HomeMy WebLinkAbout10-7298Phelan Hallinan &Schmieg, LLP
Lawrence T. Phelan, Esq., Id. No. 32227 ~4~~~_O~~fC~
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205 ~~ ~~~ Pf~OTH~J~dO~t'~2'{
Michele M. Bradford, Esq., Id. No. 69849 2~!(~ ~~~( 22 f~~ ~~ 32
Judith T. Romano, Esq., Id. No. 58745
Sheetal R. Shah-Jani, Esq., Id. No. 81760 ~~~B~~I.Q~~ {/Q~~~`;~
Jenine R. Davey, Esq., Id. No. 87077 PE~NSYLVAE~IA
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
Allison F. Wells, Esq., Id. No. 309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000 252886
BAC HOME LOANS SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
Plaintiff
v.
ROGER T. RUSE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
Defendant
File #: 252886
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. Io'~~
CUMBERLAND COUNTY
-~ a~
~~
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 #: 252886
1. Plaintiff is
BAC HOME LOANS SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
2. The name(s) and last known address(es) of the Defendant(s) are:
ROGER T. RUSE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 04/24/2007 ROGER T. RUSE and ANGELA P. RUSE made, executed and delivered
a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR
COUNTRYWIDE BANK, FSB which mortgage is recorded in the Office of the Recorder
of CUMBERLAND County, in Mortgage Book No. 1991, Page 997. 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 11 /01 /2008 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 #: 252886
6.
The following amounts are due on the mortgage:
Principal Balance
Interest
10/01 /2008 through 11 / 16/2010
(Per Diem $19.4559)
Attorney's Fees
Late Charges through 11/16/2010
Costs of Suit and Title Search
Escrow Deficit
Subtotal
Suspense Credit
TOTAL
7.
8
9
$114,353.41
$15,117.23
$650.00
$816.04
$550.00
$4,05. 9.2~
$135,545.91
f 151 _RRl
$135,394.03
Plaintiff is nat seeking a judgment of personal liability (or an in pers~nam 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.
This action does not come under Act 91 of 1983 because the mortgage is more than
twenty-four (24) months in arrears.
File #: 252886
10. Plaintiff hereby releases ANGELA P. RUSE, from liability for the debt secured by the
mortgage.
WHEREFORE, Plaintiff demands an in r~.m judgment against the Defendant(s) in the sum of
$135,394.03, together with interest from 11/16/2010 at the rate of $19.4559 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.
P AN HALLI AN & MIEG, LLP
By:
^ Lawrence T. Phelan, sq., Id. No. 32227
^ F ancis S. Hallinan, Esq., Id. No. 62695
^ aniel 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
^ Allison F. Wells, Esq., Id. No. 309519
Attorneys for Plaintiff
File #: 252886
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the Borough of
New Cumberland in the County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the northerly line of Sherwood Road, 338.58 feet measured southwestwardly
along Sherwood Road from the northwest corner of Sherwood Road and Brandt Avenue; thence
northwestwardly along the westerly line of Lot No. 28, Block'A' on the hereinafter mentioned plan
135.03 feet to a point on line of lands now or formerly of Don Hench; thence by same southwestwardly
60 feet to a point; thence along the easterly line of Lot No. 26, Block 'A' southeastwardly 135.27 feet to a
point on the northerly line of Sherwood Road; thence along Sherwood Road northeastwardly 21.65 feet
to a point; thence along Sherwood Road by a curve to the left having a radius of 25 feet an arc distance of
14.08 feet to a point; thence continuing northeastwardly along Sherwood Road 26.35 feet to a point, the
place of Beginning.
BEING Lot No.27 Block 'A' on the Plan of Lots of Highland Park Extension which plan is recorded in
the Cumberland County Recorder's Office in Plan Book 5, Page 59.
PROPERTY ADDRESS: 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-
1449
PARCEL # 26-23-0543-196
File #: 252886
.•
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.
n ttorney for P ai tiff
DATE: ~ ~ w
File #: 252886
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
BAC Home Loans Servicing, LP
vs.
Roger T. Ruse
d
FILED-OFFICE
OF THE PROTHONOTAR
20 10 DEC 10 PM I*- ? 4
CUMBERLAND COUNTY
PENNSYLVANIA
Case Number
2010-7298
SHERIFF'S RETURN OF SERVICE
12/03/2010 05:17 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December
3, 2010 at 1717 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Roger T. Ruse, by making known unto himself personally, at 711
Sherwood Road, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the
same time handing to him personally the said true and correct copy of the same.
