HomeMy WebLinkAbout11-8218PHELAN HALLINAN & SCHMIEG, LLP
Robert P. Wendt, Esq., Id. No.89150 _
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza ATTORNEY FOR PLAINTIFF
Philadelphia, PA 19103 R b, 0
215-563-7000
BANK OF AMERICA, N.A. SUCCEQ d ?r °
MERGER TO BAC HOME LOANS SE071 NG, L.P. COURT OF COMMON PLEAS
F/K/A COUNTRYWIDE HOME LOANS
SERVICING, L.P. CIVIL DIVISION
7105 CORPORATE DRIVE
PLANO, TX 75024 TERM
Plaintiff NO. 1 1_ ?? l g "? U l
V.
CUMBERLAND COUNTY
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Defendants
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 274682
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NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
File #: 274682
Plaintiff is
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE HOME LOANS SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
2. The name(s) and last known address(es) of the Defendant(s) are:
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 10/01/2007 ANTHONY M. SCIORTINO and HEATHER A. SCIORTINO made,
executed and delivered a mortgage upon the premises hereinafter described to
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A
NOMINEE FOR COUNTRYWIDE BANK, FSB which mortgage is recorded in the
Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No.
200739018. By Assignment of Mortgage recorded 05/20/2011 the mortgage was
assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage
Instrument No. 201114551. The mortgage and assignment(s), if any, are matters of
public record and are incorporated herein by reference in accordance with Pa.R.C.P.
1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to
pleadings if those documents are of public record.
4. The premises subject to said mortgage is described as attached.
The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 02/01/2011 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
File #: 274682
by written notice sent to Mortgagor, the entire principal balance and all interest due
6.
thereon are collectible forthwith.
The following amounts are due on the mortgage as of 08/12/2011:
Principal Balance $255,563.72
Interest $9,994.76
01 /01 /2011 through 08/ 12/2011
Late Charges $248.91
Property Inspections $35.00
Escrow Deficit 756.39
TOTAL $266,598.78
7
9
Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as
required by the mortgage document, as applicable, have been sent to the Defendant(s) on
the date(s) set forth thereon.
The action does not come under Act 6 of 1974 because the original mortgage amount
exceeds the dollar amount provided in the statute.
File #: 274682
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$266,598.78, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN & SCHMIEG, LLP
dBy.
Ro ert P. Wendt, Esq., Id. No.89150
Attorney for Plaintiff
File #: 274682
LEGAL DESCRIPTION
All that certain parcel of land situate in the East side of Heisey Road, in the Township of
Monroe, County of Cumberland and Commonwealth of Pennsylvania, being known and
designated as follows:
Parcel 1:
BEGINNING at a concrete monument on the eastern dedicated right-of-way line of Heisey Road,
T-560, at line of Lot No. 22 on the hereinafter mentioned Plan of Lots; thence along the Eastern
dedicated right-of-way line of Heisey Road, T-560, North 00 degrees 27 minutes 40 seconds
West, a distance of 100.47 feet to a point; thence along Lot No. 20 on the hereinafter mentioned
Plan of Lots, North 89 degrees 36 minutes 55 seconds East, a distance of 199.13 feet to a point;
thence along other lands now or formerly of Donald E. Deckman and Marian R. Deckman,
husband and wife, South 00 degrees 23 minutes 00 seconds East, a distance of 100.47 feet to a
point; thence along line of Lot No. 22 on the hereinafter mentioned Plan of Lots, North 89
degrees 36 minutes 55 seconds West, a distance of 198.99 feet to a concrete monument, the place
of BEGINNING.
Being Lot No. 21 on a Final Plan of Major Subdivision for Donald E. Deckman, prepared by
Rodney Lee Decker and Associates, dated October 21, 1986 and recorded in Subdivision Plan
Book 51, Page 140.
Parcel 2:
File #: 274682
BEGINNING at a concrete monument set on the Easternmost dedicated right-of-way line of
Heisey Road (T-560), at the common point of adjoiner of Lots No. 20-A and No. 20-B on the
hereinafter mentioned plan; thence departing from said right-of-way and extending along Lot No.
20-A, North eighty-nine (89) degrees thirty-six (36) minutes fifty-five (55) seconds East, for a
distance of one hundred ninety-nine and nineteen hundredths (199.19) feet to a steel pin at other
lands now or formerly of Donald E. Deckman and Marian R. Deckman, husband and wife;
thence extending along said land, South zero (00) degrees twenty-three (23) minutes five (05)
seconds East for a distance of fifty and twenty hundredths (50.20) feet to a steel pin at Lot No.
21; thence extending along Lot No. 21, South eighty-nine (89) degrees thirty-six (36) minutes
fifty-five (55) seconds West, for a distance of one hundred nineteen and thirteen hundredths
(119.13) feet to a steel pin set on the Easternmost dedicated right-of-way line of Heisey Road;
thence extending in and along said right-of-way line, North zero (00) degrees twenty-seven (27)
minutes forty (40) second West, for a distance of fifty and twenty hundredths (50.20) feet to a
concrete monument at Lot No 20-A, said monument marking the place of BEGINNING.
BEING designated as Lot No. 20-B on an Amendment of a final plan of major subdivision
prepared for Donald E. Deckman by Rodney Lee Decker and Associates, which Amendment is
dated January 14, 2004, and recorded in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania in Plan Book 89, Page 22.
TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, driveways,
passages, waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances,
whatsoever unto the hereby granted premises belonging, or in any wise appertaining, and the
reversions and remainders, rents, issues, and profits thereof; and all the estate, right, title,
File #: 274682
interest, property, claim and demand whatsoever of Grantor(s), as well at law as in equity, of, in,
and to the same.
PROPERTY ADDRESS: 485 HEISEY ROAD, MECHANICSBURG, PA 17055-9773
PARCEL # 22-11-0280-095
File #: 274682
VERIFICATION
,hereby states that h s e ' ?Mt, UICe of, BANK OF
AMERICA, N.A., Plaintiff in this matter, that he she s authorized to make this Verification, and
verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true
and correct to the best of hi er owledge, 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.
DATEC '?6rrJd&
File #: 274682
Name: SCIORTINO
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C
o?rA -4
Name:
Title:
`;i
BANK OF AMERICA, N.A.
File #: 274682
Phelan Hallinan & Schmieg, LLP
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallman, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Jay B. Jones, Esq., Id. No. 86657
Andrew L. Spivack, Esq., Id. No. 84439
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Courtenay R. Dunn, Esq., Id. No. 206779
Allison F. Wells, Esq., Id. No. 309519
William E. Miller, Esq., Id. No. 308951
Melissa J. Cantwell, Esq., Id. No. 308912
Mario J. Hanyon, Esq., Id. No. 203993
Andrew J. Marley, Esq., Id. No. 312314
Robert W. Cusick, Esq., Id. No. 80193
John M. Kolesnik, Esq., Id. No. 308877
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
BANK OF AMERICA, N.A. SUCCESSOR BY
MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE
HOME LOANS SERVICING, L.P.
Plaintiff ;
VS.
FILED-OFFICE
04- THE PROTHONOTAI i
2012 FEB -6 AM 9: 36
CUMBERLAND COUNT'
PENNSYLVANIA
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
ANTHONY M. SCIORTINO No. 11-8218-CIVIL
HEATHER A. SCIORTINO
Defendants
PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE
0.? 411.75 ? 4
Ck- I l -s:2r gy
?-? aZD z ?o
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above
captioned matter.
PHEL AN & SCHMIEG, LLP
By:
awrence T. Phelan, Esq., Id. No. 32227
41 Francis S. Hallinan, Esq., Id. No. 62695
? Daniel G. Schmieg, Esq., Id. No. 62205
? Michele M. Bradford, Esq., Id. No. 69849
? Judith T. Romano, Esq., Id. No. 58745
? Jenine R. Davey, Esq., Id. No. 87077
? Lauren R. Tabas, Esq., Id. No. 93337
? Jay B. Jones, Esq., Id. No. 86657
? Andrew L. Spivack, Esq., Id. No. 84439
? Chrisovalante P. Fliakos, Esq., Id. No. 94620
? Courtenay R. Dunn, Esq., Id. No. 206779
? Allison F. Wells, Esq., Id. No. 309519
? William E. Miller, Esq., Id. No. 308951
? Melissa J. Cantwell, Esq., Id. No. 308912
? Mario J. Hanyon, Esq., Id. No. 203993
? Andrew J. Marley, Esq., Id. No. 312314
? Robert W. Cusick, Esq., Id. No. 80193
9"fohn M. Kolesnik, Esq., Id. No. 308877
Attorneys for Plaintiff
Date: February 3, 2012
/tam, Svc Dept.
File# 274682
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
Sheriff
Jody S Smith o
Chief Deputy 2012 FEB 28 AM 8:34
Richard W Stewart { /}}/?ry(( ¢p( i{i{ {{ ?`y7?
Solicitor .}?? pyG 1 \? V ?? i 11f4 ? FJ i iJ i 4 P I
PENNSYLVANIA
Bank of America, NA
Case Number
vs.
Anthony Michael Sciortino (et al.) 2011-8218
SHERIFF'S RETURN OF SERVICE
02/24/2012 12:10 PM - Brian Barrick, Corporal, who being duly sworn according to law, states that on February 24,
2012 at 1210 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Anthony Michael Sciortino, by making known unto himself personally, a
The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland Cou
Pennsylvania 17013 its contents and at the same time handing to him personally the said true and c r ct
copy of the same.
BRIAN BARRICK:, DEPUTY
SHERIFF COST: $38.00
February 23, 2012
SO ANSWERS,
r
RON R ANDERSON, SHERIFF
4/04/2012
Tony Sciortino
485 Heisey Rd.
Mechanicsburg, PA 17055
717-439-3161
NO. 11-8218-CIVIL Cumberland County
Bank ok America, N.A. Successor by
Merger to BAC Home Loans Servicing,
L.P. F/K/A Countrywide Home Loans Servicing L.P.
Plaintiff,
VS.
Anthony M. Sciortino
Heather A. Sciortino
Defendants(s)
cdl? APR 18 AN 11: ? r
CUMBERLAND COUNT'I"
PENNSYLVANIA
TO: Office of the Prothonotary
Cumberland County Courthouse,1 Courthouse Square, Carlisle PA 17013
I represent myself. All pleadings, motions, notices, or other papers should be served
on me.
I have been working with Bank of America for the past 12 months on a home
modification loan and have replied to all questions and provided all documentation
that has been asked for. Even though I have been doing my due diligence by
providing everything asked for they have been impossible to work with. They
continue to ask for the same documentation, 8 times now, and refuse to return my
phone calls. I have escalated my concerns to my client reps supervisor and still have
not had any return phone calls. I was under the understanding that since I continue
to work with them that would prevent a filing of foreclosure but obviously they are
not communicating with the persons who have filed the complaint. In addition they
have made the claim I am not living in my house which in turn cancelled my home
owners insurance. I have provided BOA and Travelers copies of my paid Electric bill
showing my usage proving I still reside in my home but as usual I have been
ignored. My dealing with BOA has been dehumanizing and unfair and they clearly do
not want to work with me. This being said after the last go around of them asking
me for the same documentation for a 91h time explained I no longer want to pursue a
loan modification and would like to proceed with a short sale. Although I provided
this in writing to them as asked I still have not been contacted on the next steps. In
addition I am hiring a realtor to put my home up for sale. All I want to do is work
with BOA on a resolution that will work for both of us. The options of a short sale,
regular sale or reinstatement payment will give both of us acceptable results if Bank
of America would actually put some time in to working on this with me.
1 EP. Co-OF 'iCE
PHELAN HALLINAN & SCHMIJ,?G,•WROT OTAR?
3
Joseph Schalk, Esquire
1617 JFK Boulevard, Suite 1400 48
,?? 2? A? ???
i2
One Penn Center Plaza r SERLAND C "Ty
Philadelphia, PA 19103 PEKNSYI.VANiA
215-563-7000
Bank of America, N.A. Successor by
Merger to BAC Home Loans Servicing,
L.P. F/K/A Countrywide Home Loans
Servicing, L.P.
VS.
Anthony M. Sciortino
Heather A. Sciortino
Attorney for Plaintiff
Cumberland County
. Court of Common Pleas
. Civil Division
. No. 11-8218-Civil
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against HEATHER A. SCIORTINO,
Defendant for failure to file an Answer to Plaintiff's Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as
follows:
As set forth in Complaint
TOTAL
$266,598.78
$266,598.78
I hereby certify that (1) the Defendant's last known address is 223 SOUTH ENOLA
DRIVE # A, ENOLA, PA 17025, and (2) that notice has been given in accordance with Rule
Pa.R.C.P 237.1. A 1 _ . J-
Date LI l ?/
J
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: V1 -? I I nn r ? _
PHS # 274682
K, r,squiic
Plai f
PROTHONOTARY
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CeA I o`?StSV
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274682
,AtLP-
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PHELAN HALLINAN & SCHMIEG, LLP
Attorney for Plaintiff
Joseph Schalk, Esquire
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Bank of America, N.A. Successor by
Merger to BAC Home Loans Servicing,
L.P. F/K/A Countrywide Home Loans
Servicing, L.P.
. Cumberland County
. Court of Common Pleas
Civil Division
VS.
Anthony M. Sciortino
Heather A. Sciortino
. No. 11-8218-Civil
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he is the attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge of the
following facts, to wit:
(a) that Plaintiff is without information sufficient to determine whether the
defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise
within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as
amended.
(b) that defendant HEATHER A. SCIORTINO is over 18 years of age and
resides at 223 SOUTH ENOLA DRIVE # A, ENOLA, PA 17025.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date a (??
274682
(Rule of Civil Procedure No. 236) - Revised
Bank of America, N.A. Successor by Cumberland County
Merger to BAC Home Loans Servicing,
L.P. F/K/A Countrywide Home Loans Court of Common Pleas
Servicing, L.P.
Civil Division
VS.
. No 11-8218-Civil
Anthony M. Sciortino
Heather A. Sciortino
Notice is given that a Judgment in the above captioned matter has been entered
against you on p7h"?--
By
If you have any questions concerning this matter please contact:
Phelan Hallinan & Schmieg, LLP
Joseph Schalk, Esquire
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
* * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT
ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. **
274682
i
BANK OF AMERICA, N.A. SUCCESSOR BY
MERGER TO BAC HOME LOANS SERVICING,
L.P. F/K/A COUNTRYWIDE HOME LOANS
SERVICING, L.P.
Plaintiff
V.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Defendant(s)
TO: HEATHER A. SCIORTINO
223 SOUTH ENOLA DRIVE # A
ENOLA, PA 17025
DATE OF NOTICE: -Z'
COURT OF COMMON PLEAS
CIVIL DIVISON
NO. 11-8218-CIVIL
CUMBERLAND COUNTY
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE, CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOT ICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER., THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUI' AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(7i( 7) 249-3166
1-1 By:
Dana OA sky, Esquire
Attorn- V101inan Plaintiff
Phelan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
PHS l# 274682
?746T Z
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff a????tr pf t?nhbr?r
Jody S Smith h¢
?
Chief Deputy tff?
Richard W Stewart .s
Solicitor OFFICE OF THE "RIFF
Bank of America, NA Case Number
S. 2011-8218
Anthony Michael Sciortino (et al.)
SHERIFF'S RETURN OF SERVICE
11/04/2011 07:25 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
November 4, 2011 at 1925 hours, he served a true copy of the within Complaint in Mortgage Foreclosure,
upon the within named defendant, to wit: Heather A. Sciortino, by making known unto herself pesonally, at
223 S. Enola Drive #A, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time
handing to her personally the said true and correct copy of the same.
GERALD WORTHINGTO EPUTY
11/30/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Anthony Michael Sciortino, but was unable to locate hin
in his bailiwick. - He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Anthony Michael Sciortino. Request for service at 485 Halsey Road, Mechanicsburg,
Pennsylvania 17055 the Defendant was not found to be residing at this address. A neighbor advised
Deputies, Anthony Michael Sciortino is only found at the residence for a brief amount of time. To date The
Mechanicsburg Postmaster has been unable to provide a good forwarding address for the Defendant.
11/30/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Heather A. Sciortino, but was unable to locate her in his
bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Heather A. Sciortino. Request for service at 485 Heisey Road, Mechanicsburg, Pennsylvania
17055 the Defendant was not found to be residing at this address.
SHERIFF COST: $89.00 SO ANSWERS,
November 30, 2011 ROW? R ANDERSON, SHERIFF
(c) CrnmtySuUe Sheriff, Teleosofl, Inc.
tit s12 NUS 3:43
uAIY
n141asYLp Ap
PHELAN HALLINAN & SCHMIEG, LLP
BY: JOSEPH P. SCHALK, ESQUIRE
Identification No. 91656
126 Locust Street
Harrisburg, PA 17101
(215)563-7000
BANK OF AMERICA, N.A. SUCCESSOR BY
MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE
HOME LOANS SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
Plaintiff
VS.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Defendants
Attorney for Plaintiff
Court of Common Pleas
Civil Division
Cumberland County
No. 11-8218-CIVIL
MOTION FOR SUMMARY JUDGMENT
Plaintiff respectfully requests that the Court enter an Order granting summary judgment in its
favor in the above-captioned matter and in support thereof avers as follows:
1. There are no material issues of fact in dispute.
2. Plaintiff is seeking only an in rem judgment in this mortgage foreclosure action.
3. Defendant, HEATHER A. SCIORTINO has failed to file an Answer to the Complaint,
and Plaintiff has entered a default judgment against her. A true and correct copy of Plaintiff s
Praecipe for Judgment is attached hereto, incorporated herein by reference, and marked as Exhibit G.
4. Defendant, ANTHONY M. SCIORTINO, has filed an Answer to the Complaint in
which he has effectively admitted all of the allegations of the Complaint, as is further addressed in
Plaintiffs attached Brief.
5. Pennsylvania Rule of Civil Procedure 1029 provides that averments in a pleading to
which a responsive pleading is required are admitted when not denied specifically or by necessary
implication.
6. In his Answer, Defendant failed to deny the default, amounts due, mortgage and
Plaintiff s compliance with Act 6 of 1974 and Act 91 of 1983, therefore he is deemed to have
admitted all allegations of Plaintiff s Complaint. True and correct copies of Plaintiffs Mortgage
Foreclosure Complaint and Defendant's Answer are attached hereto, incorporated herein by
reference, and marked as Exhibits C and D, respectively.
7. Defendants executed the Mortgage promising to repay the loan on a monthly basis. A
copy of the Mortgage, which is recorded in the Office of the Recorder of Cumberland County in
Mortgage Instrument No. 200739018 and has been redacted to remove confidential account
information, is attached hereto, made part hereof, and marked Exhibit A. A copy of the Note, which
has been redacted to remove confidential account information, is also attached hereto, made part
hereof, and marked Exhibit Al .
8. The Mortgage was assigned to Plaintiff. Said transfer was documented by an
Assignment of Mortgage, which is recorded in Assignment of Mortgage Instrument No. 20111455 1.
A copy of the Assignment to Plaintiff, which has been redacted to remove confidential account
information, is attached hereto, incorporated herein by reference, and marked as Exhibit A2.
9. The Mortgage is due for the February 1, 2011 payment, a period in excess of nineteen
(19) months. An Affidavit confirming the default and the amount of the debt is attached hereto,
incorporated herein by reference, and marked as Exhibit B.
10. Defendant's default is also evidenced by Plaintiffs loan history, a copy of which has
been redacted to remove confidential account information, and is attached hereto, made part hereof,
and marked Exhibit F.
11. The last payment applied to the Defendant's mortgage was on or around January 12,
2011. Plaintiff applied this payment to Defendant's account for the January 2011 payment, as is
evidenced by the attached loan. history on Defendant's account (see Exhibit F). The account remains
due and owing for the February 1, 2011 payment. Furthermore, Defendant has not provided proof of
any payments they might have made.
12. The notice provisions of Act 6 of 1974 do not apply to this action because the original
Mortgage amount exceeds the dollar amount provided in the statute, as is further addressed in
Plaintiff s attached Brief. Nevertheless, Plaintiff sent Defendant a letter notifying them of his default
and of Plaintiffs intent to foreclose. A copy of the letter (along with proof of mailing) is attached
hereto, made part hereof, and marked Exhibit E.
