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HomeMy WebLinkAbout11-0082~ 1 ATTORNEY FOR PLAINTIFF BAC Home Loans Servicing, LP :COURT OF COMMON PLEAS f/k/a Countrywide Home Loans :CIVIL DIVISION Servicing LP 475 Cross Point Parkway =Cumberland County UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings~udren.com Getzville, NY 14068 Plaintiff v. Jason M . Sanseverino x,41 ~ O a, Kimberly B. Sanseverino :'NO. u P.O. Box 614 Camp Hill, PA 17001 Defendant(s) .~ Q COMPLAINT IN MORTGAGE FORECLOSURE ~"~:~3 C~ _; ,; ~~1 ,.~ ~, ~ ~ ~ -c rrn _ ;_ ~o _C. c,rr Ica ~~ ~~ s-*~ o ~~ .:. ~~ o ~ ~ L i ~ aga nst ~ h claims set forth in the following pages, you must take ~actiori'{ 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 HAVE BEEN SUED IN COURT. If you wish to defend YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LPIWYER 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, IBIS OFFICE MAY BE ABLE TO PROVIDE YOII WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDIICED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Av=so Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, uste~tiene ~ Q~ ~ ~qa•°~~ ~~ 1 ~ 33 veinte (20) Bias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la Corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A IIN AHOGADO INE~DIATANENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SIIFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLANE POR TELEFONO A LA OFICINA CIIYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGIIAR DONDE SE PDE'DE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 r , 1. Plaintiff is the Corporation designated as such in the caption on a preceding page, who is the legal holder of the Mortgage and is in the process of formalizing the Assignment of Mortgage to be sent for recording. 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 4 Victor Lane MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Silver Springs COUNTY: Cumberland DATE EXECUTED: 04/25/07 DATE RECORDED: 05/03/07 BOOK: 1990 PAGE: 4647 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of f principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 12/31/10: Principal of debt due $166,286.53 Unpaid Interest at 6.75 from 04/01/10 to 12/31/10 (the per diem interest accruing on this debt is $30.75 and that sum should be added each day after 12/31/10) 8,405.43 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $230.92 and that sum should be added on the first of each month after 12/31/10) 342.82 Late Charges (monthly late charge of $56.91 should be added in accordance with the terms of the note after 12/31/10) 227.64 Additional Cost and Fees 640.00 Partial Payment Balance (200.00) Attorneys Fees (anticipated and actual to 5~ of principal) 8,314.33 TOTAL $184,621.75 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the r mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A" , and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $184,621.75 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDR BY: Att ALL THAT CERTAIN PARCEL OF LAND SITUATE IN THE TOWNSHII' OF SILVER SPRINGS, COUNTY OF CUMBERLAND, COMMONWEALTH OF PENNSYLVANIA, BEING BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE NORTHERN SIDE OF VICTOR DRIVE AT THE DIVIDING LINE BETWEEN LOTS NOS. 13 AND 12 AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE BETWEEN LOT NOS. 13 AND 12, THE FOLLOWING 2 COURSES AND DISTANCES: (1) NORTH 32 DEGREES 32 MINUTES 44 SECOND WEST, A DLSTANCE OF 90 FEET TO A POINT AND (2) NORTH 02 DEGREES 32 MINUTES 45 SECONDS WEST, A DISTANCE OF 123.83 FEET TO A POINT AT LANDS NOW OR FORMERLY OF MARIE A. SIMMONS; THENCE ALONG SAID LANDS NOW OR FORMERLY OF MARIE A. SIMMONS, NORTH 87 DEGREES 27 MIlWTES 14 SECONDS EAST, A DISTANCE .OF 108.92 FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOT NOS. 13 AND 1 AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE BETWEEN LOTS 13 AND 1, THE FOLLOWING 2 COURSES AND DLSTANCES: {1) SOUTH 02 DEGREES 32 MINUTES 45 SECONDS EAST, A DISTANCE OF 72.49 FEET TO A POINT; AND (2) SOUTH 32 DEGREES 32 MINUTES 46 SECONDS EAST, A DISTANCE OF 50.00 FEET TO A POINT ON THE NORTHERN SIDE OF VICTOR DRIVE FIRST MENTIONED ABOVE; THENCE ALONG SAID NORTHERN SIDE OF VICTOR DRIVE, SOUTH 57 DEGREES 27 MINUTES 14 SECONDS WEST, A DISTANCE OF 120 FEET TO A POINT ON THE SAME AT THE DIVIDING LINE BETWEEN LOT NOS 13 AND 12 AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, THE PLACE OF BEGINNING. BEING LOT NO. 13 AS SHOWN ON A CERTAIN FINAL SUBDIVISION PLAN ENTITLED :WILLOW MILL ESTATES", DATED JULY 26, 1985, AND RECORDED IN THE OFFICE OF THE RECORDER OF DEED FOR CUMBERLAND COUNTY IN PLAN BOOK 40, PAGE 106. HAVING THEREON ERECTED A DWELLING HOUSE KNOWN AND NUMBERED AS 4 VICTOR LANE, MECHANICSBURG, PENNSYLVANIA. TAX ID: 38-13-0985-108 AS DESCRIBED IN MORTGAGE BOOK 1990 PAGE 4647 e4w~lcaF~marfoa '+IM- doss Lars PO 9oor. 9(-46i Ternecx~la.. GA. ~Z.~aR9-9(}48 SandPrryifve+irts to: P,O. Box- 75222 4Ydrvr~tars.OE t9$AB•5222 Sand ~ ta: PO Bajc 51T0. MS SV3148 S9rnl Valley, CA 9+3085 7113 8257 1474 4838 8063 20' 0176413-? .1,~1~~~9y1~,~In.9~i~lt.li~lll~luyllll,i~iiiirill.~.~~~nr,.) Jason M Sansevenno PO Bt3X 6'14 Cfi~MP HILL, PA 17t)t71-0614 PRESORT Fe-s1-Class Mal[ 9.x.5, Pnsta~e arts eras Pale WSO SEX y~8~. T ,q ataPAa <,~zrs~~oa~zcr,r, { Bawki~~erica IIRMIaf I.ssnt P.O 8ax 6bt369d DatAas, 7a' 75265-0654 $enr! F~Y~3G'fattF r0- P.Q. Box 75222 Witrn+ngfon..DE 399fA6-Si22 August 9. 201 Q Jasan M Sansevenna PQ BOX 6t4 CAMP HILL, PA 17001-0614 Certlfred Mail: 7113 8257 147-i 4838 8063 Retum Receipt Renuested Regular Mafl Aclcourrt No.: 167516642 Property Address: 4 Victor Ln Mechanicsburg, PA 17050 Current Servicer: BAG Home Loans Servicing. LP A~GT 91 NfJTiCE TAKE A~TlC~IV Tt~ SAVE YC~U R H t~ M E F F~t~ M FtJ-RELC~SURE This Notice contains important legal information. N you have any questions, rsprasentatives at the Consumer Cradlt Counseling Agency may be able to help explain it You may also want to contact an attorney in your area. The local bar association may be able to help ypu find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCtA, PLIES AFECTA SU DERECHO A CONTINUAR YIVIENDO EN SU GASA. Si NO CO~MPRENDE EL CONTENIDO DE ESTA NOTIFICACI~N OBTENCiA UNA TRADUCCtbN INMEDU-TAMENTE LLAMANDO ESTA AGENCW {PENNSYLYANUI HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PR~STAMO POR EL PROCiRAMA LLAMADO "HOMEOWNE'R'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU H~OTEGA. HOMEOWNER'S NAME{S):. PROPERTY ADDRESS: LOAN ACCT, NO.: ORIGINAL LENDER: CURRENT LENDER-SERVICER: VYyrlrlt fistru¢tlona: • Make pear cfiertr palrapEe In B.tC Hnrna trine Sarvr~ng, LP • Qnnt sand rah • f§ea~ea ind.lda exunon uilh pnUr payn~rot FflF of iLr ttT71Nl RahTi)ci71 C>~ICid:i. +yc;fegl l3 pilcufaled on a nud+,lybeaN&. Aanrdngly. Y71plPll inr ail frMi rcaMnrc. insf,dng Fe4n~arp. i# I~iCUiafcd 3tu?8tx d enrwal rgereal, i~respai9ive trf the aGJW aumaer of days in the rwafi. ~~ For ggr~dll R14N19. ~r~ I$ t~14J~IPyi dalt~' GutA[:. Cssis # x385 daYyle~lr .lason M Sanseverino 4 Victor Ln Machanicsbura. PA 77050 16751 tii842 BAC Nome toms Servidirg. LP is a aubsadFary of Bank at America, hi.A,. Poeese arse lvir a~aa~ant. rumGa an ail chedGS aral ~xreaucrdence.. `NC rn8Y p>!ape }S11/9 tae MIt g,Ty Oaylt1ClM tCiurT~U Qf rfilE='lR3d t]y }LWr ir+~im~ nr3illLLr~l. 941h1e/A ie S(X?ISYICdB bW. BLLFA9 t f 722 tYi'CHQC{t ti Accofir>< Number. 187516B4Z-3 Jason M Sanseverino Balance hue tar charges Ysied shove: S~ar647a7 es ai Auaust 5.2010_ 4 Vidnr l_n ~~~ a{zfele errei, nl[Mrsalerr on me ren?n:e scb? of Isis c«.p~~. IiAef~,at,lfSlJUf{~, PA 1?asn ' Ate, ~, aL4P A J Ilr~~.~.il~nu~rq~l~..Il~lf~r.lirhl(Ir~'I'lllr~~.~lt~.~il.E~.l ArrkNin~.M 6~ar~ BAC Home Loans Servicing, LP PO BflX 15222 (iarece a WifmingRan, [3E 19$$6222 (~"~`' 16t51bb42300000564T5?000564757 t:58699~058t: i6?5 i664 2ff• Ht)MECyWNER'S EMERGENCY MC~RTGAGE'4SS1$TANCE PR©GR,~4M YOU MAY BE ELIGIBLE FOR FINANG ALASSISTANGE WHICH GAN SAVE YOUR HOME FROM FOREGLOSLIRE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"j, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act you are entitled to a temporary stay of foreclosure on yaur mortgage for Thirty (30} days from the date of this Notice. During that time you must arcange and attend a 'lace-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY CONSUMER CREDIT C~!NSELING AGENCIES - If you meet with one of the ~nsumer cred€t counseling agencies listed at the end t>i this notice, the fender may NOT take action against you for Thirty (30) days after the date of this meeting. The names. addresses and teleohorie numbegg of designated consumericredit counsstlina aaeneie~ fir the county in wlhit~i the orooerty is located are sat forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advl~ your lender immediately of yaur intentions. APPLIGATK)N FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later In this Notice (see follattving pages tar specific information about the nature ~ your defauNt.) If you have-tried and are unable to resalvethis problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. Ta do so, you must fill out, sign and file a completed Homteowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies I~ted at the end of this Notice. Only consumer credit counseling agencies have applications for the ptngrarrt and they w111 assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST tae filed or postmarked within Thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY, IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibllitycxiteria established by the Aci. Tate Pennsylvania Housing Finance Agency has saty (f30) days to make a decision after it receives your application. Quring that time, no foreclosure proceedings will be pursued against you rf you have met then time requirements set forth above. You wi11 be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED A5 AN ATTEMPT TO COLLECT THE DEBT. (ff you have filed bankruptcy you can still apply for Emergency Mortgage Astalstance.) NOTICE OF INTENT TO FORECLOSE YOUR. HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED MI THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. NATURE OF THE DEFAULT -The 14fQRTGAGE debt held by the above lender an yaur properly located at: 4 Victor Ln Mechanicsburg, PA 17050 IS SEMIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS far the following months and !fie fallowing amounts are now past due: Monthly Charges: 0510t/2010 Irate Chases: 05/0112010 Other Gharaes: Uncollected Late Charges: Uncollected Casts: Partial Payment. 