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HomeMy WebLinkAbout10-6352Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 ? 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 252098 BAC HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff V. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO 395 PEIPER ROAD SHIPPENSBURG, PA 17257-9425 Defendant OTA ?. `° .... i, . .. s 1 p.y . ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM 0-,,,-.t-Ferm NO. CUMBERLAND COUNTY O 041.00 Pa Am at toIa--"45 0 a'49a30 eb?` (- ?„ . ?itll?10 be# 000ft File #: 252098 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 252098 1. Plaintiff is BAC HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO 395 PEIPER ROAD SHIPPENSBURG, PA 17257-9425 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/14/2000 CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO made, executed and delivered a mortgage upon the premises hereinafter described to AMERICA'S WHOLESALE LENDER which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1607, Page 14. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 252098 6 The following amounts are due on the mortgage: Principal Balance $116,863.61 Interest $14,773.48 06/01/2009 through 10/05/2010 (Per Diem $30.0274) Attorney's Fees $650.00 Late Charges through 10/05/2010 $805.20 Costs of Suit and Title Search $550.00 Escrow Deficit ?3,913.97 Subtotal $137,456.26 Suspense Credit ($4$7.45) TOTAL $136,968.81 7 Plaintiff is nQt seeking a judgment of personal liability (or an in nerssonam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 252098 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $136,968.81, together with interest from 10/05/2010 at the rate of $30.0274 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP ?!7 By: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ?ourtenay R. Dunn, Esq., Id. No. 206779 LITAndrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 252098 LEGAL DESCRIPTION ALL that certain real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin at line of lands now or formerly of AI-Hart Inc., thence along lands now or formerly of Al-Hart Inc., North 65 degrees 53 minutes 31 seconds West, 607.52 feet to an iron pin at line right of way of United States Route Number 81; thence along the right of way of United States Route Number 81, North 43 degrees 49 minutes 28 seconds East, 221.49 feet to an iron pin; thence along same, North 43 degrees 49 minutes 28 seconds East, 883.97 feet to an iron pin; thence South 46 degrees 10 minutes 32 seconds East, 35.09 feet to an iron pin in Peiper Road (Township Route T-301); thence in Peiper Road, (Township Route T-301), South 10 degrees 30 minutes 59 seconds West, 716.30 feet to a railroad spike; thence continuing in said road, South 24 degrees 6 minutes 29 seconds West, 124.07 feet to an existing railroad spike; thence in the same, South 24 degrees 6 minutes 29 seconds West, 299.98 feet to the place of BEGINNING. CONTAINING 9.11 acres, more or less, according to the draft of survey of Carl D. Bert, P.L.S., dated June 17, 1995 and being Tract Nos. 1 & 2 thereon. PROPERTY ADDRESS: 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 PARCEL # 39-14-0171-006 File #: 252098 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: Attorney for Plaintiff File #: 252098 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - Sheriff Jody S Smith Chief Deputy ? Richard W Stewart Solicitor `w BAC Home Loans Servicing, LP Case Number vs. Christopher G. `Delcampo 2010-6352 SHERIFF'S RETURN OF SERVICE 11/08/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Christopher G. Delcampo, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Christopher G. Delcampo. After several attempts The Complaint in Mortgage Foreclosure has expired. SHERIFF COST: $87.00 SO ANSWERS, ('S?" X. z2z-__? November 08, 2010 RON R ANDERSON, SHERIFF nor °; 'Sof,'t'(_ Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BAC HOME LOANS SERVICING, LP Plaintiff j LEA-t 2 11 APR I I AM 9' 11 °J 1PENN S ?VANII\ ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION vs. : CUMBERLAND COUNTY CHRISTOPHER G. DELCAMPO A/K/A No. 10-6352-CIVIL TERM CHRISTOPHER G. DEL CAMPO Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE l:% ??? 110.00 N a*)- Q?as?-to9 TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN & SCHMIEG, LLP By:UL-4-r- -- ? Lawrence T. Phelan, Esq., Id. No. 32227 ['Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorneys for Plaintiff Date: April 8, 2011 /clo, Svc Dept. File# 252098 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BAC HOME LOANS SERVICING, LP Court of Common Pleas Plaintiff Civil Division vs. Cumberland County CHRISTOPHER G. DELCAMPO : A/K/A CHRISTOPHER G. DEL CAMPO No. 10-6352-CIVIL TERM Defendant ORDER AND NOW, this l day of ?C?11, upon consideration of Plaintiff's motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED, that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on the above captioned Defendant, CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO, by: 1. Posting of the premises: 395 PEIPER ROAD, SHIPPENSBURG, PA 17257 by the Sheriff or a non-party competent adult; and 2. First class mail to CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO at the mortgaged premises located at 395 PEIPER ROAD, SHIPPENSBURG, PA 17257. 3 Publication in accordance with PA. R.C.P. 430. m C :> s PHS# 252098/CLO It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. BY THE COURT: J. ?Cc: CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO 395 PEIPER ROAD, SHIPPENSBURG, PA 17257 10 3r t l 1 l o? PHS# 252098/CLO I- 'LE O-OFF4c? I-i ' - TH r R0T1-(GNRAR-T' Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 2011 NOY 22 AM 10: 14 CUMBERLAND COUNT PENNSYLVANIA ATTORNEYS FOR PLAINTIFF BAC HOME LOANS SERVICING, LP Plaintiff VS. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 10-6352-CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail to the following person, CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO, at 395 PEIPER ROAD, SHIPPENSBURG, PA 17257 on November 18, 2011, in accordance with the Order of Court dated October 31, 2011. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Phelan Hallinan & Schmieg, LLP DATE: November 18, 2011 By: PHS 252098 ,^elan Hallinan & Schmieg, LLP Lawrence o.32227 Francis S. Hallinan, Esq., Id. No. 2695 Daniel G. Schmieg, Esq., Id o. 62205 Michele M. Bradford, ., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P, Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Co R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 Attorneys for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 w Attorney For Plaintiff One Penn Center Plaza I C Philadelphia, PA 19103 r TK pROTIJONOTAR 215-563-7000 AM t, ?r? BAC HOME LOANS SERVICING LP fourt of Common Pleas Plaintiff CU pUiRLAND N Civil Division vs CUMBERLAND County CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO No. 10-6352-CIVIL TERM Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP. Date: December 28, 2011 By. PHEL N, HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff Printed Name: Robert W. Cusick, Esq. Bar Id. No. 80193 PHS# 252098 Attorneys for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 i- IL D-OF FIr" Attorney For Plaintiff One Penn Center Plaza OF THEE PROTHdNOTQP-"f Philadelphia, PA 19103 215-563-7000 11: 05 mil or-P !qo AM BAC HOME LOANS TY : Court of Common Pleas Plaintiff vs CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Civil Division CUMBERLAND County No. 10-6352-CIVIL TERM Defendant PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P., 2352 TO THE PROTHONOTARY: Kindly substitute Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based are as follows: Plaintiff BAC Home Loans Servicing, LP has merged with and into Bank of America, N.A. under the provisions of the National Bank Act. Bank of America, N.A. is successor by merger to BAC Home Loans Servicing, LP and, as a matter of federal law, is deemed to be the same company as BAC Home Loans Servicing, LP and all rights, franchises, and interests of BAC Home Loans Servicing, LP in and to every type of property (real, personal, and mixed) and choses in action are transferred to and vested in Bank of America, N.A., without any deed or other transfer. Accordingly, the name of the plaintiff has changed to Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP. Kindly amend the information on the d cket accordingly. 2g Date: December', 2011 1 i ?- By: - I PHELAN, HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff Printed Name: Robert W. Cusick, Esq. Bar Id. No. 80193 PHS# 252098 Attorneys for Plaintiff ara? 's e, 00 p4aO? I-- ek9 9 v C) 2t, ? PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF BAC HOME LOANS SERVICING, LP Plaintiff COURT OF COMMON PLEAS V. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant CIVIL DIVISION NO. 10-6352-CIVIL TERM CUMBERLAND COUNTY CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe for substitution of party plaintiff to Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP was served by regular mail to the person(s) on the date listed below: CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO 395 PEIPER ROAD SHIPPENSBURG, PA 17257-9425 Date: December 2011 By: V u PHELA , HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff Printed Name: Robert W. Cusick, Esa. Bar Id. No. 80193 PHS# 252098 Attorneys for Plaintiff ILED-OFFICE PHELAN HALLINAN & SCHMIEG,?LLNC PROTHONOTARY Attorney for Plaintiff Robert W. Cusick, Esq., Id. No.80193 2012 JAN 13 AN 9: 54 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ',.,UMBERLAND COUNTY Philadelphia, PA 19103 PENNSYLVANIA 215-563-7000 BANK OF AMERICA, N.A. AS CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP COURT OF COMMON PLEAS VS. : CIVIL DIVISION CHRISTOPHER G. DELCAMPO A/K/A No. 10-6352-CIVIL TERM CHRISTOPHER G. DEL CAMPO . PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO, Defendant(s) 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 $136,968.81 Interest - 10/06/2010 to 01/09/2012 $13,842.63 TOTAL $150,811.44 I hereby certify that (1) the Defendant's last known address is 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date l l l Robert Cusick, Esquire aM?% I $0 R Attorney for Plaintiff 01 ? C k?- uu s?u? 4( DAMAGES ARE HEREBY ASSESSED AS INDICATED. Q 4 - Mow.I? DATE: 1 ? 13? ! a PHS # 252098 c? ,nt+,,, •., o #. PROTHONOTARY 252098 PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP : CUMBERLAND COUNTY : COURT OF COMMON PLEAS VS. : CIVIL DIVISION CHRISTOPHER G. DELCAMPO A/K/A No. 10-6352-CIVIL TERM CHRISTOPHER G. DEL CAMPO AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO is over 18 years of age and resides at 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date w - ??IID Rob usick, Esquire Attorney for Plaintiff 252098 (Rule of Civil Procedure No. 236) - Revised BANK OF AMERICA, N.A. AS CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP COURT OF COMMON PLEAS VS. : CIVIL DIVISION CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO No. 10-6352-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on 11 IS By: If you have any questions concerning this matter please contact: Robert W. Cusick, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff V. CHRISTOPHER G. DELCAMPO, A/K/A CHRISTOPHER G. DEL CAMPO Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-6352-CIVIL TERM CUMBERLAND COUNTY TO: CHRISTOPHER G. DELCAMPO, A/K/A CHRISTOPHER G. DEL CAMPO 395 PEIPER ROAD SHIPPENSBURG, PA 17257-9425 DATE OF NOTICE: /o1 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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. PHS # 252098 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By /7/ drew Marley, Esq ' e Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 252098 ILE0-0F F ICS: Phelan Hallinan & Schmieg, L I E IPR O T HO N 0 TA R 'Attorney For Plaintiff 1617 JFK Boulevard, Suite 140QQ r One Penn Center Plaza 1G11 FEB 22 Ate 10- 1 J Philadelphia, PA 19103 CUMBERLAND COUNT`? 215-563-7000 PENNSYLVANIA BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff vs CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant Court of Common Pleas Civil Division CUMBERLAND County No. 10-6352-CIVIL TERM TO THE PROTHONOTARY: PRAECIPE ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ? Please mark the above referenced case Settled, Discontinued and Ended. ® Please Vacate the judgment entered. ? Please mark the in rem judgment Satisfied and the action Discontinued and Ended. Date: 2 2/ /Z PHELAN WLD ,Jn<SCHMIEG, LLP By: PHS # 252098 KoWsnik, Esq., Id. No. 308877 Attorney for Plaintiff aw? -U 01-'st M LA\ C r--it 115931 12 # a-133 a Phelan Hallinan & Schmieg, LLP Attorney For Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, Court of Common Pleas LP Plaintiff vs Civil Division CUMBERLAND County CHRISTOPHER G. DELCAMPO, A/K/A No. 10-6352-CIVIL TERM CHRISTOPHER G. DEL CAMPO Defendant CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO 395 PEIPER ROAD SHIPPENSBURG, PA 17257-9425 Date: ?2/41111- By: John olesni c, Esq., Id. No. 308877 Attorney for Plaintiff PHS # 252098 c:=, ?Z7 FTI =30 _: rare Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Matthew G. Brushwood, Esq., Id. No. 310592 Dana B. Ostrovsky, Esq., Id. No. 83921 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION : CUMBERLAND COUNTY VS. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO : No. 10-6352-CIVIL TERM Defendant PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE 411.95 PA AT" e4 J1'70GVg& Of a79&W, TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. & SCHMIEG, LLP By: wrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Jay B. Jones, Esq., Id. No. 86657 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Cantwell, Esq., Id. No. 308912 ? Mario J. Hanyon, Esq., Id. No. 203993 ? Andrew J. Marley, Esq., Id. No. 312314 ? R ert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 ? Matthew G. Brushwood, Esq., Id. No. 310592 ? Dana B. Ostrovsky, Esq., Id. No. 83921 Attorneys for Plaintiff Date: March 19, 2012 /kpl, Svc Dept. File# 252098 PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff VS. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendants COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY w.a 10-6352-CIVIL TER L No 'C' . PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: Jo icrel Kolesnik, Esq., Id. No.308877 rnev for Plaintiff Date: May 22, 2012, /cjv, Svc Dept. File# 252098 O $11.15 PAATTV PHELAN H4,UINAN & SCHMIEG, LLP e'* 1 lq 1 cotog R?---ar-?a &0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ,?t?ttitp O1 ? itii bn f OFF CE -"E ERIFF Li ' L'_ ' ? '111"` i '` 1 2: 1 , f BAC Home Loans Servicing, LP Case Number vs. 2010-6352 Christopher G. Delcampo SHERIFF'S RETURN OF SERVICE 06/07/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Christopher G. Delcampo c/o Carl Delcampo Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Carl Delcampo Jr. Request for service at 395 Peiper Road, Shippensburg, Pennsylvania 17257 is vacant. SHERIFF COST: $53.00 June 07, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (C) CouniySuite Sheriff, Teleosoft Ira;. PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff ?- y? r l_ COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO No. 10-6352-CIVIL TERM Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. AN & SCHMIEG, LLP By: Jo ihael Kolesnik, Esq., Id. No.308877 fo r Plaintiff Date: June 13, 2012 JHK/ccp, Svc Dept. File# 252098 1) j ?k..IF IIgg41q? V-49-7(a-74 F BANK OF AMERICA, N.A. AS SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, . LP Civil Division Plaintiff CUMBERLAND County V. No.: 10-6352-CIVIL TERM CHRISTOPHER G. DELCAMPO Defendant BOARD OF SUPERVISORS FOR MAGISTERIAL DISTRICT SOUTHAMPTON TWP., CUMBERLAND JUSTICE NUMBER 09-3-01 COUNTY, PENNSYLVANIA Plaintiff DOCKET NO. CV-0000039-10 V. CUMBERLAND Coug CHRISTOPHER G. DELCAMPO r Defendant r s SETTLEMENT STIPULATION <= ?C7 3 Z W --e o -t M tp Q (3M Board of Supervisors for Southampton Twp., Cumberland County, Pennsylvania (hereinafter "Southampton Township"), by and through their attorney, Richard Webber and Bank of America, N.A. successor by merger to BAC Home Loans Servicing, L.P. (hereainfter `Bank of America"), by and through its attorney, Lauren R. Tabas, Esquire, hereby stipulate as follows: WHEREAS Bank of America is the holder of the mortgage executed by Christopher G. Delcampo a/k/a Christopher G. Del Campo on April 14, 2000 upon the property at 395 Peiper Road, Shippensburg, PA 17257-9425 (hereinafter "Property") in favor of America's Wholesale Lender, which mortgage was recorded in the Office of the Recorder of Cumberland County, on April 19, 2000 in Mortgage Book No. 1607, Page 14. An assignment of mortgage was recorded in the Cumberland County Recorder of Deeds on January 18, 2012 as Instrument Number 201201696 WHEREAS on March 24, 2010, the Honorable Harold E. Bender entered a default judgment in favor of Southampton Township and against Defendant Christopher G. Del Campo in the base amount Page 1 of 4 of $1,600.00 and an additional $500.00 per day due to ongoing violations at the Property in Magisterial District Court 09-3-01, Docket No. CV-39-10 (hereinafter referred to collectively as "ongoing violations"). WHEREAS on October 6, 2010, Bank of America, N.A. filed a Complaint in Mortgage Foreclosure against Christopher G. Delcampo a/k/a Christopher G. Del Campo for failure to tender the required monthly mortgage payments due July 1, 2009 and each month thereafter in the Cumberland County Court of Common Pleas under Docket No. 10-6352-CIVEL TERM (hereinafter "foreclosure action"). WHEREAS the parties hereby stipulate: 1. In exchange for tender of $7,500.00 (Seven Thousand Five Hundred Dollars) Southampton Township agrees to release Bank of America, its successors and assigns from liability and responsibility, financially, personally, or otherwise, for the fines accruing against mortgagor Christopher G. Delcampo a/k/a Christopher G. Del Campo, and the Property, for violations of various ordinances relating to the condition of the Property until Bank of America, physically gains possession of the property. 2. Bank of America shall tender funds as stated in paragraph (1) to Southampton Township within ten (10) days of the complete execution of the Stipulation. 3. Any and all liens placed on the Property by Southampton Township as related to the ongoing violations will be considered junior to the mortgage lien of Bank of America, its successors or assigns. 4. If Bank of America, its successors or assigns, postpones or otherwise cancels a scheduled Sheriff's Sale of the Property in the currently pending foreclosure action, or subsequent foreclosure action, for any reason, there will be no penalty, financial or otherwise, assessed against Bank of America, its successors or assigns. Page 2 of 4 5. If the Property is sold to Bank of America, its successors or assigns, or a purchaser for value at Sheriffs Sale, any and all liens placed on the property by Southampton Township related to the judgment will be divested by the sale as a junior lien. 6. Should the Property sell at Sheriffs Sale to Bank of America, its successors or assigns, within sixty (60) days of the completion of an ejectment action and confirmation that the property is vacant, Bank of America, its successors or assigns, shall cause the Property to be brought into compliance with all Township Ordinances. 7. This stipulation shall not act to preclude Southampton Township from bringing a personal action against Christopher G. Delcampo a/k/a Christopher G. Del Campo or any of his heirs, successors or assigns. 8. The attorneys executing this Stipulation have done so only after having discussed the terms with their respective clients and having obtained their consent to be bound by the terms of this Stipulation. 9. This stipulation may be executed in counterparts. 10. A facsimile version of a signature on this document shall be treated for all purposes as the equivalent of the original signature. 11. Upon execution of the parties, Counsel for each shall be responsible for having the within stipulation docketed and entered of record in its respective action. 