of every mortgage of record: Name Address BAC Home Loan Servicing, 475 Getzville, NY 14068 LP f/k/a Countywide Home Loans Servicing LP Members 1st Federal 5000 Louise Drive Credit Union Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 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 82 Keefer Way Mechanicsburg, PA 17055 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: October 5, 2010 UDREN LAW OFFICES, P.C. BY: Attorneys fy6Y'~Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE 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. ARItEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(~udren.com BAC Home Loan Servicing, LP f/k/a Countywide Home Loans Servicing LP Plaintiff v. Patrick J. Neal Lisa M. Neal Defendant (s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVI5ION Cumberland County MORTGAGE FORECLOSURE NO. 10-5369 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Patrick J. Neal 82 Keefer Way Mechanicsburg, PA 17055 ~~ ~~ ---~ - ~ _,.~ ~ ~ E . - ~...3 .,.) . t:~Y ~ ~- ~- ~ :-~ w: , ~ ° :,.. , ~ . Your house (real estate) at 82 Keefer Way, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:OOAM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $126,729.59, 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 0~9NER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate actioa: 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. c 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. YOII SHOIILD TAKE THIS PAPER TO YOIIR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OiJT WHERE YOII CAN GET LEGAL HSLP. 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 pleadingsC~udren.com BAC Home Loan Servicing, LP :COURT OF COMMON PLEAS f/k/a Countywide Home Loans :CIVIL DIVISION Servicing LP =Cumberland County Plaintiff v. :MORTGAGE FORECLOSURE Patrick J. Neal =NO. 10-5369 Lisa M. Neal• Defendant (s ) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lisa M. Neal 82 Keefer Way Mechanicsburg, PA 17055 Your house (real estate) at 82 Keefer Way, Mechanicsburg, PA 17055 is scheduled to be sold at the Sheriff's Sale on March 2, 2011, at 10:OOAM in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $126,729.59, 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 LAVPYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THS OFFICE LISTED BELOW TO FIND OUT WHSRB 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 17Q13 717-249-3166 800-990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5369 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOAN SERVICING, LP f/Wa COUNTYWIDE HOME LOANS SERVICING LP, Plaintiff (s) From PATRICK J. NEAL and LISA M. NEAL (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 $126,724.59 L.L.$.50 Interest from 1016/10 to 3/2/11 ongoing per diem of $12.52 to actual date of sale including if sale is held at a later date -- $1,852.96 Atty's Comm Atty Paid $185.50 Plaintiff Paid Date: 10/5/10 (Seal) Due Prothy $2.00 Other Costs Da 'd D. Buell, Prothonotary By: Depu REQUESTING PARTY: Name: LORRAINE DOYLE, ESQUIRE Address: UDREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 111 WWODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 34576 UDREV LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 41 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 BAC Home Loan Servicing, LP f/k/a Countywide COURT OF COMMON PLEAS Home Loans Servicing LP € CIVIL DIVISION : Cumberland County Plaintiff s' V. M -r ?? Z? ? r*i CA7 ? "SJ rgry Patrick J. Neal Cn Lisa M. Neal = NO. 10-5369 r2 'ir> a z -? Qs Defendant (s) z? N CTt AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 4 Plaintiff, by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B" 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 17 Dated: C&Cvi , 2011 UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff Daniel S. Siedman, Esquire PA ID 306534 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 BAC Home Loan Servicing, LP `COURT OF COMMON PLEAS f/k/a Countywide Home Loans =CIVIL DIVISION Servicing LP :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Patrick