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HomeMy WebLinkAbout11-4326SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929 LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF VS James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: I l-y 3a? G "? COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE % - -? ?4- 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. 0M 49A oo? ck# 3looa71 ' 'au a591 17 NOTICIA LE RAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECRA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929 LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 DEFENDANT NO: COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Merrill Lynch Credit Corporation, the address of which is, c/o PHH Mortgage Corporation, 2001 Bishops Gate Blvd., Attn: Mail Stop SV-01, Mount Laurel, New Jersey 08054, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: Merrill Lynch Credit Corporation (s): James E. Morrison Mortgagor (b) Date of Mortgage: July 7, 2006 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1958, Page 2167 Date: July 13, 2006 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DeNARDO, LLC Date: BY: Attorneys for Plaintiff S & D File No. 11-039515 Prepared By: Rolanda Gllkle-Carrethers, Merrill Lynch Credit 5201 Gate Parkway Jacksonville, FL 32256 (800) 443-6184 Return To: Merrill Lynch Credit Corporation 2001 Bishops Gate Blvd, Mount Laurel, NJ 08054 Parcel Number: 29-15-1247-060 P.0tCERT P. t 2006 JUL 13 RM 10 94 en. iOdsw"a.+e"c tMl t?,,,Na.1. n1?`>u "iw`r..r.r, uYl/4eS4 ----- Commonwealth of Pennsylvania ---- Spas Above "Is Use For Retarding Data OPEN-END MORTGAGE This Mortgage sec um %ture advances 1. DATE AND PARTMS. The data of this Morigago (Security Insh=eat) is Ju iy_ 7,_ 2006 and the parties, their addresses and tax identification numbers, if required, are as follows: -- - - - - MORTGAGOR: James E Morrison, A MARRIED PERSON 30 EAST SLATE HILL R D, CARLISLE, PA 17013 © If chocked, refer to the attached Addendum Inco po ed heroin, for additional Mort, ? . signatures and acIcnowledpwts. LENDER: Merrill Lynch Credit Corporation 5201 Gate Parkway Jacksonville. FL 32256 2. CONVLTANCE. For good and valuable consideration, the receipt and su>lliclenly of which is admowtedged, and to secure the Se urod Debt (defined below) and Mortgagor's pcrformuco under this Security Instuvman4 Mortgagor grants, bargains, conveys and mortgages to Lendar the foilowing described property: See Attached PBINBYLVANIA - HOME EQUITY UNE OF RA®IT WOUGAGE ow mR wmA, mw Q Fm (page t of s) 1441 ariio arMW"a Ina. &. CkW. MH Fam oCM6ar04"A 611012004 6(PA) (04011 v11P Md"We S iutl M una (4005:1-7211 SL.* 1400W I l i BK I '9 5 8 PG 216 7 Etoii6t 111411 k " Vol J ? The properly is located in ............. CUMBERLAND ............. at 30 EAST STATE ............... .............. ress) (City) Pennsylvania (Add 17013 Together wiW (ZIP Code) - oil rights, easements, appuurteseaacea, royalties, mineral righ oil and gas riches, all water and riparian rights. ditches, and water Kock and all existing cad future linprafgmeats, ,vueturoa, Stdereer. old f9placements that may now, or at any time In the future, be part of the real estates described above (all rcfarad to as "Property)) MAXWUlW OBUGATION 1iAW. The total p1cipal anhount seamed by this Security Instrument at any one time shall not exceed S l OQ, 000 , 00 _ . This limitation of amount does not Include interest and other feces and charges validly made pursuant to this Security lastrumeaL Also, this iiahitation does not apply to. advances made under the terms of this Security . all react to protect Lender's security and to perform any of do ewveeagais contained in this Security Inatrrmsenk SECURED D19BT AND FUTURZ ADVANCZ& The tarn "Secured Debt" to ddhW as follows, A. Debt Incurred Mader the terms of all promissory note(s), contract(s). panusty(ies) or other avtdence of debt described below and all their vac adona, renewals, modifio stienn or substitutions. (Your most spsef/leaily tdennlo the debt(s) seewhrd and your should lnalad, the final maturity data of such debt(s).) As Indicated in the home equity line agreement dated 7/7/2006, with a maturity date of 7/7/2036, B. All lhture advances ftom Lender to Mortgagor or oil= future obligations of Mortgagor to Lender under any proanluory note, oontract, guaranty, or other evidence of debt eareautted by Mortgagor in favor of Lander aft this Security instrument whether or not this Security Instrument is speolHealiy refamoed. If more than one person s l$= Security Imetreaarmt, each Mortgagor agree that this Security Instrument will scoure an hturo advances and Mai obligations that are given to or Insured by my one or more M r, or say one or more M?gor and others. All hrtuure advances and other Rowe obN r' are smwW by this Security Instrument even though all or phut may tat yet be advomA An lid= advam ad other thture obligations are scoured as if made on the data of this Security Instrument. No1bhq In this Security Instrument shall constitute a cotnmibuent to rake addltieaal or Uwe loans or advances In any amount. Any such commitment must be agreed to in a separate writing, C. AN other obligations Mortgagor owes to Leader, wbialt may late arise, to the latent not p account rohibited by law, Lrolndlmg, but not limited to, liabilities for ova* WW relating to arty deposit agreement between Mortgagor and Leader. D. AN additional sum advanced and mcpa?= incurred by Lem for insuring, Odwwiw 17e?g• the PeLgwrty ®d its value and any other sums edvanccd and for incurred by Leader under the terms of this Security InmumeaL In the O vent that Leader fails to provide any required notice of the right of resoiagio% Leader waives Wit, eau security Interest lathe Mortgagors principal dwelling that is created by this Swan* 1 a" 04*W 014eUn9, hn, eR clad, YU r•«m OrP-MTO PA 91169004 (Pop 2 of e) MjW9-#MA) 194091 8K 1958PG2 E 68 S. MORTGAGE COVSKAMS. Mortgagor agrees that the covenants in this "on are material obligations under the Secured Debt and M Security Instrument. If Mortgagor breaches say axaveaaut In this section, Lender may refuse to make additional extensions of credit and reduce the credit limit. By act c mrcWng either ramody on Mortgagor's breach, Lender does not waive Larder's right to later consider the event a breach If it happens again. Paymuts. Mortgagor agrees that all payments under the Secured Debt will be paid when due and in accordance with the terms of the Secured Debt and this Security Instrument. Prior Security Iaterats. With regard to say other mortgage„ deed of t uvk security agreement other lien document that created a prior security interest or encumbrance on the Property, Mortgagor agrees to matte all psymcata when due and to perform or comply with all covenants. Mortgagor also agras not to allow arty modilication or cdenston of, nor to request my fiduro advances under, note or agreement secured by the lien document without Leader's prior wmittea approval. Claims Against Title. Mortgagor will pay oil tastes, assessments, lieaa, encumbrances, have payments, ground rants, utilities, and other cb aqn relating to the Property when due. Leader may require Mortgagor to provide to Leader copies of all notices that such amounts are due and the roccipte evidencing Mortgagor' a paymait; Mortgagor will defend title to the Property against any claims that would impair the lien of this Security Instrument, Mortgagor agrees to assign to Leader, as requested by Lender, any rights, claims or defenses Mortgagor may have against parties who supply labor or materials to maintain or improve the Property. Property Condition, Alterations and Lgwwfion. Mortgagor will keep the Property in good condition and make all repairs diet are reasonably necessary. Mortgagor shall not commit or allow any waste, impairment, or deterioration of the Property. Mortgagor agrees that the nature of the ocaampaney and use will not substantially change without Leader's prior written oonseuL Mortgagor will not permit my change In any license, restrictive oovenant or coacment without Lender's prior 1r,- consent. Mortgagor will no ft Leader of all demands, praceadings, claims and action Mortgagor, and of any loss or damago to the Property. Lender or Lender's agents tray, at Lender's option, enter the Property at any reasonable time for the purpose of Inspecting the Property. Leader aholl give Mortgagor notice at the time of or before an Inspection specifying a reasonable purpose for the imspietlon. Any Inspection of the Property shall be entirely for Leader's benefit and Mortgagor will In no way rely on Lender's InVccoon. Authority to Perform. If Mortgagor fails to perform any duty or any of the covenants eattsimtd is this Security Instalment, Leader may, without notice„ perform or assure them to be performed. Mortgagor appoints Lender as attorney in fact to sign Mortgwem name or pay sty mtmmt rasa my paribrmanoa Lando' a right to perform for Mortgagor shall not create an obligation to perform, and Larder's failure to perform will not preclude Lender from exercising any of Leadef s other rights under the law or this Security loWument. LeseOufti CandanNuma; Planned Unit Deveiopmeate. MortMor agrees to comply wi3 provisions of any lease If this Security Instrument is on a leasehold. If the Property includes a unit in a condominium or a plarmed unit development, Mortgagor will perform all of Mortgagor' a duties under the coveomts, by-laws, or regulations of the condominium or planned unit development. Condemnation. Mortgagor will give Leader prompt notice of any pending or threatemed action, by private or public entities to purchase or take any or all Of the Property through condemnation, eminent taw ex*- syd"s, ant, aL Cloud, RN Form OCROnsm 11104004 (Ove 3 or any 10 40A) (1401) VA 1958PG2 169 domain, or any other mesas, MortgeSor wWorizes Intervene in M he aabive described =dc= or oWum MarlSagor assigns tD ?Bmpr's nice is any of ChW to daasrges 001111000d with a ??.4 or, ott Such er Wdpg of t all prooeor may Peda oet of of this xWvd or proceeds shall be eonsldered Payrtratta and w1U be aPF as Property. Instrument. qty +?reem This assiment of aat Or Other lien d Wit, °Vbject to We'"" of MY Pdo Provided dee&h S.Oaay d of Vas. 1'asatrr 1 Mortgagor shall keep Property insured ag.inst loss end risks reasonably aYaoeiatod with the Pro* flood, gwft and other hasards maJrttatrred io the aaraunts and for the perty due to its typo and iocmion, Thle iasuraooe shall br the Preceding two saatences can chap Pe during th that e to Lends required. aced LDebtender no hull p War, to providing We faauraace shall be chosen urMi Hof the Securod panoe carrier ortIpw Lelldgeg s* withheld, If Morino al to mWntWns? I to Leader's approval, which shall not be oP e4 obtain coveerW to protectLergoes rights Inv heSp o" &swMd eb. Leads this Smaity boirm ant Pe+ty aocaediag to the cermn U1 All lnsuraaoe Policies and renewals shall be maptabis to Leader and 'rWP do"" s =don whtermicaff applicable, "loss P4Ye° clam. MvrlSagor shall mInclude uaodiatdy standard nodfy Lender sadsdom renewals. If Leads regoLw; M nsumm or AW hare the right to hold the llatea pres and nrtawal notion. Upoaoloes, r Wl y giv"to Lander aq receipts of paid carries and Leader. Leader ragor shall give immodiate notice to the insmanoe Tier and Led nmY make Proof of loss if not made imp = of the o ?d in writing, all insurance Procesda shall be spPlted to the reatoratim or repair Unlesm oPortipor to the Sma-ed el II [Lot eruat d whether or not then due, at Lenders option, A" iita of Proceeds to riaaP postpone the due date of the sehedahsd Opp tims th Leader, e amount of any Payment, Any excess will be paid to the Payasis nor dun phred by Pw? befilie the s right 10 any Wwmce Paltoka and proceeds ?t yft Pr0? acquIettlon shall pass to Lead, to the o rtent of the ft ffom dirge m the before the acquisition Seotaed Debt itamR Pb"dd ndAdditiopal Doeataeata, Mortgagor will Provide to Lardw u ormattoa Lender nW dean reasonah P? roes tot, auy deliver, and late spy additional documents or certifications that Lander Mortgagor pn dgto may consider necessary to a Mortgegor's obligetiom under this y I lrratrttm an 01111111 On cpa dy Security eits and d Lando Larder's der's 6, WARRAM OF T Tr" Security warrants that Mortgagor is or will be law[W ego" Co the eyed ??akswent ad has the right to i ? o Mind of the warrants that the property s ben Ivey, sell, and DUN ON 0 bbra was ofr d, M Ply is uneatarm "Cept fm, 7. 04 U• Lender may, at its option, declare the outtre 'l a or l"liatdy due cad pWAIc upon the amstlon of; or contrad far the p?a?e wed to be parg of the C.A.R. S9iI applieabla ? This right to subject b the raMctiom impos a or sale of 8. 019FAULT. Mort by federal law S+gor will be. In default if may of the fallowlag occur; Socured Debt B open end home orrower ewes In frwd or material epresaetation in connection with the Paymaats. Any Couns"er Bmovmr On Pgw? Debt that is as open sad bane equity plan fitV to make a payment when due, ?, (B,ad rr al ??n4 ha, 81, t?aq MN Fan OCP'MrafN 11/long" Omp 4 of 8) BKI958PG217o' Property. Any notion or inaction by the Borrower or Mortgagor occurs that adversely abbots he Property or Lender's rights In the Prapaty. This includes, but is not Umiyd to, the fOtio a) Mortgagor fails to maintain red ?° ( required bhnrraaoe on the Property; (b) Mortgagor transfers the Property; (e) Mortgagor commiti waste or otherwise destructively urea err fWb to mahCWn the Property such that the action or inaction adversely affects Ladd a security; (d) Mortgagor halls to ps y taxes on the Property or otherwise fails to act and thereby calm a lien to be filed against the Property that it senior to the lien of this Security Instrument; (c) a sole Mortgagor dies; (f) if more than one Mortgagor, any Mortgagor dies and Loader's sawrhy Is aefvasely affected; (g) the Property is takol through eminent domain; (h) a judgment is filed against Mortgagor sad subjects Mortgagor and the Property to action that adversely affects Letndees interest; or (I) a prior lieaaholda fbrodoaes on the Property and as a result, Leader' a interest is adversely affected. Executive 0111cers. Any Borrows Is an executive officer of Leader or an 4MIlate and such W;, ,r becomes Indebted to Leader or another leads In on aggregate amount greater than the amount permitted under federal laws and regulations. 9. RCS ON DEFAULT. In addition to say other remedy available under the tams of this Security Instrument. Lender may woolerate the Secured Debt and foreclose this Secrity Instrument in a manner provided by law if Mortgagor Is in dofnult. In some htstances, federal and state law will require Leader to provide Mortgagor with notice of the right to cure, or other notion and may establish time schedules for forcoloswe actions. At Cho option of the Lender, all or any part of the agreed fbea and charges, accrued interest and principal shall become Immediately due and payable, after giving native if required by law, upon the occurnnee of a default or anytime theroafler. The acceptance by Lender of say sum in payment or partial payment on the Soca vd Debt after the balance is due or is accelerated or after fbreclosure pr odsting deftalL By not oceedings are Sled shall not constitute a waiver of Leadeea right to require complete cure of Ida consider the eveany romedy an nt defult if it s da6ult, Candor does aoi Leadees right to I happens agahL. 