RYAN BURGETT, D
SHERIFF COST: $43.30
December 08, 2010
SO ANSWERS,
RON r R ANDERSON, SHERIFF
r,! CcAm*vSua, She; +f, To. ec:so't Inc.
ED-OFFICF
PR iH
PHELAN HALLINAN & SCHMIEG, LLP'W'Y § ROTNONOTAAttorney for Plaintiff
Melissa Scheiner, Esq., Id. No.308912 n 0 A.UG 23 APB 10 3g
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza CUMBERLAND COUNTY
Philadelphia, PA 19103 PENNSYLVANIA
215-563-7000
BAC HOME LOANS SERVICING, L.P.
VS.
ROGER T. RUSE
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 2010-7298
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 ROGER T. RUSE,
Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff s damages as
follows:
As set forth in Complaint $135,394.03
Interest - 11/17/2010 to 08/19/2011
$5,369.83
TOTAL $140,763.86
I hereby certify that (1) the Defendant's last known address is 711 SHERWOOD ROAD,
NEW CUMBERLAND, PA 17070-1449, and (2) that notice has been g' en in accordance with
Rule Pa.R.C.P 237.1.
Date
Melissa Scheiner, Es uire am *14 obPdo?
Attorney for Plaintiff
CIS I+ l 161143
DAMAGES ARE HEREBY ASSESSED AS INDICATE.??93V1$
DATE: MQ?+
? C
PHS # 252886 252886
PHELAN HALLINAN & SCHMIEG, LLP
Melissa Scheiner, Esq., Id. No.308912
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney for :Plaintiff
BAC HOME LOANS SERVICING, L.P.
VS.
ROGER T. RUSE
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 2010-7298
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 it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief
Act of Congress of 1940, as amended.
(b) that defendant ROGER T. RUSE is over 18 years of age and resides at 711
SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
Date dlaw ?/ __/
Melissa cheiner, Esquire
Attorney for Plaintiff
252886
(Rule of Civil Procedure No. 236) - Revised
BAC HOME LOANS SERVICING, L.P. CUMBERLAND COUNTY
VS. COURT OF COMMON PLEAS
ROGER T. RUSE
CIVIL DIVISION
No. 2010-7298
Notice is given that a Judgment in the above captioned matter has been entered
against you on By:
If you have any questions concerning this matter please contact:
Melissa Scheiner, 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
ONLYENFORCEMENT OFA LIEN AGAINST PROPERTY. **
BAC HOME LOANS SERVICING, L.P. COURT OF COMMON PLEAS
CIVIL DIVISON
V.
ROGER T. RUSE
Plaintiff
Defendant(s)
TO: ROGER T. RUSE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
DATE OF NOTICE: August 8, 2011
NO. 2010-7298
CUMBERLAND COUNTY
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.
HVIPORTANT 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 # 252886
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
PHS # 252886
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
AA141 'A
By:
is e e . rad o
Attorney for Plaintiff
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO10-7298 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, L.P. Plaintiff (s)
From ROGER T. RUSE
(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: $140,763.86 L. L.: - >. $o
Interest from 8/22/2011 to Date of Sale ($23.46 per diem) -04,'75. t.
Atty's Comm: % Due Prothy: $2.00
Arty Paid: $175.80
Plaintiff Paid:
Date: 12/V2611
Other Costs:
1
avid D. Buell, Proth notary
By:
(Seal)
Deputy
REQUESTING PARTY:
Name: DANIEL G. SCHMIEG, ESQUIRE
Address: PHELAN HALLINAN & SCHMIEG, LLP
1617 HK BOULEVARD, SUITE 1400
ONE PENN CENTER PLAZA
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC COURT OF COMMON PLEAS
HOME LOANS SERVICING, LP
Plaintiff CIVIL DIVISION
v
ROGER T. RUSE
Defendant(s)
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due
Interest from 08/22/2011 to Date of Sale
($23.46 per diem)
TOTAL
Note: Please attach description of property.