13. The Temporary Stay as provided by the Homeowner's Emergency Mortgage
Assistance Program, Act 91 of 1983, has terminated because Defendants have failed to meet with an
authorized credit-counseling agency in accordance with Plaintiffs written notice to Defendants (see
Exhibit E).
14. Plaintiff provided Defendant with the opportunity for review for loan modification
under the federal government program: Home Affordable Modification Program (RAMP). Upon
review, Defendant did not meet the requirements of the HAMP program. Plaintiff is interested in any
reasonable settlement offer; however, Plaintiff is entitled to proceed with its foreclosure until such
settlement is completed. A copy of the HAMP denial letter dated April 23, 2011, is attached hereto,
made part hereof, and marked as Exhibit H.
15. Plaintiff provided Defendant with a reinstatement quotes on April 17, 2012 and May
8, 2012, but Defendant has failed to cure their arrears the loan. A copy of Plaintiffs reinstatement
quotes, which have been redacted to remove confidential account information, are attached hereto,
made part hereof, and marked as Exhibit I.
16. Defendant has failed to sustain their burden of presenting facts which contradict the
averments of Plaintiffs Complaint.
17. Plaintiff submits that its request for attorney's fees is reasonable. Plaintiff will address
this issue further in its attached Brief.
18. Defendant has the right to reinstate or payoff the loan up until one hour before a
scheduled Sheriffs Sale.
WHEREFORE, Plaintiff respectfully requests that an in rem judgment be entered in its favor
for the amount due plus interest and costs as stated in the Affidavit in support of the Motion for
Summary Judgment, for foreclosure and sale of the mortgaged property.
Respectfully submitted,
PHELAN HALLINAN & SCHMIEG, LLP
Date: By:
ose h chalk, Esquire L k?
Atto ev for Plaintiff
Prepared By:
EARRY DAVIS
UNTRYI.CDE HOME LOANS, 1NC.
X25 17INCOI-N DR W, STE 40-0
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After Recprding Return To:
Chicago Title
ServiceLink Division
400 Corporation Dr
Aliquippa, PA 15001
Parcel Number::
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Premises:
485 HE?ISEY RD
I'SECi7ANi CSBJRG
PA ! ;C55-971"73
(Space Above'rhis Line For Recording Dalai
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MORTGAGE
MIN
PENNSYLVANIA-Sing48 Family-Fannie Mae/Freddie Mac UNIFORM iNs-rRUMENT WITH MERS
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1006A-PA (0?;Cmdto Page 1 of 16 Form 3039 1101
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DOC D :
DEFINITIONS
Words used in multiple sections of this document are defined below and other words are defined in Sections 3,
11. 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in
Section 16.
(A) "Security Instrument" means this document, which is dated CC l OBER C1, 201C)7
together with all Riders to this document.
(B) "Borrower" is
ANT ONY M SCIORTINO, AND HEATHER A SC-TORTTdO
Borrower is the mortgagor under this Security Instrument.
(C) "M) RS" is Mortgage Electronic Registration Systems, Inc. MFRS is a separate corporation that is acting
solely as a nominee for Lender and Lender's successors and assigns. MFRS is the mortgagee under this
Security instrument. MFRS is organized and existing under the laws of Delaware, and aas an address and
telephone number of P.O. Box 2026, Flint, Alt 48501-2026, tel. (888) 679-MFRS.
(U) "Letider" is
Countrywide Sank, FSB.
Lender is a
FED SVCS BANK
organized and existing under the laws of THE UNITED STATES
Lender's address is C
1 177 North Fc17_' I':ax Si.. Ste-500
A? exandr-'a, VA 22314
(E) "Note" means the promissory note signed by Borrower and dated OCTOBER 01, 20 )7
The Note skates that Borrower owes Lender
I't^;O A'*UPED SIXTY SIX THOUSAND and 00!10=7
Dollars (U;S. $ 2 6 6, C, 0 0 . 00 ) plus interest Borrower has promised to pay this debt in regular
Periodic Payments and to pay the debt in full not later than NOVEMBER 01, 2037
(F) "Property" means the property that is described below under the heading "Transfer of Rights in (lie
Property."
(G) "Loap" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges due
under the mote, and all sums due under this Security Instrument, plus interest.
(H) "Riders" means all R.lders to this Security Instrument that are executed by Borrower. The following
Riders are to be executed by Borrower [check box as applicable]:
M Mortgage-PA
7006A-PA (06!0 7) rage 2 of 16 Form 3033 1,101
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? Adjustable Rate Rider
? Balloon Rider
? VA Rider
(1) "Alp .rticable Law" means all controlling applicable federal. state and local statutes, regulations, ordinances
and admlthistrative rules and orders (that have the effect of taw) as well as all applicable final, non-appealable
judicial ojinions.
(J) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other
charges that are imposed on Borrower or the Property by a condominium association, homeowners association or
similar or0nization.
(K) "El }ctroaic Funds Transfer" means any transfer of funds, other than a transaction originated by cheek,
draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument,
computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an
account. Such tem7 includes, but is not limited to, point-of-sate transfers, automated teller machine transactions.
transfers initiated by telephone, wire transfers, and automated clearinghouse transfers.
(L) "Esgrow items" means those items that are described in Section 3.
(M) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, cr proceeds paid by
any third (party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage
to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property;
(iii) convgance in lieu of condemnation; or (Iv) misrepresentations of, or omissions as to, the value and/or
condition pf the Property.
(N) ";mortgage Insurance" means insurance protecting Lender against the nonpayment of, nr default on,
the Loan.
(0) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the.
Note, plus(h) any amounts under Section 3 of this Security Instrument,
(P) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its
implementing regulation, Regulation X (24 CT R. Part 3500), as they might be amended rom time to time,
or any additional or successor legislation or regulation that governs the same subject matter. As used in this
Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed in regard to a
"federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under
RESPA.
(Q) "Successor in Interest of Borrower" means any party that has taken title to the Property, whether or not
that party has assumed Borrower's obligations under the Note and/or this Security Instrument.
DOC
? Condominium Rider
? Planned Unit Development Rider
? Biweekly Payment Rider
i C *
? Second Home Ridttr
? 1.4 Family Rider
® Other(s) [specify)
-,EGAL DESCRIPTION
TRANSFE)t OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and
modifications of the Note; and (ii) the performance of Borrower's covenants and agreements under this Security
Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to iMERS (solely
as nominee for Lender and Lenders successors and assigns) and to the successors and assigns of MERS, the
following described property located in the
M N%ngage-HA
1000A-PA (06107)
Page 3 of 16
Form 3039 1101
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DOC ID »`:,
COUNTY of CUMBER'-AND
IType or RecordloR Jurisdictiortl ltiame or Recording Jurisdlctioul
SEE EXH73, ZT "A" ATTACHED HERETO AND MADE A PART HEREOF
which currently has the address of
485 HETSEY RD, MECHANICSBURG
Istrcea'CitL l
Pennsylvat is 17 055-9773 ("Property Address") :
IZrp Q&I
TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements.
appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions sball also be
covered by this Security Instrument. All of the foregoing is referred to in this Security Insnvment as the
"Property." Borrower understands and agrees that MFRS holds only legal title to the Interests granted by
Borrower in this Security Instrument, but, if necessary to comply with law or custom, MFRS (as nominee for
Lender and Lender's successors and assigns) has the right: to exercise any or all of those interests, including, but
not lim red to, the right to foreclose and sell the Property: and to take any action required of Lender including,
but not limited to, releasing and canceling this Security Instrument.
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the
right to niortgage, grant and convey the Property and that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims
and demands, subject to any encumbrances or record.
THIS: SECURITY INSTRUMENT combines uniform covenants for national use and non•uniforrn
covenants with limited variations by jurisdiction to constitute a uniforin security instrument covering real
property.
M k1ortgage-Pik
1006A-PA (00M) Page a of 16 form 3039 1,01
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DOC ID #.
UNf FORM COVENANTS, Borrower and Lender covenant and agree as follows:
1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges.
Borrower shall pay when due the principal of, and interest on. the debt evidenced by the Note and any
prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items
pursuant to Section 3. Payments due under the Note and this Security Instrument shalt be made in U.S. currency.
However,` if any check or other Instrument received by Lender as payment under the Note or this Security
Instrument Is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the
Note and this Security Instrument be made in one or more of the following forms, as selected by Lender:
(a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashiers check, provided any such
check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or
(d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated in the Note or at such
other loca?tion as may be designated by Lentler In accordance with the notice provisions in Section 15.
Lender m4y return any payment or partial payment If the payment or partial payments are insufficient to bring
the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan current,
without w;aver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments In the
future, bui Lender is not obligated to apply such payments at the time such payments are accepted. T each
Periodic Pityment is applied as of its scheduled due date, then Lender need not pay interest cn unapplied funds.
Lender mq hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower
does not do so within a reasonable period of time. Lender shall either apply such funds or return them to
Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note
immediately prior to foreclosure, No offset or claim which Borrower might have now or in the future against
Lender sh4li relieve Borrower from making payments due under the Note and this Security Instrument or
performing the covenants and agreements secured by this Security Instrument.
2. Application of Payments or Proceeds. Except as otherwise described in this Section Z, all payments
accepted ajid applied by Lender shall be applied in the following order of priority: (a) interest due under the
Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each
Periodic P$yment in the order in which It became due. Any remaining amounts shall be applied first to late
charges, so#cond to any other amounts due under this Security Instrument, and then to reduce the principal
balance of the Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient
amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge.
If more than one Periodic Payment Is outstanding, Lender may apply any payment received from Borrower to
the repayment of the Periodic Payments if, and to the extent that, each payment can be paid in i'ull. To the extent
that any ei(cess exists after the payment is applied to the full payment of one or more Periodic Payments,
such excess may be applied to any late charges due. Voluntary prepayrnenis shall be applied first to any
prepayment charges and then as described in the Note.
Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the
Note shall riot extend or postpone the due date, or change the amount, of the Periodic Payments.
3. }funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under
the Note, until the Note Is paid in full, a sum (the "Funds") to provide for payment of amounts due for. (a) taxes
and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance
on the Proorty; (b) leasehold payments or ground rents on the Property, if any: (c) premiums for any and all
insurance rlquired by Lender under Section 5; and (d) Mortgage Insurance premiums. if any, or any suns
payable by Borrower to Lender In lieu of the payrnent of Mortgage Insurance premiums in accordance wish the
M Mortgage-PA
1006A-PA (Of/07) Page 5 of 16 Form 3038 1101
1, ,..-11 n n- -n. -_ ,.,,t 04 ',AA710A1 R .. P- ? -f 10
DOC =D #:
provisions of Section 10. These items are called "Escrow Items." At origination or at any time during the term
of the Lopn, Lender may require that Community Association Dues, Fees, and Assessments, if any, be escrowed
by Borrower, and such dues, fees and assessments shall be an Escrow item. Borrower shall promptly furnish to
Lender aW notices of amounts to he paid under this Section. Borrower shall pay Lender the Funds for Escrow
Items uniess Lender waives Borrower's obligation to pay the Funds for any or all Escrow (tents. Lender may
waive Borrower's obligation to pay to Lender Funds for any or all Escrow !terns at any ilme. Any such waiver
may only'), be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable,
the amounts due for any Escrow Items for which payment of Funds has been waived by Lender and, if Lender
requires, 'shall furnish to Lender receipts evidencing such payment within such time period as Lender may
require. 1 orrower's obligation to make such payments and to provide receipts shall for all purposes be deemed
to be a coNenani and agreement contained In this Security Instrument, as the phrase "covenant and agreement" is
used in Spctioat 9, If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower
fails to pqy the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such
amount a4d Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may
revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section 15 and,
upon suctt revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required under
this Secd 'n 3.
Len er may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the
Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under
RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of
expenditules of future Escrow Items or othetwistr in accordance with Applicable Law.
The funds shall be held in an Institution whose deposits are insured by a federal agency, instrumentality, or
entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan
Bank. Leader shalt apply the Funds to pay the Escrow items no later than the time specified under RESPA.
Lender shill not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or
verifying 'the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits
Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to he
paid on the Funds, Lender shall not be required to pay Borrower any interest or earnings on d ? Funds. Borrower
and Lender can agree in writing, however, that Interest shall be paid on the Funds. Lender shall give to
Burrower,. without charge, an annual accounting of die Funds as required by RESPA.
If Chore is a surplus of Funds held in escrow. as defined under RESPA. Lender shall account to Borrower
for the excess funds In accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under
RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount
necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments.
If there is a deficiency of Funds held In escrow, as defined under RESPA, Lender shall notify Borrower as
required b)r RESPA, and Borrower shall pay to Lender the amount necessary to inake up the deficiency in
accordance with RESPA, but in no more than 12 monthly payments.
Upon- payment in fu11 of all sums secured by this Security Instrument. Lender shall promptly refund to
Borrower 4ny Funds held by Lender.
4, Charges: Liens. Borrower shall pay all taxes, assessments, charges, fines, and impositions
attributable( to the Property which can attain priority over this Security Instrument, leasehold payments or Ipound
rents on the' Property, If any, and Community Association Dues, Fees, and Assessments, if any. To the extent
that these items are Escrow Items, Borrower shall pay them in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to
M. Mongaga-t A
1006A-PA (0$/07} Page 6 of 16 Form 3039 1101
?Q >`
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DOC _D #:
Lender, but only so long as Borrower is performing such agreement: (b) contests the lien in good faith
defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the
enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded: or
(c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security
Instrument. If Lender determines that any part of the Property Is subject to alien which can attain priority over
this Security Instrument. Lender may give Borrower a notice identifying the lien. Within 10 days of the date on
which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in
this Section 4.
Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting
service used by Lender in connection with this Loan.
5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the
Property insured against loss by fire, hazards Included within the term "extended coverage," and any other
hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance.
This insurance shall be maintained in the amounts (including deductible levels) and for the periods that Lender
requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan.
The insurance carrier providing the insurance shall be chosen by Borrower subject to Lenders right to
disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to
pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification and
tracking services: or (b) a one-time charge for flood zone determination and certification services and subsequent
charges each time remappings or similar changes occur which reasonably might affect such determination or
certification. Borrower shall also be responsible for the payment of any fees imposed by the l:edenal Emergency
Management Agency in connection with the review of any flood zone determination resulting from an objection
by Borrower.
If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage.
at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or
amount of coverage. Therefore, such coverage shall cover Lender, but might or might not protect Borrower,
Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and might
provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cast of the
insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have
obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower
secured by this Security Instrument. These amounts shall bear interest at the Note rate front the date of
disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment.
All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to
disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or
as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender
requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower
obtains any form of insurance coverage, not otherwise required by lender, for damage to, or destruction of, the
Property, such policy shall include a standard mortgage clause and shall name Lender as mortgagee andlor as an
additional loss payee.
In the event of loss. Borrower shall give prompt notice to the insurance carrier and Lender. Lender may
make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing,
any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to
restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is
not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance
proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to
M Mortgage-PA
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Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds
for the repairs and restoration in a single payment or in a series of progress payments as the work is completed.
Unless an agreement Is made in writing or Applicable Law requires interest to be paid on such insurance
proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees for
public adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance proceeds and
shall be the sole obligation of Borrower. If the restoration or repair is not economically feasib9e or Lender's
security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security
Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds shall be
applied in the order provided for In Section Z.
If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and
related matters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier
has offered to settle a ciaim, then Lender may negotiate and settle the claim. The 30-clay period will begin when
the notice is given. In either event. or If Lender acquires the Property under Section 22 or otherwise. Borrower
hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts
unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to
any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar
as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to
repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument, whether or
not then due.
6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence
within 60 days after the execution of thls Security Instrument and shall continue to occupy the Property as
Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees
in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which
are beyond Borrower's control.
7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not
destroy, damage or Impair the Property, allow the Property to deteriorate or commit waste on the Property.
Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the
Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to
Section 5 that repair or restoration Is not economically feasible, Borrower shall promptly repair the Property If
damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in connection
with damage to. or the taking of, the Property, Borrower shall he responsible for repairing or restoring the
Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs
and restoration In a single payment or in a series of progress payments as the work Is completed. If the insurance
or condemnation proceeds are not sufficient to repair or restore the Property. Borrower is not relieved of
Borrowers obligation for the completion of such repair or restoration.
Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable
cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice
at the time of or prior to such an interior Inspection specifying such reasonable cause.
8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process.
Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent
gave materially false, misleading, or inaccurate information or statements to Lender (or failed to provide Lender
with material Information) in connection with the Loan. Material representations include. but are not limited to,
representations concerning Borrower's occupancy of the Property as Borrower's principal residence.
9. Protection of Lender's Interest in the Property and frights tinder this Security Instrument.
If (a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a
M Mortgage-PA
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11 1eenr?i n LIM rnl ro11Mi Inert H nnI171CMR . Amino R nr 1Q
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legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this Security
Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a
lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower
has abandoned the Property, then Lender may do and pay for whatever is reasonable or appropriate to protect
Lender's interest in the Property and rights under this Security Instrument, including protecting and/or assessing
the value of the Property, and securing and/or repairing the Property. Lender's actions can include, but are not
Ihnited to: (a) paying any sutras secured by a lien which has priority over this Security Instrument; (b) appearing
in court: and (c) paying reasonable attorneys' fees to protect its Interest in the Property and/or rights under this
Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property Includes.
but is not limited to, entering the Property to make repairs, change locks, replace or board -up doors and
windows, drain water from pipes, eliminate buflding or other code violations or dangerous condillons, and have
utilities turned on or off. Although Lender may take action under this Section 9, Lender does not.have to do so
and is not under any duty or obligation to do so. it is agreed that Lender incurs no liability for not taking any or
all actions authorized under this Section 9,
Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured
by this Security Instrument. These amounts shall bear Interest at the Note rate from the date of disbursement and
shall be payable, with such interest, upon notice from Lender to Borrower requesting payment.
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease.
if Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees
to the merger in writing.
10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan,
Borrower shall pay the premiums required to maintain the Mortgage Insurance hi effect. If, for any reason, the
Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that
previously provided such insurance and Borrower was required to make separately designated payments toward
the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obCain coverage
substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the
cost to Borrower of the Mortgage Insurance previously in effect. from an alternate mortgage Insurer selected by
Lender. If substantially equivalent Mortgage Insurance coverage is not available, :Borrower shall continue to pay
to Lender the amount of the separately designated payments that were due when the insurance coverage ceased
to be in effect. Lender will accept, use and retain these payments as a non-refundable loss reserve in lieu of
Mortgage Insurance. Such foss reserve shall be non-refundable, notwithstanding the fact that the Loan is
ultimately paid In full, and :Lender shall not be required to pay Borrower any interest or earningq on such loss
reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in thle amount and
for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is
obtained, and Lender requires separately designated payments toward the premiums for Mortgage Insurance.
If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was reggIred to make
separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums
required to maintain Mortgage Insurance in effect, or to provide a non-refundable lass reserve, until Lender's
requirement for Mortgage Insurance ends in accordance with any written agreement between Oorrower and
Lender providing for such termination or until termination is required by Applicable Law. Nothing in this
Section 10 affects Borrowers obligation to pay interest at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may
incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter
Into agreements with other parties that share or modify their risk, or reduce losses. These agreements are on
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terms and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these
agreements, These agreements may require the mortgage insurer to make payments using any source of funds
that the mortgage insurer may have available (which may include funds obtained from Mortgage Insurance
premiums),
As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsurer, any other
entity, or any affiliate of any of the foregoing, may receive (directly or indirectly) amounts that derive from (or
might be characterized as) a portion of Borrowers payments for Mortgage Insurance, in exchange for sharing or
modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender
takes a share of the insurer's risk in exchange for a share of the premiums paid to the insurer, the arrangement is
often termed "captive reinsurance." Further:
(a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage
Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will
owe for Mortgage Insurance, and they will not entitle Borrower to any refund.
(b) Any such agreements will not affect the rights Borrower has - if any - with respect to the
Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may
include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage
Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any
Mortgage Insurance premiums that were unearned at the time of such cancellation or termination.