10. EXFXNW; ADVANCES ON COVEXANTB; ATTORNEYS' FEFSi EXUZCMON COSTS. If Mortgogor breaches my eaveaant In this Security Imstrranmt, Mortgagor agrees to pay an WgxWes Lender Incurs In performing such covenants or protecting Its scarify interest In the Property. Such expenses include, but are not limited to, fees incurred for irulrecting, preserving, or otherwise p" tooling the Property and Leader' a security Interest. These expenses are payable on demand sad will bear Intaut from the date of payment until paid in Sall at the highest rate of h*rm in effect as provided in the tams of the Soused Debt Mortgagor agrees to pay all cosy and Cotpenow incurred by Lender in collecting, onforeing oi protecting Lender's rights aid remedies under this Soeerity instrument. This amount may include, but Is not iimhod to, aftorneW fees, court costs, and other legal atpeases. To the anent permitted by the United Slates Barrio" Code, Moor, aage- psi the reasonable attorneys' fear Lender Inars to Called the Secured Debt sa awarded by say •w .,:; exercising jurisdiction under the Bankruptcy Code. Tbls Security Inetrantmt shall remain in effect until released. Mortgagor agrees to pay for any recordstiou coop of such redease. 11. ENVIRONMENTAL LAWS AND HAZARDOUS StM7ANCES. As used to this section, Enviroammtal Law mesas, without limitation, the Comprehensive EavlronmesW Reaponse, Compensation and Liability Act (CERCLA, 42 U.S.C. 9601 et seq.), and all other federal, state and ?1814 Beater a/dwe. he, M, OWA UN Faye OCNINTG AA IN00004 (cap 5 o18) 11I"'(PM twee) BKA 958PG217-1' local laws. regulations, ardidmoca, court orders, attorney general opinion; or interpretive letters concerning the public health, safety, welfare, eavirontaatt or a humdous substance; and (2) Hazardous Substance meats toy toxic, radioactive or barn *W twderfal, waste, pollutant or eewtamhunt which has characteristics which reader the substance doanger= or potentially dangerous to the public health, safely. wal1kre or eatvironmeeaL The jean includes, without litdtatiay nay substances defined as "bazeedous material," "toxic substances,- "hazardous wastes" or "hazardous substance" under any EnviromneaW Law. Mortgagor represents. warrants and sgretcs that: A. Except m provkoauly disclosed and sclmowledged in writing to Lender, no Haztudous Subst,-, Is or will be looted, stored or released on or in the Property. This restriction does not apply to smell quantities of Hazardous Subomcess that are generally recognized to be appropriate for the normal use and malutctumce of the property. B. Except m previously disclosed and acknowledged In writing to Lander, Mortgagor tenant have been, are, and shall retrain in f dl oomplianeo with any applicable Environma,ta Law. C. Mortgagor shell immediately notify Leader if a release or threatened raleuse: of a Hazardous Substance occurs on, under or about the Property or there Is a violation of any Enviromnattal Law concerning the Property. In such an eve ct, Mortgagor dull take all necmwy remedial action In accordance with any EnviraamesnW Lave. D. Mortgagor shall immedlucly notify Lander in writing as soon as Mortgagor has reason to believe there Is any Paulin; or threatened investigation, duke, or proceeding relating to the release or threatened release or any Hazardous Substance or the violation of any Environmental Law. 12. ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided In a separate agreement; Mortgagor will not be required to pay to Larder tt uh for taxes and insurance In escrow. 13. JOINT AND MMMUAL LIABU W; CO-SIGNERS; SUCCLSSORS AND ASSF(WO BOUND. All duties under this Security Inutnuc ut are joint and Individual. If Mortgagor Security Instrument but does not sign an evidence of debt, Mortgagor does so only to w,, .. Mortgagor', Interest in the Property to some payment of the Sowed Debt and Mortgagor doers not agree to be personally liable an the Secured Debt. If this Semidry Instrument scoum a guaamty between Lender and Mortgagor. Mortgagor agrees to waive any rights that may prevent Lander Burn bringing anry action or alahn against Mortgagor or my party hsddAW under the obligation. Theca rights may include, but are not Utdtod to, any mil-"c mcy or one-salon laws. Thee dutlets and benefits of this Security Instrument shall bind and benefit the successors and assigns of Mortgagor and Lender. 14. SMRABMI Y; INTEIIPRETATION. This Security Instrument may not be amended or modified by oral agrament. Any motion In Ws Security Instrument, attedunenns, or any agreement related ^o the Secured Debt that owdicts with applicable law will not be effective:, union that law expressly j 1 impliedly permits the variations by written agreement. If any section of this Security In:- cannot be enforced according to Its tams, that section will be severed and will not z:} enfwambigty of the remainder of this Security Instrument. Whmover usod, We sinpin shall luck", the plural and the plural rho shrg dol. The captions and headings of the sections of this Se curl inetrumeat am for convenience only and are not to be used to ' Security Inatrument. Time to of the cssenee in this security instrument. °t or define the terms of taa? ank" aye?R tin, ere. OWA MN Fan CCP4 gaTGPA a11e12004 (Aapa d O18) W1#(FA)teasy L 8K 1958P62172' IS. NOTICE, Unless otherwise required by law, any notice shall be given by dellveulog it or by maiNng it by first class mall to the appropriate Party's address on page 1 of this Security Ludnmteot, or to any other address designated In writing. Notice to one mortgagor will be deemed to be notice to all mortgagors. 16. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any right to appralsoment relating to the Property. 17. LINE OF CREDIT. The Secured Debt includes a revolving lino of aredlL Although the Secured Debt may be reduced to a zero balance, Ibis Smarity instrument will remain In effort until released. ' 18. APPLICABLE LAW. This Security Instrument is governed by the laws as agreed to In the Secured Debt, except to the extent required by the laws of the jurisdiction where the Property is located, and applicable federal laws and regulations. Any provision that appoints Lender as an agent is not wxhf--± to the provisions of 20 PA. C.S.A. Suction 3601 et seq. (Chapter 56; Decedents, T' :-- - .. , Fiduciaries Coda). Lender, by exercising any of its rights under this Security Instrument, does so tu. the sole benefit of Lander, 19. RIDERS. The covenants and agreements of each of the riders chocked below ore incorporated Into end supplement and amend the terms of this Security InstrumenL L.J all applicable boxes] AssigementofLeases and Rarts Mother ------------------ 20. O PURCHASE MONEY. This Seomity Instrument secures advances by Leader used in whole or in part W acquire the Property. Accordingly, tills Soeudty Instrument, and the lien hereunder, Is and shall be construed as a purchase money mortgage with all of the rights, priorities and benefits thereof under the laws of the Commonwealth of Pennsylvania. 21. ® NOTICE TO BORROWER. TM DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE INTEREST RATE. 22. C3 ADDITIONAL TERMS. 11911 ' *11'n s' Ina, SL 004 MN "0041 yTGM $11612004 on" 7 of e) g(PA) Nrost 8th 1958PGZ 173. SIGNATURES: By siipdag below, Mortgagor, Intending to be legally bound hereby, agrees to the tame and covenants contained In thin SawAty hretrament and in my attmius ta. Mortgagor alga acknowledges receipt of a copy of this Security Instrument on the date shed on page 1. (Si _ amen ...... __ __ _ -------------- - son ate) (Slgesture) , (-- -------------------------- ---- - ------- (Witness) ----------------------------- ACSNOWLBDGN ,NTt COMMONWEALTH OF PA COUNTY OF CWfflff-{LAVIp (Inds- thOn this, e the day of ? R. 'e?s qrrl e victual) !;pod officer personally ePP? - known to me (or sadsactorily proven) to be the person(s) whose esme(s) is subseibed to the within instrument, and sclanowiedged dw helshc executed the some for the purposm therein contained. In witness whereof, I hareanto set my hand and ofB My commission o spires: - -- Notary Public ---- --------------------------- Title Officer CHROnNA L IERW . M,y publio HWmpdon TWP„ Cotsrty of Carnbartalld hh? ?rtNtt>ssion E*hw July 14 toot: It Is bmvby owtified that the address of the Lender wi n • I l 5201 - e Pari4tla?i - Jeckony_I.e,- F1, 3225!}-------_-----_ - ------ --- ---- ---- ----------- - 1114 awe.. OWN" bc. 8L M4 Ni fern 0CP4e mTGpA eligR004 ?51PA)104091 (F ti of B) 8K 1958PG2 1•74 • -- - - -- -.... . , ?, ?..?o ? : ?o t??lt?: vOa?UY'L ra3c' server' . . Fax Server 7/5/2008 11:47 AM PAGE 5/011 Fax Server SCHEDULE A - Continued 4. The land referred to In this commitment Is as described as follows: ALL THAT CERTAIN TRACT OF LANG WITH THE IMPROVEM61M THEREON RECTED, SITUATE IN NORTH MIDIXETON TOWNSHIP, CUMBERLAND COUNTY PENNYLVANIA, SOUNDED AND DESCRIBED AS pOLLOWS: ' BEGINNING AT AN IRON PIN ON THE SOUTHERN LINE OF HILL CREST AVENUE (4o FE ET WIDE} WHICH BEWNNING POINT IS LOCATED SU n FEET MBAKW= IN AN EASMARDLY AL I E RFCTION MU THE CEO OF LON= GAP ROAD (LR EASTERN LINE OF SOUTHERN LIE OF SAID HILL CREST A PROPERTY CONVEYED TO JOHN R. MILLER AND AND H E MILLER, HIS WIFE BY DEED DATED JUNE 2, IM; THENCE FROM SAID BEGINNING POINT CONTINUING BY THE SOUTHERN LINE OF HILL CREST AVENUE SOUTH u DEQFtM 20 MINUTES EAST 194M FEET TO AN IRON IRf11; THENCE BY OTHER PROPERTY BEING RETAINED BTTHE ESTATES OF ARTHUR R. KL INGER ApiD GLADY'S!. KLINGER, DECEASED, SOUTH u DBORM=MINUTES"SECOMS FEET ORW O?TOHN RR. AND B TEM H. WL,EN NORTH I DEGM 30 MINUTES EAST 23L34 Y FEET TO THE PLACE OF BEGINNING. I Cery this Iu be res,u,uL,_ In Cutttberland County PA OKI 958PG-2 1,75 Date: 11/15/2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE* The name address andWhono number of CConlumrs Crept Counseling Aencies serving your County ._u.._A L_ 'r- This Notice contains important legal informadon. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAC16N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFF.CTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA N07IFICAC16N OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PR$STAMO 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. * (Must be at least 30 point type) r_7__.XK)bf "?' " HOMEOWNER'S NAME(S): JAMES MORRI SON PROPERTY ADDRESS: 30 E SLATE HILL RD CARLISLE, PA 17013 IRAN ACCT. NO.: ORIGINAL LENDER: MwrW Lynch CURRENT LENDERAMRVICERt PITH MORTGAGE CORPORATION HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE, ACT OF 1913 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS. AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FO tw [g M .. Under the Act, you are entitled to a temporary stay of foreclom on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrimp and attend a Nboo4o-face" meeting with cite of the consumer credit counseling secedes listed at the and of this Notice. TICS MIE'ETING MUST t KY_UR Wit` fW TUM1rV_TII41ro vnt n A Va 'W Tom ti. - - -- -. CONSIM CREM CO rnrsQnor AGENCIES .. If you meet with one of the consumer credtt eoaaseling agencies listed at the egad of this notice, the lender may NOT tale action against you for thirty (30) days after the date of this meeting. The names addrea.ea and t1?+hone mobera of?all2d g *mer credit es?:WW " #&UdM for the S in which the 1110OU ra (oM- am sit Earth at the end of (his N6622 It face mooting. Advise your harder iyy of your intentions. is only necessary to schedule one face-to- AMJICATION FOR MORTGAGR WANCE .. Your mortgage is in default for the reason: set forth law in this Notice (ace following pages for specific information about the natum of your default). You have the right to apply for financial asaistanco from the Homeowner's Emergency Mortgage Assistance Program. To do so. you must fill out, sign and file a completed Homeownerls F.ntergency Assistance Program Application with one of the doaigaated ooneumer credit oounseling agencies hated at the card of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete applicstion to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency, YOU SHOULD FILE A MEMO APPLICATION AS SOON I f e? ,R IF YOU RAVE A MBBTTNG IVJTH A COUNSIILINO AGENCY WITAJN IS DAYS OF TRB POSTMARK DATE OF 72rlS NOT ICS MI& FILE, AN APPLICATION WITH PIIFA WITHIN SO DAYS OF THAT AW77NG, THEN WE LBNDBR WILL BE MUFORARIEF PBl9 PZV MtD FROAISTA477NGA POBKCLOSURN AGAINST YOUR PROPERTY, AS WLAINED ABOVE, IN T7JB SBCTJON CALLED "TBMPOMtARYSTAYOF FORBCLOSURSM. P A LATE APPLICATION WALL NOT PRUVANT WE L8MER FROM STARTING A FUROM 4UBB ACTION, BI1T IF YOUR APPLICA2I0N LS BVENTIJALLY APPROVBD AT ANY TATS BEFORB A SHERIFF'S SAL$ Tffv FOM'BCWSLW WILL BBSTWEA AGENCY ACT ON -- Available Amds for emwripmay mortgage assistance an vay limited. They will be dieburaod by the Agency under the eligibility criteria established by the Act. no Pennsylvania Housing I'mancc Agency has sixty (60) days to make a decision after it receives your a Wicstion. During that time, no forecloaure proooodings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of Its docision on your application. NOT& IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTi-1', TUE FOLLOWING PART OF THIS NOTNZ 18 FOR INFORMATION FURP08E8 ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT TUB DEBT. Vu have MW baskru can 0111 a for Em Mortgage Aalsmnee. HOW TO CURE YOUR MORTGAGE DIMULT jj ;;nQ it ug; , NA= OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at; 30 E SLATE HILL RD CARLISLE, PA 17013 IS SERIOUSLY IN DEFAULT because; A, YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts am now pant duo: Start/5nd a9/1S/2010 tbroagh 111U/201Y st vuisble monthly payntenb I.Am"XLE03"! MGM Aemedi $40 ML SNAG J<iel. 00.00 Qmm S490- Recoverable Advasem 9111110111111L SIM Other chum LopI ie komize TOTAL AMOUNT rA[j DUE: &3136.79 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do nol uaa if not applicably,) NIA HOW TO CURE' ALT r You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDE& WHICH IS & , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME{ DUE DURING THE THIRTY (30) DAY PERIOD. Pa== moat be made a thus by " ca ices ru.?L --.:fi-d h odor ode ?' l( r? v money m-..li PHU MORTGAGE CORPORATION 3001 BISWS Gate Blvd Mt. Laurel, NJ OMS4 Attention= Cub Maaaaemenl Departacnt SV 19 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter, iii not use if not a=licabla) u z vu uu recur c ulaB THE D6Fw rr.T .. If you do not cure tie defatth within THIRTY (30) DAYS of the date of this Notice, This mans tbst the erttite outstanding balance of this debt will be vonaidoted due immediately and you may lose the chatter to pay the mortgage in monthly instelMaents. U fill payment of the total amount pan due is not made within THIRTY (30) DAYS, the lender also intends to instntct its attorneys to start legal action to IF THE MOHTCAGF IS FOARQ nape UPON .- The mortgaged property will be sold by the Sipiff to pay off the mortgage debt. If the leader refers your ease to its attorneys, but you cure the delinquency before the leader buns legal proceedings against yok yon will still be required to pay the reasonable attorney's fees that were actually incurred, up to 530.00. However, if legal proceedings are started asking you, you will have to pay all reaamble attoreeys' fm actually incurred by the lender am if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable poets. ad In rectalred to my aftrWs fe". -- The lender may elan AUG you perecnally for the unpaid principal balance and all other sums due under the mortgage. auvai a., aa?se>, L1b1''wuLT CU TO sHUMI st.r F .. If you have not ourod the default within the THIRTY (30) DAY panne gad foreoloaure pr?eedirtga have begun, von stilt have site ri to oars the, ,;; gmm= lhe sale. at env than uo to oar body beLnrS L1,S Sale yoL svdo to by DUW` A2 t dna am acv late or other dwoLdn dim ?rsrsnoehta, ,yes fuss and 99 -- - ? ? 