PHS # 252886
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NO.: 2010-7298
CUMBERLAND COUNTY
$140,763.86
$4,715.46
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$145,479.32 -- -'
Phelan Hallinan & Sch 'eg, LLP
Daniel G. Schmieg, Esq., Id. No.62205
Attorney for Plaintiff
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LEGAL, DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of New Cumberland in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the northerly line of Sherwood Road, 338.58 feet measured
southwestwardly along Sherwood Road from the northwest corner of Sherwood Road and Brandt
Avenue; thence northwestwardty along the westerly line of Lot No. 28, Block 'A' on the
hereinafter mentioned plan 13 5.03 feet to a point on line of lands now or formerly of Don Hench;
thence by same southwestwardly 60 feet to a point; thence along the easterly line of Lot No. 26,
Block 'A' southeastwardly 135.27 feet to a point on the northerly line of Sherwood Road; thence
along Sherwood Road northeastwardly 21.65 feet to a point; thence along Sherwood Road by a
curve to the left having a radius of 25 feet an are distance of 14.08 feet to a point; thence
continuing northeastwardly along Sherwood Road 26.35 feet to a point, the place of Beginning.
BEING Lot No.27 Block'A' on the Plan of Lots of Highland Park Extension which plan is
recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 59.
TITLE TO SAID PREMISES IS VESTED IN Roger T. Ruse, husband, by Deed from Roger T.
Ruse and Angcla P. Ruse, h/w, dated 05/22/2009, recorded 05/26/2009 in Instrument Number
200917224.
PREMISES BEING: 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449
PARCEL NO. 26-23-0543-196
PHELAN HALLINAN & SCHMIEG, LLP
Daniel G. Schmieg, Esq., Id. No.62205
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza i`f? 1 i
Philadelphia, PA 19103 .
215-563-7000
BANK OF AMERICA, N.A. AS SUCCESSOR i
Mft
BAC HOME LOANS SERVICING, LP
Plaintiff
v
ROGER T. RUSE
Defendant(s)
CERTIFICATION
Attorneys for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.: 2010-7298
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
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
BY'? --
Phelan Hal man & Schmieg, LLP -
Daniel G. Schmieg, Esq., Id. No.62205
Attorney for Plaintiff
BANK O+'AMERICA, N.A. AS SUCCESSOR BY COURT OF COMMON PLEAS
MER ER TO BAC HOME LOANS SERVICING, LP
Plaintiff CIVIL DIVISION
v. y t rT,.e ??; f'qO.• 2010-7298
ROGER T. RUSE
Defendant(s) f
CUMBERLAND COUNTY
PHS # 252886
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 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Address (if address cannot be reasonably ascertained, please so indicate)
ROGER T. RUSE
2. Name and address of Defendant(s) in the judgment:
Name
SAME AS ABOVE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
Address (if address cannot be reasonably ascertained, please so indicate)
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 so 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)
MERS AS A NOMINEE FOR COUNTRYWIDE P.O. BOX 2026
BANK, FSB FLINT, MI 48501-2026
COUNTRYWIDE BANK, FSB 1199 N FAIRFAX ST STE 500
ALEXANDRIA, VA 22314-1453
COUNTRYWIDE BANK, FSB 6100 OAKTREE BLVD., STE #310
C/O COUNTRYWIDE HOME LOANS, INC. INDEPENDENCE, OH 44131
ATTN: LAURA FINLEY
COUNTRYWIDE BANK, FSB SERVICELINK DIVISION
C/O CHICAGO TITLE 4000 INDUSTRIAL BLVD
ALIQUIPPA, PA 15001
HERS, INC. FORMALLY 3300 CSNN' 34TH AVENUE, OCAI,A, FL 34471
AS OF 12/6/10 1901 E. VORHEESE ST, SUITE C
DANVILLE, IL 61834
5.
0
Name and address of every other person who has any record lien on the property:
itlame Address (if address cannot be reasonably ascertained, please indicate)
None.
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
None.
Address (if address cannot be reasonably ascertained, please so indicate)
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 so indicate)
TENANT/OCCUPANT
ANGELA P. RUSE
BANK OF AMERICA, N.A.
MERS AS NOMINEE FOR BANK OF
AMERICA, N.A.
Domestic Relations of
Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Internal Revenue Service Advisory
U.S. Department of Justice
U.S. Attorney for the Middle District of PA
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
136 PARTRIDGE CIRCLE
CARLISLE, PA 17013
1800 TAPO CANYON ROAD
MAIL ID #CA6-914-01-43
SIMI VALLEY, CA 93063
P.O. BOX 2026
FLINT, MI 48501
13 North Hanover Street
Carlisle, PA 17013
P.O. Box 2675
Harrisburg, PA 17105
1000 Liberty Avenue Room 704
Pittsburgh, PA 15222
Federal Building, P.O. Box 11754
228 Walnut Street
Harrisburg, PA 17108
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 he bject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authoritie
Date: - O ° t By:
Phelan allinan & Schmieg, LLP
Daniel G. Schmieg, Esq., Id. No.62205
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.: 2010-7298
VS.