11. Assignment of Miscellaneous Proceeds, Forfeiture. All Miscellaneous Proceeds are hereby
assigned to and shall be paid to Lender.
If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the
Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such
repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has
had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction,
provided that such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a
single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made
in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be
required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is
not economically feasible or Lenders security would be lessened, the Miscellaneous Proceeds shall be applied to
the sums secured by this Security Instrument, whether or not then due, with the excess, if any. paid to Borrower.
Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2.
In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall
be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid
to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of
the Property immediately before the partial taking, destruction, or loss in value is equal to or greater than the
amount of the sums secured by this Security Instrument immediately before the partial taking, destruction, or
loss in value, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security
instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by the following fraction:
(a) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value
divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in
value. Any balance shall be paid to Borrower.
In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of
the Property immediately before the partial taking. destruction, or loss in value is less than the amount of the
sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender
M Mortgage-PA
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otherwise agree in writing„ the Miscellaneous Proceeds shalt be applied to the sums secured by this Security
Instrument whether or not the sums are then due.
If the Property Is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party
(as defined in the next sentence) offers to make an award to settle a claim for damages. Borrower fails to respond
to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the
V]iscellaneous Proceeds either to restoration or repair of the Property or to the stuns secured by this Security
Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower Miscellaneous
Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous Proceeds.
Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's
judgment, could result in forfeiture of the Property or other material impairment of Lenders Interest in the
Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration has
occurred, reinstate as provided in Section 19. by causing the action or proceeding to be dismissed with a ruling
that, in Lenders judgment, precludes forfeiture of the Property or other material impairment of Lenders interest
in the Property or rights under this Security Instrument. The proceeds of any award or claim for damages that
are attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to
Lender.
All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in
the order provided for in Section Z.
12, Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for
payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to
Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any
Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any
Successor in Interest of Borrower or to refuse to extend dine for payment or otherwise modify amortization of
the sums secured by this Security Instrument by reason of any demand made by the original Borrower or any
Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy including,
without limitation, Lender's acceptance of payments from third persons, entities or Successors In Interest of
Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the exercise of any
right or remedy.
13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants and
agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs
this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this Security Instrument
only to mortgage, grant and convey the co-signer's interest in the Property under the terms of this Security
Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees
that Lender and any other Borrower can agree to extend, modify, forbear or make any accommodations with
regard to the terms of this Security Instrument or the Note without the co-signer's consent.
Subject to the provisions of Section 18, any Successor in interest of Borrower who assumes Borrower's
obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's
rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations
and liability under this Security Instrument unless Lender agrees to such release in writing. The covenants and
agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors
and assigns of Lender.
14. Loan Charges. Lender may charge Borrower fees for services performed in connection with
Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security
Instrument, Including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any
other fees, the absence of express authority in this Security Instrument to charge a specific fee to Borrower shall
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not be construed as a prohibition on the charging of such fee. Lender may not charge fees that are expressly
prohibited by this Security Instrument or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that
the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted
limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the
permitted limit: and (b) any sums already collected from Borrower which exceeded permitted limits will be
refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or
by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial
prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the
Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver
of any right of action Borrower might have arising out of such overcharge.
15, Notices. All notices given by Borrower or Lender in connection with this Security instrument must
be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to have been
given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent
by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law
expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated a
substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of
address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only
report a change of address through that specified procedure. There may be only one designated notice address
under this Security Instrument at any one time. Any notice to Lender shall be given by delivering it or by
mailing it by first class mall to Lenders address stated herein unless Lender has designated another address by
notice to Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been
given to Lender until actually received by Lender. If any notice required by this Security Instrument is also
required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement
under this Security Instrument.
15. Governing Law; Severability; Rules of Construction. This Security Instrument shall be governed
by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations
contained in this Security lushltment are subject to any requirements and limitations of Applicable Law.
Applicable Law might explicitly or implicitly allow the parties to agree by contract or it might be silent, but such
silence shall not be construed as a prohibition against agreement by contract. In the event that any provision or
clause of this Security Instrument or the Note conflicts with Applicable Law, such conflict shall not affect other
provisions of this Security instrument or the Note which can be given effect without the conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and include
corresponding neuter words or words of the feminine gender: (b) words in the singular shall mean and include
the plural and vice versa: and (c) the word "tray" gives sole discretion without any obligation to tame any action.
V. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18,
"Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to.
those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow
agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser.
If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a
natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior woluen consent,
Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this
option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
M Mougage•PA
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If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide
a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which
Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the
expiration of this period. Lender may invoke any remedies permitted by this Security Instrument without further
notice or demand on Borrower.
19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower
shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest
of. (a) five days before sale of the Property pursuant to any power of sale contained in this Security Instrument;
(b) such other period as Applicable Law might specify for the termination of Borrowers right to reinstate; or
(c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender
all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred;
(b) cures any default of any other covenants or agreements; (c) pays all expenses incurred in enforcing this
Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection. and valuation
fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this
Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest
in the property and rights under this Security Instrument, and Borrower's obligation to pay the suns secured by
this Security Instrument, shall continue unchanged. Lender may require that Borrower pay such reinstatement
sums and expenses in one or more of the following fors, as selected by Lender: (a) cash; (b) money order;
(c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an
institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds
Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain
fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of
acceleration under Section 18.
20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The :Vote or a partial interest in the
Note (together with this Security Instrument) can be sold one or more times without prior notice to Borrower.
A sale might result in a change In the entity (known as the "Loan Servicer") that collects Periodic payments due
under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the
Note, this Security Instrument, and Applicable Law. There also might be one or more changes of the Loan
Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written
notice of the change which will state the name and address of the new Loan Servicer, the address to which
payments should be made and any other information RESPA requires in connection with a notice of transfer of
servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of
the Mote, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be
transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided
by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an
individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security
Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of,
this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given In
compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a
reasonable period after the giving of such notice to take corrective action, If Applicable Law provides a time
period which must elapse before certain action can be taken, that thne period will be deemed to be reasonable for
purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to
Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to satisfy the
notice and opportunity to take corrective action provisions of this Section 20.
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21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances
defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following
substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides,
volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials: (b) 'Environmental
Law" means federal laws and laws of the jurisdiction where the Property Is located that relate to heahh, safety or
environmental protection: (c) "Environmental Cleanup" includes any response action, remedial action, or
removal action, as defined In Environmental Law: and (d) an "Environmental Condition" means a condition that
can cause, contribute to, or otherwise trigger an Environmental Cleanup.
Borrower shall not cause or permit the presence. use, disposal, storage, or release of any Hazardous
Substances, or threaten to release any Hazardous Substances, on or In the Property. Borrower shall not do, nor
allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law,
(b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous
Substance, creates a condition that adversely affects the value of the Property. The preceding itwo sentences
shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that
are generally recognized to be appropriate to normal residential uses and to maintenance of the Property
(including, but not limited to, hazardous substances in consumer products).
Borrower shall promptly give Lender written notice of (a) any investigation, claim, demand, lawsuit or
other action by any governmental or regulatory agency or private party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any Environmental
Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any
Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance
which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or
regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance
affecting the Property is necessary. Borrower shall promptly take all necessary remedial actions In accordance
with Environmental Law. Nothing herein shall create any obligation an Lender for an Enviromnental Cleanup.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
22, Acceleration; Remedies. Under shall give notice to Borrower prior to acceleration following
Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration
under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among
other things: (a) the default; (b) the action required to cure the default; (c) when the default must be
cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured
by this Security instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall
further inform Borrower of the right to reinstate after acceleration and the right to assert in the
foreclosure proceeding the non-existence of it default or any other defense of Borrower to acceleration and
foreclosure. If the default is not cured as specified, Lender at its option may require immediate payment
in full of all sums secured by this Security Instrument without further demand and may foreclose this
Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in
pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs
of title evidence to the extent permitted by Applicable Law.
23. Release. Upon payment of all sums secured by this Securit) Instrument, this Security Instrument and
the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy
this Security Instrument. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for
releasing this Security instrument, but only if the fee is paid to a third party for services rendered and the
charging of the fee is permitted under Applicable Law.
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24. Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or
defects in proceedings to enforce this Security instrument, and hereby waives the benefit of any present or future
laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and
homestead exemption.
25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour
prior to the con ntencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
26, Purchase Money Mortgage. If any of the debt secured by this Security Instrument is tent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
27. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to fiine under the
Note.
BY SIGNING BELOW, Borrower accepts and agrees to the temis and covenants contained in this Security
Instrument and in any Rider executed by Borrower and recorded with if.
_ (Seal)
ANTHONY N'. SCICRT -Borrower
HEATHER A. SCIORTINO
-. (Seal)
Borrower
_. (Seal)
Borrower
(Seal)
Borrower
tit Mortgage-PA
1006A-PA (06!07) Page 15 of 15 Form 3039 1101
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COMMONWEALTH OF PENNSYLVANIA, County ss:
On this, the _. day of be re rne, the
uad rsip2aed officer, personally appeared
known to me (or satisfactorily proven) to be the
person(s) whose name(s)..isfare subscribed to the within instrument and acknowledged that #e/Vvethey executed
the same for the purposes herein contained.
IN WITNESS WHEREOF. I hereunto set my hand and official seat.
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
Notarial Seat
Dennis L. Wise. Notary Pubic
ttampdsn Two., Cumbertand County
My Cornm'tssion Expires Sept. 20.2010
Member, Pennsvwvania Associatiwi of Notaries
Certificate of R ace
the correct address of the wit
Witness my hand this
M Mortgage-PA
1006A•PA (06107)
1
Title of Officer
I , do hereby certify (hat
is P.O. Box 2026, Flint. Ml 48501-2026.
day of-0 a jj& I ---_--
Agent of Mortgagee
Page 16 of 16
Form 3039 1101
ncj4 cj?1nA 1 0.40-CO AAA r`1 IAA0001 A AIM t'^1 WTV I..,t -x.,>nn7von+u . Pte- 'F; of 1 q
Exhibit "A"
Legal Description
All that certain parcel of land situate in the East side ol'Heisey Road, in the Township of
Monroe. County of Cumberland and Commonwealth of Pennsylvania, being known and
designated as follows:
Parcel l:
BEGINNING at a concrete monument on the eastern dedicated right-of-way line of Heisey
Road, T-560, at line of'Lot No. 22 on the hereinafter mentioned Plan of lots; thence along the
Eastern dedicated right-of-way line of Heisey Road, T-560, North 00 degrees 27 minutes 40
seconds West, a distance of 100.47 feet to a point; thence along Lot No. 20 on the hereinafter
mentioned Plan of Lot`, north 89 degrees 36 minutes 55 seconds East, a distance of 199,13
feet to a point; thence along other lands now or formerly of Donald E. Deckman and Marian
R. Deckman, husband and wife, South 00 degrees 23 minutes 00 seconds East, a distance of
100.47 feet to a point; thence along line of Lot No. 22 on the hereinafter mentioned Plan of
Lots. North 89 degrees 36 minutes 55 seconds West, a distance of 198.99 feet to a concrete
monument, the place of BEGINNING.
Bein- Lot No. 21 on a Final Plan of Major Subdivision for Donald E. Deckman, prepared by
Rodney Lee Decker and Associates, dated October 21, 1986 and recorded in Subdivision Plan
Book 51, Page 140.
Parcel 2:
BEGINNING at a concrete monument set on the Easternmost dedicated right-of-way line of
Heisey Road (T-560), at the common point of adjoiner of Lots No. 20-A and No. 20-B on the
hereinafter mentioned plan; thence departing from said right-of=way and extending along Lot
No. 20-A, North eighty-nine (89) degrees thirty-six (36) minutes fifty-five (55) seconds East,
for a distance of one hundred ninety-nine and nineteen hundredths (199,19) feet to a steel pin
at other lands now or formerly of Donald E. Deckman and Marian R. Deckman, husband and
wife; thence extending along said land, South zero (00) degrees twenty-three (23) minutes
five (05) seconds East for a distance of fifty and twenty hundredths (50.20) feet to a steel pin
at Lot No. 21; thence extending along Lot No. 21, South eighty-nine (891 degrees thirty-six
(36) minutes fifty-five (55) seconds 'Vest.. for a distance of one hundred nineteen and thirteen
hundredths (119.13) feet to a steel pin set on the Easternmost dedicated right-of-way line of
Heisey Road: thence extending in and along said right-of-way line. North zero (00) degrees
twenty-seven (27) minutes forty (40) second West, for a distance of fifty and twenty
hundredths (50.20) feet to a concrete monument at Lot No 20-A, said monument marking the
place of BEGINNING.
BEING designated as Lot No. 20-3 on an Amendment of a final plan of major subdivision
prepared for Donaid E. Deckman by Rodney Lee Decker and Associates, which Amendment
is dated JanuarY 14, 2004, and recorded in the Office of the Recorder of Deeds in and for
Cumberland County. Pennsylvania in Plan Book 89, Page 22.
d.4 is in
i.,,-r $ onmvnn,H . P- 17 If 1q
Exhibit "A"
Legal Description
TOGETHER with all and singular the buildings, improvements. ways, streets, alleys.
driveways, passages, waters, watercourses. rights, liberties. privileges, hereditaments and
appurtenances, whatsoever unto the hereby granted premises belonging, or in any wise
appertaining, and the reversions and remainders, rents. issues, and profits thereof- and all the
estate, right, title, interest, property, claim and demand whatsoever of Grantor(s), as well at
law as in equity, of, in, and to the same.
Taxi Parcel M: 22-11-0290-095
143141!
/`I Ik A17rM AMn rni IKMV I-f ff 9M7QQMR - Pana 1R of 1G
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number- 200739018
Recorded On 10110/2007 At 12:42:28 PM * Total Pages -- 19
* Instrument Type - MORTGAGE
Invoice Number - 6411 user ID - RAK
* Mortgagor - SCIORTINO, ANTHONY M
* Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.
*Customer- SERVICE LINK
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JUSTICE
RECORDING FEES - $39.50
RECORDER OF DEEDS
AF'F'ORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
mnmar_ nnrn 866 _ 50
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
Y Certify this to be recorded
in Cumberland County PA
RECORDER O D EDS
rao
" - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
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Prepared by_ HARRY DAVIS
NOTE
OCTOBER 01, 2007
(Date) -
MECHANICSBURG
lcityl
485 HEISEY RD, MECHANICSBURG, PA 17055-9773
!Property Address)
PENNSYLVANIA
(State)
1. BORROWER'S PROMISE TO PAY
In return for a loan that I have received, I promise to pay U.S. $ 266, 000.00 (this amount is called
"Principal'), plus interest, to the order of the Lender. The Lender is
Countrywide Bank, FSB.
I will make all payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly
rate of 6.375 %.
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B)
of this Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by making a payment every month.
I will make my monthly payment on the FIRST day ofeach month beginning on
DECEMBER 01, 2007 . I will make these payments every month until I have paid all of the principal and interest and any
other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due
date and will be applied to interest before Principal. If, on NOVEMBER 01, 2037 , I still owe amounts under this Note, I
will pay those amounts in full on that date, which is called the "Maturity Date."
I will make my monthly payments at
P.O. Box 660694, Dallas, TX 75266-0694
or at a different place if required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount ofU.S. $ 1, 659. 49
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a
"Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a
payment as a Prepayment if I have not made all the monthly payments due under the Note.
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my
Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment
to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of
the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment
unless the Note Holder agrees in writing to those changes.
S. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other
loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from
me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the
Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated
as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of FIFTEEN calendar
days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.000 % of my
overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B) Default
If l do not pay the full amount of each monthly payment on the date it is due, I will be in default.
MULTISTATE FIXED RATE NOTE-Single Family-Fannle Mae/Freddie Mae UNIFORM INSTRUMENT Initials:
Page 9 of 2
1-5N (0207).09 CHL (010104)(d) VMP Mortgage Solutlons, Inc. (800)527-7291 Form 3200 1101
a,
111111111
* 2 3 9 9 1
46
LOAN #:?
()GiNAL
LOAN
(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all
the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or
delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above,
the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be
paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys' fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first
class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that
different address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety
or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights
under this Note against each person individually or against all of us together. This means that any one of us may be required to
pay all of the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
10. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as
this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this
Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full
of all amounts I owe under this Note. Some of those conditions are described as follows:
If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not
a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written
consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide
a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which
Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the
expiration of this period, Lender may invoke any remedies permitted by this Security instrument without further
notice or demand on Borrower.
PAY707HE OtmER OF PAY 701M ORDER OF
exr r rrRYYNDE (1gN1ts LOANS. INC
?- YrfP OA PIL-'OOURSE --r WnHOur RECOURSE
COUNTfryym trVK W 001.94n M M HOME LOANS, NO
.ttcEtl 7 DY fytA,thr (>Z ?ja lar,?,?
t/u1R1Evemn KOMESJOtANDER
r $ZZOmw ePRES(DE a Ei cunvE vicE PRmG DEN('
WI HE HA (S) -3EAQ9)_0F THE UNDERSIGNED.
(Seal)
ANTHONY M. CIORTINO -Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
_ (Seal)
-Borrower
[Sign Original Onlyl
4W -SN (0207).01 CHL (10104) Page 2 of 2 Form 3200 1101
lq,5-yle
Recording Requested By: 1J13111111
Bank of America 1
Prepared By: OOOLNY
Diana DeAvila
888-603-9011
450 E. Boundary St
Chapin, SC 29036
When recorded trail to:
CoreLogic
450 E. Boundary St.
Attn: Release Dept.
Chapin, SC 29036
DocID# 14617942282710075
Tax ID: 22-11-0280-095
Property Address:
485 Heisey Rd
Mechanicsburg, PA 17055-9773
Property Location:
Township of MONROE
rA00.AM 13989477 3113/20ri This spice forXmrdeYs use
Mlle #: MFRS Phone #: -
ASSIGNMENT OF MORTGAGE
For Value Received, the undersigned holder of a Mortgage (herein "Assignor") whose address is 3300 S.W. 34TH
AVENUE, SUITE 101 OCALA, FL 34474 does hereby grant, sell, assign, transfer and convey unto BAC HOME
LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP whose address is 8609
WESTWOOD CENTER, VIENNA, VA 22183 all beneficial interest under that certain Mortgage described below
together with the note(s) and obligations therein described and the money due and to become due thereon with
interest and all rights accrued or to accrue wider said Mortgage.
Original Lender: COUNTRYWIDE BANK, FSB
Mortgagor(s): ANTHONY M SCIORTINO, AND HEATHER A SCIORTINO
Date of Mortgage: 10/1/200", Original Loan Amount: $266,000.00
Recorded in Cumberland County, PA on: 10/1012007, book N/A, page N/A and instrument number 200739018
This Mortgage has not been assigned unless otherwise stated below:
I?d
MS//WHEREOF, the undersigned has caused this Assignment of Mortgage to be executed on
r?
-
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,
INC.
fJ J
BY '=fl-7E?JU
Bud Kamyabi, Assistant Secretary
r1 MADC01 A Ain r-nF 1POTv inct # ?M 114551 - Pane 1 of 3
..?
`?
State of California
County of Ventura
On f? before me, Irma Diaz, Notary Public, personally appeared Bud Kamyabi, who proved to
me on t fie basis of satisfactory evidence to be the persons whose namefd) is/ardsubscribed to the within instrument
and acknowledged to me that heAhe 4wy executed the same in hisAerf wirauthorized capacity(icS), and that by
his4mq# * signature(4 on the instrument the persono, or the entity upon behalf of which the personA acted,
executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing
paragraph is true and correct.
WITNESS my hand and official sea]. IRMA 01AZ
Commission 1903988
JYLI z @My Notary Public - CaliforniVentura County
Notatf Public: Irma Diaz (Seal) Comm. Expires Sep 13,204
My Commission Expires: 4/13/2014
I hereby certify that the address of the within named assignee is:
8609 WESTWOOD CENTER, VIENNA, VA 22183
ba Signature
nc r?r. rnm- n.cn-nn5 ri M AOr.rn ANIM rnii.mi i-t 119(1417 A SG1-P-9of4
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-5370
Instrument Number - 201114551
Recorded On 5/20/2011 At 12:00:43 PM * Total Pages - 3
* .fastrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number - 87208 User ID - JM
* Mortgagor - SCIORTINO, ANTHONY M
* Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC
* Customer - CORELOGIC
FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $23.50
JUSTICE
RECORDING FEES - $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
Certification Page
DO NOT DETACH
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of this legal document.