130190111101 tasntgage to tOa The Cur* your default is the rnaum set forth in this ao*o will restore your position as if you bad sever de[anked. .- It is estimated that the earlieg date that such a Sheriff, Sale of the mortgaged property Gould be held would be approxbmtely sIX (6) months ftm tM date of tbk Notim. A notice of the actual date of the ShedfPs Sale will be sent to you before the sale. Of course, the amount needed to cure the default Will faexuase the loagor you welt. You may find out at any time exactly what the required payment or action will be by oontaetittg the lender. I=e of Mde 0193*vsr_ PITH MORTGAGE CORPORATION AddOULMI Wdwp's Gate Blvd Mount Laurel, NJ 08054 Fhoay Numban (? 6q-7111 ?Ktlli?,;(g36) 917.2700 Coarser Pe, roe. AUR HELOC Collection Depsrtaeent, SM EFFEL-r OF SH Ri M$ SAI _V. _ You should realize that a Shodfi's We will end your ownership of the mortgaged propWtY and Your fight to occupy it. If you continue to live in the property after the Shedd Sale, a lawsuit to rantove you and your furnishings and other belongings could be started by the leader at any time. AMILLU'I74N OF MORTGAGE .. You _ may or _u„_ my not (CHECK ONE) sell or trsoxfw your home to a buyer or ttsndbree who will assume the moWPP dobt, provided that all the outstanding payments, chaff and attorney's fees and costs are paid prior to or at the sale and that the other mquir melts of the mortgage ate satisfied. YOU MAY RIGHI: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF, • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURB THE DEFAULT, (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TRAM 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. i, i F r CONSUMER CREDIT COUNSEI.,ING AGENCIES SERVING YOUR COUNTY (FX in a ba of all Counn ins Awed 1ss d is Agggg& c. MR Z +CpUW7In w*kh dog nromm L located. gains addlBa d mfu ifmmom..r.). HEMAP Consumer Credit Counseling Agencies ReW AN updated: al V20pa 10:09:21 AM ADAMS Cotatty Mon valley Unemployment Committee ta00 Wests"A Adems Coumy Interhltb Housing AuMertiy 3rd Floor HIP IPA 1 40 0 H PA 13120 6 1 17925 412.4412 4 717.934.ta18 F Amerbsn Red Cress • Hanow? Cdepler 861 alalevae = 329 CWNBW Sweat PMtsbunph. PA 13229 Hanover, PA 17391 412 981.8906 717.837.6706 Housing Services, Inc, CCCS of Wesbra PA 710 2MO Unplatonn Rood Subs 1000 HsrdsbM PA 17102 P19eburph,PA 15219 809.611.2227 412.2111.9773 ass.311.2227 Penns Me Howing Finance Agency ft Merana 2276 Swallow Hill Road 443 PhUWWpM@ Avenue BBwg 200 Waynesboro, PA 17290 PI14burgh, PA 16220 717.711I2.3286 412.4292642 ALLEGHENY Cwx ty urban tags of Pittsburgh Acorn of MNphany County 610 Wood shaft 5007 Pawn Avenue PM" h. PA 16222 Sulb 900 412.227.480¢ PhIsbumh, PA ISM ARMSTRONG County 412.441.0661 Arms"" County Community Action Agency Action Housing, Inc 124 Amhadds Road 425 11111% Avenue Sulb 211 Suits 930 W1tsn ing. PA 18201 Pittsburgh, PA 13219 724,548.8405 412.281.2102 000.792.2001 CCCS of Western PA Rama Plan g CCCS of Western PA pj A Lo gonewMv d River Park Commons ANWo. PA 10002 2400 "**y skes6 suits 400 900.5112227 Pittsbargh. PA 15209 SKS11.2227 080.511.2227 8116.611.2227 Ind ens Ca Community Action Program 827 Water Sba) Community Aaron Scutihwut adm 187 55 East trans Strad I Wine, PA 16701 Waynesburg, PA 15370 724.4052857 724.8622093 Felt Hawing Partnership of Greater Pittsburgh, Inc. 28401JbwVAvenue Sulb 266 Pfatbnrgh. PA 13272 412.991.2536 GaANW Jubibe Assodates 6199 Pen Avenue Pltirburyh. PA 18424 412.086.3200 BEAVER County Action Houe ft Inc 425 B9h Avenue Sulb9S0 Pl9eburgh, PA 15219 412.2912102 000.792.2801 Pops 1 of is i 0 HEMAP Consumer Credit Counseling Agencies Report last updated: 6fV200 %0:21 AM CCCS of Western PA CCCS of La" VWky 971 TAlyd Street 3671 Crescent Court East Sewn, PA 15009 VAN", PA 16062 666A/1.2227 610.621.4011 566.611.2227 $00.637At115 t ousl PPOrNun5lss of Beaver County Commooky Aeeon CommRtee i f 3 e A ? 77 Unit 1 Bsrver, PA 15009 337 EaK PSSnShow BMlddnm, PA 16015 i 724.726.7611 St0.691.5620 BEDFORD County NNSMnorI ood Housing Servlcas of IbedlnS CCCS of Western PA 213 N 6M SOW 8nrse 1030 Royrd Renax Plan Rendn g, PA 19601 917 A Logan Boulevard ANNA, PA 16602 610.372.0433 $"Al l.2227 SdmylkNl Cammunlty Acdon 656.611.2227 225 N. Contra Street 4 Powvft PA 179tH TAWend Servlaes Ito. 570.822.1995 636 East Min 6fnel Swnwm. PA 15501 BLAIR County 514.445-525 800.462.0146 Blair County Community AWon Agency BERK$ Count 2100 Stn Avenue SuNs 102 y PO Bonn 1633 ; Amerlaen Cram Csunes"no Inatllute AN=*. PA 16602 614.940.3051 e 937 Norton Hernawer etreo PoNsW^ PA 19400 CCCS of NwMeeetern PA 666.212.6741 202 W. HeadbnAvenue 955.212,0741 Slate CaMp., PA 18a01 Amofaen Craft Colnsellnp Institute 514.238.3668 500.622.6637 300 NoM Podatown PSw sum 210 CCCS of Western ?A Exton. PA 19341 gnat Raanax Plan 688.212.8741 $58.217,6741 917 A !open BoulMrd Aeoana PA 15602 , Amerles" F1nen oW CouneNlny Services 886.5118227 688.5118227 ? 200 Bergey Suke 4 BRADFORD County Hatfield, PA 19440 267826.7903 CCCS of NerMweetern PA AmeAeen FkwWd Counts Nip Sarvleee 4guly 104 900 Pam Avenue SUmdebwp, PA IWW Wyonbft PA 19010 670.420.89SO 267225.7903 500.822,9637 500.400.3039 Budget Coueaeft Career CCCS of Ncr9neatern PA 401 Laurel Stnwt 247 North FM Street PMeian PA 15640 ` ReeMM PA 19901 , MAN.= 610.375.7865 9301922.9637 Pepe 2 of 16 r i HEMAP Consumer Credit Counseling Agencies Report lost updaW; af11200610M:22 AM The T1abab Centw of NorSssetem PA !sucks CounNy Housing Group 12261kdn Strout 4700 d DnrbM Plre d W, PA 16431 AM3 6041 DWyleslown, PA 18001 r . 800.1112.4045 «6AK0200 808.006.0280 ? Th e Tralvall Center Northessom PA Buda County Housing Group E The 015 West Mal 8oubwfd 703 S. Ek«r Avenue Sulte MA Cuskaftm PA 1851 PA 18040 , 866.15150.0200 6 .808.0412 0280 400.0!{2.4046 BUCKS Count 6ueks County Housing Group y 349 Durham Rod Acam Housing Corporation OML86 1, 20 10047 0 844 NoM Breed Strad 858 Phbddo* PA 18130 215,766.1221 Busks County Housing Group American Credit Counseilag I s6ivite Mwbvl . PA 19067 837 K M Hanover Strad WI.8I8.0280 PotMWML PA 16400 806.06 AM) 080.212.0741 t 806.213.0741 9uaks County Haaslog Group Anut«n Credit Counselling ksdtule 2324 Second Stns Pte gulls 17 030 Wed SUM Road W40dolown. PA 16040 SUBS 201 8150.850.0200 Warminster, PA 18074 216.444.0420 880.212.6741 CCCB of Delaware Vail" American CndN Counseling kntlpaee C1dIw0o gocist SaPAM Buldng 7340 Jackson net 300 No0? PolMloo n Pike 2PA 10136 Suits 210 210.613.8660 Exbn, PA 16341 860.212 6741 CCC6 of Delaware Valley F . 18011 Wakwl 8tr«t Amer)«n Credit Counseling Inelllute 10111 Floor P hWidNphis, PA 10107 ` Be COMAS Itred 215.663.50645 Codsevlla, PA 10620 8158.212.6741 CCCB of Delaware Valley 800.212.6741 1230 Now ROdgere Road Amarloan Financial Counseling Servioes SURD F1 Bridal, PA 10007 175 Tra" Avenue 215.588.6665 SUM One r WapW PA 10067 CCCS of Lehigh Valley 267.228.7003 800 400 3030 3671 Cr«sentCcurtE«t 3 . . WNWW, PA 18052 American Financial Courm"ng 6ervl«s 610.621.4011 000.837.0815 1017 Wak h R«d PN16"phb. PA 18115 267248 7003 Craft Coum«Iing Carrier . 832 Second Street POs Rl *w% PA 16004 215.300.18611 Page 3 of 18 HEMAP Consumer Credit Counseling Agencies RdW Met updated: 8/11200610:0x:22 AM DlvrnNlai Communky servtoee I 4 Ny Ad$oa Praoran Dbwn Hoop wwswft" 1920 SPA 2081 SVW Bas 187 Ph9addatM. PA 19143 bblun, PA 16701 216&80.3611 724.466.2657 POS CDC 1201 WON Olney Avenue Tableland Services 14a. PhleWeMlhM. PA 19141 636 MOM Mob BYpt bameroaL PA 15501 216.64&8766 614.448.9628 Onnuuffowtt 8anletnWnt 500.462.0148 6616 Wayne Avenue 7%w NOIfCAM Group MMeddphM, PA 19144 4200 oll rd Avenue 81rb200 218.549.5104 N&*Am Comb o, PA 167i4 RACE 614.94x.4444 187 W. AIM"W Avenue CAMERON County 2nd Fl PhIMdeoft. PA 19140 CCCS of Wooten PA 215.428.6026 The FroWn Cap* Counselling 1 ?? 824 Franklin Avenue p 16001 500 Broad 8fre it 6O 86.L56111,,22227 27 s, PA 19141 Phbd*W 568 311,2217 215.324.7800 Urban LWapue of PhNo"plrla No"Its n30 CammuMty Aa1len Corp. P Box 1818 Me" Street 135 Wet 41h Skeet 201h Fbar PNMddoft, PA 19103 Emporl u t, PA tbe34 814.456.1101 216.661.5070 BUTLER County AsSon HoueleS, Inc 426 681 Avenue sub 960 Pllktburph. PA 15219 412.251.2102 800.792.2x01 CCCS of Weabm PA Boftr Co" Caren Link PuSmen Cowneraa Cenlar 112 Hollywood Orlwo Buftr PA 15001 888.511.2227 688.611,4227 CAMBRIA County CCCyC?B of WWe1ern PA Real" pion 017 A Loper Bo rued Altoona, PA 111602 65111.3112227 11111111.511.2227 CARBON County CCCS of Lehlph valley 3971 Cmmott Cad East WhIt". PA 18062 610.821.4011 500.537.9816 CCCS of NonhusUm PA 401 Laurel Shpt PMamn.PA 19940 870.8021227 800.922.9637 CCCS of Na1M O Wrn PA 411 Main SIFGM 491 10104 Sboudeburp.PA /6300 670.420.810 900.922.9637 COMM ON Ease OpportueNy of Lumps CewKy 183 Arnbertme W&ASAene. PA 18702 070.021140510 800.822.09 Pape 4 of 16 i i 4 r 1 } } f 1 i b I f y t HEMAP Consumer Credit Counseling Agencies Report Iset updated: 8x112008 iO.•08:23 AM Community Aetion Cwnmutee American Financial Counseling Swviees E = 387 a FIMI 8trwt BMhlehon, PA 18015 HatBcid, PA low 010.01.6020 297,228.7803 Schuylkill Commw4ty Action American Financial Counseling Services 228 N. Contra Street 170 TnftW Avenue PoW11%PA 17801 Suite One 570.621190 Wayne, PA t9067 CENTRE C t 287.270.7803 oun y W0.4911,3M CCCS of Northesdern 4A Amarlean Pod Croes of Cheater 201 Basin abet 1770 Edparnoat Avenue suite 6 Chester, PA 19013 Willemoort,PA 17701 610,874.1484 570.323.W lOO.i22.2537 APIA CCCa of NorMraal rn PA 2147 North Sixth Shoat Philadelphia, PA 19122 202 W Kmdb t Avenue 210.230.6780 Stale Co#gk PA 16801 814,236,31160 Budget Coumeling Centw 800.222.9637 247 North Filth Sbeat COCA of Wesnwn PA 1 Bl01 0178611 "pAmax Ple=a Sau 917 A P 0 Carrell Pork Community Council, Inc. A 111 8 0210 Mater wam 666,511.2227 PN *Ns. PA 19131 gpA11.2221 210.877.1107 Lyeom.Ckrtn Co Cannot to Comm Aatiea CCCS of Delwwe Valley 2136 t N ooln Street 720 E. kit" St . P.O. Box 3665 Sulle 170. Menhd Building WMamaport, PA 17703 Wed Chaster, PA 19382 $70.320.0587 216.063.51166 CHESTER County Chesler Communuy w wmnwd Prgeot Acorn NwBing Corporalim 412 Avenue of the Stetee PO Box 541 1140 North Broad Street Clrseter. PA 12016 a. PA 19130 k 010.870.160:f 216 7 ..1221 American Credh Coerrealing Institute DWersftd Commurft Services Dimon House 21 Satoh Church Sbad 1920 South 201h Street Wed Chester. PA 12380 PhIl dm0le, PA 12145 000,212.8741 215.336.3011 0Bl.2t2.0741 American CredR Counseling Ineukda FOB CDC 1201 West Okay Avenue 845 Cestes Street Coatesville PA 18020 PhI@kIW . PA 10141 , 1186,212.11741 216.50.6765 6611.212.0741 oermentosnr 8eulement 5038 wWwAvenuo amn r Fh alpNs. PA 12144 216.649.3104 Page 5 ar 16 HEMAP Consumer Credit Counseling Agencies RaW Ian updated: 111IM 0810.ft23 Akt HAZE CM of W aWn PA 187 W. ABeoh&W Avenue t Royal Rrrtex PMsa 2ndM Sloidevard Phiktdelphle, PA 19140 =, PA 18602 216.428.8025 888.5112227 886.511.2227 Mousing Partnership of Chanter county 41 West LanoNter Ave Indiana Co. Communiy Action Program 0oWn0bwn, PA 18336 827 Weir Street 810.518.1522 Box 187 mom Fa9owshtp Noaas MON. PA i 4.4a5.256713701 ?2 302 South Jackman Oust i Meda. PA 19083 The MWCAM Grog 610406,0434 4200 Cmwfont Avenue i SWte 200 NWUVAv t Counseling Service Northam Cembrla, PA 15714 5001 Noah Broad 9trast 814.946.4444 PhBadelphla, PA 19141 216,314.7500 CLINTON County Phk Counad For CommunnyAdvmrk CCCS of Northeastern PA 100 Nam 1781 Swat 201 BNIn Street Suft ODD SWte 6 PhMedelpfda, PA 19103 WShunaport PA 17701 218,587.700.1 870.325.8627 800.930.4003 800.922.9637 Tabor Community Services, loo. CCCS of NorMwastem PA Sulle I SIM Cdkoe, PA 16801 Lanosnr, PA 17802 814,238.36ss 717.397.5182 800.922.9537 800.765.5062 I ten Lsegw of PMtadetphla 2136 Unodn Byastomm io Comm Action Isis kit" Sbset P.C. Box 3568 201h Floor VW*m M PA 17703 PhIladeghla, PA 19103 370.328,0587 215,681.8070 COLUMBIA County CLARION County CCCS of Waetern PA CCCS of Northasatern PA 401 taunt Suet Ma Caw Link Pullman Commoroe Center PNbrten, PA 18610 It hot/wood B 0. 7 nW r. PA 10001 "10637 900,922959 80 SN.6113227 BSS.61 13227 CRAWFORD County CLEARFIELD County Booker T. W"noton Center CCU of Northeastern PA 1720 Ma9and Swat Ede, PA 18503 j. 202 W. MwMhm Avenue 814.4534744 State Cdogs, PA 16001 814238,3008 CCCS of Western PA 800.922,9537 4402 Peach Street Ens, PA 16609 858.5112227 ext 108 i 080,5113227 ext tog Pegs 6 of 18 t I r HEMAP Consumer Credit Counseling Agencies i t Report last updated: IH1700511k0624 AM Cesar for Forty Services. Inc. Cpmmunly Asdon Commission of Capitol Mellon 213 Center Strsst 1614 Deny Sbwt Meadville, PA 16336 Hrrfebtop, PA 17104 614.337.6160 717332.9767 Greater Irate Communhy Aodse Ce nnuties Loveehl& Ins. + 18 West 97H Stn" 2320 NaBt 0 Sveel W* PA 16601 HarfMwg. PA 17110 014.405.4501 717.232.2207 Shenenga Vsky L"Ma League, Inc. PHFA r 601 1rl 1-, - Avenue 211 North Front 8"at I Fsrrd, PA 10121 Herdebap, PA 17110 724.061.6310 717.700.3040 i 8t. Martin Cer"sr 1701 Ponds Street DELAWARE County EM, PA 16603 814.462.8113 Aow Corporation M 6No i Broad S CUMBERLAND County Philadelphia. PA 10130 Adana County interfolth Housing Authority 216.786.1221 40 E High Stmt Advocates for Financial independence Oettyeburg, PA 17326 202 IM ? as 717.334.1615 RW* P PA 190TS 2115.381121110 CCCS of Woolens PA 2000 I.Ingloolovini o American Credit Counseling Institute T Nw*6wg. PA 175 Siraf d Avenue 7 Sala 1 856.011.2227 Wayne, PA 10067 810671.7110 Con nunky Asdon Comminlon of Cspltel Region 806.212.6741 1611 Derry Skeel Hi ntebar0, PA 17104 Amsdoon Financial Counseling Services 717.232.0757 170 Trafford Avenue Loveehip, Inc. SUNS One W". PA 10087 2320 North WIN Street 267220.7003 Harrisburg, PA 17110 800,490,3030 1 717.232,7207 Morenrtls AmeAoan Red Cross of Cheater i 1729 Edgenwit Avenue 43 PhNodelphis 4 CIS. 19013 Waynesboro, PA 17 65 810.ST1.1484 7t7.702.3286 PHFA APM 2147 N&M Sixth Sheol 211 North Front Skeet PhMdelphle. PA 19122 Herdeburg. PA 17110 210335065 717.780.9040 800342.2397 Carroll Park CsmmueSy Council, too. DAUPHIN 11 County 6218ha"erstem CCCS of W*mrn PA PltMedMPMe. PA 19131 215.877-1157 7000L4gteebwn Rood Herrteburg, PA 17102 880,011.2227 80111.511.2227 Page 7 of 111 HEMAP Consumer Credit Counseling Agendas Repart lent updated: 6/1/200610:0&24 AM CCCS of Delaware Valley Phba Council For Community Adv n d "DO VVdlr#A Strasi 100 NoM 17th Sleet 10Th rim Subs 1106 PhYadelpWe, PA 19107 Ph6adeb0te, PA 19103 215.868.5686 215.567.76D3 800,060.1863 CCCS of Delaware Valley 200 North PwAderwe Road Urban League of ftlabiphls Mach. PA 19063 1N6 Meksi Strent 216453.5066 200 Floor PA 19103 CCCS of Delaware Valley 210 661.6070 700 E. Meeker St Sutle 170. Marshall Binding ELK County Went Chester, PA 19362 215.683.6886 Nordorn Tier Community Action Corp. P.O. Box 389 mu" Wwonim ant project Chamber Com 138 Vast 40 Street 412 Avenue of flee States Emp Timm, PA 16634 PO cos 641 614.466.1101 Chanter, PA 10016 610.876.8683 ERIE C*Unty OlversiMd Community Ssrvlau Booker T. WuMnoon Center 1920!1cm 20 3"M Erie, PA 1660 PhBelsiptua, PA 10146 614.463.5744 216.330.3611 CM of Wesiern PA FCdt CDC 1402 Peach Still 1201 Vast Olney Avenue Eris, PA 16606 PhW SW*, PA 19141 860.611.7227 owl 100 215.649.0755 888.5t1,2227 eat Oeenentown Settlement 106 5536 Wayne Avenue Oreater Brie Comma mhy Action Committee We C 16 West 4TH $hmt PNMdsiphte, PA 19144 file, PA 10501 215.649.3104 814.459.4661 MACE St. Moron Cellar 107 W. AOep "Avenue 1701 Parade Street 2nd A Ede, PA I WM PhNW*hte, PA 19140 814,452.6113 215.426.6026 Volon for Independent Housing Partnership of Chester County ilD7 Payne Avenue 41 Went Umcememr Ave lint, PA 15603 DosokvW^ PA 19236 814.874.001W 610.618.1522 800.636.9886 Me& FellowoMp House FAYETTE County 90@ 8ou0 Jackson Street Merle, PA 19063 AD"" Homan. Inc 610.686.0434 425 60 Avenue SuBe 050 _ ?? 