ROGER T. RUSE CUMBERLAND 7 UN-TY
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY rT
TO: ROGER T. RUSE
711 SHERWOOD ROAD =
NEW CUMBERLAND, PA 17070-1449
"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 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449 is
scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse,
South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $140,763.86 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 Sheriff s 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling? 15-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to tAe 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
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. 2010-7298
BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME
LOANS SERVICING, LP
vs.
ROGER T. RUSE
owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland
County, Pennsylvania, being
(Municipality)
711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449
Parcel No. 26-23-0543-196
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMENT AMOUNT: $140,763.86
Phelan Hallinan & Schmieg, LLP
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
215-563-7000
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000 Attorney For Plaintiff
BAC HOME LOANS SERVICING, Court of Common Pleas
L.P.
Plaintiff Civil Division
vs CUMBERLAND County
ROGER T. RUSE
No. 2010-7298 C-j
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ENTRY OF APPEARANCE <CD
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TO THE PROTHONOTA RY: -?-1 w
Kindly enter my appearance on behalf of Bank of America, N.A., ash ?°
successor by merger to BAC Home Loans Servicing, LP.
Date: October 11, 2011
By:
N CHMIEG, LLP
Attorneys for Plai tiff
Printed Name:
Bar Id. No.
PHS# 252886 Attorneys for Plaintiff
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400 Attorney For Plaintiff
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
BAC HOME LOANS SERVICING, Court of Common Pleas
L.P.
Plaintiff Civil Division
vs CUMBERLAND County .II3
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ROGER T. RUSE No. 2010-7298 z?
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Defendant ..<D
PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF
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PURSUANT TO Pa.R.C.P., 2352 ?C--
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TO THE PROTHONOTARY: -C
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 docket
Date: October 11, 2011
AN &c SCHMIEG, LLP
Attorneys for Plain 'f
Printed Name: I 1A
Bar Id. No.
PHS# 252886 Attorneys for Plaintiff
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Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney For Plaintiff
BAC HOME LOANS SERVICING,
L.P.
Plaintiff
VS
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PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF <
> o °I
r
ENTRY OF APPEARANCEQ ?
TO THE PROTHONOTARY: t? C-5?
Please mark the judgment in the above-captioned matter to the use of Bank of
America, N.A., as successor by merger to BAC Home Loans Servicing, LP, located
7105 Corporate Drive, Plano, TX 75024. _
Court of Common Pleas
Civil Division
CUMBERLAND County
Date: October 11, 2011
PHELAN,ALLINAN & SCHMIEG, LLP
Attorneys or Pl of
Printed Name: 74
Bar Id. No.
PHS# 252886 Attorneys for Plaintiff
PHELAN HALLINAN & SCHMIEG, LLP
One Penn Center at Suburban Station ATTORNEY FOR PLAINTIFF
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
BAC HOME LOANS SERVICING, L.P.
COURT OF COMMON PLEAS
Plaintiff
V. CIVIL DIVISION
ROGER T. RUSE NO. 2010-7298
Defendant CUMBERLAND COUNTY
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe to
mark judgment to Bank of America, N.A., as successor by merger to BAC Home
Loans Servicing, LP and substitution of party plaintiff was served by regular mail to the
person(s) on the date listed below:
ROGER T. RUSE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
Date: B
LINA & seifMIEG, LLP
-Y-f4
Attorneys for Plainti
Printed Name:
Bar Id. No.
PHS# 252886 Attorneys for Plaintiff
F11 E -01 i'';;
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GUMBERLANO'OUNTY
PENNS i'LVA.iIA
IN THE COURT OF COMMON PLEAS OF 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
V.
ROGER T. RUSE
No.: 2010-7298
Defendant
RULE
AND NOW, this day of '1n O1a a Rule is entered upon the Defendant
to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess
Damages.
Defendant shall have twenty (20) days from the date of this Order to file a response to
Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY T COURT
J.
252886
Robert W. Cusick, Esq., Id. No.80193
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
TEL: (215) 563-7000
FAX: (215) 563-3459
/ ROGER T. RUSE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
&&,6 mailed 11414
elddl
9,57996
252886
iNE PROTHONOTARI
7012 ,JAN 11 AM 9: 51
CUMBERLAYLVANUA T`l
PENN
Phelan Hallinan & Schmieg, LLP
Sheetal R. Shah-Jani, Esq., Id. No.81760
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.
ROGER T. RUSE
Defendant
No.: 2010-7298
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's January 5, 2012 Rule directing
the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be
granted was served upon the following individual on the date indicated below.