8alat'rce: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION fl2a not use If nat. aaallcabliet $5,476.84 ~ 170.73 $0.00 $0.00 (50.001 ;5,847.57 13,40 Name Loans S+ervicirtg. LP is a subsidiary of Bartle of America, N.A. E-mail use: Pmt yrarr r_-mall s~ddross ttelnw u~ allow trq 7n seM y+au Inian+radon an yaur acxourtt. AecouM Nurnber: 187~166t2 Jason M SanaeVarina E-main addrnse_ Herr ttre po~ct your psymants: A1R atrepted p~syrnarrt9 cat 17~alDel and rrgsreet , be applied to the longest autstar-diryg instaimertt duo, artless rnherwiee expreeely prcltiG~d re lireitett by law I! lvu turbnW. an arnaunt in ~ A'S ytxr acfitxluled monthly amaum, we xi! apply yaur payrnerttw as +oNows: llg is montltty payments of rxsxAl+al and inroareat, tlli eacmw ciafirasnolsa, iNI1 leis rharges and rnher arnotmrs ymu care in txxnak^dnn wMh yaur loan arcs Irv? to rerlurs the otJOStarrdfng tpak balance or yaur loan. Please epedNy N you werrt an addidnnal amount appie3ID lucre pa>,metnis, rasher Ulan principal reduatian_ PotrEdarsd ahecktr: Pnstdated rheas xtit be pra.assad an the e1aLa recervad unlare a loan counselor agrees nz honor the date wrrttdw an the rhar}k as a rondnion rat a rerraynrent plan. HOW TO CURE THE DEFAULT -Yau may cure the default within THIRTY i~1 DAYS of the date of this notice EY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH tS 53,64't,ST PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavmersts must be made elttter tw cashier's ehecx_ certified check ar money order made oavabie and sent to: BAG Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222. You can cure env other defautt by taking the folbwine action within THIRTY f301 DAYS of ttte date of this letter, (Da not use if not aoolicablel 1F YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights 1lo accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immedlatety and you may lose the chance La pay the mortgage in monthly installments. If full payment of the total amourrt past due is not made within THIRTY (30} DAYS, the lender also intends to instruct its attameys to start legal action tc. fontrciose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be saki by the Shertif to pay off the mortgage debt. If the lender refers your case to Its attorneys, but you aura-the delinquency taefore the tender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal pr+aceedtngs are started against you. you will have to pay all reasonable attorney's fees actually incurred by the lender even If they exceed $50.00. Any attorney's fees will be added to the amount you owe file lender, which may also include other reasonable assts. tE you aura the default within the THIRTY (30) DAY period, you will not be requtr~sd to pay attorney`s fees. YOU HAVE THE RIGHT TO REMlSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EIiISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES -The lender may also sue you personally far the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SAt_E - If you have not cured the default within the THIRTY (30y DAY period and far>3closure proceedings have begun, you still have the right to cure the defautt and prevent the sate at any trme up to one hour before the Sheriff's Sale, Yau may da so by paying the total amnunt then past due, plus any late or other charges then due, reasonable attorney's fees and ousts connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as speclfled to writing by the lender and by pertorming any other requirements underthe mortgage. Curing your default in the n-anner set Earth in this notice wiN restore your mortgage to the same pasRion as If you had Haver defaulted EARLIEST POSSit3LE SHER~F'S SALE DATE - ft is estimated that the earliest date that such a Sheriff's Sate of the mortgage property could be hold would ire approximately six. (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the defautt will increase the longer you wall Ynu may find out at any time exactly what the required payment or action will be by contacting the lender, HOW TO CONTACT THE LENDER: Name of Lender- BAC flame toerrs Serv/c/r-g, LP Address: P. O. Box 66r78t# Dallas. TX T526+6-08SM Phone Number: t-Br~G651-Q702' Fax Number: 1-8tT-23P~68#1 Contact Person: MS 7702-9TT-O~-73 Atterrt5ion: Loan Counselor Email Addr+sss: Ta ensure secure email ,communications please lag on to the. BAG Hame Loans Servicing, LP Website at www.bankofamerlca.cam and email us by navigating through the Customer Service link provded EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy lt. tf you continue to Ifve in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may sell ar transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attamey's fees and casts are paid prior to ar at the sale and that the outer requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SEI_t. THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THtS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME P051TtON AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE T1ME5 IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, Your loan is in defautt, Pursuant. to your loan documertts, BAG Hame Loans Servicing, LP may, enter upon and conduct an irtspectlon of your property. The purposes of such an inspection are tc> (i} ot>seroe the physical condition of ynur property, (ii} verify that the property is or~upied andior (III) determine the ldenilry of the occupant. H you do not cure the defautt prior to the inspection,. other actions to protect the mortgagee's Incenest in the property (including, but not limited to, wiMerizatian, securing the property, and yL BAO Hama Loam Sarvirdng. LP is a sunsidory of Bilk of America, N.A_ 7113 8257 $474 4636 8Q63 valuation services) may be taken. The coats of the abave~ciesaribed inspections and prpperty preaervatian efforts will be charged to your account as prawided in your security instrument. tf you are unable to cure the default an ar before September 8, 2010, BAG Home Loans Servicing. LP wants you to be aware of various options that may be available xo you through BAC Hame Loans Servicing, LP to prevent a foreclosure sale of your property. For example: Repayment Plan; It Is possible that you may be eligible for some form of payment assistance through BAC Hama Loans Servicing, LP. OUr basic plan requires that BAG Home Loans Servicing„ LP receive. up front, at least't~ of the amount necessary to bring the account curnent, and that the balance of the overdue amaurvt be paid, along witty the regular monthly payment, aver a defined period of time. Other Reaymernt plans also are available. Loan Modif"ecation: Or, rt is possible that the regular monthly payments can be lowered through a modifiaaiion cal the loan by reducing the interest rate and then adding the delinquent payments to the current. loan balance. This foreclosure attemative, however, is limit®d to certain loan types. Sale of Your Propett}r: Or, 'rf you are willing to sell your home in order to avoid foreclosure, R is possible that the sale of yaur home can be approved through BAC Home Loans Servicing, LP even if yaur hams Is worth Iess than what is owed on k. • Deed-in-Lieu: Or, if your property is free from other dens or encumbrances, and If the default is due to a senousfinancial hardship which is beyond your control. you may be et~ible to deed your property directly to the Noteholder and avoid ~e foreclosure sale. H you are interested in discussing any oaf these foreclosure altematVes worth BAG Hame Loans Servicing, LP, you must contact us Immediately. Please be advised that your decision to pursue any of these options is strictly voluntary. if you request assistance, BAC Home Loans Senvlcing. LP will need to evaluate whether that assistance wilt he extended'to you. In the meantime, BAG Home Loans Servicing, LP will pursue atl of its rights and remedies under the loan documents and as permitted by law, unless It agrees otherwise in writing. Failure to bring your loan current or tb enter into a written agreement t>y September 8, 2010 as outlined above will result. in the acceleration of your debt. Time is at the essence. if you have any questions concerning this notice, please contarct Loan Counseling a,^,enter immediately a€ 1-800-669-©1 Ct2. J+4C Hame Loans 5envian®. t. P is a st>bsidiery of Bank of America. N.R. 7F.13 857 L474 4838 $063 ,Attachment: Itemization of Charges and Fees Monthly Charges: 05/0112410 - 08F3112014 Late Charges: 45/01/2414 - 0713112014 Other Charges: Ungotrected Late Charges: Partial Payment. Balance: ~' TOTpL DUE:. $'I.369.21 $56.91 $5,476.84 $170.7'3 $4.00 r~o.4~f 55,647. ST BAC Name Loans Servicing. LP ~ a subsi~iar}r cA Bank rrf Amersca, hl.A. (" OP.'Sl_?MER CREFIIT CQi11~.TSEI_I24TG .AGENCIES SF.R~.'INCi 3'C7i_JR Ct~I_~!V'T'~F CUMFIERLAND C(7UNTY PHFR Rdanm Gots+ty InteHaith ~-touamg Ruthariy Lstaeahip, Inc. 217 worth Front: Str®et 40 E Htgh Street. 232!'9 worth 5th Street HarNabvg. PR 1771!7 Gettystrurg. PR 13325 fiarri;tt7Urg. PR 11110 717 7~.3A4C1 717:33+1,1518 71?.7.32.2207 800.:342,2397 CCC.S at 1Mes7rrm PR Comrnuntry Rctfon Commeslon of Captia/ Meranetha 24900 Ungiesttiwm Roan Reglon 43 Phllatlelphe Avertue Harrittbury, PA 17702 1574 DerrySq'ee9 Waynsebor~p, PA 17258 888.571.2227 HarriAhug, PA 171C]W 717.782.3285 888.511.2227 717..232.9757 6ap~kifAn~srios '~' hour I.arrs PC1 Bloc 9CS48 gemecxdp. GA 92589-A(}48 Sond P'wameiHS ;!D: P.C2. BQx 15222 4Virn~npbnn. ~E. 998A6.5222 ,Srnd ~ en: PO Box 517Q. MS SV31d8 Siml Valley. CR 83085 i PRESpRT FMrst-Class Maft tt.5. P~nntz~gia arMB was Paics WSC3 7113 8057 1474 4838 8®713 29'f t~(lf#fl4T '11'"~I~~IIIIIf1~11rIE'I~~~nill~~~n~I~~MId~PI"'~~~llh~.li~~l Kimberly B Sanseverino PC? BC7X 6'14 CAMP HILL, PA 1?W1-Q674 eaana, s hoax ~~oe~x~~rr Bawka~America ~1- IIOMIR I.Oalli P. a. B~ ss ~,r~~, rx 75796-c~ss~ ~aa4 P~rm«an; na P. p. Box 75722 WiTtruragtara. flE 498-5722 August 9. 