15219 2 00011 Noah Brow Street 4 .ZBI..2102 Phladelphlo, PA 19141 800.792 2801 218,324.7600 Pape 6 of l e HEMAP Consumer Credit Counseling Agencies Report hW updalad; Nif200610:08,26 AM i CCCB of Wesgm PA Mwawithe 1 NWM OsM Square 43 M*dalphls Avenue A2 Orden Center Drive 2 PA 15001 Weynmesboro, PA 17288 M-511.2 888.611.2 227 717.782.3285 868.811,2227 FULTON County Canmtonyy Miles Southwest CCCS of Mdarn PA 6811" Greene SYsM COW" shopping; Center Waynesburg, PA 16370 970 S, Oesrga St 724.882.2593 Yak, PA 17403 Fayepe Co Comm 137 NWM 9aeson Avenue ua Agency, Inc. 688 811.2227 8BB 611.2227 i UNonbw^ PA 13401 Marana9u 724.437.8050 S00 427 INFO 43 Philads"Is Avenue . . Waynesboro. PA 17288 Tal"and Services Inc. 717,782.3288 ' 636 Fact Man swat GREENE County Soma et, PA 16601 Milan Housing Inc 814.146.9828 SWAG2 0148 , 425 ON Avw" ; . FOREST County Bulb 980 PMtabumgh, PA 13219 WamrwnForest Counties Eoonomk O PPoramni4n Council 41121812102 000.7921801 1209 Pennsylvania Ave, West P.O. Sex 647 Wwrwn PA 10386 CCCB of Motors PA , 814.728.2400 1 Norm Gab Square #2 Owden Center Drive FRANKLIN Count Orenburg, PA 108011 y 688.6111,2227 Adams County Inladelth, Housing Authorhy SK 511.2227 ` 40 E HO Swst A 17325 Com i mushy Action goathwat 717 334 1518 38 Elm Gmene Sbw . . Waynesburg, PA 13370 American Red Cross • Hanover Cbapew 724.8621p93 629OwbieSvw HUNTINGDON Count Hanover, PA t7331 y 717.837.3780 CCCS at Northesstwn PA CCCS of WaMrn PA 202 W. Hamillon Avenue SStake PA 15801 2000 Unglestowi Road 11.3 11138. B 7 SPA 17102 953 BOO g22 9;f37 889. 131 . . 888.611.2227 CCCB of We" PA l CCCB of Western PA Royal Raise 917 A ! P 9 Shopift Gnu Nbona PA 18602 YQAc, PA 17403 , 088 611.2227 868.6111227 868.6111227 4 11811.8+1.2227 Community Action Commission of CapSM Region tau tarry SbaM ' Harrisburg, PA 1716 i 717.232.0767 i Page 9 of 1 e HEMAP Consumer Credit Counseling Agencies Report iatupdslW! SI112000 *00:25 AM INDIANA Cowity Wiled Nslg="& Cod Centers or Northeastern PA CCCS of Nhetern PA 495 Mdw 9ranMrrPA I , 8605 1 N&O Oslo Square 7 570.5480705 M2 Arden (:error Drive Greensburg. PA 15601 LANCASTER Cowlty 665.811.2227 5.511,2227 Be", Inc. Indians Ca Community Action Program 447 South Pdna Street Lanaslr, PA 17603 527 water Street 717.352.5167 Box 1S7 Irrdana. PA 15701 CCCS of I ehlgh Valley 724.4651667 3571 C?ncenl Court East JEFFERSON Count Vftlehe5, PA 10062 y 610.821.4011 CCCO of Western PA eoo.a37.961s Butlr County Caner Link Pubm Commerce Center CCCS of WeeNn PA 1112 Hollywood Drive Colonist Shopping Cantor Buser, PA 16001 570 a. George at *Ul 1.2227 York. PA 17405 565.511.2227 065,511.2227 lndleas Co. Community Aglgt Program 880.5111227 527 Water Street OpportunNy Inc. Box 157 301 Feet Market Sternal Irdlens. PA 15701 York PA 17403 724,4801667 717.424.3648 JUNIATA County Tana Communky Services, Inc, CCCS of Northeastern PA 3W Q wn9 Swe1 SuIN 1 202 W. Hemlllon Avenue Lancester PA 17602 Stale College, PA 16601 , 717.357.5182 514/389608 600 798.5062 000.022.5637 LAWRENCE County CCCS of Western PA ? T A ROM CCCS of weelern PA 0 1 A Low Boulevard 912 Chestnut Sweet Altoona, PA 16002 Suite 227 005.6111227 005 5111227 Meadville. PA 16336 . 805.5111227 LACKAWANNA County 11111111.511.2227 Catholic Social Services Have" of Beaver County Slm sArror unit 1 Averwe S Flow! BMW PA 15000 Samlon, PA 15605 . 724.720.7511 070A6e.3015 CCCi of NoKheratern PA Lawrence County Social Sirvkes, Inc. 401 Lsuref Shale PO lee Box 241 Want OnM O Street Pkhbn. PA ISM 570.5021227 Ne e, PA 10103 900.5122.9557 724.608.7254 724.568.7564 Paps 10 0118 HEMAP Consumer Credit Counseling Agencies Report IM updelad: OMAN 10MM AM {bong Valley Urban League, inc. LYCOMING County 6011 11- Avenue Famed, PA 16121 CCCIlof Narikeepm PA 724.901.3310 401 LeurN SUeI i 1`19e0on, PA 19840 LEBANON County 670.602.2227 900.922.9557 aotwyikul Conun"ly Action 226 N Cer1lre abeet CCCB of Northeastern PA PD*Yft PA 17901 201 Beahr Sheet 570.022.1998 Me 8 Tabor Coa m inky Serviam Inc. Wilwaporl, PA 17701 670,323.6927 506E Khp Street 900.922.9677 xuae 1 Lancester. PA 17602 Lyaom.Chft Co Comm to Comm Aatlon 717,397 8192 2156 Unooln Sheet 900,700.6002 P.O. Box 9686 Vflbm"ort PA tno9 LEHIGH County COOS of Lahlgh valley MCKEAN County 3671 Cmawnt Court feet Mild u9,PA 18092 No dwo'norCoramnityActionCap, 610.021.4011 P.O. Box 309 x00.977.9616 135 West 4th 8lreul Community Action Committee Empork", PA 16654 r 1114.4x6.1161 of the Lrdplt valley 1357 East F91Ur 8"40 MERCER County , Bexdel m, PA /cola 610.x91.6920 CCCa of Weaterrr ?A Butler County Caner unk Pullman Co mnaroe Gntr aabuylMil Cammunity Action 112 Hollywood Odve 225 N. Comm atreat Butler, PA 19001 Po&Ao, PA 179111 114"11.2227 670.622.1903 89x.611.2227 LUZERNE County Shenengo Valley urban Laevue, tea CCC8 of Northeaetern PA 001 Ir Avenue FarteA. PA PA 18121 401 Learnt Stet 724.991.9310 P11191o;%PA 16810 579.602.2227 MIFFLIN County 600-922.M7 Comm. on Eeon Opportunity of Lucerne County CCCS of NoAhaatlarn PA 202 W. Harntbn Avenue 169 Amber Lane State Coleq% PA 15801 , Wawa.Bw%PA 18702 W.276.3110 S70.620A810 900AMOS37 600.1422.0969 8cbuy8d0 Community Action CCClIof Weetem PA Royal Remax Plus 226 K CV" Seat 917 A Lorgan Berri wwd PollaWls, PA 17901 Ahoona, PA 10902 670.622.1996 66&611.2227 United Neixlrborhoed Centre of NorflreWem PA NM 1.2227 426 Alder Sheet y Sdanlen, PA 18606 070.346.0769 Pays 11 of 10 HEMAP Consumer Credit Counseling Agencies R*Wd INK updated: N04% 100,20 AM MONROE County American Credit Couneell" 1nstRyte Cagrolk Social ServloN 646 COOK $4140011 CG@Wdkl6 PA T9920 SaIM Cal w6w Maw 665.212.6741 1 5 KIM Road Scanlon. PA 16303 666212.6741 670.366.3016 Anherkaa Fkuaolal Counseling ServlNa CCCS of Nortf a tam PA 175 Tr*ftgd hlle One Avwhw 8 , 401 La" Street W"ria. PA 190S7 PNmon PA 16640 267.226.7903 670.002 227 600.802.9W7 800.400.3039 CCC6 of NortheNtem PA Counseling SeMOea 6 7 f h 11 Main 4 obw 1 W ele Rp Phladdo%K PA 19115 DUN a Stoudsbutq? PA 16360 670 420 806 267226,7509 r . . 0 800 622 6637 American Fina"al CounaeNno Servlsaa . . 671 N Boom Road ConanuMty A Mm Coi a Glanskle. PA itID36 2071267903 of the LLee4h Vauey 1337 E d P n ub ev" Na81iN 4M PA 1801, American Financial Counseling ServkN 010 081 66 Dewy Ras . . 8ulle4 MONTOOMERY County HaSeld , PA 15440 Mom _ 816 NoM &*W Strom atlon 7.67.22 2 26 228.7803 b n Ppu Ilnp Services 40 F l ? o , ftbddphla PA 19130 5 Weal O art ia r? , 216.766 1221 NWIst wn, PA 18403 i . 207.228.7809 American Credit Coun ellas M0ude CCCS of Delaware Valley 937 North Me mww Street 1508Nown PA 19480 1008 Walnut ft w , 666112.6741 806.212 6741 10th Floor 18107 1 . 180 216 AmeAan Credit Covek"Nng Indituts CCC6 of Ddeware valMy 300 Noah P06e10wn Pke Suba 210 ? PsAuhay Wee[ Etdon, PA 19341 subs, 20Q Slue Sd PA 19424 680112.6741 808.212 6741 , 216.5036666 , . i 9 American Credo CoemeNn Mstidrla 8 CANtw Community lmprovenhehht pr*ct 526 Dekalb Street 412 of iM Stages Nwrlalm, PA 19401 w 541 PO Sow 641 ChNW PA 10010 010.971.2210 566.212.6741 , 610.8706669 American Croft CounNNnp inethft C unity Action Devafopmerht Canr n CADCOM 530 West Suet Road 113 E Male Sl Subs 201 Wwmlr*W, PA 18874 16.1ti wit, PA 19401 210.444,9429 810277,6369 + 680.212.6741 i Page 12 of 18 HEMAP Consumer Credit Counseling Agencies Report lad updated: 0111200810,627 AM "Mentown Settlement CCCS of Norlhwatern PA 6 m We"Avenuo 201 Bain Strut 8uHe0 Ph118CIS hie. PA 19144 PA 17701 215.649.3104 570.32].W 670.32L5527 Housing Partnership of Cheater County 800.6x2.9637 41 Wat Lanowtar Ave 6ohuy0d11 Community Action DownNpbw, n, PA 19335 225 N. Cerwo SdOM 610.61611622 PONrA , PA 17601 Media Feaowahip Noun 610.622.1966 302 Sodh Jackson Seal PERRY County Media. PA 19003 610.560.0434 CCCS of Wedam PA NoMwOd CeunadNrp Servks 2000 Unplaslorm Road Hudeasp, PA 17102 8001 Nam Blood Sir*" 506.6tl.2227 Ph9adelphia, PA 19141 600.511.2227 215.324.75M PINK Caurro9 For Community cil For Advnmt hI Came-fty Action Commisdan of Captial Region 1614 Do" SMet I Nord f HOMW V, PA 17104 auto $Do 717 32.9757 Phbddphia, PA 19103 215.507.7603 Lovahlp, Inc. 000.930.4603 2320 Nwlh Silt Street MONTOUR Count 7.9 17110 3 2 y 717 2 20 CCCS of Northumant PA M?anatM 401 Laird Sews 43 Philadelphia Avenue Pltldon, PA 16640 570 6021227 Waynaaboro, PA 17268 . 000.922.9537 717.7023285 PHILADELPHIA Cowley NORTHAMPTON County Aaom nlousap Corpal " CCCe of Ldfth Y 3671 CrNOwt Cmrt Eat Philaddphla PA 119130 VAIW 6, PA ISM , 218.766 1221 510.621.4011 . 6110.837.60/6 AdvoaWe for Financial Independence Community Action Committee 1800 Soullt Braced Street M 1 I of Ow Lehl6h Valley W kddpNa PA 19145 1367 East FMIh Street , 215 3592010 BONAW.PA 10015 . 010.091.8820 American Croft Counwanp Insapds NORTHUMBERLAND Count t 80 Coates 6"d y y CoslseWe. PA 19320 CCCS of Northeastern PA 666.212.6741 855 212 0741 401 Laurel bind . . PIMa6, PA 15840 S . 7 American Credit COunw5no InAttub 022,0637 600M.02x.963 SW Wet SOeet Road Suite 201 Warminster, PA 18974 215.444.9429 800,212.6741 Pape 13 of 18 HEMAP Consumer Credit Counseling Agencies Report lean updated: SM/200e 10:114W AM Amsrkan Rawls) Counseling ServIM OlvsnlAsd Community Service 175 Tnffond Avenue 0140 Hotwe gulle one Wayne, PA 19067 1980 South 20Mh 11"M I'Madsl0k, PA 19145 287.228.7901 215.336.5611 600.400.3039 Marken Financial Counseling Services Esperanse 42 61 North 6111$11 est } 1917 Welsh Real PhMa PA 19140 R h9ad Nplhle , PA 19115 74 216.32421.0.0740 ? ? ? 1 FOB CDC AFM 2147 Noah S6iMr Soft 1201 WooCh"Avenus PhWkk% hk, PA 10141 PhIlads"s, PA 19122 210.849.8165 215235.6766 Calrolt Park Commwalty Couneli, Inc. tllemtontewrt Sso m em 5639 Wayn a Avenue 5210 modes Swd Bldg C Phlodot tk, PA 19131 PhMadelphle PA 10144 ! 215.077.1157 216.640.3104 CCCS Of Dslswan Valley MACE t606 Walnut Steel 167 W. Allegheny Avenue 10111 Floor 2nd Fl Ffilledsiphis. PA 19107 PhgedelpAk, PA 19140 216 215.426.6026 CCCS of Delewere Valley NWowk Alliance for Community Advancement One Chary HE 2740 NwM Front Street Salts 215 Phlkddplds, PA 19133 Cherry l UI, PA 06002 210.8874932 215.663.6665 CCC6 of Delewaro Valley Mousing /woclatlon of Detew4rrs Valley 1500 Walnugbmt Catholic 30*1 SerAm SuMdtng Bulls 001 7340 Jaducn Street Philadelphia, PA 10102 I' MedNPhle. PA 19130 216.545.0010 216.663.11M Cenbo Pedro Clever, ino Housing Association of Delaware Valley an N" Walt Street 627 West EM Avenue Phlkdelphh• PA 19123 Philadelphia, PA 19140 215.970.0224 216227.7111 i Chesser Commturlty lmprovement Project 4226 Intercultural P ?Se~? Inc. Chestnut 9 412 Avenue of Ow Satin PhkdNphle, PA 19104 PO Box 541 216 306.1206 Cheebr,PA 190th 610.1176.6061 Korean Com muni ty Dsvslopmat amcss Catw ?? 6056 NOM 6111 Street 416 Vlhat 9omagM Street PNW@ . PA 19120 215.278.8e3p PhMsdoWft PA 19133 215.76y.Me70 ua.ny Reeouroa Comtell of Spanish SPmthrt0 Organ W don 714 sure 1 1 ON Street Sti00 t 70540 North Franklin Sliest d pttle PA 19106 PI*Wdphk. PA 11723 215 0 . 34 216 62000 216.027.3100 . . Pegs 14 of 18 HEMAP Consumer Credit Counseling Agencies Report IM updated. 61112000 10..%U AM ML Airy, USA 6703 Germantown Avenue SWW 200 PNIW*hle. PA 19119 216.944.0021 New Kaninglal COMMV ty Development Corp 2515 Frer*W Avenue PN1ads". PA 10125 215.427.0350 Northwest Counsesng Service 5001 NOM Broad SOnst Philadelphia. PA 10141 215.324.7500 Phlie Couned For Community Advmni 100 North 176t Simat suite 609 PhIsdsWft. PA 19103 216.867.7503 600.930.4683 Philadelphia Senior Center 509 South Broad Street Phkdalphla, PA 19147 215.846.9879 South Philodeiphla N.O.M.E.B. 1444 Point Brass Avenue PtWodel". PA 19146 218,334.4430 Southwest Community Osvetepmem Corporation 6328 Pas" Avenue PhiWelphle, PA 19142 215.729.0800 The Partrwshlp CDC 4028 Market Sheet suite 100 @01s, PA 19104 218.682.1612 United ComrrunWas Southeast Philedefphis 2029 South ism Street PhlteaNpW, PA 19148 216.467.8700 Urban League of Philadelphia 1818 MR" Street 20th Floor Ml*ddphla, PA 19103 216.681.8070 WeN Oak Lane CDC 6269 t M4W Pike Phgad610100. PA 19141 215124.0660 PIKE County CCCS of NaMwslem PA 401 Laurel $11est Plftb. PA 15640 S70AM"27 800.022.9637 CCCS of Northeastern PA 411 Mai Skeet suite 104 Stroudsburg, PA 18300 670.420.0910 500.9218637 POTTER County Northam Tier Community Action Corp. P.O. Boa 300 13S West4th 8kaat Emporkan, PA 16134 814.465.1161 SCHUYLKILL County Budget Counseling Canter 247 North FMh Skeet Reeding. PA 19601 61o.376.7568 CCCS, of Lehigh Valley 3671 Crescent Court Beat Whitehall. PA 18062 610.821.4011 800.837.9015 Comm. so Eam Opportunity of Lusarm County 183 Amber Lone WShea.BrM. PA 16702 1170.826.0510 800.822.0369 Sehuy"I Community Action 226 N. Centre Strut Po#rAW. PA 17801 670.622.1998 SNYDER County CCCS of Western PA 2000 Lk jiisai m Road Harrisburg. PA 17102 668.6113227 688.611.2227 cff Derry SM?ition Commission of Capdat Region Hadabuto, PA 17104 717.232.0757 Page 150f16 HEMAP Consumer Credit Counseling Agencies Report leaf updated: 811!20081001:28 AM SOMERSET County TIOGA County CCCO of West" PA 1 NOM Go" Sauan CCCS of Narlhmwm PA 02 O wden Cantor Wve 401 LWW Stmt 111110an PA 1840 W4QwonabL% A 158111 11 222? , 570.802.2227 . 886.511,2227 w 000'' Fayette Co Carnnltudy Mow A08aey, One, The Trahab Center of MontweaWn PA 114 E. Sea Avanw 137 Noah Bneon Avenue Wddxm 16801 Unlonlown. PA 15401 8252 570.724 8 12 724.437.8060 1100.427.I1NIP0 . ' Tableland Sarvloa Mc The Trehab Confer of Northeastern, PA . 635 Eat Main 8traat 1226 Ma4t Stew Sanaraa6 PA 15501 i $7093 8, 18431 8841 1 870.2263 814.446.8828 800.452.0148 . . 800.082.1015 UNION County SULLIVAN County CCCS of NatbaeWn PA CCC& Of 1110MIMINern PA 401 Laurel St" 401 Laurel SVeal Pllbbn, PA 1840 P100ban. PA 1840 570.802.2227 $70.002.2227 800.022.9537 800.822.8637 TM Treheb Cenlar of Nartlwe1wn PA CCCS Of Nord+aetarn PA 2018" Street 1228 Maln Street Salb 6 Hawwbb, PA 18431 670.263 8041 WMWNwK PA 17701 . 800.00x.4015 S 800.022.0537 The Trahab Carew of kodheat8m PA CCCS of WaWn PA r Germa 00 Saw n 3So" P.O. R%W Remex Ptah Owt% PA 18014 PA 017 A LW Boulevard A1lo r PA 6 50'921L 9w4, or e, 1 11M 856.611.2227 ?' 858.511.2227 SUSQUEHANNA County Ll+aam.ChNn Co Corrun to Cam n AW*n The Trehab Canal of Nordwaetern PA 2138 Lktooin Sheet 10 Pub6a Avwwa P.O. Bat 3508 PO Box 306 16B61rrrporL PA 171113 Mo"04C PA 18801 570.325.0667 570.278.3336 VENANGO County SW-M.4045 TM Traheb Canal of Northeastern PA CCC6 of Waalam PA 1225 Mein 31104 Bu r y Cww Unk Pullman Commerce Center Honeadeb PA 18431 112 lywood Odvo . 570.M.Ml Butler. PA 16MI $00.082.4046 866.5112227 880.511.2227 Canal for Fowly Services. 