TOTAL PAID $50.50
I Certify this to be recorded
in Cumberland County PA
. ,o
RECORDER O D EDS
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
Wiuuiuii
,)QNC:»n1I O-Fn-An ANA f 1INACCD1 AMr) (`r)l WTV Inod $ OfNI IASFI - Pane 4 of 4
BANK OF AMERICA, N.A.
SUCCESSOR BY MERGER TO BAC
HOME LOANS SERVICING, L.P.
F/K/A COUNTRYWIDE HOME
LOANS SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
PLAINTIFF
V.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
DEFENDANTS
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 11-8218-CIVIL
PLAINTIFF S AFFIDAVIT IN SUPPORT OF ITS
MOTION FOR SUMMARY JUDGMENT
STATE OFD Y.' i 11:.1 y} )
ss.
COUNTY OF
being duly sworn according to law, deposes and says:
1. I am employed in the capacity of A;,k A V;,,. at Bank of America,
N.A., as an officer of Bank of America, N.A. Plaintiff in the within matter.
2. In said capacity, I am familiar with the account that forms the basis of the instant
foreclosure action and am authorized to give this Affidavit.
3. The information in this affidavit is taken from Bank of America, N.A.'s business
records. I have personal knowledge of Bank of America, N.A.'s procedures for creating these
records. They are: (a) made at or near the time of the occurrence of the matters recorded by persons
with personal knowledge of the information in the business record, or from information transmitted
by persons with personal knowledge; (b) kept in the course of Bank of America, N.A.'s regularly
conducted business activities:; and (c) it is the regular practice of Bank of America, N.A. to make
such records.
4. The Defendants, Anthony M. Sciortino and Heather A. Sciortino, made executed
and delivered a Mortgage upon the premises, 485 Heisey Road, Mechanicsburg, PA 17055-9773,
on October 1, 2007, to Mortgage Electronic Registration Systems, Incorporated as a Nominee for
Countrywide Bank, FSB.
5. Plaintiff is the last assignee of the Mortgage by virtue of an Assignment of Mortgage
dated May 13, 2011 and recorded on May 20, 2011 at Assignment of Mortgage Instrument No.
201114551.
6. Defendants' mortgage payments due February 1, 2011 and each month thereafter are
due and unpaid.
7. The amounts due on the mortgage are as follows:
Principal Balance $255,563.72
Interest $23,058.31
01/01/2011 through 05/31/2012 @ 6.375
Attorney s Fees $3,508.75
Property Inspections/BPO $115.00
Cumulative Late Charges $248.91
Escrow Deficit $5,885.90
TOTAL $288,380.59
Defendants have failed to reinstate the account.
Plaintiff provided Defendants with a Notice of Intention to Foreclose Mortgage.
10. Plaintiff continues to suffer unjust financial losses as it pays the taxes and insurance
on the property as they become due to avoid a tax upset sale and/or loss to its collateral, all of
which accrues to the benefit of Defendants and to the severe detriment of Plaintiff.
11. Plaintiff properly accelerated its mortgage to protect its interests.
4- Aza?? 7r,r,L
Name:Mvk; %a CO. 4ea&A,
Title: R3bis?w? V t.. %LS"A"?-
Bank of America, N.A.
On this day of 20g, before me a notary public, the
undersigned officer, personally appeared the above named person, known to me (or satisfactory
proven) to be the person whose name is subscribed to the within instrument, and acknowledged that
shq! executed the same for the purposes therein contained.
In witness hereof, I hereunto set my hand and official seal.
C MIWIONW TH OF PENNSYLVANIA
Stamp/Seal: NOTARIAL SEAL Notary Public
Dana M. Maguire, Notary Public
North Beaver Township, Lawrence Cowtty
M commission expires April 16 2013
Sciortino, PHS# 274682
Court tf Comm Pleas
Civil Cover Sheet
CUMBERLAND County
S
E
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N
A
For Prothonotary Use Only:
Docket No:
The information collected on this-form is used solely for court aGlminis1ration purposes. This fol-111 Cloys not
elrrlnle lll('111 1)r lho f lill4 (711!1 CPrvirr, of nlonlhnav rw nlhov nlmo- r rn,l A- I-- , ,/ o I
Commencement of Action:
0 Complaint ? Writ of Summons ? Petition
? Transfer from Another Jurisdiction ? Declaration of Taking
Lead Plaintiff's Name: BANK OF AMERICA, N.A. Lead Defendant's Name: ANTHONY M. SCIORTINO
SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, L_P. F/K/A COUNTRYWIDE HOME
LOANS SERVICING, L.P.
Are money damages requested. ? Yes ? No Dollar Amount Requested: El within arbitration limits
(Check one) ?x outside arbitration limits
Is this a Class Action Suit? ? Yes ?x No 7 Is this an MDJ Appeal? ? Yes ?x No
Name of Plaintiff/Appellant's Attorney: Phelan Hallinan & Schmieg, LLP
? Check here if you have no attorney are a Self-Represented Pro Sel Litigant)
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
? Intentional ? Buyer Plaintiff Administrative Agencies
? Malicious Prosecution ? Debt Collection: Credit Card ? Board of Assessment
? Motor Vehicle ? Debt Collection: Other ? Board of Elections
? Nuisance ? Dept. of Transportation
? Premises Liability ? Statutory Appeal: Other
S
E
C
T
I
O
N
B
? Product Liability (does not
include mass tort)
? Slander/Libel/ Defamation
? Other:
PROFESSIONAL LIABLTTY
? Dental
? Legal
? Medical
? Other Professional:
Pa.R. C.P. 205.5
? Employment Dispute:
Discrimination
? Employment Dispute: Other
? Other:
? Zoning Board
? Other:
MISCELLANEOUS
? Common Law/Statutory
Arbitration
? Declaratory Judgment
? Mandamus
? Non-Domestic Relations
Restraining Order
? Quo Warranto
? Replevin
? Other:
Updated 01/01/2011
V,
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
FAX: 215-568-7616
Email: complaints@fedphe.com
Representing Lenders in
Pennsylvania and New Jersey
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Re: BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE HOME LOANS SERVICING, L.P.vs. ANTHONY
M. SCIORTINO
ACTION IN MORTGAGE FORECLOSURE
Dear Sir/Madam:
Enclosed are an original and 3 copies of a Civil Action in Mortgage Foreclosure
relative to the above captioned matter for filing with your office. A check for filing has been
attached in the amount of $92.00. The sheriffs office advised our office on 09/28/2011 that
sheriffs costs total COST for this file. If there is a concern regarding the costs, please contact
LYNNETTE BRITTON at PH&S; please do not return the Complaint to our office.
Please file the Complaint and return your receipt to us in the enclosed stamped, self-
addressed envelope, together with a time-stamped copy of the first page of the Complaint.
I would also appreciate your taking the additional copies of the Complaint, the
check for service, and the enclosed service sheet(s) to the Office of the Sheriff for service on the
defendant(s).
Thank you for your cooperation.
Very u uiy y vurs,
Phelan Hallinan & Schmieg, LLP
COMPLAINT DEPARTMENT
File #: 274682
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
FAX: 215-568-7616
Email: complaints@fedphe.com
Representing Lenders in
Pennsylvania and New Jersey
OVERTIME, WEEKEND SERVICE, MILEAGE APPROVAL
To: The Sheriffs Department of CUMBERLAND County
Re: Attached Service Request
We recognize that service of mortgage foreclosure complaints is a difficult task as many
defendants attempt to evade service. Please note that we specifically authorize OVERTIME,
WEEKEND SERVICE AND MILEAGE for service. The sheriffs office advised our office on
0912812011 that sheriffs costs total COST for this file. If there is a concern regarding the costs,
please contact LYNNETTE BRITTON at PH&S; please do not return the Complaint to our
office.
Further, we specifically authorize a ten ($10) dollar fax fee for the transmission of the
service return to .our office at the service faxline of 215-568-7616. This applies to all cases whether
service has been made or not. We would appreciate this fax transmission within 24 hours of the
service return completion.
Please call Francis S. Hallinan or Dan Schmieg with any questions or requests you may
have. Thank you for your efforts.
Phelan Hallinan & Schmieg, LLP
COMPLAINT DEPARTMENT
File #: 274682
PHELAN HALLINAN & SCHMIEG, LLP
Robert P. Wendt. Esq.. Id. No.8915n
1617 JFK I3oule%ard. Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
274682
BANK OF AMERICA, N.A. SUCCESSOR BY
MERGER TO BAC HOME LOANS SERVICING, L.P
F/K/A COUNTRYWIDE HOME LOANS
SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
Plaintiff
V.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Defendants
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO.
CUMBERLAND COUNTY
CIVIL ACTION - LAVA
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 274682
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
rsnm oon_oinA
.,...
File 4: 274682
1. Plaintiff is
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE HOME LOANS SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
2. The name(s) and last known address(es) of the Defendant(s) are:
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 10/01/2007 ANTHONY M. SCIORTINO and HEATHER A. SCIORTINO made,
executed and delivered a mortgage upon the premises hereinafter described to
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A
NOMINEE FOR COUNTRYWIDE BANK, FSB which mortgage is recorded in the
Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No.
200739018. By Assignment of Mortgage recorded 05/20/2011 the mortgage was
assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage
Instrument No. 201114551. The mortgage and assignment(s), if any, are matters of
public record and are incorporated herein by reference in accordance with Pa.R.C.P.
1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to
pleadings if those documents are of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 02/01/2011 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
File #: 274682
by written notice sent to Mortga-or, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage as of 08/12/2011:
Principal Balance $255,563.72
Interest $9,994.76
01/01/2011 through 08/12/2011
Late Charges $248.91
Property Inspections $35.00
Escrow Deficit $756.39
TOTAL $266,598.78
7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
8. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as
required by the mortgage document, as applicable, have been sent to the Defendant(s) on
the date(s) set forth thereon.
9. The action does not come under Act 6 of 1974 because the original mortgage amount
exceeds the dollar amount provided in the statute.
File #: 274682
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$266,598.78, together with interest, costs, fees, and charges collectible under the mortgage
including but not limited to attorney fees and costs, and for the foreclosure and sale of the
mortgaged property.
PHELAN HALLINAN & SCHMIEG, LLP
By: v ` '/W?
Ro ert P. Wendt, Esq., Id. No.89150
Attorney for Plaintiff
File #: 274682
LEGAL DESCRIPTION
All that certain parcel of land situate in the East side of Heisey Road, in the Township of
Monroe, County of Cumberland and Commonwealth of Pennsylvania, being known and
designated as follows:
Parcel 1:
BEGINNING at a concrete monument on the eastern dedicated right-of-way line of Heisey Road,
T-560, at line of Lot No. 22 on the hereinafter mentioned Plan of Lots; thence along the Eastern
dedicated right-of-way line of Heisey Road, T-560, North 00 degrees 27 minutes 40 seconds
West, a distance of 100.47 feet to a point; thence along Lot No. 20 on the hereinafter mentioned
Plan of Lots, North 89 degrees 36 minutes 55 seconds East, a distance of 199.13 feet to a point;
thence along other lands now or formerly of Donald E. Deckman and Marian R. Deckman,
husband and wife, -South 00 degrees 23 minutes 00 seconds East, a distance of 100.47 feet to a
point; thence along line of Lot No. 22 on the hereinafter mentioned Plan of Lots, North 89
degrees 36 minutes 55 seconds West, a distance of 198.99 feet to a concrete monument, the place
of BEGINNING.
Being Lot No. 21 on a Final Plan of Major Subdivision for Donald E. Deckman, prepared by
Rodney Lee Decker and Associates, dated October 21, 1986 and recorded in Subdivision Plan
Book 51, Page 140.
Parcel 2:
File #: 274682
BEGINNING at a concrete monument set on the Easternmost dedicated right-of-way line of
Heisey Road (T-560), at the common point of adjoiner of Lots No. 20-A and No. 20-B on the
hereinafter mentioned plan; thence departing from said right-of-way and extending along Lot No.
20-A, North eighty-nine (89) degrees thirty-six (36) minutes fifty-five (55) seconds East, for a
distance of one hundred ninety-nine and nineteen hundredths (199.19) feet to a steel pin at other
lands now or formerly of Donald E. Deckman and Marian R. Deckman, husband and wife;
thence extending along said land, South zero (00) degrees twenty-three (23) minutes five (05)
seconds East for a distance of fifty and twenty hundredths (50.20) feet to a steel pin at Lot No.
21; thence extending along Lot No. 21, South eighty-nine (89) degrees thirty-six (36) minutes
fifty-five (55) seconds West, for a distance of one hundred nineteen and thirteen hundredths
(119.13) feet to a steel pin set on the Easternmost dedicated right-of-way line of Heisey Road;
thence extending in and along said right-of-way line, North zero (00) degrees twenty-seven (27)
minutes forty (40) second West, for a distance of fifty and twenty hundredths (50.20) feet to a
concrete monument at Lot No 20-A, said monument marking the place of BEGINNING.
BEING designated as Lot No. 20-B on an Amendment of a final plan of major subdivision
prepared for Donald E. Deckman by Rodney Lee Decker and Associates, which Amendment is
dated January 14, 2004, and recorded in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania in Plan Book 89, Page 22.
TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, driveways,
passages, waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances,
whatsoever unto the hereby granted premises belonging, or in any wise appertaining, and the
reversions and remainders, rents, issues, and profits thereof, and all the estate, right, title,
File #: 274682
interest, property, claim and demand whatsoever of Grantor(s), as well at law as in equity, of, in,
and to the same.
PROPERTY ADDRESS: 485 HEISEY ROAD, MECHANICSBURG, PA 17055-9773
PARCEL # 22-11-0280-095
File #: 274682
VERIFICATION
i , hereby states that h s e
OiCk ?p ;Art?of, BANK OF
AMERICA, N.A., Plaintiff in this matter, that he she s authorized to make this Verification, and
verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true
and correct to the best of hi er owledge, information and belief. The undersigned
understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating
to unworn falsification to authorities.
DATEO?E???(? _
File #: 274682
Name: SCIORTINO
(:::?L -1 ?. 1) Ila
Name: Lclk ?
Title:e?S6?
BANK OF AMERICA, N.A.
File #: 274682
Request for Service
R T"onias K!:..e cheriff
Cumberland County Office of the Sheriff
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.6390
Fx: 717.240.6397
BANK OF AMERICA, N.A. SUCCESSOR Court Number: $ctNum
BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE Expiration Date:
HOME LOANS SERVICING, L.P.
Type of Action:
Mortgage Foreclosure Complaint
Defendant/s: ANTHONY M. SCIORTINO, HEATHER A. SCIORTINO
Serve Upon: ANTHONY M. SCIORTINO
Address for Service:
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Alternate Address for Service:
Type of Service:
? Personal ? Adult in Charge ? Deputize ? Certified Mail ? Posting (copy of
court order required)
Special Service Instructions:
**If service is to be made by deputized service to another county please specify which
county
Filing Attorney's Information:
Name: Phelan Hallinan & Schmieg, LLP
Francis S. Hallinan, Esquire
Address: 1617 JFK Boulevard, Suite 1400
one Penn C,-ntPr PIa7A
Philadelphia, PA 19103
Telephone: 215-563-7000 x 1482
Request for Service
1? jhnm?c Kl;ne Sheriff
Cumberland County Office of the Sheriff
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.6390
Fx: 717240.6397
BANK OF AMERICA, N.A. SUCCESSOR Court Number: $ctNum
BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE Expiration Date:
HOME LOANS SERVICING, L.P.
Type of Action:
Mortgage Foreclosure Complaint
Defendant/s: ANTHONY M. SCIORTINO, HEATHER A. SCIORTINO
Serve Upon: HEATHER A. SCIORTINO
Address for Service:
223 SOUTH ENOLA DRIVE # A
ENOLA, PA 17025
Alternate Address for Service:
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Type of Service:
? Personal ? Adult in Charge El Deputize ? Certified Mail ? Posting (copy of
court order required)
Special Serv ice Instructions:
**If service is to be made by deputized service to another county please specify which
county
A
F
mg tt orney's Information:
Name: Phelan Hallinan & Schmieg, LLP
Francis S. Hallinan, Esquire
Address: 1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Telephone: 215-563-7000 x 1482
Request for Service
R. Thomas Kline Sheriff
Cumberland County Office of the Shenii
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.6390
Fx: 717.240.6397
BANK OF AMERICA, N.A. SUCCESSOR Court Number: $ctNum
BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE Expiration Date:
HOME LOANS SERVICING, L.P.
Type of Action:
Mortgage Foreclosure Complaint
Defendant/s: ANTHONY M. SCIORTINO, HEATHER A. SCIORTINO
Serve Upon: HEATHER A. SCIORTINO
Address for Service:
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Alternate Address for Service:
223 SOUTH ENOLA DRIVE # A
ENOLA, PA 17025
Type of Service:
? Personal ? Adult in Charge ? Deputize ? Certified Mail ? Posting (copy of
court order required)
Special Service Instructions:
**If service is to be made by deputized service to another county please specify which
county
Filing Attorney's Information:
Name: Phelan Hallinan & Schmieg, LLP
. Francis S. Hallinan, Esquire
Address: 1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Telephone: 215-563-7000 x 1482
F ? .erg j??{} j 1\J,
4/04/2012
Tony Sciortino
485 Heisey Rd.
Mechanicsburg, PA 17055
717-439-3161
NO. 11-8218-CIVIL Cumberland County
Bank ok America, N.A. Successor by
Merger to BAC Home Loans Servicing,
L.P. F/K/A Countrywide Home Loans Servicing L.P.
Plaintiff,
VS.
Anthony M. Sciortino
Heather A. Sciortino
Defendants(s)
2012 APR IS
AM 11: < <1
"UMBERLAND COUNT
°ENNSYLVAti
TO: Office of the Prothonotary
Cumberland County Courthouse, I Courthouse Square, Carlisle PA 17013
I represent myself. All pleadings, motions, notices, or other papers should be served
on me.
I have been working with Bank of America for the past 12 months on a home
modification loan and have replied to all questions and provided all documentation
that has been asked for. Even though I have been doing my due diligence by
providing everything asked for they have been impossible to work with. They
continue to ask for the same documentation, 8 times now, and refuse to return my
phone calls. I have escalated my concerns to my client reps supervisor and still have
not had any return phone calls. I was under the understanding that since I continue
to work with them that would prevent a filing of foreclosure but obviously they are
not communicating with the persons who have filed the complaint. In addition they
have made the claim I am not living in my house which in turn cancelled my home
owners insurance. I have provided BOA and Travelers copies of my paid Electric bill
showing my usage proving I still reside in my home but as usual I have been
ignored. My dealing with BOA has been dehumanizing and unfair and they clearly do
not want to work with me. This being said after the last go around of them asking
me for the same documentation for a 9th time explained I no longer want to pursue a
loan modification and would like to proceed with a short sale. Although I provided
this in writing to them as asked I still have not been contacted on the next steps. In
addition I am hiring a realtor to put my home up for sale. All I want to do is work
with BOA on a resolution that will work for both of us. The options of a short sale,
regular sale or reinstatement payment will give both of us acceptable results if Bank
of America would actually put some time in to working on this with me.
( k A ? -L?- -1 --
?j N doll
Bank of America
Hone Loans
PO Box 9048
Temecula. CA 92589-9048
Send Payments to:
P.O. Box 15222
Wilmington. DE 19886-5222
Send Correspondence to:
PO Box 5170, MS SV314B
Simi Valley, CA 93065
kW.
7196 9006 9295 1185 6369
20110404-7
Anthony M Sciortino
485 Heisey Rd
Mechanicsburg, PA 17055-9773
PRESORT
First-Class Mail
U.S. Postage and
Fees Paid
WSO
8LQPAt 1267012/23/2010
Bankof America
Send Payments to:
Hall loans P.O. Box 15222
P, 0. Box 660694
Wilmington, DE 19886-5222
Dallas, TX 75266-0694
April 4, 2011
Certified Mail:
Anthony M Sciortino 7196 9006 9295 1185 6369
485 Heisey Rd Return Receipt Reauested
Regula
r Mail
Mechanicsburg, PA 17055-9773
Account No.: 1 7 94 22827
Property Address:
485 Heisey Rd
Mechanicsburg, PA 1 7 055-97 73
Current Servicer:
BAC Home Loans Servicing, LP
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortaaae on Your home is in default, and the lender intends to foreclose. Specific
information about the nature of the defauk is provided in the attached pages
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home.