ROGER T. RUSE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
DATE: I b ' Z
Phelan nan & h eg, LLP
By:
Sheeta R. Shah-Jani, E u'
Attorney for Plaintiff
252886
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BANK OF AMERICA, N.A. AS SUCCESSOR BY
MERGER TO BAC HOME LOANS SERVICING,
LP
Plaintiff
vs.
ROGER T. RUSE
Defendant
CIVIL DIVISION
NO. 2010-7298
ORDER
s?
AND NOW, this day of , 2012, after
consideration of Plaintiff's Motion for Service of Notice of Sale Pursuant to Special Order of
Court, it is hereby:
ORDERED that pursuant to Pa. R.C.P. 430(a), service of the Notice of Sale is
permitted on Defendant ROGER T. RUSE by:
_ REGULAR MAIL TO, ROGER T. RUSE at, 711 SHERWOOD
ROAD, NEW CUMBERLAND, PA 17070-1449
CERTIFIED MAIL TO, ROGER T. RUSE at, 711 SHERWOOD
ROAD, NEW CUMBERLAND, PA 17070-1449
r/ POSTING 711 SHERWOOD ROAD, NEW CUMBERLAND, PA
17070-1449
PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH
PA.R.C.P. 3129.2 (D).
BTU
J.
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PHS # 252886
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CC PHELAN HALLINAN & SCHMIEG r
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1617 JFK Boulevard, Suite 1400
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Philadelphia, PA 19103
Copy ma-led Rg/1
ROGER T
RUSE
.
711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449 -
?:
IN THE COURT OF COMMON PLEAS t '3
+J,
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.: 2010-7298
ROGER T. RUSE
Defendant
ORDER
AND NOW, this 7 day of? ' 2012, upon consideration of Plaintiff's
Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered
upon Defendant shall be and is hereby made absolute and Plaintiff's Motion to Reassess
Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED
to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows:
Principal Balance
Interest Through March 7, 2012
Per Diem $19.19
Late Charges
Legal fees
Cost of Suit and Title
Property Inspections
Suspense/Misc. Credits
Escrow Deficit
TOTAL
'!v:9 `d L-3JZIti ?
Plus interest from March 7, 2012 through the date of sale at six percent per annum.
Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above
figure.
?/ Me L'SS« -?' (an4,,oell, t.-?
4x s e
lepes rp.a.1e-d j
gg 1
$114,353.41
$24,045.70
$816.04
$1,325.00
$788.00
$560.00
($151.88)
$6,363.47
$148,099.74
B HE COURT:
252886
PHELAN HALLINAN & SCHMIEG, LLP
Melissa J. Cantwell, Esq., Id. No.308912
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney for Plaint?f
J, T,
At?
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2
o C
cE;L AQ COUNTY
c?w?lSYLVANIA
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
BANK OF AMERICA, N.A. AS SUCCESSOR BY
MERGER TO BAC HOME LOANS SERVICING,
LP
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
V.
ROGER T. RUSE
Defendant(s)
No.: 2010-7298
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of
the persons or parties named, at that address, set forth on the Affidavit and as amended if
applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return
Receipt stamped by the U.S. Postal Service is attached hketo Exhibit "A".
Melissa J. Cantwe , Esquire
Attorney for Plaintiff
Date:
IMPORTAN NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PHS # 252886
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BANK OF AMERICA, N.A. AS SUCCESSOR BY
MERGER TO BAC HOME LOANS SERVICING, LP
Plaintiff
V.
ROGER T. RUSE
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.: 2010-7298
CUMBERLAND COUNTY
PHS # 252886
AMENDED 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 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449.
Name and address of Owner(s) or reputed Owner(s):
Name Address (if address cannot be reasonably ascertained, please so indicate)
2.