J. Neal :NO. 10-5369 Lisa M. Neal Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 BAC Home Loan Servicing, LP f/k/a Countywide Home Loans Servicing LP, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 82 Keefer Way, Mechanicsburg, PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name Address Patrick J. Neal 82 Keefer Way Mechanicsburg, PA 17055 Lisa M. Neal 82 Keefer Way Mechanicsburg, PA 17055 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 s 4. Name and address of the last recorded holder of every mortgage of record: Name Address BAC Home Loan Servicing, 475 Getzville, NY 14068 LP f/k/a Countywide Home Loans Servicing LP Members 1st Federal 5000 Louise Drive Credit Union Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept. 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 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 82 Keefer Way Mechanicsburg, PA 17055 Bowman's Village 104 Keefer Way Mechanicsburg, PA 17055 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: rfgV(,--f ? , 2011 UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff Daniel S. Siedman, Esquire nw rn -5nLr'3w 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 BAC Home Loan Servicing, LP f/k/a Countywide Home Loans Servicing LP Plaintiff V. Patrick J. Neal Lisa M. Neal Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 10-5369 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Patrick J. Neal and Lisa M. Neal PROPERTY: 82 Keefer Way, Mechanicsburg, PA 17055 Improvements: RESIDENTIAL DWELLING 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. ?IT 41 w 0 x L Z CD C2 _r Z CD O O OD O v c CS CD iv C2 Cn T O 3 W co v v CD Q m CD A O 3 c w Q C 0 O a C. cr V 7 O W D1 O cD 7 C7 -4 CD° U1 . A W N O cD OD V D) cn A W N s r' QDN CD c z N ?fl.3 Q m ( D C o O c CODm7 D CL N N Cl) ?35 m _ 1 O ? 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C J w 0 Dq n m 3 r x Egg . c 0 3 m ? O 4O1 OC1 O C m = 1 . V.3 .z o,o F@ m -n;U m N d•N o .0 a o n N O 7 m °- rn y 3 T o y aim 2- _ ?l m-wlD m9 d 03 m -n cn cD coo. l o m y y 3 N 0 W - m a mm= Tcn c d'm 3 m= y a °c3?m'S m m m ay+m N ' CD y ? o q _ X 11 9 . .. ow°?w , x <? m v, c O N TI o d-N 0 m 6 CD ' -U_ N ' O L ? N V CL m r `? N 0 co 0 V 0 C ? cg ? ? n 3 CL V C ? m CL 7 0 t t o t o r A W N ; -' m OD V C? Cn A W N r ?Dn c 3 m e N p, ?+ N tT C (D c 1 a o . z :4 8 c .? ;ct 3 a z p 'm8AZ s - m5 zx?m5 D D + Zr (A? rm O c O Z-4 T M-0o 0 n m myom v •? n 3 m $ M m o m ao c?a ro 7:v D w m m 0000 ji ? 3 H I ? ? o 1 16 - Mg, ?.., 1313M w a lsn - m ° o ?Q = D ? a : _ $ i N m m a°? . ? Q_ 33 , ? o a a p o D PL 2 CL a 111 m o o _ fl Q ? yy??}t - n CA '0 n . go ?- $ b - a fill 3 i i O 8 >`' ?T SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor BAC Home Loans Servicing, LP vs. Case Number Patrick J. Neal (et al.) 2010-5369 SHERIFF'S RETURN OF SERVICE 01/03/2011 07:40 PM - Deputy Ryan Burgett, 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 82 Keefer Way, Mechanicsburg, PA, Cumberland County. 01/03/2011 07:40 PM - Deputy Ryan Burgett, 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: Patrick J. Neal at 82 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 01/03/2011 07:40 PM - Deputy Ryan Burgett, 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 Patrick Neal, Husband, who accepted as "Adult Person in Charge" for Lisa M. Neal at 82 Keefer Way, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. SHERIFF COST: $908.94 SO ANSWERS, January 21, 2011 RONW R ANDERSON, SHERIFF r-:XHIBIT 6 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 BAC Home Loan Servicing, LP f/k/a Countywide Home Loans Servicing LP 475 Getzville, NY 14068 Plaintiff V. Patrick J. Neal Lisa M. Neal 82 Keefer Way ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS . CIVIL DIVISION ? ? ' Cumberland County . rn 70 C= G7 :Z r -<> cn N:. NO. 10-5369 r--.;_. --+ _? C--) o cr r ter, Mechanicsburg, PA 17055 Defendant(s) PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: August 1, 2011 Attorney for Plaintiff 10080127-1