This Notice explains how the program works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE
DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselina Aaencv
The names, addresses and phone numbers of Consumer Credit Counselina Agencies servina your County are listed at the
end of this Notice. If you have any questions. you may calthe Pennsvlvania Housina Finance Aaencv toll free at
1-800-342-2397. (Persons with impaired hearina can call 1-717-780-18691
This Notice contains important legal information. 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, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN
SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): Anthony M Sciortino
PROPERTY ADDRESS: 485 Heisey Rd
Mechanicsbura. PA 1 70 55-9 773
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER: BAC Home Loans Servicing. LP. a subsidiarv of Bank of America. N.A.
This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan
Please write your account number on all checks and correspondence.
We may charge you a fee (of up to $40.00) for any payment returned or rejected by your financial institution, subject to applicable law. SLOPA1 12670 1212MO10
Payment Instructions: Account Number: 179422827-8
- Make your check payable to BAC Anthony M Sciortino Balance Due fo r charges listed above: $6,491.98 as of April 4, 2011.
Home Loans Servicing, LP 485 Heisey Rd Please update e-mail information on the reverse side of this coupon-
. D-1 send rash
Please include coupon with your
Mechanicsburg, PA 17055-9773
Aroma
payment pdr,c;?
BLDPAI
For all full month payment periods, FA--1
interest is calculated on a monthly basis. III, I II, 1 I 111 IJ I,
"1
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" Escrow
Accordingly, interest for all full months, I I
I
1
I
I
1
I 1111
111 I I
I
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inauding February, is calculated as BAC Home Loans Servicing, LP
301360 of annual interest, irrespective of Fsok
the actual number of days in the month. PO BOX 1 5222 7wa!
For partial months, interest is calculated Wilmington, DE 19886-5222
daily on the basis of is 365 day year. 1-800-669-6654
179422827800000649198000649198
e: 58 6 9 900 581: 1 7 9 1. 2 2 8 2 40
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP
YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
(THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for
Thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY
(301 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE
UP TO DATE. THE PART OF_THIS _ NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO
BRING YOUR MORTGAGE UP TO DATE
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the
end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The names,
addresses and telephone numbers of desianated consumer credit counseling agencies for the county in which the property is located
are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of
your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see
following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with
the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To
do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice- Only consumer credit counseling agencies have
applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. Your application MUST be filed or postmarked within Thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME
PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision
after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART
OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS
MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE.
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at:
485 Heisey Rd Mechanicsburg, PA 17055-9773
IS SERIOUSLY IN DEFAULT because
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due:
Monthlv Charaes: 02/01/2011
Late Charaes: 02/01/2011
Other Charges: Uncollected Late Charges:
Uncollected Costs:
Partial Payment Balance:
TOTAL DUE:
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable)
$6,326.04
$165.94
$0.00
$0.00
($0.00)
$6,491.98
This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan.
E-mail use: Providing your e-mail address below will allow us to send you information on your account.
Account Number: 179422827
Anthony M Sciortino E-mail address:
How we post your payments: All accepted
payments of principal and interest will be applied to
the longest outstanding installment due, unless
otherwise expressly prohibited or limited by law. If
you submit an amount in addition to your scheduled
monthly amount, we will apply your payments as
follows: (i) to outstanding monthly payments of
principal and interest, (ii) escrow deficiencies, (iii) late
charges and other amounts you owe in connection
with your loan and (iv) to reduce the outstanding
principal balance of your loan. Please specify if you
want an additional amount applied to firture payments,
rather than principal reduction.
Postdated checks: Postdated checks will be
processed on the date received unless a loan
counselor agrees to honor the date written on the
check as a condition of a repayment plan.
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE
TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6,491.98 PLUS ANY MORTGAGE PAYMENTS AND LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cashier's check, certified check or money order made payable and sent to:
BAC Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not
applicable)
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the
lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt
will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the
total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If
the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you
will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the
default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO
REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE
NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due
under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY
period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one
hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as
specified in writing by the lender and by performing any other requirements underthe mortgage. Curing your default in the manner
set forth in this notice will restore your mortgage to the same position as if you had never defaulted
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage
property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the
Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: BAC Home Loans Servicing, LP
Address: P. O. Box 660694 Dallas, TX 75256-0694
Phone Number: 1-800-669-6654
Fax Number: 1-817-230-6811
Contact Person: MS TX2-977-01-13
Attention: Loan Counselor
We are currently developing a process to ensure secure email communications for your Home Retention inquiries. In the
interim, please contact us at the telephone number or address provided.
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your
right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt,
provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other
requirements of the mortgage are satisfied-
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE
DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER.
TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Your loan is in default. Pursuant to your loan documents, BAG Home Loans Servicing, LP may, enter upon and conduct an inspection
of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the
property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other
actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and
This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan.
valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be
charged to your account as provided in your security instrument.
If you are unable to cure the default on or before May 4, 2011, BAG Home Loans Servicing, LP wants you to be aware of various
options that may be available to you through BAG Home Loans Servicing, LP to prevent a foreclosure sale of your property. For
example:
Repayment Plan: It is possible that you may be eligible for some form of payment assistance through BAC Home Loans
Servicing, LP. Our basic plan requires that BAG Home Loans Servicing, LP receive, up front, at least '/z of the amount
necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular
monthly payment, over a defined period of time. Other repayment plans also are available.
Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan
by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure
alternative, however, is limited to certain loan types.
Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of
your home can be approved through BAG Home Loans Servicing, LP even if your home is worth less than what is owed
on it.
• Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial
hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the
foreclosure sale.
If you are interested in discussing any of these foreclosure alternatives with BAC Home Loans Servicing, LP, you must contact us
immediately. If you request assistance, BAG Home Loans Servicing, LP will need to evaluate whether that assistancewill be extended
to you. In the meantime, BAC Home Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as
permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by May 4,
2011 as outlined above will result in the acceleration of your debt.
If your loan is currently being evaluated for a loan modification, forbearance or other loan assistance solution, this notice will not cancel
or delay that evaluation process. However, it is important that you promptly respond to all requests made in connection with your
evaluation for a loan assistance solution, including all requests for you to contact us and any documentation required. If you do not
comply with these requests in a timely manner, it may cause your loan to enter the foreclosure process as indicated in this notice. If
your loan is not eligible for a loan assistance program, please note this letter will continue to serve as notice of our right to initiate
foreclosure.
Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at
1-800-669-6654.
This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan.
Attachment: Itemization of Charges and Fees
Monthly Charaes: 02/01/2011 - 04/3012011
Late Charaes: 02/0112011 - 03/31/2011
Other Charges: Uncollected Late Charges:
Partial Payment Balance:
@
TOTAL DUE:
$2,108.68
$82.97
$6,326.04
$165.94
$0.00
0.00
$6,491.98
M?v
This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan.
7196 9006 9295 1185 6369
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.3422397
Community Action Commission of Captial
Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
PA Interfaith Community Programs Inc
40 E High Street
Gettysburg, PA 17325
717.334.1518
This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan.
Options are Available to Help You
Avoid Foreclosure
Call the number on the enclosed notice to learn more.
When you call, please have your income and expense information available
so we can discuss which option(s) could work for you.
Options to consider if your goal is to stay in your home
;>
Home A federal government program that allows you to repay the loan on newly agreed upon terms, which
Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or
Modification extending the term of the loan. You may be eligible for this program if you meet the following
Program requirements:
(HAMP)
• The home is your primary residence and you currently live in it.
• The amount you owe on the first mortgage is equal to or less than $729,750 for a single-family
home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit
property
• You have experienced a hardship that has impacted your income. For example, a significant
increase in your mortgage payment OR reduction in your income OR other hardship.
Your mortgage was obtained before Jan. 1, 2009.
• Your payment on your first mortgage (including principal, interest, taxes, insurance and
homeowner's association dues, if applicable) is more than 31 % of your current gross income. To
calculate this, divide your first mortgage payment by your gross income (income before taxes).
Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the loan up
Reinstatement to date until the day of your foreclosure sale.
Repayment A temporary agreement which allows for the repayment of the unpaid, past due amount along with
Plan regular mortgage payments. This may include principal, interest, fees, and/or costs assessed to your
loan.
Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments for a
Forbearance period of time, to allow you to re-establish your ability to make the required payments.
Agreement
Loan Repay the loan on newly agreed upon terms, which may include lowering the interest rate, placing
Modification amounts past due at the end of the loan, and/or extending the term of the loan.
(non-HAMP)
Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you
(FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your
Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due.
Options to consider if you cannot or do not wish to stay in your home
Home Designed to help borrowers who are eligible for the Home Affordable Modification Program (HAMP)
Affordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the
Foreclosure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction
Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agreement
Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of
(HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer
ownership of your property to us in order to avoid foreclosure.
Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short
Preforeclosure sale, you sell your property for less than the total amount owed on the loan (subject to agreement by
Sale your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of
(non-HAFA) foreclosure.
Deed in Lieu of Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not
Foreclosure able to sell the property through a short sale. With a deed in lieu of foreclosure, you agree to
(non-HAFA) voluntarily transfer ownership of your property to us in order to avoid foreclosure.
We are here to help you. Please call us today.
7196 9006 9295 1185 6369
Hay Opciones Disponibles Para Ayudarle a
Evitar la Ejecucion Hipotecaria
Llame al numero que aparece en la notificacion adjunta para obtener mas
informacion
Cuando (lame, tenga la informacion de sus ingresos y gastos disponibles Para quo podamos
discutir cual opcibn(es) pueden funcionar Para usted_
Opciones a considerar si su objetivo es permanet:er en su casa
<:::
: :<1r.
41.
.........................................
Home Affordable . ................................................................................................................................................................................:..........................
Un programa del gobierno federal que le permite pagar el prestamo bajo los nuevos terminos
Modification acordados, que pueden incluir la reduccibn de la tasa de interes, agregando la cantidad adeudada
Program (RAMP) al final del prestamo, y / o extender el plazo del prestamo. Usted puede ser elegible para este
programa si cumple con los siguientes requisitos:
• La casa es su residencia principal y actualmente vive en ella.
• La cantidad adeudada en la primera hipoteca debe ser igual o menos clue $729,750 dblares
para una vivienda unifamiliar, $934,200 dblares para una propiedad de 2 unidades, $1,129,250
dblares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades
• Ha experimentado una dificultad clue ha afectado sus ingresos. Por ejemplo, un aumento
significativo en su pago hipotecario O reduccibn de sus ingresos U otras dificultades.
Obtuvo su hipoteca antes del 01 de enero 2009.
• Su pago de la primera hipoteca (incluyendo principal, interes, impuestos, seguro y cuotas de
asociacibn de propietarios, si se aplica) debe ser mas del 31 % de sus ingresos brutos actuales.
Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes de
impuestos).
Restablecimiento Si usted puede traer sus pagos del prestamo hipotecario al dia, se le aceptaren los fondos
del Prestamo necesarios para que el prestamo este al dia hasta la fecha de la venta judicial.
Plan de Pago Un acuerdo temporal clue permite el pago de la cantidad adeudada, cantidad del pago atrasado
junto con los pagos regulares de la hipoteca. Esto puede incluir principal, interes, honorarios y/o
costos aplicados a su prestamo.
Acuerdo Un acuerdo por el cual nos comprometemos a no proceder con la ejecucibn hipotecaria y/o
Temporal de coleccibn de pagos por un periodo de tiempo, para permitirle clue restablezca su habilidad de
Tolerancia hacer los pagos requeridos.
Modificacidn de Pagar el prestamo bajo los nuevos terminos acordados, clue puede incluir la reduccibn de la tasa
Prestamo de interes, agregando la cantidad adeudada al final del prestamo, y/o extender el plazo del
(no por medio prestamo.
de RAMP)
Reclamo Parcial Si usted tiene un prestamo de la Administracibn Federal de Vivienda (FHA) y sus pagos esten
(solamente vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, este programa
prestamos de to este disenado para que su prestamo este al dia mediante la creacibn de una segunda hipoteca /
FHA) gravamen sobre su propiedad por la cantidad adeudada.
Opciones a considerar si no puede o no desea quedarse en su casa
Home Disefiado para ayudar a los prestatarios clue son elegibles para el Programa de Home Affordable
Affordable Modification (HAMP), pero no tuvieron exito en obtener una modificacibn permanente a traves del
Foreclosure programa. HAFA ofrece la posibilidad de una venta corta y, si no tiene exito, una entrega de
Alternatives escritura para evitar juicio hipotecario. Una venta corta es una transaccibn en la clue usted vende su
Program propiedad por menos de la cantidad adeudada en el prestamo (sujeto a previo acuerdo de su
(HAFA) administrador / prestamista / inversionista), resultando en la liberacibn de nuestro derecho de
retencibn sobre su propiedad y evitar la ejecucibn hipotecaria. Una entrega de escritura para evitar
juicio hipotecario es una transaccibn en la clue usted est;5 de acuerdo de transferir voluntariamente
las escrituras de su propiedad a nosotros con el fin de evitar la ejecucibn hipotecaria.
Venta Corta/ Se ofrece a los prestatarios clue no son elegibles para HAMP u otras alternativas de retencibn de
Venta antes de hogar. Con una venta corta, usted vende su propiedad por menos de la cantidad total adeudada en
Ejecucion el prestamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultando en la
Hipotecaria (no liberacibn de nuestro derecho de retencibn sobre su propiedad y evitando la ejecucibn hipotecaria.
por medio de
HAFA)
Entrega de Se ofrece a los prestatarios clue no son elegibles para HAMP u otras alternativas de retencibn de
Escritura Para hogar, y clue no pudieron vender la propiedad a traves de una yenta corta. Con una entrega de
Evitar Juicio escritura para evitar juicio hipotecario, usted este de acuerdo a transferir voluntariamente las
Hipotecario escrituras de su propiedad a nosotros para evitar la ejecucibn hipotecaria.
(no por medio
de HAFA)
Estamos aqui para ayudarle. Por favor llamenos hoy.
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https://tools.usps.com/go/TrackConfirmAction?qtc_tLabelsl=71969006929511856369 7/25/2012
PHELAN HALLINAN & SCHMIIW, *XUMAIty Attorney for Plaintiff
Joseph Schalk, Esquire
1617 JFK Boulevard, Suite 1400 2612 JUN 27 AN 10: 48
One Peon Center Plaza ?TLy?11t11 TY
Philadelphia, PA 19103
215-563-7000
Bank of America, N.A. Successor by Cumberland County
Merger to BAC Home Loans Servicing,
L.P. FAUA Countrywide Home Loans Court of Common Pleas
Servicing, L.P.
Civil Division
VS.
No. 11-8218-Civil
Anthony M. Sciortino
Heather A. Sciordno
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSME
NT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against HEATHER A. SCIORTINO.
Defendant for failure to file an Answer to Plaintiffs Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as
follows:
As set forth in Complaint
TOTAL
$266,598.78
S266,598.78
I hereby certify that (1) the Defendant's last known address is 223 SOUTH ENOLA
DRIVE # A, ENOLA, PA 17025, and (2) that notice has been given in accordance with RW
Pa.R.C.P 237.1.
Date '?
T h Shall! R ,,.,.,ft
Ott ey'?or Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: U khq
PM # 274682
a n -
INE1W
PROTHONOTARY
274682
(Rule of Civil Procedure No. 236) - Revised
Bank of America, N.A. Successor by Cumberland County
Merger to BAC Home Loans Servicing,
L.P. F/K/A Countrywide Home Loans Court of Common Pleas
Servicing, L.P.
Civil Division
vs.
: No. 114218-Civil
Anthony M. Sciortino
Heather A. Sciortino
t Atli
Notice is given that a Judgment in the above captioned matter has been entered
against you on a? t ,r
i
By: 3.0
If you have any questions concerning this matter please contact:
Phelan Hallinan 8t Schmieg, LLP
Joseph Schak Esquire
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
** THIS FLRMISA DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBT AND
ANYINFORMATIONOBTAINED WILL BE USED FOR THATPURPDSE. IF YOU
HAVE PRE VIO USL Y RECEIVED A DISCHARGE INBAN" UPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT
ONLY ENFORCEMENT OFA LIEN AGAINST PROPERTY. **
274682
Phelan gallinan & Schmzeg, LLP
1617 JFK Boulevard, Suite 1400
one Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Fax #: 215-568-7616
VICTORIA SNICTAREVA Representing Lenders in
Legal Assistant Pennsylvania and New Jersey
May 1, 2012
Office of the Prothonotary
Cumberland County Courthouse,
I Courthouse Square
Carlisle, PA 17013
Re: BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, L.P. FIKIA COUNTRYWIDE HOME LOANS SERVICING, L.P.
v, ANTHONY M. SCIORTINO, and HEATHER A. SCIORTINO
No. 11-8218-CIVIL
Action in Mortgage Foreclosure
Premises: 485 HEISEY ROAD, MECHANICSBURG, PA 17055-9773
Dear Sir/Madarn:
I would appreciate your entering a Judgment against defendant(s), ANI` TONY M.
SCIORTINO, and HEATHER A. SCIORTIN?O, relative to the above matter.
Enclosed is the original Praecipe Par Default Judgment with copies of 237.1 notices for
your records, together with my check to your order for payment of fees and costs. In addition,
please mail tin-u-stamped copies of the Default Judgment to the defendant(s) in the pre-
addressed stamped envelopes included. Kindly, send. me your receipt and a stamped copy of the
Praecipe for Default Judgment in the stamped self-addressed envelope, which .I have provided.
If there are anv questions concerning the above matter, please contact me immediately.
Yours truly;
VICTORIA SNIGAREVA for
Phelan l lallinan & Sclimieg, LLP
274682
PHEI,AN HAI.LINAN & SCHMIE(i. IA P
Matthew Bnzshwood, Esq.:. Id. No.3 f 0592
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
BANK OF AMERICA, N.A.
SUCCESSOR BY MERGER TO BAC
HOME LOANS SERVICING, L.P. F/K/A
COUNTRYWIDE HOME LOANS
SERVICING, L.P.
V&
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
No. 11-8218-CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO ` I-IE' PRO' I'I ION OTARY:
Kindly enter judgment in favor of the Plaintiff and against ANTHONY M.
SCIORTINO, .end HEATHER A. SCIORTINO, Defendarit(s) for failure to file an Answer to
Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the
mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Complaint
TO1'A_I_.
$266,598.78
$266,598.78
I hereby certify that (1) the Defendants' last known addresses are 485 HEISEY ROAD,
MECHANICSBURG, PA 17055-9773 and 223 SOUTH ENOI,A DRIVE,4 A, ENOI.,A, PA
17025, and (2) that notice has been given in accordance with 1 Zla
37.1,
2
Date
M,ttl wood, Esquire
Attorney for Plaintiff
DAMAGES ARL lIEREBY ASSESSED AS INDICATED.
DATE:
?! 9s " ..74bS_2
PROTHONOTARY
274682
PHELAN HALLINAN & SCIIMIEG, LLP
Matthew Brushwood, Esq., Id. No.310592
1617 JFK. Boulevard. Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
BANK OF AMERICA, N.A.
SUCCESSOR BY MERGER TO BAC
HOME LOANS SERVICING, L.P. F/K/A
COUNTRYWIDE HOME LOANS
SERVICING, L.P.
VS.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
No. 11-8218-CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge
of the following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of
Congress of 1940, as arnended.
(b) that defendant ANTHONY M. SCIORTINO is over 18 years of age and
resides at 485 1lEfSEY ROAD, MECHANICSBURG, PA 17055-9773.
(c) that defendant IIEATIIER. A. SCIORTINO is over 18 years of age and
resides at 485 IIEISEY ROAD, MECIIANICSBURG, PA 17055-9773 and 223 SOUTH
ENOLA DRIVE # A, ENOLA, PA 17025.
This statement is made subject to the
relating to unsworn falsification to authorities.