12. Counsel for Bank of America, its successors or assigns, shall provide a copy of the stipulation to the Sheriff of Cumberland County in the event the property is listed for Sheriffs Sale so that the costs of sale, as applicable, can be adjusted in accordance with the stipulation and any proposed schedule of distribution shall be made in accordance with this stipulation. Page 3 of 4 Date: Lauren R. Tabas, Esquire Phelan Hallinan & Schmieg, LLP One Penn Center at Suburban Station 1617 J.F.K. Blvd - Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Date: Richard L. Webber, Jr., Esquire Board of Supervisors for Southampton Township, Cumberland County, Pennsylvania 126 East King Street Shippensburg, PA 17257 Page 4 of 4 PHELAN HALLINAN & SCHMIEG, LLP By: LAUREN R. TABAS, ESQUIRE Identification No. 93337 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Bank of America successor by merger to BAC Home Loans Servicing, L.P. 7105 Corporate Drive Plano, TX 75024 Plaintiff VS. Christopher G. Delcampo A/K/A Christopher G. Del Campo 395 Peiper Road Shippensburg, PA 17257-9425 Defendant Attorney for Plaintiff : Court of Common Pleas : Civil Division : Cumberland County CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Settlement Stipulation were served on the parties listed below: Via fedex: Richard L. Webber, Esquire Weigle & Associates, P.C. 126 East King Street Shippensburg, PA 17257-1397 Via Regular Mail: Christopher G. Delcampo A/K/A Christopher G. Del Campo PA/17257-9425 2- DATE: L4 21AI BY: Lauren R. Tabas, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A. AS SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP Civil Division Plaintiff CUMBERLAND County VS. No. 10-6352-CIVIL TERM CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant AMENDED ORDER AND NOW, this /? day of V1 , 2012, upon consideration of Plaintiff's Motion for Amended Order for Service, it is here y ORDERED and DECREED, that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of (the Complaint and all future pleadings on the above captioned Defendant, CHRISTOPHER G. DELCAMPO, by: 1. Posting of the premises: 395 PEIPER ROAD, SHIPPENSBURG, PA 1725 9425 by the Sheriff or a non-party competent adult; and 2. First class mail to KAREN SPERLING GREENE, CO-GUARDIAN and CARL DELCAMPO JR., CO-GUARDIAN for Defendant, CHRISTOPHER G. DELCAMPO at last known address, 103 HILLSIDE AVENUE, TENAFLY, NJ 07 and at the mortgaged premises located at 395 PEIPER ROAD, SHIPPENSBURG, P 17257-9425. PHS# 252098/CCP It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. COURT: J. Cc: CARL DELCAMPO JR., CO-GUARDIAN FOR DEFENDANT, CHRISTOPHER G. DELCAMPO 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 / 103 HILLSIDE AVENUE TENAFLY, NJ 07670 KAREN SPERLING GREENE, CO-GUARDIAN FOR DEFENDANT, CHRISTOPHER G. DELCAMPO 103 HILLSIDE AVENUE TENAFLY, NJ 07670 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 4t es Ma ,"Ied 711611a 4elic -.? 4 c PHS# 252098/CCP t PHELAN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff TAE. PROTHONOTAR : 2012 JUL 24 A1410? 44 r,UMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendants No. 10-6352-CIVIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the captioned matter. PHELAN H SCHMIEG, LLP B Allison F. , Esq., Id. No. 309519 Attorney for Plaintiff Date: July 20, 2012 AXW/ccp, Svc Dept. File# 252098 QYk} R. Q 1 eke ?a ?s?? p?,a7 33a Phelan Hallinan & Schmieg, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff VS. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant(s) ATTORNEYS FOR PLAINTIFF i_LI?J 12 JUL 31 "UMBERLAI €'ENNSY COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 10-6352-CIVIL TERM AMENDED AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the captioned matter was sent by regular mail, to the following persons, KAREN SPERLING GREENE, CC GUARDIAN, FOR DEFENDANT CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL and CARL DELCAMPO, JR., CO-GUARDIAN, FOR DEFENDANT CHRISTOPHER G. DELCAMPi CHRISTOPHER G. DEL CAMPO at 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 and 103 HILLSIDE AVENUE, TENAFLY, NJ 07670 on July 25, 2012, in accordance with the Order of Court da 17`h' 2012. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S relating to unworn falsification to authorities. & SCHMIEG, LLP DATE: July 27, 2012 By: L John chae Kolesnik, Esq., Id. No.308877 A ney for Plaintiff Ian Hallinan & Schmieg, LLP ., iit F;LC THONOTAT 'Y' AM 10:40 COUNTY ANIA AWA July §4904 Phs # 252098/ccp AFFIDAVIT OF SERVICE - CUMBERLAND ccP PLAINTIFF BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP COUNTY: CUMBERLAND COURT NO. 10-6352-CIVIL TERM DEFENDANT CHRISTOPHER G. DELCAMPO TYPE OF ACTION - ~` A/K/A CHRISTOPHER G. DEL CAMPO XX Mortgage Foreclosure z.°a +~.~ x ~~ ~ ~ Eviction ,~, ~ m - SERVE AT: XX Civil Action sza >~ laint on Promissory 1 Com ~ ~ r7= ~ rr, CARL DELCAMPO, JR., CO-GUARDIAN ~ j p - ~ "~ ~ ~ ~ FOR CHRISTOPHER G, DELCAMPO ~ ~ Ca A/K/A CHRISTOPHER G. DEL CAMPO t~`--~ am i ~, ~ 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 "'c „' ~ ~ *** ~~ o ~ ~~ ***PLEASE POST THE PROPERTY ***IN ACCORDANCE WITH THE***** --r ~ ~``~ ~-:: ~~ ***ATTACHED COURT ORDER****** - - ~ervea Posted and made known CARL DELCAMPO, JR., CO-GUARDIAN FOR CHRISTOPHER G. DELCAMPO A/K/A ', CHRISTOPHER G. DEL CAMPO, Defendant on the ~? day of~ Ul _ 20 ~Z I at ~~ o'clock, ~. M., at C/O CARL DF,LCAMPO, JR., GUARDIAN, 395 PEIPER ROAD, SHIPPENSBURIi, PA 17257-942, in the manner described below; Defendant personally served. ', _ Adult family member with whom Defendant(s) reside(s). Relationship is ', Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or astral place of business. ~ _ an office of said defendant company. Other: ^ {.1'-~7sf~ _~ _..• Description: Age Height. Weight _ Race Sex _ Other I, _~01"~ ~b jl , a competent adult, being duly sworn according to law, depose and state that I personally posted a true an~ correct copy ufihe Complaint in Mortgage Foreclosure issued in the captioned case on the date and the address indicated above. I understand th t this stafemcnt is made subject ioihe penalties of 18 Pa. C.S. Sec. 4904 relatin ~ to unsworn fal ' tcation to authoritigs.~ DATE: --Z~.'3©- 1Z NAME: _~~ t 1~ /~ - __ _ __ PRIlJTED NAME: ___ y~" `~ /~ a j' ~. _.. _~~- W. NOT SERVED On the _ day of , 20_, at _ o'clock __. M., Defendant NOT FOTJND because: Vacant Does Not Exist -Moved _ Does Not Reside (Not Vacant) No Answer on _at Service Refi~sed Other: PHS# 252098 ~TD AFFYDAVIT t)F SERV[CE -CUMBERLAND ccP PLAINTIFF BANK OF AMERICA, N.A. AS SUCCESSOK 13Y MERGER TO I3AC HOME LOANS SERVICING, LP COUNTY: CUMBERLAND COURT NO. 10-6352-CIVIL TERM DEFENDANT CHRISTOPHER G. DELCAMPO TYPE OF ACTION A/K/A CHRISTOPHER G. DEL CAMPO XX Mortgage Foreclosure Eviction ', SERVE A"I': XX Civil Action ~ v ' KAREN SPERLING GREEN CO-GUARDIAN Complaint on Promissory N_o> ,:,, -~ FOR CHRISTOPHER G, DF,LCAMPO ~~ --r ~ F~=t~..