1M. 213 Carew Sho Meadville. PA 15335 $14.337.8430 r Pape 18 0?18 HEMAP Consumer Credit Counseling Agencies RePod Vet updated: 8/11200610:0820 AM Greater Erls Community Art 18 wart 8711 isn Committee StreM Ede. PA 16601 614.469.4661 St, Martin Carper Vol Pants attest Ede, PA 16603 614.462.6113 WARREN County Sookar T. Washinston Canter 1720 Holwrd Sired Erie, PA 16503 514.453.5744 0=8 of Western PA 4402 Pesch Sleet Ede. PA 1es00 550.61!4227 sri 105 880.61 1,2221 ext 105 Greater Erie Community AMm CommNlee 16 Wets 9TH SVaM Ede, PA 1!601 1114.459.4681 St. Msr9s Canter 1701 Parade Stroet Eris, PA 161103 914.462,8113 Warren-Forest CounBa Eeonamie Opponunlty CoaneN 1209 Pan"ve nle Ave, Wets P.Q Box 647 Warren, PA 16365 814.720 2400 WABHINGTON County Action Houslns, Inc 428 6m Avenue Sutb still 412 USI)LO 1 PA 16218 6011.702.2801 CCCS of WssWn PA 1 Norm OMs $*we 02 GUden Cantor Ddve Gr wsrlbw% PA 16801 680.611.1227 CCCS of Wsateru PA 41 Eou CheMmd Sinai WSW** n, PA 10901 988.811.2227 808.811.2227 Conrn &"y Action southwest 69 Eats Graters aaeet -liyi lurp,PA 15370 CCoemnrnity AoBas st AhneM 160 West Sesu SreM Sulb 304 WeMMnston,PA 16301 724,226.8660 Mon VMlsy Use 06prient Commit o 1800 Wets stmt 3rd Floor Hom~,PA 15120 4124020082 WAYNE County CWHft Spew soma" Sw CMharhns Manor S Knox Rand Sorsnton,?A 18606 670.666.3016 CCCS of Northeastern PA 411 Mein Street Suhs 104 udsbrrq. PA 18360 600.922.8637 CM of Northeseeern PA 401 Lewo S"M PNIMon.PA 18640 670.802.2227 800AY1.8637 The Trehab Center of Northosawn PA 1225 Mah Street Hanndote, PA 18431 5ro.263.8041 800.862.4046 United NNyldbarhood Cotten of NoMhe own PA 428 Alder Sto t Sannten. PA 18006 670.346.0780 WESTMORELAND County Action HousMs, Ina 425 8m Avenue Suss 060 Pkbbtcph,PA 15219 412.281.2102 600.7s2.2801 Popi7ot1e HEMAP Consumer Credit Counseling Agencies Report loot updated: 81112008108:29 AM CCCII of weetenr PA 1 NwA lido Square 02 Orden Canter DM Orerptrvrg PA 15801 888.61f.2227 885,611.2227 Comnwnlty Antic* Southwest 58 East Oreane Street WWMIGIMNS 724.0112 PA 16970 .211103 Irrdlsrra CO. Community Action Program 827 Woler Strout Sod 167 Indluts, PA 16701 724.468.2867 1 SOD Viso Stroh oft Canmhoe 3rd Floor Homado , PA 15120 412.482.0862 TabMlend 9rvlooo Inc. 836 !East main Street 80aeroel. PA 15801 614.446.96x6 900.482.11148 WYOMING County Ca"19 Social Servtaea SMIM CaB+Mno Manor 5 Knox Road Saronton, PA 16695 670.668.3019 CCC9 of Northces1 PA 401 Lw W Sweet PRIMM, PA 16640 670.9022x27 900.922.9637 Comm. on Soon Opportunity of luwaa County 163 ArMw Lane Wlk-B ma. PA 18702 570.526.0510 800.822.0359 The Trekob Center of Northeaetenr PA 115 SR 928 Tunkhennock. PA 16067 670.950.9840 800.982.4045 The Trohab Center of NaMoadorn PA 1225 Main Srcet Honoodole. PA 16431 570259.9841 800.082.4045 L MNeIghbehood Carom of Nrdmatern PA Scent 8oraaen. PA 18806 570.MOM YORK County AAdonrEHe?t?Iatrfa0h Rung Awhorlty 40 PA 17326 717.334.1 18 Aedwtcan Red Gross • Hanover Chapter 529 Carlwe Street Hanover. PA 17351 717.897.3788 Saes. hra 447 South Prince Serum Lancaster. PA 17803 717392.5487 CCCS of WasWo PA 2000Lia9Ieeloaa Road Harddm& PA 17182 588.811.2227 856.611.2227 CCCS of W906M PA Colonial Shopping Center 970 S. imgs St Y064 PA 17403 858.811.2227 566.611.2227 HOWng Alliance of York 36 South Duke event York. PA 17401 717.864.1841 Opporkinky 301 Bast N?gred York. PA 17408 717.424.3945 ------------------ ai 0 r o ??? w o.. 0 N I 0 O .a v ? 000 a ? if j 0 .-j I P P d k Y 00 n 0 0 a L li I 7003 2260 0002 4734 4367 ; 7003 2260 0002 9734 9387 d if '-A VERIFICATION 4(64) r Q4? hereby states that he/she is of PHH Mortgage Corporation, servicing agent for Plaintiff, in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: Name: .4eu, S Title: 'es S&D FILE NO: 11-039515 James E. Morrison SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT '1011.Ifs'- 21 AM 10: J!4 'UMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:11-4326-CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $118,570.32 in favor of the Plaintiff and against the Defendant, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of Mortgage Debt Due and Unpaid Interest through July 15, 2011 $99,778.21 $3,189.50 Late Charges Escrow Advances Attorney Fees & Costs of Foreclosure TOTAL BY $140.00 $14,135.61 $1,327.00 $118,570.32 Christopher A. DeNardo, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant and damages are assessed as above in the sum of $118,570.32. 11-039515 Pro. Prothy. cioµ .3&1940q ?Vo?u- .r SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PHH MORTGAGE 4001 LEADENHALL ROAD MAILSTOP SV-01 MT. LAUREL, NJ 08054 PLAINTIFF VS. James E. Morrison DEFENDANT(S) STATE OF: Pennsylvania COUNTY OF: Montgomery COURT OF COMMON PLEAS CUMBERLAND COUNTY 11-4326-CIVIL AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, 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. SHAPIRO & DENARDO, LLC By: Christopher A. DeNardo, Esquire Sworn to and subscribed before me this day of ?J ?l ?L 1 ,201 1. CoMU"W-EALTM OFeqftL 'lV JennN6rM Notes S" AN7q UPPer Merlon Two eY, Notary PW* -Pkft OCL 19 N ublic rover Pens n '2014 ania Aeration O. NoWfes .r SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 11-4326-CIVIL CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, June 8, 2011 to the following Defendants: James E. Morrison, 30 East Slate Hill Road, Carlisle, PA 17013 Sheena Mayer, Legal Assistant to Christopher A. DeNardo, Esquire for Shapiro & DeNardo, LLC ,JP SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 11-4326-CIVIL NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: James E. Morrison DATE OF NOTICE: June 8, 2011 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 (10) 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o Name por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: James E. Morrison, 30 East Slate Hill Road, Carlisle, PA 17013 Christopher A. DeNardo, Esquire Shapiro & DeNardo, LLC Attorney for Plaintiff f SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:11-4326-CIVIL CERTIFICATE OF SERVICE I, Christopher A. DeNardo, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: James E. Morrison, 30 East Slate Hill Road, Carlisle, PA 17013 Date Mailed: T- 1 U- I I SHAPIRO & DeNARDO, LLC BY: Christopher A. DeNardo, Esquire Attorney for Plaintiff SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:11-4326-CIVIL CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 and that the last known address of the judgment debtor (Defendant) is: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 SHAPIRO & DeNARDO, LLC BY: Christopher A. DeNardo, Esquire Attorney for Plaintiff 11-039515 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse Curtis R. Long Prothonotary Courthouse Square Carlisle, PA 17013 TO: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 11-4326-CIVIL NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylv 'a, you are hereby notified that a Judgment has been entered against you in the above proce ing dic elow. -119111 Proth '4 [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE AT (610)278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN gLVANIA, CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Mw rS y Caption: O Confessed Judgment = = Other cnr- < > ? _ Merrill Lynch Credit Corporation File No. (- 3a? PLAINTIFF Amount Due $118,570.32 a"c-) x ° VS. Interest July 16, 2011 to Dece ° 7 X01 P. m is $1,507.28 W Atty's Comm Costs James E. Morrison DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: L% S S. OU t' OAC? ga.oo 1 ?{• va 96 4 It Wo it Signature: Print Name: Christopher A. DeNardo, Esquire Address: 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 78447 S. snc_c_ L( (z-? acs a <<? Lulr -F OT I SSS t,"C: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4326 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MERRILL LYNCH CREDIT CORPORATION Plaintiff (s) From JAMES E. MORRISON (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: $118, 570.32 L.L.: $30 Interest July 1 b, 2011 to December 7, 2011 is $1,507.28 Atty's Comm: % Due Prothy: $2.00 Atty Paid: $187.50 Other Costs: Plaintiff Paid: Date: 7/21/11 1 David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: CHRISTOPHER A. DENARDO, ESQUIRE Address: 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 78447 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 g?JLLtl? 1t//?['p'A R 1 i ?JUL 21 f M 10: 43 'UMSERLAND COUNTY PENNSYLVANIA Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison DEFENDANT NO: 11-4326-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Merrill Lynch Credit Corporation, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 30 East Slate Hill Road, Carlisle, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s) James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 CACH, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: Merrill Lynch Credit Corporation, Plaintiff 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 5. Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 30 East Slate Hill Road Carlisle, PA 17013 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. Section 4904 relating to unsworn falsification to authorities. SHAPIRO & DeNARDO, LLC BY: Christopher A. DeNardo, Esquire 11-039515 r -- j ?i O?i O TA R SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE 2-011 JUL 21 AM 10: ?8 ATTORNEY I.D. NO: PA Bar # 78447 CUMBERLAND COUNTY 3600 HORIZON DRIVE, SUITE 150 pIENNSYLVAN1A KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison DEFENDANT NO: 11-4326-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Your house (real estate) at: 30 East Slate Hill Road , Carlisle, PA 17013 29-15-1247-060 is scheduled to be sold at Sheriff s Sale on December 7, 2011 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the courtjudgment of $118,570.32 obtained by Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF THL E 2012 APR -5 AFB 9: ;; f-U $ERLAND COUNT\,,` PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. James E. Morrison DEFENDANT NO: 11-4326-CIVIL SUGGESTION OF BANKRUPTCY TO THE PROTHONOTARY: It is hereby suggested of record that James E. Morrison Defendant in the above captioned case has filed Bankruptcy under Chapter BK 13, under Docket No. 11-08086 on December 2, 2011, in the Middle District of Pennsylvania and the above captioned Action in Mortgage Foreclosure is accordingly stayed during the pendency of the Bankruptcy!, BY: Christopher A. DeNo, Esquire Attorney for Plainti SKERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor PENHSY! 4'A 1A Merrill Lynch Credit Corporation Case Number vs. James E Morrison 2011-4326 SHERIFF'S RETURN OF SERVICE 09/29/2011 12:16 PM - Deputy Valerie Weary, 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: James E Morrison at 30 East Slate Hill Road, North Middleton Township, Carlisle, PA 17013, Cumberland County. 09/30/2011 04:44 PM - Deputy Stephen Bender, 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 30 East Slate Hill Road, Carlisle, PA 17013, Cumberland County. 12/02/2011 As directed by Christopher A. DeNardo, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/7/2012 02/22/2012 As directed by Christopher A. DeNardo, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/4/2012 04/03/2012 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: $766.90 SO ANSWERS, April 03, 2012 RONI4 ' R ANDERSON, SHERIFF 2 3 Sly .rrL.?-01-01 SHAPIRO & DeNARDO, LLC H- P OTHONOTAR`f BY: CHRISTOPHER A. DeNARDO, i 10; ?1 ,lUI 3- 1 ESQUIRE _ 1 !ATTORNEY I.D. NO: PA Bar # 78447 CUMBERLAND COUNTY 3600 HORIZON DRIVE, SUITE 150 PENNSYLVANIA KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison DEFENDANT NO: 11-4326-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Merrill Lynch Credit Corporation, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 30 East Slate Hill Road, Carlisle, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s) James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-0 1 MT. LAUREL, NJ 08054 CACH, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: Merrill Lynch Credit Corporation, Plaintiff 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 5. Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 30 East Slate Hill Road Carlisle, PA 17013 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. Section 4904 relating to unsworn falsification to authorities. SHAPIRO & DeNARDO, LLC BY: Christopher A. DeNardo, Esquire 11-039515 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 11-4326-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Your house (real estate) at: 30 East Slate Hill Road, Carlisle, PA 17013 29-15-1247-060 is scheduled to be sold at Sheriff s Sale on December 7, 2011 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:OOAM to enforce the court judgment of $118,570.32 obtained by Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY Or CUMBERLAND) NO 11-4326 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MERRILL LYNCH CREDIT CORPORATION Plaintiff (s) From JAMES E. MORRISON (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: $118, 570.32 L.L.: $.50 Interest July 16, 2011 to December 7, 2011 is $1,507.28 Arty's Comm: % Due Prothy: $2.00 Atty Paid: $187.50 Other Costs: Plaintiff Paid: Date: 7/21/11 David D. B 11, Prothonot (Seal) Deputy REQUESTING PARTY: Name: CHRISTOPHER A. DENARDO, ESQUIRE Address: 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 TRUE COPY FROM RECORD In TesWnony whereof, l here unto set my hand and the seal of said Court at Carlisle, Pa. This • a , day of 201(, - Prothonotary Supreme Court ID No. 78447 On August 25, 2011 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 30 East Slate Hill Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 25, 2011 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2011-4326 Civil Merrill Lynch Credit Corporation VS. James E. Morrison Atty.: Christopher A. DeNardo ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the center- line of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060. BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and re- corded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. 62 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 21, October 28, and November 4, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this da of November, 2011 Notary NOTARIAL SEA DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co. 2Cft Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 14e Patr10tAV?C(W5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf-of The Patriot-News Co. aforesaid by virtue and pursuant to a Tesoiutron unaninrouslypassed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/21/11 # * - 7T 10/28/11 11/04/11 Sworn o aryl subscribed b" m?this,* day of November, 2011 A.D. r Notary GONIMONWEALTM ?F PENW VANIA • Notarial Seel Sherrie L. Owens, Notary Public Low Paxton t on""on?P , ?. 