Date
A
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Pa. C.S. Section 4904
Efod, Esquire
aintiff
274682
(Rule of Civil Procedure No. 236) - Revised
BANK OF AMERICA, N.A. SUCCESSOR CUMBERLAND COUNTY
BY MERGER TO BAC HOME LOANS
SERVICING, I.P. F/K/A COUNTRYWIDE COURT OF COMMON PLEAS
HOME LOANS SERVICING, L.P.
VS. CIVIL DIVISION
ANTHONY M. SCIORTINO No. 11-8218-CIVIL
HEATHER A. SCIORTINO
Notice is given that. a Judgment in the above captioned matter has been entered
against you on
By:
If you have any questions concerning this matter please contact:
Phelan Ilallinw--i & Schmieg, LLP
Matthew Brushwood, Esquire
Attorney for Plaintiff
1617 .IFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
** THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND
ANYINFORMAATIOA'OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HA VE PREVIOIiSL Y RECEI VED A DISCIIARGE IN BAIVKR UPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECT A DEBT, BUT
ONLI'E.NFORCEMENT OFA LIF_NAGATM57'PROPERTY. **
274682
B2", vK.OT' A`dLKICA, N.A. St r_C.I:SSOK f3Y
bvll P,(ll:;R I'C.? t>_ C IIOMWI LOANS SERVIC 1,NG
5 RVICI' G, 1, R
I'! KN U
A,NTTf()N '";'N;1. SCiC31?11M)
Defendant{s
DATE OF NOTIC CIVIL
1.f ). ANTFIONY ?.?I. SCH)WFINO
4 ` HEISEY IZC-AI:)
?III C i IANIf.'S131 N G, PA 17C1: S ? 773
M,
..k -.,. .__?___... ...,_..._
541 :1121811M
Ct. `V11 IIRT-lN J) C .#.tl 'Y
THIS FrRA-1 IS A, DEBT C. (,)I, J..;C"lOR AT-] l."MPTING "1"O MEN ' A I;)>I T. TTIIS NOW 0
r:
IS Sl-:\11' 'I'C) YOU IN AN t>,` lf,,N11'°I O ( , :f THE I C)I I3'1 t.I) ;}: ?S ItI;E EItItI D TC)
IIEKE-.IN, AND ANN' 1NFOR144A'I ION OKFAIi AA? FRCA4 WE 'VIVII L I3 . 'USED FOR" fl,&T
PC'I P0SF- IF YOU I.CAVE PRIsMUSLY R1 C:;??`IVET I) A (?I' >C.;FIi?:l tai? TN HA.NKIil..lE'".1"C;Y.
'BUS ;t:)IPASI'r?N.31:'s.NCE, 'S NOT ANT) NOT BE Trs ll, AN
A,l".'EMP-I F(C) l-( ,,I,F:(`A I71'.FI"I`, B C)N.L.Y AS I_;Nf'0P(`',Alj',N,' C. 1,11,,'N AO"UNS7`
PROPIAITY.
M T'() I3 TAX r NC)'I' (q j-r
YC)": flitl:', IN .I EJ'Al_(I T lit ACSI YOU IIAVE I AILki) '10 I N'I FR A WRITTEN
API'EAkA:l CE. PERSONALLY OR BY =l`I ORNI Y AN.I) FILE IN WRFII;`J<__; Wl'lIt I11E CC(;Rj'
YOUR DEFENSES OR OBJ :CTIONS "1'C) FIIE CLAIMS SET FORTH AGAINST YOU. t)NLESS YC)()
AC71' WITTIIN TEN DANE FR MM THE DAT1";. 01 T.:I IIS NOTICE, A 3C;1:)t itvlEN"I' 111;14 BE ENHE-RED
AGAINST YOU tr IT11UC "T A H "RING AND YO(: JAAY IPSF YOUR PIMPI RTY OR OTII TR,
P%41'01,? I'ANT KICi I ITS.
YOU SHOULD TAKE THIS PAPER TO YC}UP LAWYER Al` 0NCI - IF YOU DO NOT
HAVE A L., WN T R. C K) ,'t.) OK ELMtiNE WE OFFICE SF FORTT _ BF10W THIS (_ F CE
CAN PRO VT )I1: YOU I W,411 .C'() fi-FA"1 IO N ;1'3C?(t.l. III}`IItiC; A i..='tirYl'.I(
11= YOU C:ANi`,,0 AFFT)RD To CII:RE ]-ANrYI?I(, :'III4 t)I'I''Ir'}:: `,JAY i Ai-31_H TO
1'llt)X'I,)L 5'0(; Wi I'{'-I It4I c`l:(`olAl.t_> t
11 i::f,RATBI It I9?:.(S0N : rV .- LI r) _iC?_1; F)"T:_ .)R N; I I
Ufficu o t r Prothoratva-Y
C.. umlbe•land Coutaty Cc?u::hotisc
t_;arli ,l PA P013
\ c., 240 6105
ASS(i(:7.t4,`)'IC N
,C1,1i• B RL ND (.;{.)UN Y `::f?( I("II(.)t1: L
2 LIT3I ?`C"Y A`v'I;It 111
1117) 249.3166
3
1_):amt''s I .,quire
p Ia irliitf
I'l.e(ar; Iiallir??ari & ;c_;??iier;: ?._I 1=
161 .. l?K. 40„
'hiladel ph a, PA I Q 103
BAI W f }FAMERIC;A, N ,A. St)C C,E:SSOR BY
TO BAC HONTE 1,0'.NS SY R IC ING,
J,.Y, i"X;:A CU1. NTRYLvIDE i-i(.)NIF l_OANS
SE'R'VI(ANIG, L.P.
llhlintiil`
V,
ANTHONY M. `CIO RT[NO
I? 111 ER. A, SC'lOR`I`]NO
)(!''Cfl aut.f>)
IILNI'IIER A. SCIOR'FI O
ENOL A, PA 170121)
I)A I E 0 NC)1 ICP : .' ti
1 VII, D[VISON
£ .;' lP1RI-A1,41" C()(iN' ,`
TI HIS I'tIv' 1 IS A .DEBT /COI I,I CT'OR n`1'Fr1?1' I'I_N(.? 1 t:3 C.X.).1 t"C A [71:13 1. T Ills NOTICE
IS i1?N" TO YOU T 11 N A"1"' Ji'?Y l I' 'J.O COI1I FC,"I' '1`131-: INDEBTEDNESS RI I°71R. E=:1) TO
11EREIN, AND E vY IE`FC 1tii1;?€IOT C}73"1't`t1N.:C:; Fl ONO YO(J W IA, BlE [ SED E )E1. T11A`1"
I'UIWOS[ . IF YOU H.A`r'I PI(EV1011SL's' RFC'F,?t%1 I;) A D[S'CFJARGE' IN j'5A.NKRUP' Cy,
TIES CORR11SPONDI.:`NC IS NOT AI 3' SHOULD '`'O 131:; CONISTRUI`P BE, AN
AT"TEMPT TO C'OLLE.C T A DEBT, B11 1' ONLY AS s`NJ ORCFNIE NT k)!` LiEN AGAINST
PROPERTY,
1.MII 01ZTA.N1' NC)`IT1CI?
'()( ARE IN DEFAULT 13 E:,x..51; W3I_s EiAs' ? F'tII,FD WI 1T"IEN
APPI-AIiANCE PFRS0` ALLY OR BY 11VI"I'OR:NEV AN11711T IN' 1A1TUTFN( ;"1H 'I HE C;C)(.:'Z.T
YOUR DEFFNSES OR. OBJEC`I°IO-NIS 'I,C) THE C;1. A11vJ`> SIA FORTH AGAIN?S 1 Y01)'LiNLESS YOU
ACTWI'111-1-Ni I`I ti DAYS FRON?'1`HE DiVi'E OF HIS NC I('., :^.."U[)GEM1:N' ' M Y I' )E I;NI'ERED
AGAINST Yo t_N WIT)IC)T;rT I1 FARING <\,NNI) YO ; " AN. L •Sf YOUR PR()I`Fki'Y ()R ()"1'111':1",
:(vIl'?)1Z`I'Aivl' IZIGI'I'S,
Yttf S11t7TJl,f) TAKE THIS PAPER TO Y,")il t. I,AYY'YFF AT ON(.," 1' YOU DO NOT
I.IAG°;E t1 I_,A iY,C:R, (:'rCf '1"C) C;R 1'I;F.I=,.1'IiQail: "1'111 ()z"t 1C;I sF t' 3 t)it lzi L7I 1..!:Ei ° 1111:5 C?F ICE'
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Ii V O A<NNNO f' AFFORD TO HI1 F' A I,AWY1=:;t„ THIS ='-& if:;.1 -MAY BI AD1,1I TO
I'ROVIl)F Y'OCs r"~rHII INFORMA'1 JN A130(..rl A(.jEIN('JI;S `1"1,1^T MAY O, I I.P I,FGAI SERVICES
O l:f_IE:II13I.ls F'E:It SONS A"1.' A El,s)t)CI;I.I) 1`1,1` 01'. Nt) > I"
O1ficc o the Prothonotary
C;urrrnerland County Coul-h use
I C'ourthous : Square
Carlisle, PA 17013
240 6195
ASSOCIATION
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H RFEN, ANT) .AN`A' :NFORM;? TIONi E.)I3T.1I"TI=:D i'aZ :)?1 'i't)I.' MLL BE USE i FOR I'It. I'
PIMO S . [I' YOU I-L'\VF; Pl1 EMUSLY REC.Ek/h'I.) ._ I)ItiC:`1:I: ,.ZErI? '.'; I3A'NI:MP"IC;Y,
'MIt {;C)I1?LSI"'(3PEli}:'.v. IS i1C4 AND SHO `I? OF' >3i 0901}01FI) j') HI, AN
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OPI,1: I Y.
1 AP0RTAINT I lAjyI:
YOU ARE 1N DEFAULT FYI),Ctlt 5ls YOU HAVI T°`AJLED `I) I NTE-_ ' 1-V<?ITTE
APPE,AK.ANCI' PERSONALLY OR L1Y ATT(.)RN1 Y AND I`11,17, IN WRITING WITH '11I1 '_ t;)1 M
YOUR I:tI_TI_>NSES OR OBJECTIONS TO `PITT=, CLA.RVIS SF.T E"'()IZTTf AGAINST YOU. UNT 1',x;5 Y(1I_r
:V'T WITHIN TI N DAYS FROM TIII:, I)ATI C)FTHIS N01"IC E, rl IC 1)C:iIt1I NT' tvT ?`' F-'RFI)
AGAINST `z'ot! b' T111OUT A 1-il AR1,NJ ANT.) YOU 11A OS YOUR PR.C)I'HItTY OR 01,14"I?
.i'yt I:'CJIt"I?t3, NI' I? It:,H' 1 `S.
Y'tU SHOULD TIME THIS PAPF',R •TO YOUR LAWYER AT ONCE. 1.1, Y'(.)(.' DO NOT
I1.V A LAWYER, M TO CM 'ITLEPHOI Ei THE, EXTICIT SI;F F{)I 111 BELOW. THIS 01TICE
f';,)?'`? PR.OVTT)T YOU VI TIT I:I?1?ORMATT N A1301?1' FI_CRIN3 A LAW` IR-.
II' YOU CANNOT AI=FC)F'D Ti) HIRE A I AshYI.TY, -Iflt, t -:11.1CF V1.1..' 1',F CAI I,1 I:
1'1ZC} .",I , `ti l.. V AM TNFORMrY'I'ItM AI1OLY A':<F;MI:;T1 i..:..` MAY (AFI S I,I AL St:RMx I
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Phelan 1-tallin?in & Scllmigs? 1'.J)
I b 17 ,IF1:: Boulevaa d, Stdl.c 4()0
(he Pwn Center Mai
MAMMA PA 10 Ti
110 N 274652
April 23, 2011
BAC Home Loans Servicing LP
5401 N Beach St
TX2-977-01-34
Fort Worth, TX 76137
ANTHONY M SCIORTINO
485 HEISEY RD
MECHANICSBURG, PA 17055
Loan Number: IM?
Dear ANTHONY M SCIORTINO:
We have reviewed your request for a loan modification under the federal government's Home Affordable
Modification Program. Unfortunately, your loan is not eligible for the Home Affordable Modification Program for
the reason stated below.
We are currently reviewing your financial information to determine if there are other options available to you.
These options may include:
• A different modification program that may help you achieve more affordable payments;
• A forbearance program. With this program you could receive lower payments or no payments for a limited
number of months to either give you time to resolve your financial difficulties or give us time to work
together with you on a more permanent solution;
• A Short Sale. With this program, you agree to sell your home at fair market value and settle your
mortgage debt for less than the amount you owe.
• A Deed in Lieu of Foreclosure. With this program, you can avoid the public auction of your home by
voluntarily transferring the title or ownership of your property to satisfy your mortgage debt.
Once we have finished reviewing your information, we will contact you within 10 days to let you know what other
options are available to you and the next steps you need to take. Please contact us at 1.888.325.5399 if you
have questions about these options.
Reason your loan was not eligible for the Home Affordable Modification Program
Under the guidelines of the Home Affordable Modification Program:
You are not eligible for a Home Affordable Modification because your current monthly housing
expense, which includes the monthly principal and interest payment on your mortgage loan plus
property taxes, hazard insurance and homeowner's dues (if any) is less than or equal to 31% of
your gross monthly income (your income before taxes and other deductions) which we verified
as $9,033.33. Your housing expense must be greater than 31% of your gross monthly income to
be eligible for a Home Affordable Modification. If you believe this income or expense is
incorrect, please call us at 1.888.325.5399 by May 23, 2011.
LMO_280_3
According to the guidelines of the Home Affordable Program, you have 30 days to appeal the decision that your
loan is not eligible for the program. Please contact us by May 23, 2011 at 1.888.325.5399, if you think that the
information used to determine your eligibility is incorrect.
Important information about foreclosure
If a foreclosure sale of your home is currently pending and on hold, that hold will continue and remain in effect
while you are considered for other foreclosure avoidance programs.
Important-Do not ignore any foreclosure notices.
You may receive foreclosure/eviction notices - delivered by mail or in person - or you may see steps being taken
to proceed with a foreclosure sale of your home. While you will not lose your home during this review period, to
protect your rights under applicable foreclosure law, you may need to respond to these foreclosure notices or
take other actions. If you have any questions about the foreclosure process contact us at 1.888.325.5399. If you
do not understand the legal consequences of the foreclosure, you are also encouraged to contact a lawyer or
housing counselor for assistance.
We're here to help
Please call us today at 1.888.325.5399 Monday-Thursday 8 a.m. - midnight Eastern, Friday from 8 a.m. -
10 p.m. Eastern, Saturday from 9 a.m. - 6 p.m. Eastern and Sunday 3 p.m. -11 p.m. Eastern if you have
any questions. We will call you in 10 days to let you know what other options are available to you and the next
steps you need to take.
You can also seek assistance at no charge from U.S. Department of Housing and Urban Development-approved
housing counselors by calling the HOPE Hotline Number (1.888.995. HOPE). Assistance in understanding this
notice is available through the HOPE Hotline by asking for MHA HELP.
Home Loan Team
BAC Home Loans Servicing, LP Bankof America How Loans
IV,
BAC Home Loans Servicing, LP is required by law to inform you that this communication is from a debt collector. However,
the purpose of this communication is to let you know about your potential eligibility for programs to help you avoid
foreclosure.
Mortgages funded and administered by ai .0 Equal Housing Lender.
?-,, Protect your personal md-a.n before -yding N, tlocument.
LMO_280_3
PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 14103
Phone 215-563-7000
Fax(215)215-568-7616
Email: FCResolution@fedphe.com
Foreclosure Resolution Department
Representing Lenders in
Pennsylvania & New Jersey
April 17, 2012
Re: BANK 01 AMI'Rl(.;A. N.A. SUCCF'SSOR 13Y MFRGEIt TO BAC HOME LOANS SERVICING, L.P.
t %f: A C'O IN`t`ItYWIDL HOME, LOANS Sl-RVIC'IN , LP. V.
ANTHONY M. SCItJIt'I'lNO and HFATJII IZ A. SC'ICJRTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Loan #: qffMon?
To Whom It May Concern:
In accordance with your recent request, please find a reinstatement figure in the amount of $33,267.62,
which is the amount needed to bring the account current with BANK OF AMERICA, N.A. Funds must be
received in our office by April 24, 2012 in order to process and forward to our client.
Upon submitting payment, please note the following:
• Personal checks will not be accepted. Certified funds purchased from a bank and money
orders. Title company and attorney escrow accounts checks, are also acceptable.
= All checks must be made payable to the mortgage company stated above, and forwarded to
Phelan Hallinan & Schmieg, LLP.
• We recommend using overnight mail to ensure that your payment is received timely.
If you intend to deliver payment in person, please call to schedule an appointment.
= Include account number on the check for proper identification.
• It is passible that additional expenditures may be incurred by either the mortgage
company or this firm in the interim period between the time these figures are generated
and the time monies are tendered. In this event, only the FULL monies will be accepted.
Acceptance of the funds is contingent upon a complete review by our client.
If you should have any questions, please feel free to contact our office.
Sincerely,
Phelan Hallinan & Schmieg, LLP
Foreclosure Resolution Department
Phelan Hallinan & Schmieg, LLP is a debt collector attempting to collect a debt. Any information received will be used for that purpose,
If you have received a discharge in bankruptcy, and this debt was not reaffirmed, this correspondence is not and should not be construed
to he an attempt to collect a debt, but only enforcement of a lien against property.
Mot` IIke mate irr this ccrmntturicaticut,gou owe the amount rf,eeitied. ttecause ol'interco, laic charges, and other charges that may vary
troika day, it) clay, the amount due ou the day you pay rosy be err i ter. Renee, iryott pay the amount shown above, an adjustment maybe
necessary after the receive your rherk. in which event tie iA ill i„rurnt yin before detwsitingahe check for collection. For further
infurmutin?t write the nodersigned orcall 215-563-7 00 and +.P: for the Reinstatement Department.
LN
PHELAN HALLTNAN & SCHMIEG, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Phone 215-563-7000
Fax(215)215-568-7616
Entail: FCResolution ct fedphe.coni
Representing Lenders in
Pennsylvania & New Jersey
Reinstatement Figure
ANTHONY M. SCIORTINO
NAME: and HEATHER A. ACCT,
SCiORTINO
DATE: April 17, 2012 Good Through: April 24, 2012
6 Payments Due @ $2,108.68
Payments Due ra) $2,086.82
1,ate Charges
Property :inspections
BPO
Property Preservation
Escrow Shortage
Suspense Credit
Sheriff Commission
Prothonotary of CUMBERLAND County Costs
Sheriff of CUMBERLAND County Costs
Additional Foreclosure Costs
Attorney Dees
Corporate Advance
Insufficient Funds
TOTAL
$12,652.08
$18,781.38
$248.91
$105.00
$0.00
$0.00
$0.00
$0.00
$0.00
$113.25
$127.00
$330.00
$910.00
$0.00
;$0.00
$33,267.62
Phelan liallinan & Schmieg, UP is a debt collector attempting to collect a debt, Any information received will be used for that purpose.
If you have received a discharge in bankruptcy, and this debt was not reaffirmed, this correspondence is not and should not be construed
to be an attempt to collect a debt, but only enforcement of a lien against property.
As of f7rr time of thie communication, you owe the amannt specified. 14ccattw of inaa ) v,t, title charges, and other charges that may vary
troll) das tr• dac, flit, amount due on the day you pay may lit, greater. ifenrc, if )ru la:,) thr amount shown above, an adjustment may be
ere s5:)r% uftel t.r revcivc? uurcheck, in which c%entwe. will Worm s lilt heforc rtct)t ,.iting the check for collection. For further
iol"'; wmkrzt, ar rill, th'. ueutrrsivncd or call 2l.°a-563-70tltl and ask for the H'instatcux-ut Department.
P
PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Phone 215-563-7000
Fax(215)21.5-568-7616
Email: FCResolution@fedphe.com
Foreclosure Resolution Department
Representing Lenders in
Pennsylvania & New Jersey
May 8, 2012
Re: BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, L.P.
F/K/A COUNTRYWIDE HOME LOANS SERVICING. L.P. v.