2010 Kimberly B Sanseverino Pa t3ax s14 CAMP HILL„ PA 17001-0814 Certifred Mail: 7113 8257 1474 4838 8070 Return Receipt Requested Regular Mail Account No.: 167516642 Property Address: 4 Victor Ln Mechanicsburg, PA 17050 Current Servicer: BAC Homy Loans Servicing. LP A~GT 9-1 NOTICE TAKE A+CT~ON TO SAVE YOIIJR HOME FROM FORECLOSURE This ie an offk~l notice that the martaaae an your home is in default. and the lender intends to toreciose. SnecMic Information about the nature of the default is provided in the attached Haase The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGPAM iHEMAPt maw be able to hg(gto sous wour h4{~, This Notice explains how the nroararn works To_see If_HEMAP Can help. vau m~~t MEET WITH A CONSUMER GREDiT COUNSELNG AGENCY WITHM ill DAYS OF THE DATE OF THIS NOTICE. Take this Natkse with vau when vau mast with the GounseNna Anencv This Notk:e contains impo-lant Isgal information. H you have any questions, repreeentatifves at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area The local bar assaciatlon may be able tr0a help you find a iewvyar. LA NOTIFICAGION EN ADJUNTO ES DE SOMA IMPORTANCIA, PLIES AFEGTA SU DERECHO A CONTINUAR VNIENDO EN SU GASA. SI NO COMPRENDE EL CONTEN~O DE ESTA NOTIFIGAGI~N OBTENGA UNA TRADUGCIC%1N INMEDIATAMENTE LLAMANDO ESTA AGENCIA {PENNSYLVANUI HOUSING FINANCE AGENCY] SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAINADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DEREGHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME{S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERI5ERYIGER: Payment lanetnacdone • Makeyar rtaaek PnyaCia to BAG Ha~ne loen-e.9arvnng LP Gont sand ash w PIma~3e~~xatt~~~ssuWnvnlh y:aur ~Y" ~+P Frx a! !u! arrtnh patt*lenl 1>~+rxi~. i+Me~at is cat~aieied ~ a meMhlybeeas, A~grdngiy:.. rntrert trr Ml fik+ rcanhs, irtciudtry! Pea~ary. as caltxaieled a~ ;7Kt€98C rA xnaway nlereel« etrstaeaave al Ina awe number oti aeys Vn mrv m:,nr,. Fcr c~sal mgMns. rtlerep! a csi.ulated Oetr!` un tree e~a~s d a3&S rmy year IKlmbarly B Sansevarino 4 Victor Ln Machanlcsbura. PA 17450 1B75i6642 BAC FIanB Loans Servicng. LP is a subsiliiary of Bank of pmarica, N.A. Please vttMe?naa' acmunl rumt~~ an all credc.~ end aa*esPardaice.. 5M1'e. map' q~pn~e yY7U a lee {Qf 8a'ry i+!ay+neM relattl:d G' r£ae~0 4y ya.ar hnaaao~ Iral~~cr~. AVOie4810 aL'C1Ir,~dC q><V. BLC'iA:1 1172:: 035:P3.QL16 CGY?ftlld /~ttfy7ttAt" 'iii ~'~~Z'3 Ktmberiy B Sartsevetirto dance Due for dtarg~es IecUed atwws: 55,641 ~7 as df Augus:9.2Q'I0. 4 Vidor to r,~a~ ~ t~~ rainrr,~ia~, do liFa reawisa s~ attn~s ~r~,. Mechanicsburg, PA 7 dt150 aacw.m,sa BIdJPA1 ll~d~Ii~nIl~~~lll'q~.~IJiI•Il~~~~l.i'1'1'~'lli~'~'1'll'~n~~~ Ai~thX~tw' ~t~» BAC Homa Loans Servicing, LP PQ BOx 15222 Wilmington. DE 19886-5222 ~~u 1b751bb423t:1CI00[I5b4757U€105b4757 ~:586990~E]518/:16?5 it664 2ls^ HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM F IF YOU COMPLY WITH THE PROVISIONS flF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE AGT OF '1983 (THE "'ACT"), YDU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRGUMSTANGES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY QF FORECLOSURE -Under the Act., you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30) days from the date of this Notice. During that time you must an'ange and attend a 'Face-to-face" meeting wtth tSrte of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR VYITHIN THE NEXT THIRTY CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of desana~~~ consumer credit counseling agencies for the county in whidt the property is lacattad are set forth at tfre end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages far spedfic intorrnation about the nature of your default.) If you have tried and are unable to resolve this Problem with tike lender. yea have the right to aPP1Y for finanelal assistance from the Homeowner's Emergency Mortgage Assistance Program, To do ~, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with qne of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete appiicakion to the Pennsylvania Housing Finance Agency. Your application MUST be hued or postmarked within Thirty (30) days of your fare-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibilityrriterie estabilshed by the Act. The PennsytvaniaHousing Finances Agency has sixty (60) days to make a decision after It receives your application. During that time, no foreclosure proceedings will be pursued against'you if you have met the time regwrements set forth above. You will tae ratified directly by the Pennsylvania Housing Finance Agency of its derision an your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE PEEING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply far Emergency Mortgage Assistance.y NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTK)N TO SAVE YOUR. HOME FROM FORECLOSURE. NATURE OF THE DEFAULT -The M412TGAGE debt held by the above lender an your property located at 4 Victor Ln Mechanicsburg, PA 7705D IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the fallowing amounts are now past due: Monthly Gharoes: 0 510 112 0 1 0 Later Gharaes: 05I0112D1D Qther Gharoes: UncoNected Late Charges'. Uncollected Gusts: Partial PaymerN Baiartce: TOTAL DUE: YQU HAVE FAILED T(3 TAKE THE Fl3LLQWING AGTI[?N fQa rat use If rat analicablet $5.476.$4 $i 7D.73 $O.DO 5D. DO CQO. DD l i5,i3+tT.'ST BAC Noma Loans 5ervidrtg, LP is a sukrsldiary of B~rlt ctf ,America, N.A, E-mair uee: Fmvicl~rg ywr e+naN address below wa agow ue id se*.nd ydu inidmeaddn do ydur s~^rrurr. i+ccoun[ Number: iB~578842 rGrtbefry 8 Sansas+ Email adcllress: How tare post your psyrrrsntt: Iut aa:apted payrnerr~ ref prMdipwt and iruareat wl® 6e applied k> Vie longest cutatvedng instEirlleM due, urrass otherwise expressly prt~itted dr IirnlOed by law. Ir emu aubr+MT an anedunt in additerae sz y«. achedulad monthly amourr, we Otis appty }our payrnerrta as rellawa: {fry ttr mdntrty payrmenta dr rasncllt~t and irrpanest, 4i1~ ~croty defldanossa, (Uil late charges and aVtier amaunt~ yrcxt crr~e in oorrwxbon with ydur loan and i:^`? tt: rerMx-.e >tre du~ten;iing r+~'~par baksnde dr ydur Ivan. Please apedry K you want an additional amaurvt appiad m fiiare , rather than principal reckrctldn PorEduhd ehedQ: Paatdahad deecks wall ba pmcasaed an the Bata rearvad unless a Iaan sdunsalar agrees ~ honer the date NtYtt9rt do tree check es a r.dnditidn rte a rrt~aymeant plan. HOW TO CURE THE DEFAULT - Yau may cure the default within THIRTY (30j DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PANT DUE TO THE LENDER, WHICH tS #5,t347.3T PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30} DAY PERIOD. Pavmwrttc m~~gr iu_. made either by Cashier's check. certified check Or money orcler made oavable and sent to: BAC Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-x222: You can cure any other defautt by taking the folbwina action within THIRTY t301 DAYS Hof tine date of this fetter. lDo not. use tf not aooliCa ble 1 IF YOU DO NOT CURE THE DEFAULT - If you da nai cure the default within THIRTY (30} DAYS of the date of this Nance, the lender intends to exercise its rights fag accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage fn monthly installments. If felt paymenI of the fatal amourn past due is not made within THfRTY (30) DAYS, the fender also intends to instruct its attorneys to start legal ac~ttion to forectic-se upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property wilt be solo by the Sheriff to pay off the mortgage debt. If the lender refers your case tD Its attorneys, but you cure the delinquency before the tender begins legal proceedings against you, you wilt still be required to pay the reasonable attorney"s fees that were actually incurred. up to $50.00. Howeuer, f legal pn7aeedings are started against you, You wilt have to pay aft rerasonable attorney's fees actually incurred by the fender even tf they exceed $50.00, Any attamey s fees will be added to the amount you owe the lender, which may also include other reasonable costs. tf you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees, YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURRE PROCEEDMG THE NON-EXLSTENCE OF A DEFAULT OR AMY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECL03~URE. OTHER LEND~j, REMEDIES -The lender may also sue you personalty for the unpaid principal balance and aft other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have net cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right. to cure the default and prevent the sate at any time up to one hour before the Sherllfs Sate, You may do so by paying the total amount then past due. Plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sate and any other costs Connected wim the Sheriffs Sale as specified in writing by the fender and by performing any other requiremerns underthe mortgage. Curing your default in the manner set forth in thus notice will restore your mortgage to the same position as ff you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated mat the earliest date that such a Sheriff's Sate of me mortgage property could be held would be approximately six. tyt3j months from the date of this Native, A notice cf the actual date of me Sheriffs Sale wilt be sent to you before me sale, Of Course, me amount needed to cure the default wail increase me longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the tender. HOW TO CONTACT THE LENDER: Name of Lender, BAC Niarrne Loans ServCcfrrg, LP Address: P. O, Box 6606it14 Defies, 77C 7526&-089 Phone Number: i~8t1~669~-0702 Eax Number: 7-877-23Q-+587! Contact Person: AfS 7712-fF77-07-t3 Attention: Loan Counselor Email Address: To ensure secure email communications please tog on to me BAC Homer Loans Servicing, LP Website at www.bankofameriCa,COm and email us by navigating through the Customer Service Iink provided EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of me mortgaged property and your right to occupy lt, ff you continue to Iive in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the fender at any time. ASSUMPTION OF MORTGAGE -You may sell or transfer your home to a buyer or transferee who will assume me mortgage debt, provided that aft the outstanding payments, charges and attorney's tees and costs are paid prior to or at me sate and that the other requiremerns of the mor~age are satisfied. YOU MAY AL"~O ~H,~,~(E THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTINt, ON YOUR BEHALF'. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT.. (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.j TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER. THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your town is in default. Pursuant tq your loan documents. BAC Home Loans Servicing. LP may, enter upon aril conduct an inspection of your property. The purposes of such an inspection are to (i} ooserve the physical condition of your property. j~ii} verity that the property is occupied and/or (lilj d~ermine the identity of the occupant. H you da not cure the default prior to the inspection, other actions to protect the mortgagee's interest in me property (including, but not limited to, winterization, securing me property, and BAC Home Loans Serviang, LP is a subsidiaay of Bank of America. N.A. 713 825' ~4~4 4888 807Q valuation senripes} may be taken. The cuts of the above~iescribed inspections and property preservation efforts will be charged to your account as prawided in your security instrument. tf you are unable to cure the default on or before September 8, 2414, BAG Hame Loans Servicing, LP wants you to be aware of various options that may be available to you through BAC Hame Loans Servicing, LP to prevent a foreclosure sale of your property, For example: • Repayment. Plan; ft is possible that you may be eligible for some form of payment assistance through BAC Home Loans Servicing. LP. Our basic plan requires that BAG Home Loans Servicing, LP receive, up front, at feast "fix of the amount necessary to bring the account current. and that the balance of the overdue amount be paid, along with the regular monthly payment, over a deUne~f period of time. Ether repayment plans also are available, • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest retie and then adding the delinquent payments to the current loan balance. This foreclosure arnative, however, is I'imiked to certain k-an types. • Sale of Your Property: Er, if you are willing io sell your home In order to avoid foreclosure, R is possible that the sale of your home can be approved #hrough BAC Home Loans Servicing, LP even tf your home Is worth lessthanwhat is owed on it. + [peed-in-Lieu: tar. if your property is free from other liens or encumbrances. and it the default is due bo a serious financial hardship which is beyond your control, you may be el~ible to deed your property directly to the Notehalder and avoid the foreclosure sale. ft you are Interested in discussing any of these foreclosure alternatives with BAG Home Loans Servicing, LP, you must contact us immediately. Please be advised chat your decision to pursue any aif these options is strictly voluntary. if you request assistance, BAC Home Loans Servicing, LP will need to evaluate whether that assistance will be extended'to you. In the meantime, BAG Hame Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement t>}r September t3„ 2414 as outlined above will result In the acceleration of your debt. Time is of the essence. ff you have any questions cXincerning this notice, please contact Loan Counseling Center immediately at 1-coo-sss-o14z. BAC Hvme l.oar-s Servian®. LF is a suoaidiary of Bank of Arnerira, N.A_ 7113 8257 1474 4838 8076 ,Attachment: Itemization of Charges and Fees Month6v Gharaes: 05f01f2010 - Ot3f31l2010 Late Charges: 05f01f2010 - 07f3112010 Other Charges: Uncot~ected Late Charges: Partial Payment Baiar-ce: TOTAL DUE: $1.369.21 $56.91 ~,' ~:* X5.476.84 $170.73 $O.ao c;i<a.oos 15,847.57 BAC Home t.oans 5erviarg. LP is a sutrsiciar~r of Bank of America, N.A. CONSl.TN1ER CREI~I? C(71JI~TSEI..ING AGEN+C'IES SER.'~+II'+TCs ~~"~i_rR COt1?tiiT~c` CUAABERLAND C©UNTY PH3=R Adanut County Interfelth He3uuenng AUlnOnty 3_t:+,retcMR, inc. 211 NoAh Frtxlfi Streei 40 E. High Slreafi 23213 North 5th Street Harrisburg. PA 17110 Gettysburg, PA 1732.5 3-larrisburg PA 17110 717:7$Q, 3940 717,.334.151 A 717.232.2207 ~0 342,2397 CCCS cN western iyA Cornhwrrty Action Comm~esi+an of Capba3 3Narsrtathe 21100 ungiestown Road Regiat A3 Phl3adel{trti~e Avenue Harriabteg. PA 17102 1514 Derry Sheet way+*bataoro, F'A 17218 BBH 511.222T Harrisburg, PA 17104 71'7.762.32135 888.511.2227 717:232.975'1 ti1M7#'f~7MK17~ .~ PRESORT /lorrlorrc FersC-Class Msi4 9s.S. Posta~s snot Pty ~` ftCi~A Fames Psirt Temec~ila. C+R 92584>-9(ht8 WSCJ 711.3 825? 1474 4838 8131 Send Fwymenfs !o; P.G. Box 75222 Wimnpton. DE 7ggAg~g222 Sand Corraspondwroa W: Pp Bux 81T0. MS SV3148 S~mf Vaeley. CA 733085 ;tptt~pg69.Y ~I~~~I~1~1~~~~~{11~~~~~1~11~1~~!{II1~~{{~1{'Ilr~'~'~"I'{I~{{{r'~ Jason M Sanseverno 4 VICTOR ~N MECHANICSBURG, PA 17450-'155'{ ~Bawkf~Arnerie~ ~M~ P.t3 Boat 68tfS9~ Deltas. TX 75266-06.94 Send Payk.krsrk7s to P.O. Box 7522'2 iNitrnir+grtron. DE 79986-5222 AUgGSt 9, 2010 Jason M Sansevenno 4 VICTOR LIV MEGHANICSi3URG, PA 17050-1551 Cerlffied Mail: ?113 8257 1474 4838 8131 Retum Receiod Re4uested Regular Mail Account No.: 167516642 Property Address: 4 Victor Ln Mechanicsburg. PA 171550 Current Servrlcer: BAC Home Loans Servicir~, LP ACT 9'I ICI C)T I C E TAMCE ACTION Tt~ SAVE 4'[7f U F~ H C1 M E F I~~ IVI FO-RECLC.~SU RE This Notiice canta~s important legal informetian. M you have any questions, representatiives al the Consumer Credit Counseling Agency may be able to help explain it. You may also want fo confect an attorney in your area. The local laar assaciiatian may be able to help you find a lawyer. LA NOTIFIGACION EN ADJUNTO ES DE SOMA IMPORTANCIA, PLIES AFECTA SU DEREGHO A CONTINUAR ViV1END0 EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFlCAG1~5N OBTENGA UNA TRADUCCIflN INMEDWTAMENTE LLAMANDO ESTA. AGENCIA {PENNSYLYANUI HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRRSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME{S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERfSERVICER: PrynwrtlmtnseHonc Mskc Y~ check Paylsde k!} B;+C Hans t.aa~ Servnng. lP oa,ti sane Leh e Please ~nd.~da ,...,fin wilh yn,~r Ra}'m2~M Rix ai Wi rtutN7 pannenk g~tnds. +nkcrt:ef ~s taaiaAare<] at w m~xithiy qa#s. AaacMngly, 1YMPJEM knr NI fill nYJfWiH, !nC11/df1{) f'eGNerf'. i9 ::atcuiated 8re; :Yti99~ d eneNke+ raere~, +resarrJrve t~f toe ~.IW nurc6er of dege to khe monh, Fa pa-al mantis. rW.reN i$ Caiatetw_] ttniA' ~ kne bases d a 3@5 tlay yea.. Jason M Sansevenno 4 Victor Ln IYlschanicsburSi~.PA ~7ost5 ~§TSiB642 BAG Htxne taans Setrviang. LP is a subsi~ary of Bank of America, F3.P,. PieasearAe~a asnt rumt~ nnai~ checks arW oarestaader~ce. 4Vt may (Nw@t!~e yVU a fee fee ~'tY c~rYkrterN R'Ita'rx'.7f a r~:jealeQ 4y 1kxk~ fmn41'v7Pl irt~fitliat. 9uL"e411U aC:k7iraGe grr. 81~PAi 5!732 ~Y?.y13:4~~t AC4i0Ur1t Fkrmb~9r.' lB75l6842~ Jason M Sanf;everina 9alance Oue tar charges skeKi abouie= 55.647af 7 as of Akx~usf 9.2at 4. 4 odor Ln ~,~:8~~~F~,k~,~~~o~mgr~~gs~4kkn~~-~. IAectkazvcsbur~, PA t7Q50 A~,~,n,~,, BLAP~9 {I~l+i'l~'lli.~ll4~Yll~~l~1~~~111'~I~~I~ll+~l~ili~+lllll.f~~.{.l. autaanw ~ BAC Home Loans Servicing, LP PO BOX 15222 cataca Wilmington, DE 1988Fi-5222 ram 1b75166423QDQUQ564?57~DQ564?57 t:586990CT58t: i6?5 1664 2+r• HOMEOWNER'S EMERGENCY MORTGAGE /ASSISTANCE PROGRAM YOU MAY BE ELIGII3L E FOR FINANCIALAS5ISTANGE WHK~H CsN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER"S EMERGENCY MORTGAGE ASSISTANGE ACT OF '1!383 (THE "ACT'"j, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANGE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30j days from the date of this Notice. During that time you must arrange and attend a 'Face-to-face" meeting with aria of the consumer credit counseling agencaes listed at the end of this Notice. TM~ MEETING MUST OCCUR 1liFITI#IN THE NEXT THIRTY BRING YOUR MORTGAGE UP TO DATE .: CONSUMER CREDIT COUNSELING AGENCIES - tf you meet wish one of the r:~ansumer credi4 counseling agencies listed at the end of this notices, the lender may NOT take action against you far Thirty (30j days after the daUe of this. meeting. The names. addresses and telephone numbers of desianat~r~ consumer credit counseling agencies for the cx~.unty in whidt the arooertv is located are set Earth at the end of this Notice. It is only necessary to schedule one face•-to-face meeting. Advise your lender immediaeely at your irrtentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see fallawtng pages far specific intormatian about the nature cf your default.} If you havetried and are unableta resolve this problem with the lender, you have the right to apply far financial assistance from the Homeowner's Emergency Mortgage Assistance Program, Ta do so, you must fill out. sign and file a compietad Homeowner's Emergency Assistance Program Application with one of the designated consumer crtedit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications far the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency.. Your appiicatlan MUST be filed err postmarked witihin Thirty (30) days of your f~.+e-to-fierce meeting, YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANGE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They wit! be disbursed by the Agency under the eligibllttycriteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (BOj days to make a decision attar It receives your application, During that time, no forteclasure proceedings will be pursued against. you ff you have met the time requirements set forth above. You will be notified directly t>y the Pennsylvania dousing Finance Agency of its decision an your application. NOTE:. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURROSES ONLY AND SHOULD NOT BE CONSIDERED A5 AN ATTEMPT TO COLLECT THE DEBT. (ff you have filed bankruptcy you can stilt apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTK)NED IN THIR NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. NATURE OF THE DEFAULT -The MQRTGAGE debt held by the above lender on your property ~cated at; 4 Victor Ln Mechanicsburg. PA 17050 IS SERI{}USLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS far the foliarwing months and the failrnaring amounts are now past due: Manthty Charoes: 05!01!2010 $5.+176.84 Late Charoes: 05!01!2010 ~w1T0.73 CJther Charoes: Uncollected t.ate Charges: $0.00 Uncollected Costs: $0.00 Partial Payment Balance: ($O.D01 TOTAL DUE: ;15,647.57 YC1U HAVE FAILED TO TAKE THE FCLLOWING ACTtC3N fDo not use If not applicable) BAC Home Loam Servi+ang. LP is a subsidiary of Bank ol'America, N.A. E-mail use: PresNd'r3 y~rr a-nfafl address below wiM allow u9 to send yzx, intnmxaiion an your aa;.ount. AGarUM Marrtber; t87~t6842 Jason M 5artsevarina E-mad address: Hwn we paeR your prrymerrts: Alt aaePOed Iseyrnerrts 1st rxirrclasr end edarest owl be ePPlfed td Yha langes^. auzLstan3ng instalmer2 due, uniass otherxdse expressly praiMt>Red ra Ilrnlted by law. rt y~au ~brrrt an arnaunt n addttirn Ay your edreriuled monthly emaunt we w~ apply your peyrnerrts as TnUaws; Ir} to rwtstanttinag montluty paymeMS ai Prarcipai and interest, [Iii eecrdw deficienvies; (liil late charges and rather arnourres yar error in axrrecaan witlh your loan erKl {iru"t ~ reduce the au~tarrding pnnc'~iper balance nt your Irian:. Please specidy K'you want an additional amaurn appied to lours payrtrerrts. rather Bran principal recfuation Paeidrtad chedca: Paetdaled dredce tNi bw prr~asa~ on trig ~iaLa rewrvad unless a loan counselor agrees ~ Manor me date wmrotyn an Ins check as a ..^,nndedan rat a repayrnerK plan. HOW TO CURE THE DEFAULT -Yau may cure the default within THIRTY {30) DAYS ofithe date of this r~tice BY PAYING THE TOTAL AMOUNT PAST DUE Td THE LENDER, WHICH IS 55,6~i7.3T PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (3U) DAY PERIOD, Pavmenis must be made either by cashier's check certified t;hecL~ar money order made oavable and sent to: BAG Home Loans Servicing, LP at R.O. Box 15222, Wilmington, DE 19886-5222. r IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (3Q) DAYS at the date of this Notice, the lender intends to exercise ies rights to sacelerate the mortgage debt. This means that the entire outstanding balances of this debt will be considered due immediately and you may lase the chance to pay the mortgage in monthly installments. if full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attameys to start legal actan to foreclose upon your nwrtgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to Its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will s#ill be required to pay the reasonable attorney's fees that were actuatly incurred, up to $SU.Qf~, However, if legal proceedings are started against you, you will have to pay ail reasonable attorney's fees ac4.ially incurred by the lender even If they exceed $50.0©. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. N you cur: the default within the THIRTY (SO) DAY period, you will not be required to pay attorney's fees, YOU HAVE THE RIGHT TO REINt3TATE AFTER ACCELERATION AND THE RIGHT TO A93ERT IN THE FOREGL03URE PROGEEDING THE NdN-E7tISTENGE OF A DEFAULT OR ANY dTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECL03URE. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If yang Crave not cured the default within the THIRTY (30} DAY period and foreclosure proceedings have begun, you still have the right w cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale, You may da so by paying the fatal amount: then past due, plus any late ar other charges then duo, reasonable attorney"s fees and costs connected with the foreclosure sale and any other costs connected witch the Sheriffs Sale as specified in writing by the lender and by performing any other requirements underthe mortgage. Curing your default in the manner seR~ farft- in this notice will restore your mortgage to the same paaition ae If you had nearer defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE - ft is estimated that the earnest date that such a Sheriff's Sale of the mortgage properly could be held would be approximately six {6) months from the date of this Notice. A notice of the actual date ai the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. Vau may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender. BAG Norrre toar-a Sarvicfrtp, LP Address: P. O. Sax 6606Z-4 Dallas, TX T526frD694 Phone Numtser: 'f-Sr'~B69r-UiQ2 Fax Number: 'faB97-230-88't? Contact Person: MS TX2-S7T-07-?3 Aiterr8iorr: toat~ Counselor I:msii Address: To ensure secure email communications please log an to the BAG Home Loans Servicing, LP Webslte at www.bankafamerica.com and email us by navigating through the Customer Service link provided EFFEGT OF SHERIFF'S SALE -Yau should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy ft. g you continue to live in the property after the Sheriff's sale, a lawsuit tcs remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may sell or transfer your home Ua a buyer ar transferee who wiu assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to ~ at the sale and that the other requiremertts of the mortgage are satisfied, YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF'. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION A5 IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT, (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.} TO ASSERT THE NONEXISTENCE OF A DEFAULT IN AMY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER.. THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELEEVE YOU MAY NAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANNSRUPTCY LAW, Your loan is in default. Pursuant to your loan documents. BAG Home Loans Servicing, LP may, enter upon and conduct an inspection of your property. The purposes of such an nsped[ian are to {i} observe the physical condetion of your property, iii}verify that the property is occupied andfor (ill} determine the identity of the occupant. If you da not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization. securing the property, and ~f .,iw BA4: Hume toaras Servicing, LP is a sresidiary of Bank flt America. NA. 71,13 8c:57 3,474 4838 81St valuation services) may be taken. The costs otthe above-described inspections and property preservation etYorts will be charged to your account as provided in your security instrument. tf you are unable LA cure rile default an ar before September 8. 201Q, BAC Hame Loans Seraicing, LP wants you to be aware of various options that may tee available to you through BAC Hame Loans Servicing, LP to prevent a foreclosure sale of your property. Far example: • Repayment Plan; K Is possible that you may be eligible for some form of payment assistance through BAG Home Loans Servidng. LP. Qur basic plan requires that BAG Home Loans Servicing, LP receive, up front, at least '}~ of the amaurrt necessary to bring the account current, and that the balance of the cwerdue amount tie paid, along with the regular mortihiy payment, over a defined period of time, Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can tae lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative„ however„ is limited to certain ban types. Sale at Your Property: Or, rf you are willing to sell your home in order to avoid foreclosure, iL is possible that the sale at your home can be approved through BAG Home Loans Servicing. LP even if your home is worth less than what is owed an it. • [3eed-in-Lieu: Car, if your property is free from other liens or encumbrances. and if the default is due tb a seriausfinaneial hardship which is beyond your can7trol, you may tie eligible to deed your property direcriy to the Nateholder and avoid the foreclcxsure sale. ff you are interested in discussing any of these foreclosure alternatives with BAG Home Loans Servicing, LP, you must contact us immediately. Please be advised that your decision to pursue any at these options is striictly voluntary. tf you request assistance, BAG Hame Loans Servicing, LP will need to evaluate whether that assistance will be extended to you. Nn the meantime, BAC Hame Loans Servicing„ LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failune~ to bring your loan current or to enter into a written agreement by September $, 2€11 C2 as outlined above will result in the acceieratian of your debt. Time is of Lhe essence. N you have any questiarts concerneng this notice, please contact Loan Counseling Center immediately at 1-8Q0-689-(l1 f32. 3AC Hame Fans Serviang. LP is a subsidiary of Bank of America. N.A. 7113 8~5? 1.474 4838 83,3E .Attachment: kemization of Charges and Fees Monthty Charges: 05{1)1{2©1© - O${3t{2t}tQ Late Charges: ©5{Ot{21)10 - C)?{3tf2Qt0 Other Charnes. llncallected Late Charges: Partial Payment Balance: '~ TOTAL DUE: $t,3fi9.2t 556.91 ~;.~; 5 t i4.73 $Q.t)0 t$0•QQ1 #5,647.87 BAG Home Loris Servicing, LP ~ a subsd~ery of Banc of America. N.A. {" ClNSL.tMER C'RE1~IT CY`li ~NSFI INiG AGENt``IES SF_RVING YC7T.JR €:~f)[_fh~ Tl' CUMBERLANd COUNTY PHFA AAarrtA Gounty ir+terfaittt r~ousang Auttxxtty i.aveahlp, tnc. 21 a Noah Front Street 40 E High Street 2320 North SCts Sleet Harrisburg. PA 17110 Gettysburg.. PA 17325 Harrisburg, PA 17110 717.780.3940 717.334.151 ~ 717'.232.2207 800.342.2397 CCCS b! Western PA Community Ac.tuxy Gammist+lon ~ Capba! Meranatha 2000 Ungiestown Road Region 43 Philatletptra Axantae Harrisburg, PA 17102 1514 Derry attest Weyneebor'o„ PA 172~t8 888..511.2221 Harrisburg, PA 17104 71T,7fi2.3285 868.511.2227 717,232.9757 ~a~FArnaricalr ~~ !loss lorw PC? Boac f11748 Tesnecc~lz~. GA. g25B9.8t}~ Send Pwynaents #i: P.C7. Box' 15222 +Mrnr~tan. PE 1k3HA6-5222 Sand Corrospa~ndence ro: PO E3nx SiTl7, MS *aV3149 Sir»I valley. CA 83U85 • ~__ PRESORT ~1-81-Chess Mafl 11.5, Postage sntl ~e•as Paid W50 71,13 825? 1474 438 8148 7171 bt160~3-7 Il~li111111~~~11" Illli~•i~~ll~i~l~lli111111'lllli~l„11~111~1~11 Kimbe-iy B Sattseverrx7 4 VICTQR LN MECHANICSBURG, PA '17450-2551 ~HawNof,Anlerie~ MOa1R I.OMIi P. t?. Bax BBD69A Dallas, T7G 7S7%-C~i94 SaKnt! P~ty#rtenf5 rt.