3
ROGER T. RUSE
Name and address of Defendant(s) in the judgment:
Name
SAME AS ABOVE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
Address (if address cannot be reasonably ascertained, please so indicate)
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 so indicate)
New Cumberland Borough
New Cumberland Borough
C/o Andrew Charles Sheely, Esquire
4. Name and address of last recorded holder of every mortgage of record:
Name Address (if address cannot be reasonably ascertained, please indicate)
MERS AS A NOMINEE FOR COUNTRYWIDE P.O. BOX 2026
BANK, FSB FLINT, MI 48501-2026
COUNTRYWIDE BANK, FSB
1120 Market Street
P.O. Box 220
New Cumberland, PA 17070
127 S MARKET STREET
P.O. BOX 95
MECHANICSBURG, PA 17055
1199 N FAIRFAX ST STE 500
ALEXANDRIA, VA 22314-1453
COUNTRYWIDE BANK, FSB 6100 OAKTREE BLVD., STE #310
C/O COUNTRYWIDE HOME LOANS, INC. INDEPENDENCE, OH 44131
ATTN: LAURA FINLEY
COUNTRYWIDE BANK, FSB
C/O CHICAGO TITLE
SERVICELINK DIVISION
4000 INDUSTRIAL BLVD
ALIQUIPPA, PA 15001
MERS, INC. FORMALLY 3300 CSW 34TH AVENUE, OCALA, FL 34471
AS OF 12/6/10 1901 E. VORHEESE ST, SUITE C
DANVILLE, IL 61834
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)
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 (if address cannot be reasonably ascertained, please so 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 so indicate)
TENANT/OCCUPANT
ANGELA P. RUSE
BANK OF AMERICA, N.A.
MERS AS NOMINEE FOR BANK OF
AMERICA, N.A.
Domestic Relations of
Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Internal Revenue Service Advisory
U.S. Department of Justice
U.S. Attorney for the Middle District of PA
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
136 PARTRIDGE CIRCLE
CARLISLE, PA 17013
1800 TAPO CANYON ROAD
MAIL ID #CA6-914-01-43
SIMI VALLEY, CA 93063
P.O. BOX 2026
FLINT, MI 48501
13 North Hanover Street
Carlisle, PA 17013
P.O. Box 2675
Harrisburg, PA 17105
1000 Liberty Avenue Room 704
Pittsburgh, PA 15222
Federal Building, P.O. Box 11754
228 Walnut Street
Harrisburg, PA 17108
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.A. § 4904 relating to unsworn falsification to authorities.
'/ l C
Date: ? Bye
t elan Hallinan & Schmieg, LLP '--Melissa J. Cantwell, Esq., Id. No.308912
Attorney for Plaintiff
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, LP
Plaintiff
vs.
17 Ai; 9:
E ±! AND CCUI? y,
'i'"I N f S YLVA N I,)?
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 2010-7298
ROGER T. RUSE
Defendant
i
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P.R.C.P., 404(2)/403
I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above
captioned matter was sent by regular mail and certified mail, return receipt requested, to ROGER T.
RUSE on 2/15/2012 at 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449 in
accordance with the Order of Court dated 2/1/2012. The property was posted on 3/17/2012.
Publication was advertised in THE SENTINEL on 2/17/2012 & in CUMBERLAND LAW
JOURNAL on 2/24/2012.
The undersigned understands that this statement is made subject to the penalties of 18
Pa.C.S. §4904 relating to the unsworn falsification to authorities.
Phel H in & Schmieg, LLP
DATE: By: ?-
Matthew B wood, Esquire
Attorney Plaintiff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
,
Ronny R Anderson
Sheriff
is
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
BAC Home Loans Servicing, LP
vs.
Roger T. Ruse
e'I'i
Case Number
2010-7298
SHERIFF'S RETURN OF SERVICE
01/10/2012 04:37 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 711 Sherwood Road, New Cumberland, PA 17070, Cumberland County.
01/12/2012 05:27 PM - Deputy Ryan Burgett, being duly sworn according to law, attempted service to the Defendant,
to wit: Roger T. Ruse at 711 Sherwood Road, New Cumberland Borough, New Cumberland, PA 17070.
The address was found to be vacant.
02/09/2012 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/2/2012
02/21/2012 Affidavit of Service to Lien holders Filed in Sheriffs Office
05/02/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on May 2, 2012 at 1000 am.
He sold the same for the sum of $1.00 to Attorney Daniel Schmieg, on behalf of BAC Home Loans
Servicing, LP. BAC Home Loans Servicing, LP, being the buyer in this execution, paid to the Sheriff the
sum of $815.16.
SHERIFF COST: $815.17
June 05, 2012
SO ANSWERS,
RONtrY R ANDERSON, SHERIFF
sz0 t 'Pd.
4 ?;22 - W 5- ?i,? y'
Ap" z?6,y.;s'
5u:te lrG
BANK OF AMERICA, N.A..AS SUCCESSOR BY
MERGER TO BA,C HOME LOANS SERVICING, LP
Plaintiff 91
V.
ROGER T. RUSE
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.: 2010-7298
CUMBERLAND COUNTY
PHS # 252886
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 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449.