ANTHONY M. SCIORTINO and HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Loan*
To Whom It May Concern:
In accordance with your recent request, please find a reinstatement figure in the amount of $35,640.94,
which is the amount needed to bring the account current with BANK OF AMERICA, N.A. Funds must be
received in our office by May 9, 2012 in order to process and forward to our client.
Upon submitting payment, please note the following:
• Personal checks will not be accepted. Certified funds purchased from a bank and money
orders. Title company and attorney escrow accounts checks, are also acceptable.
• All checks must be made payable to the mortgage company stated above, and forwarded to
Phelan Hallinan & Schmieg, LLP.
• We recommend using overnight mail to ensure that your payment is received timely.
• If you intend to deliver payment in person, please call to schedule an appointment.
• Include account number on the check for proper identification.
It is possible that additional expenditures may be incurred by either the mortgage
company or this firm In the interim period between the time these figures are generated
and the time monies are tendered. In this event, only the FULL monies will be accepted.
Acceptance of the funds is contingent upon a complete review by our client.
If you should have any questions, please feel free to contact our office.
Sincerely,
Phelan Hallinan & Schmieg, LLP
Foreclosure Resolution Department
Phelan liallinan & Schmieg, LLP is a debt collector attempting to collect a debt. Any information received will be used for that purpose.
If you have received a discharge in bankruptcy, and this debt was not reaffirmed, this correspondence is not and should not be construed
to be act attempt to collect a debt, but only enforcement of a lien against property.
As of the date of this communication, you owe the amount specified. Because of interest, late charges, and other charges that may vary
from day to day, the amount due on the day you pay may be greater. Bence, if you pay the amount shown above, an adjustment may be
necessary after we receive your check, in which event we will inform you before depositing (fie check Im collection. For further
information, write the undersigned or call 215-563-7000 and ask for die Reinstatcnicnt Depamueot.
PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Phone 215-563-7000
Fax (215) 215-568-7616
Email: FCResolutio@tedphe.com
Representing Lenders in
Pennsylvania & New Jersey
Reinstatement Figure
ANTHONY M. SCIORTINQ
NAME: and HEATHER A. ACCT.
SCIQRTINO
DATE; May 8, 2012 Good Through: May 9, 2012
6 Payments Due @ $2,108.68
10 Payments Due @ $2,086.82
Late Charges
Property Inspections
BPO
Property Preservation
Escrow Shortage
Suspense Credit
Sheriff Commission
Prothonotary of CUMBERLAND County Costs
Sheriff of CUMBERLAND County Costs
Additional Foreclosure Costs
Attorney Fees
Corporate Advance
Insufficient Funds
TOTAL,
$12,652.08
$20,868.20
$248.91
$115.00
$0.00
$0.00
$0.00
$0.00
$0.00
$129.75
$127.00
$330.00
$1,170.00
$0.00
_._$0.00
$35,640.94
Phelan Hailinan & Schmieg, LLP is a debt collector attempting to collect a debt. Any information received will be used for that purpose.
If you have received a discharge in bankruptcy, and this debt was not reaffirmed, this correspondence is not and should not be construed
to be an attempt to collect a debt, but only enforcement of a lien against property.
As 'rf tl+r datr elf tiri ro€n:nnnieatimr, you owa the amount spec if6ed. Because of interest, late charges, and other charges that may vary
from day to day, the amount due on the day you pay may° be grcafer, ltence, if you pay the amount shown above, an adjustment may be
cr ,5,+r after Ive € ecrive your check, in which event we will inforat yoti before depositing the check for collection. For further
inl(errna€ir>rr, write the undrrsifinat r call 215-563-7000 and ask for the Reinstatement Department.
PHELAN HALLINAN & SCHMIEG, LLP
BY: JOSEPH P. SCHALK, ESQUIRE
Identification No. 91656 Attorney for Plaintiff
126 Locust Street
Harrisburg, PA 17101
(215)563-7000
BANK OF AMERICA, N.A. SUCCESSOR BY Court of Common Pleas
MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE Civil Division
HOME LOANS SERVICING, L.P.
7105 CORPORATE DRIVE Cumberland County
PLANO, TX 75024
Plaintiff No 11-8218-CIVIL
VS.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Defendants
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of Plaintiffs Motion for Summary Judgment with
all exhibits in support thereof were sent via first class mail to the persons on the date listed below:
ANTHONY M. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
HEATHER A. SCIORTINO
223 SOUTH ENOLA DRIVE #A
ENOLA, PA 17025
Date: 6 .a/ B?-
J-e P.$chalk, Esquire
tto ev for Plaintiff
l?
PRAECIPE FOR LISTING CASE FOR ARGUMENT i' ILED-OF FICE
'Ir 1. 1, HE ??QNt?TAE?`r'
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY: 202 AUG - PM 3' 42
CUMBERL NQ COUNTY
Please list the within matter for the next Argument Court. :? N11S 0 AN1 A.
BANK OF AMERICA, N.A. SUCCESSOR BY
MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE
HOME LOANS SERVICING, L.P.
7105 CORPORATE DRIVE
PLANO, TX 75024
Plaintiff
VS.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
Defendants
2.
Court of Common
Civil Division
Cumberland County
No. 11-8218-CIVIL
State matter to be argued (i.e., plaintiff s motion for new trial, defendant's demurrer to
complaint, etc.): Plaintiff s Motion for Summary Judgment
Identify counsel who will argue case:
(a) for plaintiff: Joseph P. Schalk, Esquire
Address: 126 Locust Street
Harrisburg, PA 17101
(b) for defendant: Anthony Sciortino, pro se
Address: 485 Heisey Road
Mechanicsburg, PA 17055
3
4
Date
I will notify all parties in writing within two days that this case has been listed for
argument.
Argument Court Date: September 7, 2012
B / L/ 12s
q.-7S? a
1a1qu-4
a,1S9cls
PRAECIPE TO REASSESS DAMAGES
P.R.C.P.3180-3183
COURT OF COMMON PLEA= ~~
``,
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO _,
~~ `~
' `~ ~""'
BAC HOME LOANS SERVICING, L.P. F/K/A CIVIL DIVISION r*~ r" .
'~ f Y ; ~,-.
COUNTRYWIDE HOME LOANS SERVICING
L.P ~,~ ~
..-
;.. ~'
='" -~
,
.
Plaintiff ~
NO. 11-8218-CIVIL TERM ~
%, ..~
~ C~
~ ~:~~-'
_
~~' ~ ~~:
CUMBERLAND COUNTY 1~ c-~ ~"•"-
~~ ~-~..,
~-.:/
--
''.~.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Defendant(s)
PRAECIPE TO REASSESS DAMAGES
To the Prothonotary:
Kindly Reassess the Damages per the Court Order dated ~ /~ / Z in favor of the Plaintiff and against
ANTHONY M. SCIORTINO and HEATHER A. SCIORTINO, defendant(s).
As Set Forth in the Order
5288.680.59
[allies & Schmieg, LLP
hael Kolesnik, Esq., Id.No. 308877
for Plaintiff
,~~ ~-lo . SGp~ ~`~1
a
~~ ~~~ ~$
~# a$a
hc~ V~Cu ~~~
N~
BANK OF AMERICA, N.A.,
PLA-iNTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
r,..'
ANTHONY M. S
IORTINO,
'''',~rn~
~ i
~;~'
'
HEATHER A. S MORTINO, ~r ..... ~o~
-,-,
DE , ENDANTS 11-8218 CIVIL -~z
r -- °E,
IN
:PLAINTIFF'S MOTI N FOR SUMMARY U
T io a
~ ~~
off?
~
B FORE H D ERT J. ~ ~
ORDER OF COURT
AND NOVIh, this 10~' day of September, 2012, upon consideration of the Plaintiffs
Motion for Summary Judgment, the brief filed by the Plaintiff, and the Court noting that
the Defendants hive filed no response to the Motion or responsive brief,
IT IS HERBY ORDERED AND DIRECTED that Plaintiff's Motion for summary
Judgment is GRA~iTED. An In Rem judgment is entered in favor of the Plaintiff and
against the Defendants, Anthony M. Sciortino and Heather A. Sciortino for $288,680.59
plus interest from IMay 31, 2012 and any other costs and charges collectible under the
Mortgage, for foreclosure and sale of the mortgage property.
By the Court,
~~
M. L. Ebert, Jr., J.
~ Joseph Schalk, Euire
Attorney for Plainti
Anthony M. Sciortino
Defendant
~ Heather A. Sciortino
Defendant bas
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME COURT OF COMMON PLEAS
LOANS SERVICING, L.P. F/K/A COUNTRYWIDE HOME LOANS
SERVICING, L.P. CIVIL DIVISION
Plaintiff
NO.: 11-8218-CIVIL
v
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Defendant(s)
CUMBERLAND COUNTY
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due
Interest from 05/31/2012 to Date of Sale
($43.82 per diem)
TOTAL
w' r-:.y
~.~
~~ ~ ..
$288,680.59
."~
$ ] 2,269.60 ~~''~- ~" ~-~ ` "~
E ~~. °; .
.J'.. .~
i ~.i~tf w~.~..
~~~
waCr.A...J e~,..~ t...
• :~
$300,950.19 ~
~, ~,
__~
.
an Hallman & Schmieg, LLP
J Michael Kolesnik, Esq., Id. No.308877
Attorney for Plaintiff
Note: Please attach description of property.
PHS # 274682
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PHELAN HALLINAN & SCHMIEG, LLP
John Michael Kolesnik, Esq., Id. No.308877
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorneys for Plaintiff
.
~ f..,. .. 4 v j~ J .,_, ~..
i,: -~~:.
~' ~ i ~ ~'~''~ ! 3 ~ I 1 ~ v' F3
BANK OF AMERICA, N.A. SUCCESSOR BY MERGE. ,' ~~~~T`,'COURT OF COMMON PLEAS
HOME LOANS SERVICING, L.P. F/K/A COUNTRYWIDE r~l~:
LOANS SERVICING, L.P. CIVIL DIVISION
Plaintiff
NO.: 11-8218-CIVIL
v.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Defendant(s)
CUMBERLAND COUNTY
CERTIFICATION
The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned
matter and that the premises are not subject to the provisions of Act 91 because:
( ) the mortgage is an FHA Mortgage
( ) the premises is non-owner occupied
( ) the premises is vacant
(X) Act 91 procedures have been fulfilled
( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
By:
P n allinan & Schmieg, LLP
n Michael Kolesnik, Esq., Id. No.308877
ttorney for Plaintiff
,,~
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER COURT OF COMMON PLEAS
TO BAC HOME LOANS SERVICING, L.P. F/K/A .
COUNTRYWIDE HOME LOANS SERVICING, L.P. CIVIL DIVISION
Plaintiff
NO.:11-8218-CIVIL
v.
ANTHONY M. SCIORTINO CUMBERLAND COUNTY
HEATHER A. SCIORTINO
Defendant(s) PHS # 274682
AFFIDAVIT PURSUANT TO RULE 3129.1
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, L.P. F/K/A
COUNTRYWIDE HOME LOANS SERVICING, L.P., Plaintiff in the above action, by the undersigned attorney, sets forth as of the
date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 485 HEISEY
ROAD, MECHANICSBURG, PA 17055-9773.
1. Name and address of Owner(s) or reputed Owner(s):
Name •~-~ ~ ^'.
Address (if address cannot be reasonably
_ _-_
ascertained, please so indicate) .-~ :.: ~"-'
r ,~,,
ANTHONY M. SCIORTINO 485 HEISEY ROAD "~ .~~} "' _., ~__:
MECHANICSBURG, PA 17055-9773 ~,~ ~ '~-~~
t~_-x
T.~ ,% ~; -
HEATHER A. SCIORTINO 223 SOUTH ENOLA DRIVE # A ~
ENOLA, PA 17025 ~ c7 w `~,~
ter,
...r. 8~~
2. Name and address of Defendant(s) in the judgment:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
SAME AS ABOVE
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
5. Name and address of every other person who has any record lien on the property:
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the
sale.
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
~ -~
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
be affected by the sale:
Name Address (if address cannot be
reasonably ascertained, please indicate)
TENANT/OCCUPANT 485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
ANTHONY M. SCIORTINO 300 NORTH 2ND STREET
C/O RICHARD S. FRIEDMAN, ESQUIRE SUITE 402
HARRISBURG, PA 17101
ANTHONY M SCIORTINO, PRO SE 485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE, PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675
DEPARTMENT OF WELFARE HARRISBURG, PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH, PA 15222
U.S. DEPARTMENT OF JUSTICE 228 WALNUT STREET, SUITE 220
U.S. ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG, PA 17108-1754
FEDERAL BUILDING
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
Date: _~~~ By:
Phe limn & Schmieg, LLP
J ichael Kolesnik, Esq., Id. No.308877
orney for Plaintiff
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS
BAC HOME LOANS SERVICING, L.P. F/K/A
COUNTRYWIDE HOME LOANS SERVICING, L.P. CIVIL DIVISION
Plaintiff NO.:11-8218-CIVIL
vs.
CUMBERLAND CrOUP41TY
ANTHONY M. SCIORTINO -
HEATHER A. SCIORTINO ~
; ;~' ~ ~~~
_ ,
Defendant(s) "" -'c'
_.
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" .
,.
°
.:
u~ ,~ . ~~
_.~ -r-~,
NOTICE OF SHERIFF' ~-
S SALE OF REAL PROPERTY ~-- ~~ `~
:
-
`°~' ~:
c~
.~ ~, .- ..,
TO: ANTHONY M. SCIORTINO HEATHER A. SCIORTINO ~ ~.
485 HEISEY ROAD 223 SOUTH ENOLA DRIVE # ~
MECHANICSBURG, PA 17055-9773 ENOLA, PA 17025
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 485 HEISEY ROAD, MECHANICSBURG, PA 17055-9773 is scheduled to
be sold at the Sheriff's Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse, South
Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $288,680.59 obtained by BANK OF
AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, L.P. F/K/A
COUNTRYWIDE HOME LOANS SERVICING, L.P. (the mortgagee) against you. In the event the sale is
continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this
has happened, you may ca11215-563-7000.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if
the sale never happened.
S. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff
gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. This schedule will state who will be receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (l 0) days after the filing of the proposed schedule.
7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
LEGAL DESCRIPTION
All that certain parcel of land situate in the East side of Heisey Road, in the Township of Monroe, County of
Cumberland and Commonwealth of Pennsylvania, being known and designated as follows:
Parcel 1:
BEGINNING at a concrete monument on the eastern dedicated right-of--way line of Heisey Road, T-560, at
line of Lot No. 22 on the hereinafter mentioned Plan of Lots; thence along the Eastern dedicated right-of--way
line of Heisey Road, T-560, North 00 degrees 27 minutes 40 seconds West, a distance of 100.47 feet to a
point; thence along Lot No. 20 on the hereinafter mentioned Plan of Lots, North 89 degrees 36 minutes 55
seconds East, a distance of 199.13 feet to a point; thence along other lands now or formerly of Donald E.
Deckman and Marian R. Deckman, husband and wife, South 00 degrees 23 minutes 00 seconds East, a
distance of 100.47 feet to a point; thence along line of Lot No. 22 on the hereinafter mentioned Plan of Lots,
North 89 degrees 36 minutes 55 seconds West, a distance of 198.99 feet to a concrete monument, the place of
BEGINNING.
Being Lot No. 21 on a Final Plan of Major Subdivision for Donald E. Deckman, prepared by Rodney Lee
Decker and Associates, dated October 21, 1986 and recorded in Subdivision Plan Book 51, Page 140.
UNDER AND SUBJECT, NEVERTHELESS, to all rights of way, easements, restrictions and/or conditions
of record.
Parcel 2:
BEGINNING at a concrete monument set on the Easternmost dedicated right-of--way line of Heisey Road (T-
560), at the common point of adjoiner of Lots No. 20-A and No. 20-B on the hereinafter mentioned plan;
thence departing from said right-of--way and extending along Lot No. 20-A, North eighty-nine (89) degrees
thirty-six (36) minutes fifty-five (55) seconds East, for a distance of one hundred ninety-nine and nineteen
hundredths (199.19) feet to a steel pin at other lands now or formerly of Donald E. Deckman and Marian R.
Deckman, husband and wife; thence extending along said land, South zero (00) degrees twenty-three (23)
minutes five (OS) seconds East for a distance of fifty and twenty hundredths (50.20) feet to a steel pin at Lot
No. 21; thence extending along Lot No. 21, South eighty-nine (89) degrees thirty-six (36) minutes fifty-five
(55) seconds West, for a distance of one hundred nineteen and thirteen hundredths (119.13) feet to a steel pin
set on the Easternmost dedicated right-of--way line of Heisey Road; thence extending in and along said right-
of-way line, North zero (00) degrees twenty-seven (27) minutes forty (40) second West, for a distance of fifty
and twenty hundredths (50.20) feet to a concrete monument at Lot No 20-A, said monument marking the
place of BEGINNING.
BEING designated as Lot No. 20-B on an Amendment of a final plan of major subdivision prepared for
Donald E. Deckman by Rodney Lee Decker and Associates, which Amendment is dated January 14, 2004,
and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan
Book 89, Page 22.
TOGETHER with all and singular the buildings, improvements, ways, streets, alleys, driveways, passages,
waters, watercourses, rights, liberties, privileges, hereditaments and appurtenances, whatsoever unto the
hereby granted premises belonging, or in any wise appertaining, and the reversions and remainders, rents,
issues, and profits thereof; and all the estate, right, title, interest, property, claim and demand whatsoever of
Grantor(s), as well at law as in equity, of, in, and to the same.
TITLE TO SAID PREMISES VESTED IN Anthony M. Sciortino and Heather A. Sciortino, h/w,
by Deed from Anthony M. Sciortino, aka, Tony M. Sciortino and Heather A. Sciortino, h/w,
dated 01/06/2006, recorded 01/20/2006 in Book 272, Page 4225.
PREMISES BEING: 485 HEISEY ROAD, MECHA1vICSBURG, PA 17055-9773
PARCEL N0.22-11-0280-095
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. 11-8218-CIVIL
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE HOME LOANS SERVICING, L.P.
vs.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
owner(s) of property situate in the TOWNSHIP OF MONROE, Cumberland County,
Pennsylvania, being
(Municipality)
485 HEISEY ROAD, MECHANICSBURG, PA 17055-9773
Parcel No. 22-11-0280-095
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMENT AMOUNT: $288,680.59
Phelan Hallinan & Schmieg, LLP
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
215-563-7000
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 11-8218 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BANK OF AMERICA, N.A. SUCCESSOR BY
MERGER TO BAC HOME LOANS SERVICING, L.P. F/K/A COUNTRYWIDE HOME LOANS
SERVICING, L.P. Plaintiff (s)
From ANTHONY M. SCIORTINO AND HEATHER A. SCIORTINO
(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: $288,680.59 L.L.: $.50
Interest FROM 5/31/2012 TO DATE OF SALE ($43.82 PER DIEM) - $12,269.60
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $314.50 Other Costs:
Plaintiff Paid:
Date: 11/1.3/12 ~/~~ ~_ J,v~ D
~1®FLrM~. W ~~QsL
David D. Buell, Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: JOHN MICHAEL KOLESNIK, ESQUIRE
Address: PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK BLVD, SUITE 1400
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 308877
AFFIDAVIT OF SERVICE (FHLMC)
PLAINTIFF CUMBERLAND COUNTY
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC
HOME LOANS SERVICING, L.P. F/K/A COUNTRYWIDE HOME PHS # 274682
LOANS SERVICING, L.P.
DEFENDANT SERVICE TEAM/ lxh
ANTHONY M. SCIORTINO COURT NO.: 11-8218-CIVIL
HEATHER A. SCIORTINO
~orvrs
SERVE HEATHER A. S~9~R~~A18 AT: TYPE OF ACTION
223 SOUTH ENOLA DRIVE # A XX Notice of Sheriff s Sale
ENOI,A, PA 17025 SALE DATE: March 6, 2013
**DIVORCED- One cannot accept service for the other**
SERVED
C fV~ i.~
Served and made known to HEATHER A. S IORTINO, Defendant on the r day of z
, 20 ~ . at
o'clock ~'. M., at ~-~- 5 C'~~~ ~ , in the manner described below:
Defendant personally served.