26, 2uo MEMBER PENNSYLVANIA ASSoaM N OF NOTARIES Merrill 2011-4326 C1VI1 Terra Lynch Credit Corpora Vs tion A1tY' Chris s o ALL than Aher q, peNardo certain tract of land with the 'mh ovements thereon erected situate in Noa Middleton Township, Cu. County, Pennsylvania, b berland ounded and described as follows: Southern I- G at an iron pin on the fee[ Wide) which bell Crest Avenue (40 568.39 feet glanrngPointisl direction fro Casured in an E ocated twardly ap oad m the centerline o l f Longs G R (LR th line said Hill Crest 21072) A along venue; e Southern line and at the Eas ofptoperty R• Miller and Bet Conveyed t John ty g, Mil, Deed date ler o wife by n 01.m his d June 2 1975. thence from said line continu' Hill Crest u South 88 de uthe 30 minutes East 184.30 feet to an iron in; aes thence by other property being n; Glade s rate .OfgtthurR,Kl ingerand y E g degrees 33 mutes, 56 dece wed' iretained South 39 feet to an iron iner SeCpnds West 298.92 ortormerly of pm; thence bypropettynow ?o ih 1 de Je 30 ohn R. and Betty H Miller 1'°qR C place of nnnutes East 235.34 feet BEl, EL No. 29-15-124-060 Backenstohw esa and a Premises which Don E. husband and wifeMb ne• R. Backenstow, Co n?ReCprecorded in the Cumberune l and 2003 dookfDeeds m Dc)m eed B CC on Jul at,?' conveyed unto 57, pale 4521, granted adult an. James E. Morrison, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: () Confessed Judgment () Other Merrill Lynch Credit Corporation File No. PLAINTIFF ; Amount Due $118,570.32 Interest July 22, 2011 to Septembg 4 @p13S' is $8,070.40 G.> VS. Atty's Comm Costs z' •-D c,5 � zj James E. Morrison CD DEFENDANT(S) �c c , ;� TO THE PROTHONOTARY OF THE SAID COURT: r co =" The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s)described in the attached exhibit. Date: Signature: ��/_ 44fA� Print Name: Leonard J. Mucci, III, Esquire x Address: 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 — Attorney for: Plaintiff Supreme Court ID #PA Bar# 92357 It dog ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue(40 feet wide) which' beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Gladys E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife,by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. 4 a# F- -rhE PRO rho fI t, SHAPIRO &DeNARDO, LLC BY: LEONARD J. MUCCI, III, ESQUIRE 013 APR 26 P110: 38 ATTORNEY I.D. NO: PA Bar#92357 CUMBERLAND 3600 HORIZON DRIVE, SUITE 150 P LAND�,�d OO1,U g4Ty KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison DEFENDANT NO: 11-4326-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Merrill Lynch Credit Corporation, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 30 East Slate Hill Road, Carlisle, PA 17013. I. Name and address of Owner(s) or Reputed Owner(s) James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: James E. Morrison 30 East Slate Hill Road Carlisle,PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 CACH, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL,NJ 08054 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 30 East Slate Hill Road Carlisle, PA 17013 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. Section 4904 relating to unsworn falsification to authorities. SHAYIRO j& A C BY: /I G�/l/ Leonard J. Mucci, III, Esquire 11-039515 SHAPIRO &DeNARDO, LLC "' tifL R0TH+0, pTAI `, BY: LEONARD J. MUCCI, III, ESQUIRE �, � � '� ATTORNEY I.D. NO: PA Bar#92357 ` q 3600 HORIZON DRIVE, SUITE 150 CUMBERLAND COUNTY KING OF PRUSSIA, PA 19406 Pr.h'dSYL�/ABA TELEPHONE: (610)278-6800 S &D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison ; DEFENDANT NO: 11-4326-CIVIL 1 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Your house(real estate) at: 30 East Slate Hill Road, Carlisle, PA 17013 29-15-1247-060 is scheduled to be sold at Sheriffs Sale on September 4, 2013 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of$118,570.32 obtained by Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. rj S. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling(610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 L 1 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue(40 feet wide)which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road(LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller,his wife by Deed dated June 2, 1975;thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow,husband and wife,by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257,page 4521, granted and conveyed unto James E. Morrison, adult man. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 11-4326 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MERRILL LYNCH CREDIT CORPORATION Plaintiff(s) From JAMES E.MORRISON (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: $118,570.32 L.L.: Interest FROM JULY 22,2011 TO SEPTEMBER 4,2013 IS$8,070.40 Atty's Comm: Due Prothy: $2.25 Atty Paid: $980.40 Other Costs: Plaintiff Paid: Date: 4/26/13 David D.Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name: LEONARD J.MUCCI,III,ESQUIRE Address: SHAPIRO&DENARDO,LLC 3600 HORIZON DRIVE,SUITE 150 KING OF PRUSSIA,PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 92357 V a SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, r ATTORNEY I.D. NO. 311403 ' ors. KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 ' 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 , ;~y' TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison DEFENDANT NO:11-4326-CIVIL CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, 1Vleghan Williams, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff, Merrill Lynch Credit Corporation, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on July 19, 2013, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. SHAPIRO & DENARDO, LLC Date: By: /Xf� r MeghaiYWilliams Legal Assistant 11-039515 ,r U.S.POSTAGE>>PITNEY BOWES w Name and Address of Sender Check type of mail or service: Affix Stamp Here �i Shapiro&DeNardo,LLC (If issued as a 3600 Horizon Drive ❑ Certified ❑ Recorded Delivery(International) certificate of mailing, ZIP 19406 $ 001�7sO Suite 150 ❑ COD C] Registered or for additional 02 1 YY King of Prussia,PA 19406 ❑ Delivery Confirmation ❑ Return Receipt for Merchandise copies of this bill) 0001363586 JUL, 19. 2013 El Express Mail ❑ Signature Confirmation Postmark and ❑ Insured Pate of Receipt Article Number Addressee(Name,Street,City State,&ZIP Code) Postage Fee Handling Actual Value Insured IDuesencIer DC SC SH RD RR Charge if Registered Value if COD Fee Fee Fee Fee Fee 1 Cumberland County Domestic Relations 13 North Hanover Street 11-039515 MW Carlisle,PA 17013 CACH,LLC 2 4340 South Monaco Street Denver,CO 80237 Tenant or Occupant 30 East Slate Hill Road Carlisle,PA 17013 3. PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 4. /01 5. $Q 6666 t \ p 1 6. t :~ Q - I o �- A0 C4 1 U r 41 7. o U 8. Q Total Number of Pieces Total Number of Pieces Postm s r, er(N of receivi e p yee) Listed by Sender 4 Received at Post Office See Privacy Act Statement on Reverse PS Form 3877,February 2002(Page 1 of 2) omp a by pewriter,Ink or Ball Point Pen SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 1,2 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 f 3600 HORIZON DRIVE, SUITE 150 ,-- KING OF PRUSSIA, PA 19406 n TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEA C:) PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY - ' VS. NO: 11-4326-CIVIL James E. Morrison DEFENDANT PRAECIPE TO MARK THE JUDGMENT TO THE USE OF BANK OF AMERICA NATIONAL ASSOCIATION A NATIONAL BANKING ASSOCIATION AS SUCCESSOR IN INTEREST BY MERGER TO MERRILL LYNCH CREDIT CORPORATION TO THE PROTHONOTARY: Kindly mark the judgment in the above-captioned matter to the use of"Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation" as the real party/Plaintiff in interest in this action and the holder of the Note and Mortgage. SHAPIRO & DeNARDO, LLC Date: U 1 t� BY. Attorneys for Plaintiff LI �a std o� c k lAW�ac a ,4 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 11-4326-CIVIL James E. Morrison DEFENDANT CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Mark Judgment to the Use of BANK OF AMERICA, NATIONAL ASSOCIATION, A NATIONAL BANKING ASSOCIATION, AS SUCCESSOR IN INTEREST BY MERGER TO MERRILL LYNCH CREDIT CORPORATION on 1y��3 to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: James E. Morrison, 30 East Slate Hill Road, Carlisle, PA 17013 SHAPIRO &DeNARDO, LLC Date: BY: Attorneys for Plaintiff SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO ESQUIRE ATTORNEY I.D. ' ._ CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 78447 �,yF. . KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 3600 HORIZON DRIVE, SUITE 150 y' KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Merrill Lynch Credit Corporation PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison NO: 11-4326-CIVIL DEFENDANT SUGGESTION OF BANKRUPTCY TO THE PROTHONOTARY: It is hereby suggested of record that James E. Morrison Defendant in the above captioned case has filed Bankruptcy under Chapter BK 135 under Docket No. 13-04223 on August 15, 2013, in the Middle District of Pennsylvania and the above captioned Action in Mort a e gg Foreclosure is accordingly stayed during the pendency of the Bankruptcy. SHAPIRO &DeNARDO, LLC Date: ,.� BY: e<— Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny Ronny R Anderson 1711 L Sheriff Ok' T' L- PRO T'rHONI) -` ``,` Jody S Smith °'Xriti� a� ntab�;�fnfra Chief Deputy 20-13 SEE 10 Am 10: 1 Richard W Stewart UMOERLAND COUNTY, Solicitor OFFICE OF TKE SHERIFF F E IN?4 S Y L VA N I A Merrill Lynch Credit Corporation Case Number vs. James E Morrison 2011-4326 SHERIFF'S RETURN OF SERVICE 06/24/2013 05:50 PM -Deputy Noah Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 30 East Slate Hill Road, North Middleton Township, Carlisle, PA 17013, Cumberland County. 06/24/2013 05:50 PM -Deputy Noah Cline, 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 @AcceptedBy, who accepted as"Adult Person in Charge"for James E Morrison at 30 East Slate Hill Road, North Middleton Township, Carlisle, PA 17013, Cumberland County. 08/16/2013 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: $775.75 SO ANSWERS, September 06, 2013 RONRY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. Y SHAPIRO &DeNARDO, LLC BY: LEONARD J. MUCCI, III, ESQUIRE ATTORNEY I.D. NO: PA Bar#92357 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 11-03 9515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison ; DEFENDANT NO: 11-4326-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Merrill Lynch Credit Corporation, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 30 East Slate Hill Road, Carlisle, PA 17013. 1. Name and address of Owner(s)or Reputed Owner(s) James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 CACH, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: 1 Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 30 East Slate Hill Road Carlisle, PA 17013 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. Section 4904 relating to unworn falsification to authorities. SHA$IRO & A -LC BY: Leonard J. Mucci, III, Esquire 11-039515 SHAPIRO &DeNARDO, LLC BY: LEONARD J. MUCCI, III, ESQUIRE ATTORNEY I.D. NO: PA Bar# 92357 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 11-039515 Merrill Lynch Credit Corporation COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY James E. Morrison ; DEFENDANT NO: 11-4326-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Your house (real estate) at: 30 East Slate.Hill Road, Carlisle,PA 17013 29-15-1247-060 is scheduled to be sold at Sheriffs Sale on September 4, 2013 at: Cumberland_County Sheriff s Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of$118,570.32 obtained by Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call:(610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. U' Y 5: If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling(610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT- COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide)which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife,by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257,page 4521, granted and conveyed unto James E. Morrison, adult man. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-4326 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MERRILL LYNCH CREDIT CORPORATION Plaintiff(s) From JAMES E.MORRISON _(1) You directed to levy upon the property of the defendant(hand to sell SEE LEGAL _ DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: and to notify the gamishee(s)that: (a)an attachment has been issued; (b)the garnishees) 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: $118,570.32 L.L.: Interest FROM JULY 22,2011 TO SEPTEMBER 4,2013 IS$8,070.40 Atty's Comm: Due Prothy:$2.25 Atty Paid: $980.40 Other Costs: Plaintiff Paid: Date: 4/26/13 David D.Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name: LEONARD J.MUCCI, III,ESQUIRE Address: SHAPIRO&DENARDO,LLC 3600 HORIZON DRIVE,SUITE 150 KING OF PRUSSIA,PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 92357 TRUE COPY FROM RECORD in Testimony whereof, i here unto set my hand and the seal of said Cou at Carlisle,/ 0 This�daY of —1L— Prothonotary a- On May 21, 2013 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 30 East Slate Hill Road, Carlisle, as, Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: May 21, 2013 By: Real Estate Coordinator b 1 :I d bZ 8dtl [IgZ LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2011-4326 Civil Term MERRILL LYNCH CREDIT CORPORATION VS. JAMES E. MORRISON Atty.: Christopher DeNardo ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide)which beginning point is located 568.39 feet measured in an Eastwardly direction from the center- line of Longs Gap Road (LIZ 21072) along the Southern line of said Hill Crest Avenue;and at the Eastern line of property conveyed to John R.Miller and Betty H.Miller,his wife by Deed dated June 2,1975;thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R.Klinger and Gladys E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R.and Betty H.Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060. BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and re- corded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257,page 4521, granted and conveyed unto James E. Morrison,adult man. 79 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne)Editor SWORN TO AND SUBSCRIBED before me this dav of Au st 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 1900 Patriot Drive e atr ya twXew s N16chanicsburg, PA 17050 th Inquiries - 717-255-8213 Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the dates) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. -of-Aml If'-ATlnM. _nPV_-_ This ad ran on the date(s)shown below: 20114326 Chril Term MERRILL LYNCH CRED 07/28/13 CORPORATION VS. 08104113 JAMES E MORRISO j d Atty: Christopher Denaro ` 08/11/13 ALL that certain tract of land with the improvements thereon erected situate in North Middleton 'Township, Cumberland County, Pennsylvania, bounded and described at an SWO o subs refore da of Au ust, 2013 A.D. BEGINNING at an iron pin on the Southern Y 9 line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Tongs Gap Road(LR 21072) along the Southern line of said Hill Crest NOta PU IIC Avenue;and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller,his wife by Deed dated June 2,1975; COMMONWEALTH OF PENNSYLVANIA thence from said beginning point continuing Notarial Seal by the Southern line of Hill Crest Avenue Holly Lynn Warfel,Notary Public South 88 degrees 30 minutes East 184.30 feet Washington TWp.,Dauphin county to an iron pin;thetaoperty being M Commission Expires Dec.12,2016 retained by the Estates of Arthur R.Klinger MEMBER,PENNSYLVANIA AS50 A ON OF NOTARIES and Gladvs,ls.Rljnge eceased._, uS2 ShJ1_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: () Confessed Judgment () Other ` 1 _ 301 Bank of America,National Association, a File No. t 1 (a national banking association, as successor in Amount Due $118,570.32 interest by merger to Merrill Lynch Credit Interest July 22, 2011 to June 4, 2014 is Corporation $10,909.60 PLAINTIFF Atty's Comm Costs vs. -v E.i._ V)T N .? James E. Morrison rs3 - DEFENDANT(S) "�° s� --{ TO THE PROTHONOTARY OF THE SAID COURT: xcc) The undersigned hereby certifies that the below does not arise out of a retail installmer sa ; contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s)described in the attached exhibit. A Date: 0,\"\A Signature: ,� Print Name: Br. . : J Osborne Address: 3610 Horizon Drive, Suite 150 c vA s y)..St X a King of Prussia, PA 19406 � .UD c� Attorney for: Plaintiff (0(0 ui rc Supreme Court ID #PA Bar# 312169 11 S.1 s II 0.00 1 ttr't, SD.2S d. as) .so`` ( IQD)Uo Co') Pa ���53 Jd .0 l� g`1. IS a � SHAPIRO & DeNARDO, LLC w . . ,�.1:' r BY: CHRISTOPHER A. DeNARDO, 49014 JAN 22 'f ; ESQUIRE, ATTORNEY I.D. NO. 78447 C(j eh 4/f CAITLIN M. DONNELLY, ESQUIRE, p ,4i ATTORNEY I.D. NO. 311403 DNS BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America, National Association, a COURT OF COMMON PLEAS national banking association, as successor in CIVIL DIVISION interest by merger to Merrill Lynch Credit CUMBERLAND COUNTY Corporation PLAINTIFF NO: 11-4326-CIVIL VS. James E. Morrison DEFENDANT AFFIDAVIT PURSUANT TO RULE 3129.1 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 30 East Slate Hill Road, Carlisle, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s) James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: J Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 CACH, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: Bank of America,National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation 4001 LEADENHALL ROADMAILSTOP SV-01 MT. LAUREL, NJ 08054 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 30 East Slate Hill Road Carlisle, PA 17013 s 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. Section 4904 relating to unsworn falsification to authorities. SHAPIRO & DeNARDO, LLC BY: ro� / Brae J Osborne 11-039515 e. c Z,; W- SHAPIRO & DeNARDO, LLC N BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 r'.*--* CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 iC " CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America,National Association, a COURT OF COMMON PLEAS national banking association, as successor in CIVIL DIVISION interest by merger to Merrill Lynch Credit CUMBERLAND COUNTY Corporation PLAINTIFF NO: 11-4326-CIVIL VS. James E. Morrison DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Your house(real estate) at: 30 East Slate Hill Road,Carlisle, PA 17013 29-15-1247-060 is scheduled to be sold at Sheriffs Sale on June 4, 2014 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of$118,570.32 obtained by Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Bank of America,National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling(610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue(40 feet wide)which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road(LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller,his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow,husband and wife,by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257,page 4521, granted and conveyed unto James E. Morrison, adult man. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-4326 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA,NATIONAL ASSOCIATION,A NATIONAL BANKING ASSOCIATION,AS SUCCESSOR IN INTEREST BY MERGER TO MERRILL LYNCH CREDIT CORPORATION Plaintiff(s) From JAMES E.MORRISON (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: $118,570.32 L.L.: Interest JULY 22,2011 TO JUNE 4,2014 IS$10,909.60 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,794.15 Other Costs: Plaintiff Paid: Date: 1/22/2014 David D. Buell,Prothonota (Seal) • �� ' _ L/.01'/_ Deputy REQUESTING PARTY: Name: BRADLEY J.OSBORNE,ESQUIRE Address: SHAPIRO& DENARDO,LLC 3600 HORIZON DRIVE,SUITE 150 KING OF PRUSSIA,PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No.312169 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT. - Or- )80 2014' 4PR 30 I. 1:09 GUNS f-Q, A NO COUNT)/ PENN YL.VANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:11-4326-CIVIL CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Meghan Williams, Legal Assistant for Shapiro & DeNardo, LLC, attorneys for the Plaintiff, Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation, hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on February 28, 2014, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Date: 11-039515 By: SHAPIRO & DENARD Meghan Williams Legal Assistant Name and Address of Sender Shapiro & DeNardo, LLC 3600 Horizon Drive Suite 150 King of Prussia, PA 19406 Check type of mail or service: O Certified O COD O Delivery Confirmation O Express Mail O Insured O Recorded Delivery (International) O Registered O Return Receipt for Merchandise O Signature Confirmation Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street, City State, & ZIP Code) Postage Fee Handling harge Actual Value if Registered . U.S. POSTAGE» PITNEY BOWES ZIP 111,9406 $ 001.88° 387362 FEB. 28. 2614 Insured Val aer F • on Fee F 11-039515 MW Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 CACH, LLC 4340 South Monaco Street Denver, CO 80237 Tenant or Occupant 30 East Slate Hill Road Carlisle, PA 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Fee Fee 6. eel 7. 8. U z U Total Number of Pieces Listed by Sender 4 Total Number of Pieces Recei a P Office PS Form 3877, February 2002 age 1 of 1) Post Egier. Per Me o elyin erniVoye pewriter, Ink or Ball Point Pen See Privacy Act Statement on Reverse F:\FILES\Clients\10148 Morrison\10148.3.motion l.wpd Seth T. Mosebey, Esquire Attorney I.D. No. 203046 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant N N 1 BANK OF AMERICA, NATIONAL ASSOCIATION, a national banking association, as successor in interest by merger to MERRILL LYNCH CREDIT CORPORATION, Plaintiff v. JAMES E. MORRISON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2011 - 4326 CIVIL TERM t r. u ,' Y; CD- ; EMERGENCY MOTION TO POSTPONE SHERIFF'S SALE AND NOW, comes Sheri Morrison, as agent for James E. Morrison, by and through their attorneys, Martson Law Offices, and hereby files her Emergency Motion to Postpone Sheriff's Sale and in support thereof avers as follows: 1. On May 13, 2011, the above captioned action was filed against Defendant, James E. Morrison ("Defendant"). 2. On or about July 21, 2011, default judgment was entered against James E. Morrison ("Defendant") by the Plaintiff in the amount of $118,570.32. 3. Thereafter, Plaintiff filed a Praecipe for Writ of Execution on July 21, 2011, requesting that the Real Property (hereinafter defined) be sold. 4. Defendant and his wife, Sheri Morrison ("Mrs. Morrison"), filed a Voluntary Petition for Chapter 13 bankruptcy on December 2, 2011. 5. The bankruptcy case was dismissed on December 16, 2013. 6. Defendant and Mrs. Morrison filed a second Voluntary Petition for Chapter 13 bankruptcy on August 15, 2013. 7. The second bankruptcy case was dismissed on January 9, 2014. 8. Plaintiff has listed the sale of Defendant's residence that is located at 30 East Slate Hill Road, Carlisle, Cumberland County, Pennsylvania (the "Real Property"), for Sheriff's Sale on June 4, 2014. 9. Defendant is 63 years of age and currently resides with Mrs. Morrison. 10. Defendant has been undergoing treatment for dementia since approximately 2011. 11. As a result of Defendant's dementia, he experiences difficulty understanding and processing information and does not have the ability to independently handle his affairs. 12. It is believed, and therefore averred, that Defendant received pleadings and related documents in the above -captioned action from Plaintiff and/or the Sheriff of Cumberland County for which Defendant did not understand and did not provide to a competent third party to review. 13. As a result of Defendant's dementia, Mrs. Morrison has assumed the responsibility for handling Defendant's affairs pursuant to a Power of Attorney. A copy of the Power of Attorney is attached hereto and incorporated herein as Exhibit "A." 14. Mrs. Morrison has applied for a loan to refinance the debt owed to Plaintiff through American Advisors Group. Correspondence from Bryan Iijima confirming the application for financing with American Advisors Group is attached hereto and incorporated herein as Exhibit "B." 15. American Advisors Group has stated that the refinance will be approved upon receipt of an appraisal and possible negotiation of the debt owed to Plaintiff. 16. In order to refinance the debt, a 60 -day postponement of the Sheriffs Sale is required. 17. Upon information and belief, American Advisors Group has engaged in negotiations with Plaintiff to resolve the debt. 18. While the negotiations have not yet resulted in agreement, Defendant believes that the negotiations are beneficial to both parties and that both parties would benefit from a delay in the pending Sheriff's Sale. 19. No Judge has previously ruled on any other issue in this matter. 20. Counsel for Defendant contacted counsel for Plaintiff, but Plaintiff for counsel was unable to provide their client's concurrence with the relief requested herein. 21. No substantial harm will be suffered by Plaintiff as a result of the postponement; in fact, the postponement will result in Plaintiff being paid off in whole or in part. WHEREFORE, Defendant James E. Morrison requests that the Sheriffs sale of the real property located at 30 East Slate Hill Road, Carlisle, Pennsylvania, be postponed from June 4, 2014, to August 6, 2014. Dated: 6-h1jitt MARTSON LAW OFFICES Seth T. Mosebey, Esquire I.D. No. 203046 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant EXHIBIT "A" Power of Attorney Know all Men by these Presents, that 1, James E. Morrison, of 30 East Slate Hill Road, Carlisle, Cumberland County, Pennsylvania, do make, constitute and appoint my wife, Sheri -Ann W. Morrison, of 30 East Slate Hill Road, Carlisle, Cumberland County, Pennsylvania to be my true and lawful agent for me and in my name to conduct all my worldly affairs, including but not limited to the power and authority: (I) to authorize my admission to or discharge from any medical, nursing, residential or similar facility; enter into agreements for my care and authorize medical, therapeutical and surgical procedures; consent to, refuse or withdraw any care, treatment, service or medical procedure; and receive, review and obtain copies of my medical records; (2) to engage in real property transactions, including but not limited to the power to buy, sell and convey any real property; make, execute, acknowledge and deliver good and sufficient deeds, agreements, conveyances and easements; mortgage, encumber, lease, rent, dedicate, subdivide, insure and improve said real estate and execute plans, affidavits, settlement sheets and all other documents relating to the real estate transaction; (3) to engage in tangible personal property transactions, including but not limited to the power to buy, sell, lease, exchange, collect, possess, maintain, repair and insure personal property; (4) to engage in stock, bond and other security transactions, including but not limited to the power to buy, sell, exchange, transfer or otherwise dispose of any stock, bond or other security; collect dividends, interests and other distributions and vote in person or by proxy on behalf of the Principal; (5) to engage in banking and financial transactions, including but not limited to the power to execute, endorse and draw checks, draftsorders, notes and biUs of exchange; make withdrawals from any account in the name of the Principal at any institution; open and close accounts; purchase and redeem savings certificates, certificates of deposit or similar instruments; deposit funds and generally do all acts regarding any account or certificate at any bank or institution; (6) to borrow money; (7) to enter safe deposit boxes wherever located; (8) to engage in insurance transactions, including but not limited to the power to purchase, renew, convert or terminate any type of insurance, pay premiums and collect benefits and proceeds under insurance polieies; (9) to engage in retirement plan transactions; (10) to handle interests in estates and trusts; (11) to pursue claims and litigations, including but not limited tothe power to institute, prosecute, defend, arbitrate, compromise or settle any claim or lawsuit; (12) to receive government benefits; (13) to pursue tax matters; (14) to disclaim any interest in property; and (15) to renounce fiduciary positions. This Power ofAttorney shalt not be affected by disability ofthe Principal. d w�Tn IN WITNESS WHEREOF, [have hereunto set noyhand and seal tbu�+`� duyo[June, 201 1. Any other Power of Attorney made heretofore is hereby revoked and null and void. SIGNED, SEALED AND DELIVERED IN THE PRESENCE F US: /k.1 Pt DU44-AMES E. MORRISON COMMONWEALTH OF PENNSYLVANIA COUNTY OF e l.l..�-16Eli' l 4tv 1 ThiscZ day of June, 201 1, personally appeared before me, the above-named James E. Morrison and acknowledged the foregoing Power of Attorney to be his act and deed, and desired the same might be recorded as such, according to law. aforesaid. (SEAL) WITNESS my hand and notarial seal, the day and year NOTARIAL SEAL Camela J. Manges Boro of Carlisle, Cumberland County My Commission Expires June 21, 2014 5601 (c) (J LL My Commission Expires NOTICE THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON YOU DESIGNATE (YOUR "AGENT") BROAD POWERS TO HANDLE YOUR PROPERTY, WHICH MAY INCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL BY YOU, THIS POWER OF ATTORNEY DOES NOT IMPOSE A DUTY ON YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE EXERCISED, YOUR AGENT MUST USE DUE CARE TO ACT FOR YOUR BENEFIT AND IN ACCORDANCE WITH THIS POWER OF ATTORNEY. YOUR AGENT MAY EXERCISE THE POWERS GIVEN HERE THROUGHOUT YOUR LIFETIME, EVEN AFTER YOU BECOME INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE DURATION OF THESE POWERS OR YOU REVOKE THESE POWERS OR A COURT ACTING ON YOUR BEHALF TERMINATES YOUR AGENT'S AUTHORITY. YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FROM YOUR AGENT'S FUNDS. A COURT CAN TAKE AWAY THE POWERS OF YOUR AGENT IF IT FINDS YOUR AGENT IS NOT ACTING PROPERLY. THE POWERS AND DUTIES OF AN AGENT UNDER A POWER OF ATTORNEY ARE EXPLAINED MORE FULLY IN 20 Pa.C.S. Ch 56. IF THERE IS ANYTHING ABOUT THIS FORM THAT YOU DO NOT UNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO EXPLAIN IT TO YOU, I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE AND I UNDERSTAND ITS CONTENTS. 0,-617/a11-6“;i, 07C, /r E. MORRISON, PRINCIPAL 5601 (d) NOTICE I, SHERI-ANN W. MORRISON, HAVE READ THE ATTACHED POWER OF ATTORNEY AND AM THE PERSON IDENTIFIED AS THE AGENT FOR THE PRINCIPAL. I HEREBY ACKNOWLEDGE THAT IN THE ABSENCE OF A SPECIFIC PROVISION TO THE CONTRARY IN THE POWER OF ATTORNEY OR IN 20 Pa.C.S. WHEN I ACT AS AGENT: I SHALL EXERCISE THE POWERS FOR THE BENEFIT OF THE PRINCIPAL. I SHALL KEEP THE ASSETS OF THE PRINCIPAL SEPARATE FROM MY ASSETS. I SHALL EXERCISE REASONABLE CAUTION AND PRUDENCE. I SHALL KEEP A FULL AND ACCURATE RECORD OF ALL ACTIONS, RECEIPTS AND DISBURSEMENTS ON BEHALF OF THE PRINCIPAL. SHERI-ANN W. MORRISON, AGENT DATE e;%'"— c-.)