- A,O. Sox 75T22 W~irrurx~rmn. D£' ?9B9rs-5772 August 9. 2d 1 D Kimberly B Sanseverino 4 VICTOR i_nl MEGHAIVICSBURG, PA tT050-155t Gertlfied Mail. 7113 8257 1474 48'38 8148 Return Riot Requested Regular Mail Account No.: 767576642 Property Addross: 4 Victor Ln Mechanicsburg, PA 17ASt3 Cumsnt Servlcer: BAC Home Loans Servicir~, LP AGT 91 NC~TIGE T~-KE ACTIt~N TO SAVE 1~f~UR HC1ME FRC)M TC3F~EC~LCJ~SUI~E This Notice contains important k-gal information. H you have any questions, representatives at the Consumer CredK Counseling Agency may be abie to help explain it. You may also want to contact an attorney in your area. The Motel bar association may be able to help you find a lawyer, LA NOTIFICACIQN EN AD.IUNTO ES DE SUMA IMPORTANCtA. PLIES AFECTA SU DERECHO A GONTINUAR VMIENDO EN SU CASA. Si NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCIbN INMEDWTAMENTE LLAMANDO ESTA AGENCU- {PENNSYLVANIA HOUSING fiNANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRLSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALYAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU H~OTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERtSERVICER Rf>AMrR in•[ruc[ionc • rr7sice yar check pay~adeen BAG ttorna toss sgvvn{7. LP • rJOr1~15ef1~G98h • FSoaaeinGade~~txwW~r vrith ylxlr poyRBM FC< al ft11 tn]IM7 payErtenT p3FfAl3, iMe~al is cwcaielesl at s muMNy rssaee. Atxnrtlngy, hlpieal Ax alt h~i~ rran-ta. Nfvitd~i Fepruenlr. iy caiciYaied ec 3x1€99iJ M snsws+ rgerew,, area}ae+xive ur the scow nasrber of 4oyx in the marsh. ~~~ Fcr aertsi m~nhs, nu~eal w cetrvt9te4 amity ~ rtwe t9te~s d a 3~i oa9 year. Kimberly B Sansaverino 4 Victor Ln Mschanicabura. PA 17iD50 18T'S7 8842 BAC Hcxne Lcaans Serviang, LP s a subBicsry of Bank of America, hi.A. Presee tale 5rcaur 8CxouM rumEer nn eti ctirxit~a er~1 a7resuaxlettce. hnXernsl+ r~rge yqua h°e kJt any FaYrstaM t~lurt'tC~6 G relL~tl fJY iY?Wr'f~n8n7w rni.1#Wq9. sugeet p) 9Wi>vad~ taw, B~At T f 72~ :~A.4fiii1019 Acoocrnt Number. 1875t8i6d2-3 ~IGmberiy B SanSeverino Balance Due iwM charges istecf above. S5.6d?~7 as nt August 9, 2Qt 0. 4 Victor Ln r,ea~ ~ & ~~ .,to„e., on m• n~~g 5[52 olm5 ~.m E. Mecharresburg, PA t705Q Ate, etJJPA? I~"I~111.111'il~lillllll~l.lll.lllllll~~il...' AtAVR#v.4 I~~I-Ii..11i~11~~1 €s~ ,w BAG Home Loans Servicing, LP PO BOX 15222 Wilmington, RE 19886-3222 F"~` 1b751564230(l(iQD5b4757d©m5b4757 t: 58699~058t: 1675 7~6~rti 21" HOMEOWNER'S EMERGENCY 11AORTGAGE ASSISTANCE PROGRAM se ~.....e. C ~'AO csuwurrws wceascrwurc wu~r1.1 [•aN SayE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTCisiiE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERLiENCY MORTGAGE ASSISTANCE AGT OF '1983 (THE "ACT"i, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTNER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORr-_RY STAY OF FORECLOSURE -Under the Act. you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30) days from the date of this Notetxe. During that time You must arrange and attend a`lace-to-face" meeting wtth one crf the caansumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY r'ONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer ct~edlt counseling agencies listed at tfie end of this notice. the ierWer may NOT take acxion against you far Thirty (30} days after the date of this meeting. The names. It is only necessary to schedule one face-to-face meeting. Adv'sse Your lender immediatelw at your Irttenuorts. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is en default for the reasons set forth later in this Notice (see following pages for spedflc intarmat3on about the nature crf Your defautt.) If you have treed and are unable to resolve this problem with the lender. You have the right to apply for financial assistance from the Hameawner's Emergency Mortgage Assistance Program. To da so, you must fill out, sign and file a campieted Homeowner's Emergency Assistance Program Application with one of the designated consumer credit oounseling agencies fisted at the end of thes Notice. Onty consumer credit counseling agencies have applications for the program and they wilt assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST lac filed or pastmarfced within Thirty (3D} days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY, IF YOU FAIL TO 00 SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR NOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL. BE DENIED. AGENCY ACTION - Avaitabie funds far emergency mortgage assistance are very limited. They welt be disbursed by the Agency under the eliglbliity criteria established by the Act. The Pennsylvania Housing Financx~ Agency has sixty (60} days to make a decision after It receives your application. During that time, no foreaiosure proceedings will be pursued against You if you have met the time requirements set forth above. You will be notified directly t>y me Pennsylvania Housing Finance Agency of its decision an Your appllcateon. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can stilt apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR. HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAYE YOUR HOME FROM FORECLOSURE. NATURE OF THE DEFAULT • The MORTGAGE debt held by the above lender on your property lacsted at: ~ Victor Ln Mectianecsburg. PA 17050 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS far the following rnarrths and the following amounts are raw past due: Monthly Chases: OSl0112D10 $5.476.84 Late Charges: 05I01d2010 $170.73 Other Charizes: Uncollected Late Charges: $0.00 Uncollected Costs: $O.DD Partial Payment f3alarxe: (SO.OQi TOTAL DUE: fi5,64T.S7 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION [Do not ass If not annlicablel 13A~ Hama Loans Serviang, t.P is a st>bzideary of Bank al Amartca, N.A.. l:-malt use: Fmuif~Yng yaaur a-mail address fvelow wit allow tae fi semi yrxa int9mretfan an your aar~our~. Accxsurn Plumber: tB~5168a2 Ksnbe+du Ig 3ansev~eric~ E-mail address: Maw we post Your payments: I3 aorapted payrneras df pnrrcir>e!i and iatareat wi! be applied u, iha longas* arrL~u>rrdi~ insta~rrterrt due, udeas csthetwise expressly prcA~iMted er limped by law ft }rou subrrrt an arnaunt n acldtiron tcs ycxe sclrrxluled momhly amourr, we wi apply year payrnerds as follows: ii} tnr manthTy paymeMS of prerdpal and reterast. tiij eaaraw daflcianc~ee, tiff 1 late rhargas and rather amounts yarn c:+ue in caxrrectian wMh your loan arr;i (~? h2 reduce the autrotanding prndpar balenae of your loan. Please speatry it you want an additikanal amaum a{apied la tu[rre payments, ra9ter ttswe prtnrapal raduotion PorrEdatsd atrcks: Pnstdal+ad rhedcs wilt ha proceaaed an the date rewrved unlace a lean caunselar agrees ~: honor the dale wmeen nn the check as a condtfon or a repaynNSnt plan. HOW TO CURE THE DEFAULT -Yau may cure the default wRhinTHIRTY (30) DAYS of the date of this r-atice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS ;5,G4T.3T PLUS AMY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30} DAY PERIOD. P smertts must tae made elmer by cashier's ~ti~ harrinsr~ check ar money order made savable and sent to: BAC Home moans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222. r default by tak IF YOU DO NOT GORE THE DEFAULT - If you dD not cure the default within THIRTY (3©} DAYS of the date of mis Notice, the lender intends to earorcise its rights ibo accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immedla#ely and you may lase the chance to pay the mortgage in monthly installments. If full paymertt of the fatal amaurtt past due is not made within THIRTY (30} DAYS, the lender alas intends to instruct its attarrneys to start legal action to fare~cMse upon your nwrtgaged property. IF THE MORTC~GE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. it the lender refers your case to Its attorneys, but you cure the delinquency before the lender begins iagai proceedings against you, you will still be required to pay the reasonable attorney"s Bees that were actually incurred, up to $50.()0, However, if legal pnoc~edings are started against you. You wlp have to pay all reasonable attorney's fees actually incurred by the lender even if they eauaeexl $50.0©, Any attorney`s fees will tae added #o the amount you owe the lender, which may also include other reasonable costs. ff you cure the default within the THIRTY (SQ} DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT T'O REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EiCISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES -The lender may also sue you personalty for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - if you have not cured me default wimin the THIRTY (30} DAY period and foreclosure pttacaedings have begun. you still have the righf to cure the default and prevent the safe at any time up tQ one hour before the Sheriff's Saie, Yau may da so by paying the fatal amount. then past due, plus any Tate ar other charges then due, reasonable attorney's fees and costs cxsnnerbed with the foreclosure sale and any other casts connected with the Sheriffs Sale as speelfied in writing by the lender and by performing any Amer re~qulrements underthe mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as If you had never defaulted EARLIEST POSSIBLE SHERI_FI F'S SALE DATE -his estimated mat the earliest dale that such a Sheriff's Sale of the mortgage property could be held would be approxima#ely six (6} months from the date of tills Notice. A notice of the actual date of me Sheriff's Sale will be sent to you before me sale. Of course, the amount needed to cure the default viii increase me longer you wall, You may find out at any time exactly what the required payment or action will ue by oantacting the lender. HOW TO CONTACT THE LENDER: Name of Lender. BAG lYarrre toart$ Servicl~, L/' Address. P. O, Box 8BOf3t;~4 Dallas; T7C T5268-08#t+R Phone Number: t-80G1-BB9-d9Q2 Fax Number: l~81T-230-+681'1 Contact Person: MS TlC2-ST7-01-73 Attention: Loan Counselor Email Address. To ensure secure email communications please log on to me BAC Hame Loans Servicing.. LP Website at www.bankofamerica.com and email us by navigating through the Customer Service Ilnk provided EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right #o occupy it. ff you continue to Ifve in the property after the Sherft's sale, a lawsuit tca remove you and your furnishings and other belongings cxluld be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may sail or transfer your home to a buyer ar transferee who will assume me mortgage debt, provided that.. all the outstanding payments, +chargss and attorney's fees and costs are paid prior to or at the sale and that the cRher requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT, TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF, TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION A5 1F NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.} TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION E3Y THE LENDER. TO SEEK PROTECTFON UNDER THE FEDERAL BANKRUPTCY LAW. Your lawn is in default, Pursuant to year loan documents, BAC Home Loans Servicing, LP may. enter upon arx3 conduct an inspection of your property. The purposes of such an inspection are tca (i}observe the physical condition of your property, (ii} verify that the property Is ocxupied and/or (III} determine the identity of the occupant. N you do not cure the default prior to the inspection, other actions to protect the mortgagee's Interest in the property (including, but oat limited to, winterization. securing the property, and r_ :!'2~ BAS name l..aans Servicing, LP is a sratrsiriiary of Bank otAmerira, M.A_ 7113 825? 1474 4838 8144 a . valuaEtion servlpes) may be taken. The coats of the aboveiciescribad inspections and property preserwatian efforts will bs charged to your account as provided m your security instrument. If you are unable to cure the default: on or before September 8. 20t0, BAC Home Loans Servicing. LP wants you to be aware of various options that may be available to you through BAC Home Loans Servicing, LP to prevent a foreclosure sale of your property. For example: • Repayment. Plan: tt is possible that you may be eligible for some form of payment assistance through BAC Home Loans Servicing, LP. f?ur basic plan requires that BAG Home Loans Servicing, LP receive, up front, at Ieast'f~ of the amount necessary to bring the account current. and that the balance of the overdue amaunrt be paid. along with the regular monthly payment, aver a defined period of time, Other repayment plans also are available. • Loan Modification: Or. it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the Interest retie and then adding the delinquent payments to the current. loan balance. This foreclosure alternative, however, is limited to certain ban types. • Sale of Your Property: Or, 'rf you are willing fo sell your home in order to avoid foreclosure, i# is possible that the sale of your home can be approved through BAC Home Loans Servicing. LP even if your home is worth less than what 6s owed on N. Deed-in-Lieu: Or. `rf your property is free from other liens ar encumbrances. and if the default is due tb a seriousfinancial hardship which is beyond your control, you may be eflglals to deed your property directly to the Noteholder and avoid N1e toreclosure sale.. ff you are interested in discussing any of these foreclosure alternatives wtth BAC Home Loans Servicing, LP, you must contact us immediaUely. Please he advised that your decision to pursue any of these options is stricty vo~ntary. H you request assistance, BAC Home Loans Servicing, LP will need tp evaluate whether Neat assistance will be ex#ended to you. in the meantime, BAC Home Loans Servicing, LP will pursue ail of its rights and remedies under the loan documents and as permitted by law, unless tt agrees athenroise in writing. Failure to bring your loan cement or to enter into a written agreement by September 8, 2010 as outlined above will result in the ac©aleration of your debt. mime 1S of the essence. If you have any questions conoarning this notice. please contact Loan Counseling Center immediately at 1-$00-669-0102. i3{4C Hums loans Senriang, t.P is a sui6sidiary of Bank of Arierioa, N.A_ 7L13 957 3.474 4938 8149 Attachment: Kemizatian of Charges and Fees nnanthty cnarne5: E15101t201t1 - 0$J31l2010 Late Charges: 05/01d2010 - 07d31J2010 Clther Charges: Uncatiecteci Late Charges: Partial Payment Balarxx~: TOTAL DUE. $1,389.21 $56.81 $5.478.84 $1T0.73 $0.00 f X0.00 } ~5,847.5T BAC Home teens Serviang.. LP a a sukaiciery of Bank of America. N,A. ~ ~ ~ M C'(7N.'~L.TIVIFR CRFDI'T CC3UNSEI.ING ACTFI~TC`IF..S SERVING ~'l")LIR f'C7~LF?~rT4' CUMBERLAND CaUNTI' P9iFA Addme; Caunty intertraith Hau~ng Autrxxtty t<tnveahip, tnc, 211 NaAt1 Front SheeE 4Q E Hagh Sheet 2320 A.tarih 51n Sheet Hsrrishurg, PA 17110 Gettysburg. PA 17325 Harrisburg PA 17110 717.780.3940 717-334,1518 717, 232.2207 8t?0,342,23g7 CGCS or tNastem PA Ccxnmun9ty Action Comm~ssicsn of Ga~xdat Maranartha 2000 Ungtestawn Roa€t Raglan 43 Phltactetpttia Avarxre HarHeRatsg, PA 17102 1514 Derry Street. 4Vaynest'AOro, PA 17268 888..511.2227 Harrfsbarp, PA 1710+6 717.762.3285 888.5 i 1.2227 717.232.9757 V E R I F I C A T I O N I, the undersigned, am attorney for the Plaintiff and am authorized to make this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents. The statements made in the foregoing pleading are true and correct to the best of his/her information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES , P .,e'. BY: Attorney! P: UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQIIIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 ADAM L. RAYES, ESQUIRE - ID #86408 c DANIEL S. SIEDMAN, ESQUIRE - ID #306534 ~~ r~ JEROME B. BLANK, ESQIIIRE - ID #49736 WOODCREST CORPORATE CENTER c ~ 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 y n 856-669-5400 pleadings@udren.com v~ BAC Home Loans Servicing, LP :COURT OF COMMON PLEAS ~ f/k/a Countrywide Home Loans :CIVIL DIVISION -G Servicing LP €Cumberland County 475 Cross Point Parkway Getzville, ~ 1P i ~ ~ ~ r ~ la ntiff € NO. ~t (- ~ ~' ~` r ` a `' v v. Jason M. Sanseverino Kimberly B. Sanseverino P.O. Box 614 Camp Hill, PA 17001 Defendant (s ) ENTRY OF APPEARANCE TO THE PROTHONOTARY: 0 ~ ~ 0 -~ "'o n~i ~'~~ ~ o ~ o~+n Zn 0 0 ~, ~,, a N ~ -G Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire; Chandra M. Arkema, Esquire; Adam L. Kayes, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire and Jerome B. Blank, Esquire on behalf of the Plaintiff, BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP in the above-captioned matter. UDR BY: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor of c+frlo'? 144 FILED-OFFICE OF THE PROTHONOTARY 2011 JAN 24 AM 10-- 0 ? CUMBERLAND COUNTY PENNSYLVANIA BAC Home Loans Servicing, LP vs. Case Number Jason Matthew Sanseverino (et al.) 2011-82 SHERIFF'S RETURN OF SERVICE 01/06/2011 07:41 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 6 2011 at 1941 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kimberly B. Sanseverino, by making known unto herself personally, at 4 Victor Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. <-? RYAN BURGETT, D 01/19/2011 04:25 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2011 at 1625 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jason Matthew Sanseverino, by making known unto himself personally, at 94 Ashford Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $66.50 January 20, 2011 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF c; CouMySuite, Sherdf Taeosoft Irc, UDRE14 LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP 475 Cross Point Parkway Getzville, NY 14068 Plaintiff V. Jason M. Sanseverino 94 Ashford Drive Enola, PA 17025 Kimberly B. Sanseverino 4 Victor Lane Mechanicsburg, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2011-82 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: :z Gs M cn tv ? ? < c:) 3> rte a . ... X- r a (5 M co ? Kindly enter judgment in favor of the Plaintiff and against the Defendant (s) Jason M. Sanseverino and Kimberly B. Sanseverino 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 Interest Per Complaint From 1/1/11 to 8/16/11 Late charges per Complaint From 1/1/11 to 8/16/11 Escrow payment per Complaint From 1/1/11 to 8/16/11 $184,621.75 7,011.00 455.28 1,847.36 TOTAL $193,935.39 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BYE Attorneys for Plaint ' f ?? ? •, t?? v? ? q? s ?y, od ?d a 3 DAMAGES ARE HEREBY ASSESSED AS INDICATED 1(401 R? ac.3y 8`( DATE : as tt IN?? Yka+' 16t PRO ` PR4 '!? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 plleadinga@udren.com BAC Home Loans Servicing, LP COURT OF COMMON PLEAS f/k/a Countrywide Home Loans :CIVIL DIVISION Servicing LP .., 475 Cross Point Parkway :Cumberland County cr Getzville, NY 14068 i Plaintiff ce.. ,..?, . ? ? ..... .?J . CD art ? Jason M. Sanseverina Ki b l i p9 h ° ?-.? ° ° m er y B. Sansever no NO. r+ E P.O. Box 614 Camp Hill, PA 17001 rv Defendant (s) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AVISO Le han demandado a usted en la carte. Si usted quiere defenderse de estas demandas expuestas en !as paginas siguientes, usted tiene f f C? ? ?l G?3.1 17L SHERIFF`S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff u?a?4?{yy kl: ??RC?H?err??? Jody S Smith Chief Deputy t Richard W Stewart Solicitof Orc-IC=. OF T-!2 ::MFF SAC Home Loans Servicing, LP vs. Jason Matthew Sanseverino (et al.) Case Number 2011-82 SHERIFF'S RETURN OF SERVICE 01/06/2011 07:41 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 6 2011 at 1941 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kimberly B. Sanseverino, by making known unto herself personally, at 4 Victor Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETI', D" Y 01/19/2011 04:25 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2011 at 1625 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jason Matthew Sanseverino, by making known unto himself personally, at 94 Ashford Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $66.50 January 20, 2011 RYAN BURGETT, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF UDREN LAW OFFICES P C ATTORNEY FOR PLAINTIFF F WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10121013-1 BAC Home Loans Servicing, LP f/k/a :COURT OF COMMON PLEAS Countrywide Home Loans Servicing LP :CIVIL DIVISION Plaintiff ;Cumberland County V. Jason M. Sanseverino Kimberly B. Sanseverino NO. 2011-82 Defendant(s) TO: Kimberly B. Sanseverino 4 Victor Lane Mechanicsburg, PA 17050 Date of Notice: February 9, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TA.L SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL SED FOR THAT PURPOSE. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 #10121013-1 BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP Plaintiff V. Jason M. Sanseverino Kimberly B. Sanseverino Defendant(s) TO: Jason M. Sanseverino 94 Ashford Drive Enola, PA 17025 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2011-82 Date of Notice: February 9, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249.-3166 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. /'"--2 Woodcrest Corpora rater 111 Woodcres , suite 200 Cherry Hill, New Jersey 08003-3620 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP =COURT OF COMMON PLEAS f/k/a Countrywide Home Loans ?CIVIL DIVISION Servicing LP :Cumberland County 475 Cross Point Parkway Getzville, NY 14068 `MORTGAGE FORECLOSURE Plaintiff V. :NO. 2011-82 Jason M. Sanseverino 94 Ashford Drive Enola, PA 17025 Kimberly B. Sanseverino 4 Victor Lane Mechanicsburg, PA 17050 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states, upon information and belief, that the above Defendant (s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Age. Residence: Employment: Defendant: Age. Residence: Employment: Jason M. Sanseverino Over 18 As captioned above Unknown Kimberly B. Sanseverino Over 18 As captioned above Unknown This statement is made subject to the penalties of 18 Pa. C. S . §4904 relating to unsworn falsification to authorities. C:?? Nam e : Title: Company: UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP : COURT OF COMMON PLEAS f/k/a Countrywide Home Loans : CIVIL DIVISION Servicing LP : Cumberland County Plaintiff V. : MORTGAGE FORECLOSURE t? c°a Jason M. Sanseverino C NO. 2011-82 C= -- "7Y Kimberly B. Sanseverino r-r,M =C ?? Defendant (s ) ? C5 PRAECIPE FOR WRIT OF EXECUTION '? , TO THE PROTHONOTARY : ?n -, Uo Please issue Writ of Execution in the above matter: Amount due $193,935.39 Interest From 8/17/11 3,474.75 to Date of Sale December 7, 2011 Ongoing Per Diem of 30.75 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. Wte. 80 pr ?a.co Lj l y . oa u << a, sa 4 S CD Atto net's for Plain i ZUX s0 Lj-- Ck.# NO 3 ?4-ab3V4y \)jji ? c? I L a?suQ UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans S FOR PLAINTIFF ervng, LP :COURT OF COMMON PLEAS f/k/a Countrywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Jason M. Sanseverino ::NO. 2011-82 Kimberly B. Sanseverino Defendant (s) CERTIFICATE TO THE SHERIFF I HEREBY CERTIFY THAT: c-, C -- rn r=i x? c? M_ f- -0 - U') it N r 1 ? I— CD r < 73' (7 c) -ri C) C7 n I. The judgment entered in the above matter is based on an Action: A. In Assumpsit (Contract) B. In Trespass (Accident) X-C. In Mortgage Foreclosure D. On a Note accompanying a purchase money mortgage and the property being exposed to sale is the mortgaged property. II. The Defendant(s) own the property being exposed to sale as: A. An individual X B. Tenants by Entireties C. Joint Tenants with right of survivorship D. A partnership E. Tenants in Common F. A corporation III. The Defendant(s) is (are): X -A. Resident in the Commonwealth of Pennsylvania B. Not resident in the Commonwealth of Pennsylvania C. If more than one Defendant and either A or B above is not applicable, state which Defendant is resident of the Commonwealth of Pennsylvania. Resident: UDREN LAW OFFICES, P.C. Attorneys for Plaint 4tk+k_,r 1?aLo-K I PA J?D 30 ct? UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP `:COURT OF COMMON PLEAS f/k/a Countrywide Home Loans ;CIVIL DIVISION Servicing LP :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Jason M. Sanseverino NO. 2011-82 Kimberly B. Sanseverino Defendant(s) C E R T I F I C A T E c"a d ' - 3>C3 ::r C3 n =;- ;-? .1a ors: ? .r Cwt I hereby state that as the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 36 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. B Attorneys for Plain i i UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com BAC Home Loans Servicing, LP :COURT OF COMMON PLEAS rn`CX) ? f/k/a Countrywide Home Loans :CIVIL DIVISION C- T-j Servicing LP 'Cumberland County _ fro Plaintiff ?CZ) V. :MORTGAGE FORECLOSURE 3> 7X o r Jason M. Sanseverino € NO. 2011-82 MC) `A CDM Kimberly B. Sanseverino Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP, Plaintiff in the above action, by its attorney, Udren Law Offices, P.C., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 4 Victor Lane, Mechanicsburg,.PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Name Address Jason M. Sanseverino Kimberly B. Sanseverino 94 Ashford Drive Enola, PA 17025 4 Victor Lane Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address None 4. Name and address of the last recorded holder of every mortgage of record: Name Address BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP 475 Cross Point Parkway Getzville, NY 14068 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section Commonwealth of PA, Department of Revenue 13 N. Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 4 Victor Lane, Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. k DATED: August-l , 2011 UDREN LAW OFFICES, P.C. BY. Attorneys for Plai f vtp -6N r C>A to cf(d UDREN LAW OFFICES, P.C. ATTORNEY WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com FOR PLAINTIFF BAC Home Loans Servicing, LP :COURT OF COMMON PLEAS f/k/a Countrywide Home Loans :CIVIL DIVISION Servicing LP :Cumberland County Plaintiff V. 'MORTGAGE FORECLOSURE Jason M. Sanseverino :NO. 2011-82 Kimberly B. Sanseverino Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jason M. Sanseverino 94 Ashford Drive Enola, PA 17025 C-a ?rn n D as ? Your house (real estate) at 4 Victor Lane, Mechanicsburg, PA 17050 is scheduled to be sold at the Sheriff's Sale on November 18, 2011, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA , to enforce the court judgment of $193,935.39, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: -c r-? G7 -ry 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) M YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-82 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, L.P. Plaintiff (s) From JASON M. SANSEVERINO AND KIMBERLY B. SANSEVERINO (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: $193,395.39 L.L.: $.50 Interest from 8/17/11 to Date of Sale December 7, 2011 ongoing per diem of $30.75 - $3,474.75 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $199.00 Other Costs: Plaintiff Paid: Date: 8/22/11 David D. uell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: HEATHER RILOFF, ESQUIRE Address: UDREN LAW OFFICES, P.C. 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 309906 1'j IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL DIVISION BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans _77 Servicing LP 7? Plaintiff '` NO. 2011-82 V. Jason M. Sanseverino r- Kimberly B. Sanseverino Defendant (s) O R D E R w, r AND NOW, this day of 2011, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith investigation attached hereto, it is hereby ORDERED that service of the Notice of Sale upon Defendant(s), Kimberly B. Sanseverino, shall be complete when Plaintiff or its counsel or agent has mailed true and correct copies of the Notice of Sale by certified mail and regular mail to the last known address of Defendant (s) , Kimberly B. Sanseverino at P.O. Box 614 Camp Hill, PA 17001 and by posting the mortgaged premises located at 4 Victor Lane, Mechanicsburg, PA 17050. BY THE COURT: J. Co Mailers vu re, t') 0(?S P lp?3lo I ff 9J s SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - - Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ©??xir of ?u'?brr,r?h? FILED-OFFICE O THE PROTHONOTARY 20I1 DEC 22 PM 2: 26 CUMBERLAND COUNTY PENNSYLVANIA BAC Home Loans Servicing, LP vs. Jason Matthew Sanseverino (et al.) Case Number 2011-82 SHERIFF'S RETURN OF SERVICE 09/28/2011 10:19 AM - Deputy Shawn Gutshall, being duly sworn according to law, attempted service to the Defendant, to wit: Kimberly B. Sanseverino at 4 Victor Lane, Silver Spring Township, Mechanicsburg, PA 17050. The address was found to be vacant. 10/07/2011 Michelle Gutshall, Deputy, 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 4 Victor Lane, Mechanicsburg, Cumberland County. 10/11/2011 11:32 AM - Deputy Michelle Gutshall, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jason Matthew Sanseverino at 94 Ashford Drive, East Pennsboro Township, Enola, PA 17025, Cumberland County. 11/04/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kimberly B. Sanseverino, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 4 Victor Lane, Silver Spring Township, Mechanicsburg, PA 17050, address is vacant, deft. did not leave a forwarding at the post office. 12/05/2011 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/1/2012 12/21/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $985.18 December 21, 2011 SO ANSWERS, RON F ANDERSON, SHERIFF c? ?U icd C D M72(w.:24 P"Vyr &f qr? p) CnuntySuite Shenf . Teleosoft . fnc. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003 856-669-5400 BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing LP 475 Cross Point Parkway Getzville, NY 14068 Plaintiff V. Jason M. Sanseverino Kimberly B. Sanseverino P.O. Box 614 Camp Hill, PA 17001 Defendant(s) PRAECIPE TO WITHDRAW JUDGMENT A] TO THE PROTHONOTARY: ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS'?' i _ .?_ . CIVIL DIVISION Cumberland County NO. 2011-82 zi STD DISCONTINUE WITHOUT PREJUDICE Kindly mark the above captioned matter JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. LZ Attorney for Plaintiff DATED : April 26, 2012 L Wes„ Es.. ELIZAB?ID 77788 10121013-1 CA} ?q',5bl 8 a 4 tj R-7L4 gs