Name and address of Owner(s) or reputed Owner(s):
Name
Address (if address cannot be reasonably ascertained, please so iiiaicate)
ROGER T. RUSE
2. Name and address of Defendant(s) in the judgment:
Name
SAME AS ABOVE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
Address (if address cannot be reasonably ascertained, please so indicate)
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 so 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)
MERS AS A NOMINEE FOR COUNTRYWIDE P.O. BOX 2026
BANK, FSB FLINT, MI 48501-2026
COUNTRYWIDE BANK, FSB 1199 N FAIRFAX ST STE 500
ALEXANDRIA, VA 22314-1453
COUNTRYWIDE BANK, FSB 6100 OAKTREE BLVD., STE #310
C/O COUNTRYWIDE HOME LOANS, INC. INDEPENDENCE, OH 44131
ATTN: LAURA FINLEY
COUNTRYWIDE BANK, FSB SERVICELINK DIVISION
C/O CHICAGO TITLE. 4000 INDUSTRIAL BLVD
ALIQUIPPA, PA 15001
\9ERS, INC. FORMALLY 3300 CSW 34TH AVENUE, OCAL.X, FL 34471
AS OF 12/6/10 1901 E. VORHEESE ST, SUITE C
DANVILLE, IL 61834
4
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)
None.
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 so 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 so indicate)
TENANT/OCCUPANT 711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
ANGELA P. RUSE 136 PARTRIDGE CIRCLE
CARLISLE, PA 17013
BANK OF AMERICA, N.A. 1800 TAPO CANYON ROAD
MAIL ID #CA6-914-01-43
SIMI VALLEY, CA 93063
MERS AS NOMINEE FOR BANK OF P.O. BOX 2026
AMERICA, N.A. FLINT, MI 48501
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 Federal Building, P.O. Box 11754
U.S. Attorney for the Middle District of PA 228 Walnut Street
Harrisburg, PA 17108
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 he bject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsi fication to authoritie
Date: 1 O t t
By:
Phelan"Ialhnan & Schmieg, LLP
Daniel G. Schmieg, Esq., Id. No.62205
Attorney for Plaintiff
t13ANK OF AMkp-ICA; N.A. AS SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS
BAC HOME LOANS SERVICING, LP
CIVIL DIVISION
Plaintiff :
: NO.: 2010-7298
VS.
ROGER T. RUSE : CUMBERLAND COUNTY
Defendant(s) :
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: ROGER T. RUSE
711 SHERWOOD ROAD
NEW CUMBERLAND, PA 17070-1449
"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 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449 is
scheduled to be sold at the Sheriff's Sale on 03/07/2012 at 10:00 AM in the Cumberland County Courthouse,
South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $140,763.86 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.
You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
P 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
P
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. 2010-7298
BANK OF AMERICA, N.A. AS SUCCESSOR BY MERGER TO BAC HOME
LOANS SERVICING, LP
vs.
ROGER T. RUSE
owner(s) of property situate in the BOROUGH OF NEW CUMBERLAND, Cumberland
County, Pennsylvania, being
(Municipality)
711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449
Parcel No. 26-23-0543-196
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMENT AMOUNT: $140,763.86
Phelan Hallinan & Schmieg, LLP
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
215-563-7000
LEGAL DESCRIPTION
ALL THAT CERTAIN tract or Parcel of land and premises, situate, lying and being in the
Borough of New Cumberland in the County of Cumberland and Commonwealth of
Pennsylvania, more particularly described as follows:
BEGINNING at a point on the northerly line of Sherwood Road, 338.58 feet measured
southwestwardly along Sherwood Road from the northwest corner of Sherwood Road and Brandt
Avenue; thence northwestwardly along the westerly line of Lot No. 28, Block'A' on the
hereinafter mentioned plan 135.03 feet to a point on line of lands now or formerly of Don Hench;
thence by same southwestwardly 60 feet to a point; thence along the easterly line of Lot No. 26,
Block 'A' southeastwardly 135.27 feet to a point on the northerly line of Sherwood Road; thence
along Sherwood Road northeastwardly 21.65 feet to a point; thence along Sherwood Road by a
curve to the left having a radius of 25 feet an arc distance of 14.08 feet to a point; thence
continuing northeastwardly along Sherwood Road 26.35 feet to a point, the place of Beginning.
BEING Lot No.27 Block'A' on the Plan of Lots of Highland Park Extension which plan is
recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 59.
TITLE TO SAID PREMISES IS VESTED IN Roger T. Ruse, husband, by Deed from Roger T.