/ / EXH[BTT "B" Seth T. Mosebey From: Bryan Iijima <bryani@aag.com> Sent: Friday, May 23, 2014 12:58 PM To: Seth T. Mosebey Subject: James and Sheri Morrison Hello Mr. Mosebey. Sheri Morrison has notified me that you are assisting her in getting the Morrison's foreclosure sale postponed. Thank you for your help. I am the person working with her on a reverse mortgage in order to provide funds to resolve her mortgage delinquency. If you have any questions, please do not hesitate to call me. All of my contact information is listed below. Her loan file with AAG is currently on hold until her foreclosure sale is postponed. She needs to have an appraisal done next, and I didn't want to incur another cost for her until we received notice that the sale was cancelled. Please keep me informed on the status of the Sheriff's Sale postponement so I will know when it is safe to move forward with her loan. Thanks again. Have a wonderful Memorial Day weekend. Bryan lijima 1 Reverse Mortgage Professional Solutions Specialist - Solutions Department Manager Sales Manager AMERICAN ADVISORS GROUP NMLS ID: 190099 PHONE: 866.948.0003 EXT. 213 1 FAX: 866.413.4834 EMAIL: brvani@AAG.com ADDRESS: 3800 W. Chapman Avenue, Third Floor, Orange, CA 92868 APlease consider the environment before printing this email. CONFIDENTIALITY NOTICE THIS COMMUNICATION MAY CONTAIN INFORMATION THAT IS PROPRIETARY, PRIVILEGED OR CONFIDENTIAL, OR OTHERWISE LEGALLY EXEMPT FROM DISCLOSURE. IF YOU ARE NOT THE NAMED ADDRESSEE, YOU ARE NOT AUTHORIZED TO READ, PRINT, RETAIN, COPY OR DISSEMINATE THIS MESSAGE OR ANY PART OF IT. IF YOU HAVE RECEIVED THIS MESSAGE IN ERROR, PLEASE NOTIFY THE SENDER IMMEDIATELY BY EMAIL AND DELETE ALL COPIES OF THE MESSAGE. THANK YOU. 1 VERIFICATION The foregoing Motion is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Sheri -Ann W. Morrison, a:ent for James E. Morrsion Dated: 6 Zit'- 20/V F:\FILES\Clients\ 10148 Morrison \10148.3.motion l .wpd CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Emergency Motion to Postpone Sheriff's Saale was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Caitlin M. Donnelly, Esq. Shapiro & Denardo, LLC, 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 MARTSON LAW OFFICES By: Dated: k..5702 -7//r C2u4 Maify Price Ten Eat High Street Carlisle, PA 17013 (717) 243-3341 BANK OF AMERICA, NATIONAL ASSOCIATION, a national banking association, as successor in interest by merger to MERRILL LYNCH CREDIT CORPORATION, Plaintiff v. JAMES E. MORRISON Defendant AND NOW, this - day of , 2014, upon consideration of Defendant's Emergency Motion to Postpone Sheriff's Sale, it is hereby ORDERED that the Sheriff's Sale of the property located at 30 East Slate Hill Road, Carlisle, Pennsylvania, is postponed from June 4, 2014, to August 6, 2014. Counsel for Defendant shall provide notice of the entry of this Order to Plaintiff and to the Cumberland County Sheriff's Office. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2011 - 4326 CIVIL TERM ORDER Distribution: .Seth T. Mosebey, Esquire ;/Caitlin M. Donnelly, Esquire Thomas A. Placey Common Pleas Judge c3 C: C74,7▪ 2 • r. .:,,C7-_-71;:::: - C) :4;. SHAPIRO & DeNARDO,LLC y 7 H` �F' 111 • c BY: CHRISTOPHER A. CAITLIN M.DONNELLDYeES DIRE ATTORNEY I.D.UIRE, NO 3EY 114030 ��s�4��t. 3 1 PM 1 • r" QCU/t,, 5 9 CCHANDRA M.ARK MA,DLEY J. OSBORNE, ATTORNEY ATTORNEY I.D. NO. I.D.NO. 2034 37 PE N NSti �?(atiT Y Nll� 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation 2001 Bishops Gate Blvd. Attn: Mail Stop SV -01 MT. LAUREL, NJ 08054 PLAINTIFF VS. James E. Morrison DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY 11 -4326 -CIVIL Notice of the Date of Continued Sheriff's sale The Sheriff's Sale scheduled for August 6, 2014 at 10:00 AM in the above -captioned matter has been continued until October 1, 2014. Date: 96°4 BY: SHAPIRO & DeNARDO, LLC eys for Plaintiff d iNE,iSQUI R SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America, National Association, a COURT OF COMMON PLEAS national banking association, as successor in CIVIL DIVISION interest by merger to Merrill Lynch Credit CUMBERLAND COUNTY Corporation PLAINTIFF NO:11-4326-CIVIL vs. James E. Morrison DEFENDANT(S) CERTIFICATE OF SERVICE I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Date: y BY: SHAPIRO & DeNARDO, LLC A moneys for Plaintiff �s L ©as L N , ESQXMLII Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY .Ftit, 9i 4llrFat��,0TArla,.. , 2114 OCT - AM .9:35 CUM ERLAND COUNTY PENNSYLVANIA Bank of America NA vs. James E Morrison Case Number 2011-4326 SHERIFF'S RETURN OF SERVICE 03/24/2014 03:39 PM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 30 East Slate Hill Road, North Middleton - Township, Carlisle, PA 17013, Cumberland County. 03/24/2014 03:39 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: James E Morrison at 30 East Slate Hill Road, North Middleton Township, Carlisle, PA 17013, Cumberland County. 06/03/2014 As directed by Christopher Denardo, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 07/28/2014 As directed by Christopher Denardo, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014 10/01/2014 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: $850.26 SO ANSWERS, October 04, 2014 (c) CountySu: e 5'ierii`. i eleoselt. Inc. RONNR ANDERSON, SHERIFF ch 3/a 335, 0 0 On January 27, 2014 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 300 East Slate Hill Road, Carlisle, as Exhibit "A" filed with this writ and by this Reference incorporated herein. rn N Date: January 27, 2014 By: i Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2011-4326 Civil Term Bank of America N.A. vs. James E. Morrison Atty.: Christopher DeNardo ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the center- line of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Gladys E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060. BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and re- corded in the Cumberland County Recorder of Deeds Office on July I, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. 82 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 2 day of May, 2014 _Z-.-110441) Notary r COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. ,2020 Technology Pkwy Suite' 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the patriogews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newsoaoers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State 2011-4326 Civil Term Bank of America NA Vs James E Morrison Atty: Christopher Denardo ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania,, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Gladys E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July I, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. ews and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, en continuously published ever since; e or publication which is securely attached hereto is exactly as printed and published in their regular inity Weekly editions which appeared on the date(s) indicated below. That neither she nor said subject matter of said printed notice or advertising, and that all of the allegations of this statement as :ter of publication are true; and al knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on ;o. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the rectors of the said Company and subsequently duly recorded in the office for the Recording of Deeds tphin in Miscellaneous Book "M", Volume 14, Page 317. This ad ran on the date(s) shown below: 04/13/14 04/20/14 • 04/27/14 - and subscribed before m hi a ublic • day of May, 2014 A.D. COM iNWE LTH OF PENNSYLVANIA Notarial Seal Holly Lynn rotary Public r!ashirigton Twp., Dauphin County My Cc7rimission Exf:ires Dec. 12, 2016 MEMBER. PENNSYI VANTA eccr"TION OF NOTARIES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation PLAINTIFF vs. James E. Morrison DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment ( ) Other File No. 1..4/3c(, Amount Due $118,570.32 Interest July 22, 2011 to March 4, 2015 isc $13,748.80 Atty's Comm Costs C) r.."2 CZ::7 'E- rn GI C) r - <CD Zeg The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: fQLtS6 pLQ47 ac, # /100(3 V Olfr 30-1 'r 11 If I( 'I 41 II It if i-1:9; c4 ar `Ls -0 ra_.e, 1( Signature: Print Name:___icy J Osborne Address: 0 Horizon Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 312169 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 11 -4326 -CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 "11 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 30 East Slate Hill Road, Carlisle, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s) James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 2. Name and address of Defendant in the judgment: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation 2001 Bishops Gate Blvd., Attn: Mail Stop SV -01 MT. LAUREL, NJ 08054 CACH, LLC 4340 South Monaco Street Denver, CO 80237 4. Name and address of the last recorded holder of every mortgage of record: Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation 2001 Bishops Gate Blvd., Attn: Mail Stop SV -01 MT. LAUREL, NJ 08054 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 30 East Slate Hill Road Carlisle, PA 17013 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. Section 4904 relating to unsworn falsification to authorities. BY: 11-039515 SHAPIRO & DeNARDO, LLC SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144 3600 HORIZON DRIVE, SUITE 150 M mt53 CD, KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 tnr- S & D FILE NO. 11-039515 r- --4 C.) < CZ' D=1. Bank of America, National Association, a COURT OF COMMON PLEAS national banking association, as successor in CIVIL DIVISION (0 - .7c interest by merger to Merrill Lynch Credit CUMBERLAND COUNTY 713 ••< Or% Corporation PLAINTIFF NO: 11 -4326 -CIVIL VS. James E. Morrison DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison 30 East Slate Hill Road Carlisle, PA 17013 Your house (real estate) at: 30 East Slate Hill Road, Carlisle, PA 17013 29-15-1247-060 is scheduled to be sold at Sheriffs Sale on March 4, 2015 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $118,570.32 obtained by Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE 0. HUGGINS, ATTORNEY I.D. NO. 85144 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation PLAINTIFF < CZ) C) 2c) — COURT OF COMMON PLEAS'= • CIVIL DIVISION CUMBERLAND COUNTY NO: 11 -4326 -CIVIL VS. James E. Morrison DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison c/o Seth T. Mosebey, Esquire. 10 East High Street Carlisle, PA 17013 Your house (real estate) at: 30 East Slate Hill Road, Carlisle, PA 17013 29-15-1247-060 is scheduled to be sold at Sheriffs Sale on March 4, 2015 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $118,570.32 obtained by Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be cancelled if you pay back to Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings.. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Glady's E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY LD. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE 0. HUGGINS, ATTORNEY 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO 11 039515 I.D. NO. 85144 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation PLAINTIFF c COURT OF COMMON PLEAS7;.., CIVIL DIVISION CUMBERLAND COUNTY NO: 11 -4326 -CIVIL -11 rn -9 - r - r1 cD =-1"1 11:0 CD -1-1 14, —4 cr VS. James E. Morrison DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Morrison c/o Sheri -Ann W. Morrison as Power of Attorney 30 East Slate Hill Road Carlisle, PA 17013 Your house (real estate) at: 30 East Slate Hill Road, Carlisle, PA 17013 29-15-1247-060 is scheduled to be sold at Sheriffs Sale on March 4, 2015 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $118,570.32 obtained by Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay back to Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 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 be able to stop the sale through other legal proceedings. 4. 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 of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. 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. 7. 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 717-240-6390. 8. 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. 9. You have a 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 11-039515 ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin on the Southern line of Hill Crest Avenue (40 feet wide) which beginning point is located 568.39 feet measured in an Eastwardly direction from the centerline of Longs Gap Road (LR 21072) along the Southern line of said Hill Crest Avenue; and at the Eastern line of property conveyed to John R. Miller and Betty H. Miller, his wife by Deed dated June 2, 1975; thence from said beginning point continuing by the Southern line of Hill Crest Avenue South 88 degrees 30 minutes East 184.30 feet to an iron pin; thence by other property being retained by the Estates of Arthur R. Klinger and Gladys E. Klinger, deceased, South 39 degrees 33 minutes 56 seconds West 298.92 feet to an iron pin; thence by property now or formerly of John R. and Betty H. Miller North 1 degree 30 minutes East 235.34 feet to the place of beginning. PARCEL No. 29-15-1247-060 BEING the same premises which Don E. Backenstow and Anne. R. Backenstow, husband and wife, by Deed dated June 30, 2003 and recorded in the Cumberland County Recorder of Deeds Office on July 1, 2003 in Deed Book 257, page 4521, granted and conveyed unto James E. Morrison, adult man. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 LEEANE O. HUGGINS, ATTORNEY I.D. NO. 85144 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 11-039515 Bank of America, National Association, a national banking association, as successor in interest by merger to Merrill Lynch Credit Corporation PLAINTIFF VS. James E. Morrison DEFENDANT Ca COURT OF COMMON PLEARci CIVIL DIVISION z rri CUMBERLAND COUNTY <CD pc, xc NO:11-4326-CIVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY 9Z :1114V 6-130 h10i I hereby certify that I am the Attorney of record for the Plaintiff in this Action against Real Property and further certify this Property is: FHA - Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit That the Plaintiff has complied in all respects with Section 403 of the Mortgage X Assistance Act including but not limited to: (a) Service of notice on Defendant (b) Expiration of 30 days since the service of notice (c) Defendant failure to request or appear at meeting with Mortgagee or Consumer Credit Counseling Agency (d) Defendant failure to file application with Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any false statement given herein. Date: BY: SHAPIRO & DeNARDO, LLC Atto r Plaintiff EY J. OSBORNE, ESQ. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net BANK OF AMERICA, NATURAL ASSOCIATION, A NATIONAL BANKING ASSOCIATION, AS SUCCESSOR IN INTEREST BY MERGER TO MERILL LYNCH CREDIT CORPORATION Vs. NO 11-4326 Civil Term CIVIL ACTION — LAW JAMES E. MORRISON WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $118,570.32 L.L.: Interest JULY 22,2011 TO MARCH 4, 2015 IS $13,748.80 Atty's Comm: Atty Paid: $2672.91 Plaintiff Paid: Date: 10/09/2014 Due Prothy: $2.25 Other Costs: Davi Buell, Protho fary (Seal) By: Deputy REQUESTING PARTY: Name: BRADLEY J. OSBORNE, ESQ. Address: SHAPIRO & DENARDO, LLC, 3600 HORIZON DRIVE, SUITE 150, KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 312169