~. A/K/A CHRISTOPHER G. DEL CAMPO ~~ ~ ~'~ ~ ~.; 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 ~H ~ i~ ~~ ys ~l~' <;~ -~- ***PLEASE POST THE PROPERTY*** ~n ~ ,~-~-- ***IN ACCORDANCE WITH THE***** ~~ ca I ~~~. ***ATTACHED COURT ORDER****** ~ ~' Served ~C N Posted and made known KAREN SPERLING GREEN, CO-GUARDIAN FOR CHRISTOPHER G. DELCAMPO A/K/A ~ day of eel Defendant on the ~7 DEL CAMPO CHRISTOPHER G ,20 t "~ _ _ _ , . at `7 ~•~3 o'clock, ~M., at C/O CARL DELCAMPO, JR., GUARD 95 PEIPER ROAD, SHIPPENSBURG. PA 17257-942, in the manner described below: _ Defendant personally served. Adult family member with whom Defendant(s) resides}. ', Relationship is Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). ', Agent or pf:rson in charge of Defendant's office or usual place of business. ', an office of said defendant company. Other: ___~ Description: Age_ Height_ Weight Race Sex _ Other I, I, ~ON ~i, , a competent adult, being duly sworn according to law, depose and state that I personally posted a true an~ correct copy of the Complaint in Mortgage Foreclosure issued in the captioned case on the date and the address indicated above. I understand th t this statement is made subject to the penalties of ] 8 Pa. C.S. Sec:. 4904 rel in to unsworn alsifi ion to auth~es. DATE: ~ r3 ~~ ~~ NAME: __~ ~__.__ i PRITITED NAME: ~~+-' ~~~ l ~ TITLE: (~Qc~l',rs5 5 ~-d1-C.s~f!` NOT SERVED On the _ day of , 20_, at o'clock __. ivL, Defendant NOT FOUND because: _ Vacant _ Does Not Exist ~ Moved _ Does Not Reside (Not Vacant) No Answer on at Service Refused Other: PHS# 252098 L~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 10-6352 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff (s) From CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO (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: $158,078.07 L.L.: $.50 Interest FROM 9/7/2012 TO DATE OF SALE ($26.35 PER DIEM) - $4,769.35 Atty's Comm: % Due Prothy: $2.25 Atty Paid: 388.00 Plaintiff Paid: Date: 10/11/12 (Seal) Other Costs: Dy. REQUESTING PARTY: Name: ROBERT W. CUSICK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Deputy Supreme Court ID No. 80193 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) c,- P.R.C.P. 3180-3183 fBANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC COURT OF COMMON PLEAS HOME LOANS SERVICING, LP Plaintiff CIVIL DIVISION v CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 09/07/2012 to Date of Sale ($26.35 per diem) TOTAL Note: Please attach description of property. PHS # 252098 co QD cr . co 11)( ?? 6d WI ? Co, SD l r ?, l< « NO.: 10-6352-CIVIL TERM CUMBERLAND COUNTY c•-D C_-) rl?, U" ?, _.. $4,769.35 $162,847.42 L P an Hallinan & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff a 4?_ Z5 rte. ?r wo f a?rP_%;__ln? 'PP C-) Q d O? 6 O O? `? '?O O O O W OU WO 4 51 M 9 U?? a r. QP4 a d W? Q a WUa 4 VIA) D p? Va. Wo BCD v a ?41 ? U dr?j d 3 O??UWw cnd?pMW ? U d U d O W Yr M Q ?? Ua OU ? ? a° O dva ?w y a O W O w ?`??y ? W° 3 O w?a, ?UQ W 43 U '? U LEGAL DESCRIPTION ALL that certain real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin at line of lands now or formerly of AI-Hart Inc., thence along lands now or formerly of Al-Hart Inc., North 65 degrees 53 minutes 31 seconds West, 607.52 feet to an iron pin at line right of way of United States Route Number 81; thence along the right of way of United States Route Number 81, North 43 degrees 49 minutes 28 seconds East, 221.49 feet to an iron pin; thence along same, North 43 degrees 49 minutes 28 seconds East, 883.97 feet to an iron pin; thence South 46 degrees 10 minutes 32 seconds East, 35.09 feet to an iron pin in Peiper Road (Township Route T-301); thence in Peiper Road, (Township Route T-301), South 10 degrees 30 minutes 59 seconds West, 716.30 feet to a railroad spike; thence continuing in said road, South 24 degrees 6 minutes 29 seconds West, 124.07 feet to an existing railroad spike; thence in the same, South 24 degrees 6 minutes 29 seconds West, 299.98 feet to the place of BEGINNING. CONTAINING 9.11 acres, more or less, according to the draft of survey of Carl D. Bert, P.L.S., dated June 17, 1995 and being Tract Nos. 1 & 2 thereon. TITLE TO SAID PREMISES VESTED IN Christopher G. Del Campo, by Deed from Crea L. Koser, single woman, dated 04/14/2000, recorded 04/19/2000 in Book 219, Page 658. PREMISES BEING: 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 PARCEL NO. 39-14-0171-006 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A. AS SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP Civil Division Plaintiff CUMBERLAND County vs. No. 10-6352-CIVIL TERM CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant AMENDED ORDER AND NOW, this // day of fer , 201 2, upon consideration of Plaintiffs Motion for Amended Order for Service, it e y ORDERED and DECREED, that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of Complaint and all future pleadings on the above captioned Defendant, DELCAMPO, by: 1. Posting of the premises: 395 PEIPER ROAD, SHIPPENSBURG, PA 1725 9425 by the Sheriff or a non-party competent adult; and 2. First class mail to KAREN SPERLING GREENE, CO-GUARDIAN and CARL DELCAMPO JR., CO-GUARDIAN for Defendant, CHRISTOPHER G. DELCAMPO at last known address, 103 HILLSIDE AVENUE, TENAFLY, NJ 0767 and at the mortgaged premises located at 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425. the G. PHS# 252098/CCP r it is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to fife a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. COURT: Cc: CARL DELCAMPO JR., CO-GUARDIAN FOR DEFENDANT, CHRISTOPHER G. DELCAMPO 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 / 103 HILLSIDE AVENUE TENAFLY, NJ 07670 j? KAREN SPERLING GREENE, CO-GUARDIAN FOR DEFENDANT, CHRISTOPHER G. DELCAMPO 103 HILLSIDE AVENUE TENAFLY, NJ 07670 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 416?c J. C r is X G C3 m r. s C:??` . zo ter PHS# 252098/CCP PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 , ,F my Ali to. t 2 Attorneys for Plaintiff ND COll T?' BANK OF AMERICA, N.A. AS SUCCESSOR BCOURT OF COMMON PLEAS BAC HOME LOANS SERVICING, LP Plaintiff CIVIL DIVISION V. NO.: 10-6352-CIVIL TERM CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant(s) CERTIFICATION : CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Phela allinan & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff V. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-6352-CIVIL TERM CUMBERLAND COUNTY PHS # 252098 AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) c- `- - ? CHRISTOPHER G. DELCAMPO 395 PEIPER RD A/K/A CHRISTOPHER G. DEL CAMPO C/O SHIPPENSBURG, PA 17257-9425 CD KAREN SPERLING GREENE, CO-GUARDIAN AND CARL DELCAMPO JR., CO-GUARDIAN CHRISTOPHER G. DELCAMPO 103 HILLSIDE AVE p p ' A/K/A CHRISTOPHER G. DEL CAMPO C/O TENAFLY, NJ 07670-2113 KAREN SPERLING GREENE, CO-GUARDIAN -< AND CARL DELCAMPO JR., CO-GUARDIAN 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) CARL DEL CAMPO CARL DEL CAMPO C/O MARTIN BURGER 10 LT. WHEELER CT BLAUVELT, NY 10913-1244 460 BERGEN BLVD SUITE 203 PALISADES PARK, NJ 07650 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) BOARD OF SUPERVISORS, SOUTHAMPTON TOWNSHIP 200 AIRPORT ROAD SHIPPENSBURG, PA 17257 /* s SOUTHAMPTON TOWNSHIP 126 EAST KING STREET C/O RICHARD L. WEBBER, JR., ESQUIRE SHIPPENSBURG, PA 17257-1397 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 (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 395 PEIPER ROAD SHIPPENSBURG, PA 17257-9425 COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR, STRAWBERRY SQ. BUREAU OF INDIVIDUAL TAXES DEPT 280601 INHERITANCE TAX DIVISION HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE, TPL P.O. BOX 8486 CASUALTY UNIT, ESTATE RECOVERY WILLOW OAK BUILDING PROGRAM HARRISBURG, PA 17105 CHRISTOPHER G. DELCAMPO A/K/A 103 HILLSIDE AVE CHRISTOPHER G. DEL CAMPO C/O CARL TENAFLY, NJ 07670 DELCAMPO, JR, GUARDIAN CHRISTOPHER G. DELCAMPO, A/K/A 103 HILLSIDE AVE CHRISTOPHER G. DEL CAMPO C/O KAREN TENAFLY, NJ 07670 SPERLING GREENE, GUARDIAN DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 I verify that the statements made in this affidavit are true and knowledge or information and belief. I understand that false st to of 18 Pa. C.S.Arelating to unsworn falsification to au it. Date: iBy: to the best of my personal indre made subject to the penalties Phelan Ha an & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS BAC HOME LOANS SERVICING, LP . : CIVIL DIVISION Plaintiff : : NO.: 10-6352-CIVIL TERM VS. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO : CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CHRISTOPHER G. DELCAMPO CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO A/K/A CHRISTOPHER G. DEL CAMPO C/O KAREN SPERLING GREENE, CO- C/O KAREN SPERLING GREENE, GUARDIAN AND CARL DELCAMPO JR., CO-GUARDIAN AND CARL DELCAMPO JR., CO-GUARDIAN CO-GUARDIAN 395 PEIPER ROAD 103 HILLSIDE AVENUE SHIPPENSBURG, PA 17257-9425 TENAFLY, NJ 07670-2113 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 is scheduled to be sold at the Sheriff s Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $158,078.07 obtained by BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. C NOTICE OF OWNER'S RIGHTS ?;ri c-) YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale, you must take immediate action: CD 1. The sale will be canceled if you pay to the mortgagee the back payments, late charged costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000x1230. 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 215-563-7000. 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 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, CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin at line of lands now or formerly of AI-Hart Inc., thence along lands now or formerly of Al-Hart Inc., North 65 degrees 53 minutes 31 seconds West, 607.52 feet to an iron pin at line right of way of United States Route Number 81; thence along the right of way of United States Route Number 81, North 43 degrees 49 minutes 28 seconds East, 221.49 feet to an iron pin; thence along same, North 43 degrees 49 minutes 28 seconds East, 883.97 feet to an iron pin; thence South 46 degrees 10 minutes 32 seconds East, 35.09 feet to an iron pin in Peiper Road (Township Route T-301); thence in Peiper Road, (Township Route T-301), South 10 degrees 30 minutes 59 seconds West, 716.30 feet to a railroad spike; thence continuing in said road, South 24 degrees 6 minutes 29 seconds West, 124.07 feet to an existing railroad spike; thence in the same, South 24 degrees 6 minutes 29 seconds West, 299.98 feet to the place of BEGINNING. CONTAINING 9.11 acres, more or less, according to the draft of survey of Carl D. Bert, P.L.S., dated June 17, 1995 and being Tract Nos. 1 & 2 thereon. TITLE TO SAID PREMISES VESTED IN Christopher G. Del Campo, by Deed from Crea L. Koser, single woman, dated 04/14/2000, recorded 04/19/2000 in Book 219, Page 658. PREMISES BEING: 395 PEIPER ROAD, SRWPENSBURG, PA 17257-9425 PARCEL NO. 39-14-0171-006 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-6352-CIVIL TERM BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP VS. CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO owner(s) of property situate in the SOUTHAMPTON TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 395 PEIPER ROAD, SHIPPENSBURG, PA 17257-9425 Parcel No. 39-14-0171-006 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $158,078.07 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 AFF)<DAV [T OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA, N.A. AS SUCCESSOR BY M ERGF,R TO BAC HOME LOANS SERVICING, LP PHS # 252098 DEFENDANT SERVICE TEAM! Ixh =~', ~~ ~~ CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL COURT NO.: 10-6352-CIVIL TERM ~ --~ ~~ ~ SERVE CHRISTOPHER G. DELCAMPO .A/K/A CHRISTOPHER G. TYPE OF ACTION ~ ~" ~ -~~ ; ~-~ DEL CAMPO AT: XX Notice of Sheriff s Sale ~~ [ t~ ~'~ 103 HILLSIDE AVE SALE DATE: March 6, 2013 '~`~ ~ C/O KAREN SPERLING GREENE, GUARDIAN ~~ ~ ~`~~~ TENAFLY, NJ 07670 ~" ~ ~_ ~ t ,~i C ~ :~ t SERVEll ~~-I ~ '~ Served and made known to CHRISTOPHER G. DE LCAMPO A/K/A CHRISTOPHER G. DEL CAMPO, Defendant on the ~ day of N~ ts"rV18t 1~ 20 Z. , at --, o'clock ~. M., atIQ3 Nf(llS iAllE, TE ~! ~ 3'. , in the manner described below: _ Defendant personally served. _ Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. - Other: _j~(~fZjj..) g (1~ - ~/ZG'~J' SAts'7~Li Ili U Q'i/~~~~1~'~ r2~~ Description: Age ~_ Height Weight t 3 Q Race ~ Sex ~ Other I. TKOI~IA S IYI~~U91 ~> a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued iyn"}the captioned case on the date and at the address indicated above. C~T~~~ ~+IJ,~Gn- f~/ Sworn to and subscribed LISA M. CxLECH ~l r. 4M SERVICES, IIVC~L~! Z before me this _1~ day NOTiVIYPUBLICOFNEWJFasEY ~~~~~'~ ~~{'~ ~,~y,~}~~+,~ 20 '~ MYCgmmiuionl'sxpireiApnl Ib,Y014 400 ~ELLO1NSHiP ROAD i--~-o'L-•a,~' SU1TE 220 notary%, ~,(, sy: MT, LAUI~L, NJ 08064 1, NOT SERVED On the dayy of , 20 , at ~~ clock _. M., I, , a competent adult hereby state that~fendant cause: _ Vacant ~ Does Not Exist _ lvloved __ Does Not Reside (Not Vacant) No Answer on _ at _ at Service Refused Other: Sworn to and subscribed before me this day of _ , 20~. By: Notary: ATTORNEY FOR 1?LAINTIFF Lawrence T. Phelan, Esy., Id. No. 32227 Francis S. Hallinan, Esq., 1d. No. 62695 Daniel G. Schmieg, Iisy., Id. No. 62205 Michele M. Bradfw~d, Esq., Id. No. 69849 Judith T. Romano, Es,y., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. F7ial:os, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wefts, Esq., Id. No. 309519 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esy., Id. No, 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq.. Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Matthew G. Brushwood, Esq., Id. No. 310592 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ',w ;j?,- F•";r• Sheriff i" T` ; PRO T �OI"'o rh s r,,- Jody I : S Smith _$ } . G Chief Deputy ''UMBERLAND C0UN Y Richard W Stewart §" ;, � ,; ;• Solicitor 0PFCF THES"ERIFF PENNSYLVANIA BAC Home Loans Servicing, LP Case Number vs. Christopher G. Delcampo 2010-6352 SHERIFF'S RETURN OF SERVICE 12/31/2012 04:30 PM -Deputy Gerald Worthington, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 395 Peiper Road, Shippensburg, PA 17257, Cumberland County. 02/21/2013 Affidavit of Service to Lienholders Filed in Sheriffs Office 03/07/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberlad County, on March 6, 2013 at 10:00 a.m. He sold the same for the sum of$ 1.00 to Attorney Francis Hallinan, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,022.87 SO ANSWERS, May 06, 2013 RON Y R ANDERSON, SHERIFF ' NK QF AMERICA, N.A. AS SUCCESSOR BY COURT OF COMMON PLEAS iRGER TO BAC HOME LOANS SERVICING, LP Plaintiff CIVIL DIVISION V. NO.: 10-6352-CIVIL TERM CHRISTOPHER G. DELCAMPO AX/A CHRISTOPHER G. DEL CAMPO CUMBERLAND COUNTY Defendant(s) PHS#252098 AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA,N.A.AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 395 PEIPER ROAD,SHIPPENSBURG,PA 17257-9425. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained,please so indicate) CHRISTOPHER G.DELCAMPO 395 PEIPER RD A/K/A CHRISTOPHER G.DEL CAMPO C/O SHIPPENSBURG,PA 17257-9425 KAREN SPERLING GREENE,CO-GUARDIAN AND CARL DELCAMPO JR.,CO-GUARDIAN CHRISTOPHER G.DELCAMPO 103 HILLSIDE AVE A/K/A CHRISTOPHER G.DEL CAMPO C/O TENAFLY,NJ 07670-2113 KAREN SPERLING GREENE,CO-GUARDIAN AND CARL DELCAMPO JR.,CO-GUARDIAN 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) CARL DEL CAMPO 10 LT.WHEELER CT BLAUVELT,NY 10913-1244 CARL DEL CAMPO 460 BERGEN BLVD C/O MARTIN BURGER SUITE 203 PALISADES PARK,NJ 07650 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) BOARD OF SUPERVISORS, 200 AIRPORT ROAD SOUTHAMPTON TOWNSHIP SHIPPENSBURG,PA 17257 w` SOUTHAMPTON TOWNSHIP 126 EAST KING STREET C/O RICHARD L.WEBBER,JR.,ESQUIRE SHIPPENSBURG,PA 17257-1397 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(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 395 PEIPER ROAD SHIPPENSBURG,PA 17257-9425 COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR,STRAWBERRY SQ. BUREAU OF INDIVIDUAL TAXES DEPT 280601 INHERITANCE TAX DIVISION HARRISBURG,PA 17128 DEPARTMENT OF PUBLIC WELFARE,TPL P.O.BOX 8486 CASUALTY UNIT,ESTATE RECOVERY WILLOW OAK BUILDING PROGRAM HARRISBURG,PA 17105 CHRISTOPHER G.DELCAMPO A/K/A 103 HILLSIDE AVE CHRISTOPHER G.DEL CAMPO C/O CARL TENAFLY,NJ 07670 DELCAMPO,JR,GUARDIAN CHRISTOPHER G.DELCAMPO,A/K/A 103 HILLSIDE AVE CHRISTOPHER G. DEL CAMPO C/O KAREN TENAFLY,NJ 07670 SPERLING GREENE,GUARDIAN DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and c to the best of my personal knowledge or information and belief. I understand that false st to nts her 'n a made subject to the penalties of 18 Pa. C.S.A. § 49 relating to unsworn falsification to au ities. Date: 'D By Phelan Ha an & Schmieg,LLP Robert W. Cusick, Esq., Id.No.80193 Attorney for Plaintiff ` BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS BAC HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: 10-6352-CIVIL TERM VS. CHRISTOPHER G. DELCAMPO CUMBERLAND COUNTY A/K/A CHRISTOPHER G. DEL CAMPO . Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CHRISTOPHER G. DELCAMPO CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G. DEL CAMPO A/K/A CHRISTOPHER G. DEL CAMPO C/O KAREN SPERLING GREENE, CO- C/O KAREN SPERLING GREENE, GUARDIAN AND CARL DELCAMPO JR., CO-GUARDIAN AND CARL DELCAMPO JR., CO-GUARDIAN CO-GUARDIAN 395 PEIPER ROAD 103 HILLSIDE AVENUE SHIPPENSBURG,PA 17257-9425 TENAFLY, NJ 07670-2113 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house(real estate)at 395 PEIPER ROAD,SHIPPENSBURG,PA 17257-9425 is scheduled to be sold at the Sheriff s Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$158,078.07 obtained by BANK OF AMERICA, N.A.AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP(the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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 215-563-7000. 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10) days after the filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain real estate lying and being situate in Southampton Township,Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at an iron pin at line of lands now or formerly of AI-Hart Inc.,thence along lands now or formerly of Al-Hart Inc.,North 65 degrees 53 minutes 31 seconds West,607.52 feet to an iron pin at line right of way of United States Route Number 81;thence along the right of way of United States Route Number 81,North 43 degrees 49 minutes 28 seconds East,221.49 feet to an iron pin;thence along same, North 43 degrees 49 minutes 28 seconds East, 883.97 feet to an iron pin;thence South 46 degrees 10 minutes 32 seconds East,35.09 feet to an iron pin in Peiper Road(Township Route T-301);thence in Peiper Road, (Township Route T-301), South 10 degrees 30 minutes 59 seconds West,716.30 feet to a railroad spike; thence continuing in said road, South 24 degrees 6 minutes 29 seconds West, 124.07 feet to an existing railroad spike;thence in the same, South 24 degrees 6 minutes 29 seconds West,299.98 feet to the place of BEGINNING. CONTAINING 9.11 acres,more or less,according to the draft of survey of Carl D.Bert,P.L.S.,dated June 17, 1995 and being Tract Nos. I &2 thereon. TITLE TO SAID PREMISES VESTED IN Christopher G. Del Campo, by Deed from Crea L.Koser, single woman,dated 04/14/2000,recorded 04/19/2000 in Book 219,Page 658. PREMISES BEING:395 PEIPER ROAD,SHIPPENSBURG,PA 17257-9425 PARCEL NO.39-14-0171-006 5 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-6352-CIVIL TERM BANK OF AMERICA,N.A.AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP VS. CHRISTOPHER G. DELCAMPO AIKIA CHRISTOPHER G. DEL CAMPO owner(s) of property situate in the SOUTHAMPTON TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 395 PEIPER ROAD, SHIPPENSBURG,PA 17257-9425 Parcel No.39-14-0171-006 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $158,078.07 Phelan Hallinan&Schmieg,LLP Attorney for Plaintiff 1617 JFK Boulevard,Suite 1400 Philadelphia,PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-6352 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA,N.A. AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP Plaintiff(s) From CHRISTOPHER G. DELCAMPO A/K/A CHRISTOPHER G.DEL CAMPO (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 GARNISHEES)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: $158,078.07 L.L.: $.50 Interest FROM 9/7/2012 TO