Ruse and Angela P. Ruse, h/w, dated 05/22/2009, recorded 05/26/2009 in Instrument Number
200917224.
PREMISES BEING: 711 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070-1449
PARCEL NO. 26-23-0543-196
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF'CUMBERLAND)
NO10-7298 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, L.P. Plaintiff (s)
From ROGER T. RUSE
(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: $140,763.86 L.L.:
Interest from 8/22/2011 to Date of Sale ($23.46 per diem) 71S. All,
Atty's Comm: % Due Prothy: $2.00
Atty Paid: $175.80
Plaintiff Paid:
Date: 12/1/2011
Other Costs:
(Seal)
REQUESTING PARTY:
Name: DANIEL G. SCHMIEG, ESQUIRE
Address: PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK BOULEVARD, SUITE 1400
ONE PENN CENTER PLAZA
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
-? FULy
TRUE COPY FROM RECORD
In Testiriony Whereof, I here unto set my hand
and the seal of said Court at Carlisle, Pa.
This day of 20
Prothon ry
On December 19, 2011 the Sheriff levied upon the
defendant's interest in the real property situated in
New Cumberland Borough, Cumberland County, PA,
Known and numbered as, 711 Sherwood Road,
New Cumberland, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date December 19, 2011
By:
Re Estate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2010-7298 Civil Term
Bank of America, N.A. As
Successor by Merger to BAC
Home Loans Servicing, LP
vs.
Roger T. Ruse
Atty.: Daniel Schmieg
By virtue of a Writ of Execution
NO. 2010-7298, BANK OF AMERICA,
N.A. AS SUCCESSOR BY MERGER
TO BAC HOME LOANS SERVICING,
LP vs. ROGER T. RUSE owner(s) of
property situate in the BOROUGH OF
NEW CUMBERLAND, Cumberland
County, Pennsylvania, being 711
SHERWOOD ROAD, NEW CUMBER-
LAND, PA 17070-1449.
Parcel No. 26-23-0543-196.
Improvements thereon: RESIDEN-
TIAL DWELLING.
JUDGMENT AMOUNT: $140,-
763.86.
66
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 27, February 3, and February 10, 2012
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.
Marie Coyne,
SWORN TO AND SUBSCRIBED before me this
_ 10 day of Februa 2012
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
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 Home Loan Mortgage Coro is the grantee the same having been
sold to said grantee on the 2 day of May A.D., 2012, under and by virtue of a writ Execution issued on
the 1 day of December, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term,
2010 Number 7298, at the suit of Bank of America, NA as Successor by Merger to BAC Home Loans
Servicing LP against Roger T. Ruse is duly recorded as Instrument Number 201217050.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 4 day of
ILAQ- A.D.
11, A
'VW4?t Recorder of Deeds
pa=t% of DlAK CwdxftW OM My, Web, PA
MY CWWa IWM mine the Fret WK* OfJaa 2014
The Patriot-News Co.
2020 Technology Pkwy
Suite 3040
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
i4f?latriot.?lews
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commcnweaith of Pennsylvania, County of Dauphin} ss
Holly Blain, being duly sworn accord ng to !aw. deposes and says:
That she is a Staff Accountant of The Patriot News Co.. a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 194+
respectively, and all have been continuously published ever since;
That the printed notice or publication whicf 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 statemen' 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 1 he Patriot-News Co. aforesaid by )irtue 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:
2010-7298 Civli Term 01/27/12
Bank of America, NA, as
Successor by Merger to BAC 02/03/12
Home Loans Servicing, LP 02/10/12
vs
Roger T. Ruse
Atty. Danlei Schmleg
By virtue of a Writ of Execution NO.
2010-7298
BANK OF AMERICA, N.A. AS
SUCCESSOR BY MERGER TO BAC Sworn to and subscribed before rne this 24 day of February, 2012 A D.
HOME LOANS SERVICING, LP
VS.
ROGER T. RUSE
owner(s) of property situate in the
BOROUGH OF NEW CUMBERLAND _
Notary Public
,
Cumberland County, Pennsylvania, being
COMMONWEALTH OF PENNSYLVANIA
(Municipality)
711 SHERWOOD ROAD, NEW Notarial Seal
Sherrie L. Owens, Notary Public
ERLANI7; PA 17070-1449
P cel No. 26-23-0543-196 Lower Paxton Twp., Dauphin County
My Commission Expires Nov. 26, 2015
(
eage or street address) MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
provements s thereon: RESIDENTIAL
DWELLING
JUDGMENT AMOUNT: $140,763.86