DATE OF SALE($26.35 PER DIEM)-$4,769.35 Atty's Comm: % Due Prothy: $2.25 Atty Paid: 388.00 Other Costs: Plaintiff Paid: Date: 10/11/12 Dav' Buell,Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: ROBERT W. CUSICK,ESQUIRE Address: PHELAN HALLINAN&SCHMIEG, LLP 1617 JFK BLVD,SUITE 1400 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF TRUE COPY FROM RECORD Telephone: 215-563-7000 In Testimony whereof,(here unto set my hand and the seal of said Court at C rlisle,Pam Supreme Court ID No. 80193 This d,y of rothonotary r� On October 19, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA, Known and numbered as, 395 Peiper Road, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 19, 2012 By: f Real Estate Coordinator hZ8d Z1l,301161 CUMBERLAND LAW JOURNAL Writ No. 2010-6352 Civil PREMISES BEING: 395 PEIPER ROAD, SHIPPENSBURG,PA 17257- BAC Home Loans Servicing,LP 9425. vs. PARCEL NO. 39-14-0171-006. Christopher G. DelCampo Atty.: Francis Hallinan ALL that certain real estate lying and being situate in Southampton Township, Cumberland County, Pennsylvania, bounded and de- scribed as follows: BEGINNING at an iron pin at line of lands now or formerly of AI- Hart Inc., thence along lands now or formerly of AI-Hart Inc.,North 65 degrees 53 minutes 31 seconds West, 607.52 feet to an iron pin at line right of way of United States Route Number 81;thence along the right of way of United States Route Number 81,North 43 degrees 49 minutes 28 seconds East,221.49 feet to an iron pin; thence along same, North 43 degrees 49 minutes 28 seconds East, 883.97 feet to an iron pin; thence South 46 degrees 10 minutes 32 seconds East, 35.09 feet to an iron pin in Peiper Road(Township Route T-301);thence in Peiper Road,(Town- ship Route T-301),South 10 degrees 30 minutes 59 seconds West,716.30 feet to a railroad spike; thence continuing in said road, South 24 degrees 6 minutes 29 sec- onds West, 124.07 feet to an existing railroad spike; thence in the same, South 24 degrees 6 minutes 29 sec- onds West, 299.98 feet to the place of BEGINNING. CONTAINING 9.11 acres,more or less,according to the draft of survey of Carl D. Bert, P.L.S., dated June 17, 1995 and being Tract Nos. I & 2 thereon. TITLE TO SAID PREMISES VEST- ED IN Christopher G. DelCampo, by Deed from Crea L. Koser, single woman,dated 04/14/2000,recorded 04/19/2000 in Book 219,Page 658. 39 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1, and February 8, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. L1,11sa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 8 da of Feb ruai 2013 Notary NOFARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 1 The Patriot-News Co. 2020 Technology Pkwy the atr1*otwXews Suite 300 II'i Mechanicsburg, PA 17050 NOW you know �I Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17313 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS i Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkvvy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 20W4M2 CMI 01/22/13 Home Loans SorvIN LP Vs 01/29/13 Chrlstaplwr G.Dslcem c Atty.FranNs waNlnan _ 02/05/13 ALL that certain teal estate lying and being situate in Southampton 'Iba=WP, . . . . . . . . . . . . . . . . . . . . . . . . . . . . Cumberland County, Pennsylvania, bounded and described as follows: now or formerly ofron pin atI c.,of Sworn to and subscribed before m this 14 day of February, 2013 A.D. now or formerly of AI-Hart-Inc., thence Y rY, along lands now or formerly of AI-Hatt Inc., North 65 degrees 53 minutes 31 seconds West,607.52 feet to an iron pin at line right of way of United States Route Number 81; u b I I C —1P thence along the right of way of United States Route Number 81,North 43 degrees 49 minutes 28 seconds East,221.49 feet to an iron pin;thence along same,North 43 degrees 49 minutes 28 seconds East,883.97 COMMONWEALTH OF PENNSYLVANIA feet to an iron pin;thence South 46 degrees Notarial Seal 10 minutes 32 seconds East,35.09 feet to an Holly Lynn Warfel,Notary Public iron pin in Peiper Road(Township Route Washington Twp.,Dauphin County T301);thence in Pe' r Road,(Ibwnslup My Commission Explres Dec.12,2016 Route T-301),South 10 d*to-36nkutes MEMBER.PENNSYLVANIA ASSOCtAfION OF NOTARIES 59 seconds West,716.30 feet to a railroad spike;thence continuing in said road,South 24 degrees-6 minutes 29 seconds West, 124.07 feet to an existing railroad spire; thence in the same,yoatL 24 gees 6 minutes 29 seconds West,299-98 feet to the place of BEGINNING. CONTAINING 9.11 acres, more or less, according to the draft of survey of Carl D. Bert,P.L.S.,dated June 17,1995 and being Tract Nos.I&2 thereon. TITLE TO SAID PREMISES VESTED IN Cbristopher G. DelCampo, by Deed from Crea L.Koser,single woman,dated 04114/2000, recorded 04/19/2000 in Book 219,Page 658. PREMISES BEING:395 PEIPER ROAD, SHIPPENSBURG,PA 17257-9425 PARCEL NO.39-14-0171-006 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler,Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 6th day of March A.D., 2013,under and by virtue of a writ Execution issued on the 11th day of October, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6352, at the suit of Bank of America N.A. against Christopher G. Delcampo a/k/a Christopher G. Del Campo is duly recorded as Instrument Number 201315018. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this �. day of ,A.D.(;22� 1 '<jX'Ua- Recorder of Deeds of Cambertand County,Cartisie,PA tmyommiss' Expires the Fast Monday of Jan.2014 Phelan Hallinan,LLP Attorney For Plaii _ F-1 1617 JFK Boulevard,Suite 1400 �M One Penn Center Plaza W r-"' ry f C Philadelphia,PA 19103 C� 215-563-7000 ca -n ra BANK OF AMERICA, N.A. AS SUCCESSOR BY Court of Common Pleiw—,---' dr MERGER TO BAC HOME LOAN_S SERVICING, -° LP Civil Division Plaintiff CUMBERLAND County vs No. 10-6352-CIVIL TERM CHRISTOPHER G.DELCAMPO A/K/A CHRISTOPHER G.DEL CAMPO k Defendant PRAECIPE TO THE PROTHONOTARY: ❑Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ❑Please mark the above referenced case Settled,Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ® Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑Please Vacate the Judgment entered. Date: PHE N LLP By: J n Michael Kolesnik,Esq.,Id.No.308877 Attorney for Plaintiff PHS#252098 01.5 PD ATTY a9ogoy Phelan Hallinan,LLP Attorney for Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA,N.A. AS SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff Civil Division V. CUMBERLAND County CHRISTOPHER G.DELCAMPO No. 10-6352-CIVIL TERM A/K/A CHRISTOPHER G. DEL CAMPO Defendant PHS#252098 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: CHRISTOPHER G.DELCAMPO A/K/A CHRISTOPHER G.DEL CAMPO 395 PEIPER RD C/O KAREN SPERLING GREENE, GUARDIAN SHIPPENSBURG,PA 17257-9425 Date: �- PHELA LIN LLP By: Jo is ael Kolesnik,Esq.,Id.No.308877 Attorney for Plaintiff