Adult family member with whom Defendant(s) reside(s).
Relationship is ~UWt rs °~
~
_ Adult in charge of Defendant's residence who refused to give name or relationship.
~
_
_ Manager/Clerk of place of lodging in which Defendant(s) reside(s). ,~=~ "'' -
°
Agent or person in charge of Defendant's office or usual place of business. °
~'~t ~ %""~_ .
.
:
~
`
~'
_ an officer of said Defendant's company. .
~ ~.~
~
' -
~
e;',,. t ..-:t __~
Other:
Description: Age 7~ $S Height ~~. Weight ! Race Sex ~ Other `1 ~ xa -~- '
~
-
( U (,~
I,~t l ZuE~~~t L l~~r'`~ , a competent adult, hereby verify that I personally handed a true and ~ ~ ~a
r i
ct c of
~'
~.;
,
Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date an~'at t "add>s
indicated above. I understand that this statement is made subject to the penalties of I8 Pa. C.S. S ec. ~04 ~ting~o
unsworn falsification to authorities.
f ? ~ ~ ~` ~ '~
DATE:
NAME:
PRINTED NAME: ~ 1 ~2~t~ b t~'~"~( ~,G' >f ~ ~ ~
TITLE: ('~C1C~SS S~ {~ (l~ ~(`
NCIT.CFRVFII
On the day of 20 , at o'clock . M., I, , a competent adult hereby
state that~e~endyant I~F~IIfsTb-because:
_ Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant)
No Answer on _ at at
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Y
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallinan, Esq.. Id. No. 62695
Daniel G. Schmieg, Esy., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esy., Id. No. 58745
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Jay B. Jones, Esq.. Id. No. 86657
Andrew L. Spivack, Esq., Id. No. 84439
Chiisovalante P. Fliakos, Esq., Id. No. 94620
Courtenay R. Dunn, Esy., Id. No. 206779
Allison F. Wells, Esq., [d. No. 309519
Melissa J. Cantwell, Esq., [d. No. 308912
Mario J. Hanyon, Esq., Id. No. 203993
Andrew J. Marley, Esy.. Id. No. 3123 ]4
PLAINTIFF
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC
HOME LOANS SERVICING, L.P. F/K/A COUNTRYWIDE HOME
LOANS SERVICING, L.P.
DEFENDANT
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
SERVE HEATHER A. SCIORTINO AT:
223 SOUTH ENOLA DRIVE # A
ENOLA, PA 17025
**DIVORCED- One cannot accept service for the other**
SERVED
Served and made known to FATHER A. 'CIOR INO, Defendant on the ~ 5 day of ~~ ~
rg - l 0 ,o'clock. M., at 22~ O A r ~ ~ , in the manner described below:
_ Defendant personally served.
Adult family member with whom I~,efetn~ant(s) reside(s).
Relationship is l~()V~t ~ U
Adult in charge of Defendant's residence who refused to give name or relationship.
_ Manager/Clerk of place of lodging in which Defendant(s) reside(s).
- Agent or person in charge of Defendant's office or usual place of business.
_ an officer of said Defendant's company.
Other:
~~"~ rv
~r ~
sv
,:~
ty.7 ~
U :~ „~~ i
-~,'.~„ W
20 t ~ at ~~
-~ Ga
i
Descripti(~o~n~:,~ Age L S Height 5 _ Weight ~ 6U Race ~ Sex Other
I,~~ ~~~ ~U~ff~ f , a competent adult, hereby verify that I personally handed a true and correct copy of the
Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address
indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
DATE: _~ ~ (S ~ ~~ NAME: G , ~ _.
PRINTED NAME: ~~1,~ `"' 1~~ r~ i j}
TITLE: ~( (3l C. S~ ~'~.Y'1 /'P i~
NOT SERVED
On the dayy of 20 , at o'clock . M., I, , a competent adult hereby
state that~e~endant ~iecause:
Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant)
No Answer on _ at at _
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
l~
ATTORNEY FOR PLAINTIFF
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Michele M. Bradford, Esq., Id. No. 69849
Judith T. Romano, Esq., Id. No. 58745
Jenine R. Davey, Esq., Id. No. 87077
Lauren R. Tabas, Esq., Id. No. 93337
Jay B. Jones, Esq., Id. No. 86657
Andrew L,. Spivack, Esq., Id. No. 84439
Chrisovalante P. Fliakos, Esq., Id. No. 94620
Courtenay R_ Dunn, Esq., Id. No. 206779
Allison F. Wells, Esq., Id. No. 309519
Melissa J. Cantwell, Esq., Id. No. 308912
Mario J. Hanyon, Esq.. Id. No. 203993
Andrew J. Marley. Esq., Id. No. 312314
AFFIDAVIT OF SERVICE (FHLMC)
CUMBERLAND COUNTY
PHS # 274682
SERVICE TEAM/ lxh
COURT NO.: ll-8218-CIVIL
TYPE OF ACTION
XX Notice of Sheriff s Sale
SALE DATE: March 6, 2013
,.,~
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PHELAN HALLINAN, LLP Attorney for Plaintiff
John Michael Kolesnik, Esq., Id_ No.308877
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONSTAR MORTGAGE, LLC
Plaintiff,
V.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Defendant(s)
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
No.: 11-8218-CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of
the persons or parties named, at that address, set forth on the Affidavit and as amended if
applicable. A copy of the Certificate of Mailing (Form 381 and/or Certified Mail Return
it "A".
Receipt stamped by the U.S. Postal Service is attached er tet*M
i
J n Michael Kolesnik, Esq., Id. No.308877
Attorney for Plaintiff
Date: 40
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PHS # 274682
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0001 38 1 1 91 SEC 10 2012
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff.
Civil Division
V.
CUMBERLAND County
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO No.: 1.1-8218-CIVIL
Defendants
RULE
AND NOW, this day of 2013, a Rule is entered upon the Defendants
to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess
Damages.
Defendants shall have twenty (20) days from the date of this Order to file a response to
Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY THE COURT
J.
CZ CS
Can� -5� �r=
f`- C l (S i
_Cl
I>z �-
-K-
274682
Zachary Jones,Esq.,Id.No.310721
Phelan Hallinan,LLP
1617 JFK Boulevard, Suite 1400
Philadelphia,PA 19103
TEL: (215)563-7000
FAX: (215) 563-3459
�THONY M. SCIORTINO �HEATHER A. SCIORTINO
HEATHER A. SCIORTINO 223 SOUTH ENOLA DRIVE#A
485 HEISEY ROAD ENOLA, PA 17025
MECHANICSBURG,PA 17055-9773
co f I*c-s M-A LL
274682
274682
t ,
OF T�E �R�-OFFICE��
Phelan Hallinan, LLP T Aa
Allison F. Zuckerman, Esq., Id.No.309A)?APR 23 � ATYORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400 An 10: 3
One Penn Center Plaza CUMBERLAND y Philadelphia,PA 19103 PENA YiVAN1A
alison.zuckerman@phelanhallinar:com
215-563-7000
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff
Civil Division
vs.
: CUMBERLAND County
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO No.: 11-8218-CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's April 15, 2013 Rule directing
the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be
granted was served upon the following individuals on the date indicated below.
PRO SE HEATHER A. SCIORTINO
223 SOUTH ENOLA DRIVE#A
ANTHONY M. SCIORTINO ENOLA,PA 17025
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG,PA 17055-9773
Phelan Hallin P
r
DATE: By:
A 's n ucke an,Esq.,Id.No.309519
Attorne or aintiff
274682
FiL.E.0-OFFICE
OF THE PROTHONOTARY
Phelan Hallinan, LLP 2013 MAY 13 AM 10. 12
John D. Krohn, Esq., Id. No.312244 TTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400 CUMiBERLANO COUN�
One Penn Center Plaza PENNSYLVANIA
Philadelphia, PA 19103
john.krohn@phelanhallinan,com
215-563-7000
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND County
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO No.: 11-8218-CIVIL
Defendants
MOTION TO MAKE RULE ABSOLUTE
NATIONSTAR MORTGAGE, LLC,by and through its attorney, hereby petitions this
Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in
support thereof avers as follows:
1. A Motion to Reassess Damages was filed with the Court on April 5, 2013.
2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy
of its proposed Motion to Reassess Damages and Order to the Defendants on March 26, 2013
and requested the Defendants' Concurrence. Plaintiff did not receive any response from the
Defendants. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and
certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A.
3. A Rule was issued by the Honorable Christylee L. Peck on or about April 15,
2013 directing the Defendants to show cause by May 5, 2013 why the Motion to Reassess
Damages should not be granted. A true and correct copy of the Rule is attached hereto, made
part hereof, and marked Exhibit B.
4. The Rule to Show Cause was timely served upon all parties on April 22, 2013 in
accordance with the applicable rules of civil procedure.- A true and correct copy of the
Certificate of Service is attached hereto, made part hereof, and marked Exhibit C.
274682
5• Defendants failed to respond or otherwise plead'by the Rule Returnable date of
May 5, 2013.
WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show
Cause absolute and grant Plaintiff's Motion to Reassess Damages.
Phelan Hallinan, LLP
DATE: Ship Zvi,; By:
John D ohn,Esq., Id. No.312244
Attorney for Plaintiff
274682
Exhibit "A"
274682
PHELAN HALLINAN, LLP.
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia,PA 19103
(215) 563-7000
FAX#: (215) 563-3459
Phelan Hallinan, LLP Representing Lenders in
Pennsylvania and New Jersey
March 26,2013
PRO SE
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG,PA 17055-9773
RE: NATIONSTAR MORTGAGE, LLC v. ANTHONY M. SCIORTINO and HEATHER A.
SCIORTINO
Premises Address: 485 HEISEY ROAD MECHANICSBURG,PA 17055
CUMBERLAND County CCP,No. 11-8218-CIVIL
Dear Defendants,
Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages
and Order. In accordance with Cumberland County Local Rule 208.3(9), 1 am seeking your
concurrence with the requested relief that is,increasing the amount of the judgment.Please
respond to me within 5 days,by 4/1/2013.
Should you have further questions or concerns,please do not hesitate to contact me.
Otherwise,please be guided accordingly.
Very truly, urt
✓,qu ry;: •q.., Id.No.310721
ria ....... r P1' int ff'
.l III -i4 Ire,
274682
Name and Phelan Hallinan,LLP
Address 1617 3FK Boulevard,Suite 1400 Z °
Of Sender One Penn Center Plaza $ � o
Philadelphia,PA 19103 KVM
rLine Article Number Name of Addressee Siree and Post Office Address g
ANTHONY M,SCIO Poste e HEATHER A.SCIORTINO 50.46 m485 HEISEY ROAD
MECHANICS1iURG PA 170SS 9773 mr�HEATHER A.SCIORTINO ;
223 SOUTH ENOLA DRIVE#A 50.46
ENOLA PA 17025
RE:ANTHONY M.SCIORTINO CUMBERLAND PHS#2746$2!1240 page i or I "
50.92 r i
TWA Humeri py T«a NMen of Piece,
Pieties listed ty Sender Remved m Post Office MUM.Per(nameof The fill deehnbm f-fr is
ReedrinjF.mpbyee] for the +lean.ndmncnicar,dintertceionalrery.teredm>,d
reaotWroctiat Mnooneaotvek doammts uMer Fvrets Mu1 dommem reeonslnxepn,
piece so on w a limit of SS00.000 per oemrtrenoe.]lu rnada+um indemnity N7aete on
71n mutmtam indemnity paYabk n 523.000 for registered marl,um with optienat insannoe.< �`'
Form 3877 Facsimile R9005913 and 5921 torhmita wm otca
I
i 1
I
i
274682
Exhibit "B"
274682
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
NATIONSTAR MORTGAGE,LLC
Court of Common Pleas
Plaintiff
Civil Division
V.
CUMBERLAND County
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO No.: 11-8218-CIVIL
Defendants
RULE
AND NOW,this day of lQp&,� 2013, a Rule is entered upon the Defendants
to show cause why an Order should not be entered granting Plaintiffs Motion to Reassess
Damages.
Defendants shall have twenty (20) days from the date of this Order to file a response to
Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.,
BY THE COURT
J"
M
'.JJ
�
JI
274682
Exhibit "C"
274682
FILED-OFFICL
O ,y"
Phelan Hallinan, LLP F THE PROTHONOTAf
Allison F. Zuckerman, Esq., Id. No.309ZQP APR 23 AM I0�
1617 JFK Boulevard, Suite 1400 AM'�ORNEY FOR PLAINTIFF
One Penn Center Plaza CHMBWN S L
LAND GOURTY
Philadelphia,PA 19103 P VAN I�A
allison.zuckerman@phelanhallinan.com
215-563-7000
NATIONSTAR MORTGAGE, LLC
Court of Common.Pleas
Plaintiff
VS. Civil Division
ANTHONY M. SCIORTINO CUMBERLAND County
HEATHER A. SCIORTINO
No.: 11-8218-CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's April 15,2013 Rule directing
the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should notb,.
granted was served upon the following individuals on the date indicated below. " "
PRO SE HEATHER A. SCIORTINO
ANTHONY M. SCIORTINO 223 SOUTH ENOLA DRIVE#A
HEATHER A. SCIORTINO ENOLA,PA 17025
485 HEISEY ROAD
MECHANICSBURG,PA 17055-9773
Phelan Halbjaa�i: Ial'
DATE:`— r By:
tt t.Esq.No.309519
Altnri�e_,. )lri;i;ntiff
274682
f
Phelan Hallinan, LLP
John D. Krohn, Esq., Id. No.312244 ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
john.krohn@phelanhallinan.com
215-563-7000
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff
vs.
Civil Division
ANTHONY M. SCIORTINO CUMBERLAND County
HEATHER A. SCIORTINO No.: 11-8218-CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copies of Plaintiffs Motion to Make Rule Absolute
was served upon the following individuals on the date indicated below.
ANTHONY M. SCIORTINO HEATHER A. SCIORTINO
HEATHER A. SCIORTINO 223 SOUTH ENOLA DRIVE#A
485 HEISEY ROAD ENOLA, PA 17025
MECHANICSBURG, PA 17055-9773
Phelan Hallinan, LLP
DATE: D _ By:
John D. Kpghh, Esq.,Id.No.312244
Attorney for Plaintiff
274682
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
NATIONSTAR MORTGAGE, LLC Court of Common Pleas
Plaintiff
Civil Division
VS.
CUMBERLAND County
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO No.: 11-8218-CIVIL
Defendants
ORDER
AND NOW,this I�Vt day of W9, , 2013, upon consideration of Plaintiffs
Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered
upon Defendants shall be and is hereby made absolute and Plaintiff s Motion to Reassess
Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED
to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows:
Principal Balance $255,563.72
Interest Through June 4, 2013 $39,506.63
Legal fees $2,300.00
Cost of Suit and Title $1,181.77
Property Inspections $117.00
Escrow Deficit $9,288.83
TOTAL $307,957.95
Plus interest at six percent per annum.
Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above
figure.
• `.. Cp t f..f �.t
BY THE COURT:
Q . GO Rrtl�u V J.
wa_ >- =M
CD r., �� ! 274682
1
^s
U- r1C
i� TF,rE PR0TH0N0 TPA RY
PHELAN HALLINAN, LLP
Attorney for Plaintiff 2013 JUN `5 All 10*
1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY
One Penn Center Plaza PENNSYLVANIA
Philadelphia, PA 19103
215-563-7000
NATIONSTAR MORTGAGE, LLC
CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
VS. CIVIL DIVISION
ANTHONY M. SCIORTINO NO. 11-8218-CIVIL
HEATHER A. SCIORTINO
Defendants
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P.R.C.P.,404(2)/403
I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above
captioned matter was sent by certified mail,return receipt requested,to ANTHONY M.
SCIORTINO on MARCH 25,2013 in accordance with the Order of Court dated MARCH 13,2013.
The property was posted on APRIL 1,2013.Publication was advertised in THE SENTINEL on
MARCH 27, 2013 &in THE CUMBERLAND LAW JOURNAL on APRIL 5, 2013.
The undersigned understands that this statement is made subject to the penalties of 18
Pa.C.S. §4904 relating to the unswom falsification to authorities.
Phelan Hallinan, LLP
DATE: By:
Jonatl2o Lobb, Esq., Id. No.312174
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
NATIONSTAB MORTGAGE,.LLC
• CIVIL DIVISION'
Plaintiff r.-
NO. I I-8118-CIVIL
V.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Defendants
ORDER
AND NOW,this / 6G day of )22d4LA-- ,2013,after
consideration of Plaintiff s Motion for Service of Notice of Sale Pursuant to Special Order of
Court,it is hereby:
ORDERED that pursuant to Pa.R.C.P.410(a),service of the Notice of Sale is
permitted on Defendant ANTHONY M. SCIORTINO by
x
REGULAR MAIL TO ANTHONY M. SCIORTINO at 485
HEISEY ROAD,MECHANICSBURG,PA 17055-9773 Service
by mail is complete upon the date of mailing
CERTIFIED MAIL TO ANTHONY M. SCIORTINO at 485
POSTING 485 HEISEY ROAD,MECHANICSBURG,PA
HEISEY ROAD,MECHANICSBURG,PA 17055-9773
Service by mail is complete upon the date of mailing
17055-9773
PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH
PA.R.C.P.3129.2(D).
BY THE COURT:
tg
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c�►
�
PHS#274682 ° s An=' .
✓CC PHELAN HALLINAN,LLP 'ti
Vic-
1617 °
1617 JFK Boulevard,Suite 1400 o
Philadelphia,PA 19103 L < -Q
CO Anajed 311 y 13 _ Z 5
ANTHONY M. SCIORTINO,and HEATHER A. SCIORTINO g uo cD*n
485 HEISEY ROAD,MECHANICSBURG,PA 17055-9773
� N �
Name and PHELAN HALLINAN&SCHMIEG
Address One Penn Center at Suburban,Suite 1400
of Sender Philadelphia,PA 19103
Line Article Name of Addressee,Street,and Post Office Address Post
Number
ANTHONY M.SCIORTINO Co w ;
85 HEISEY ROAD N
ECHANICSBURG,PA 17055-9773 V.: N
2 #### O
^ � Oa
3 #***
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6 ####
7
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9 #### b
10' ****
12 %ANTHONY M.SCIORTINO
PHS#274862
Total Number of Total Number of Pieces Postmaster,Per(Name of Receiving
Pieces Listed by Sender Received at Post Office Employee)
LXH- *NOTICE OF SALE: CERTIFICATE OF MAILING*
CODE: 1020
7178 2417 6099 0130 0210
LXH/274682 1020
ANTHONY M. SCIORTINO
485 HEISEY ROAD
MECHANICSBURG, PA 17055-9773
--fold here(regular)
--fold here(60)
--fold here(regular)
,Lily Hiine
From: US—Postal—Service@usps.com
Sent: Monday, May 13, 2013 3:01 PM
To: Lily Hainey
Subject: U.S. Postal Service Track&Confirm email Restoration -71782417609901300210
This is a post-only message. Please do not respond.
LILY HAINEY has requested that you receive this restoration information for Track& Confirm as listed below.
Current Track&Confirm e-mail information provided by the U.S. Postal Service.
Label Number: 71782417609901300210
Service Type: Certified Mail"
Shipment Activity Location Date&Time
-------------------------------------------------------------------------------------------------------------------
Processed through USPS Sort Facility PHILADELPHIA PA 19176 April 20, 2013 7:19 pm
Depart USPS Sort Facility LANCASTER PA 17604 April 20, 2013
Processed through USPS Sort Facility LANCASTER PA 17604 April 19, 2013 1:50 pm
Depart USPS Sort Facility LANCASTER PA 17604 April 18, 2013
Processed through USPS Sort Facility LANCASTER PA 17604 April 18, 2013 10:05 am
Depart USPS Sort Facility LANCASTER PA 17604 April 18, 2013
Unclaimed MECHANICSBURG PA 17055 April 16, 2013 8:41 am
Depart USPS Sort Facility HARRISBURG PA 17107 April 2, 2013
Processed through USPS Sort Facility HARRISBURG PA 17107 April 1, 2013 11:52 pm
Depart USPS Sort Facility HARRISBURG PA 17107 April 1, 2013
Available for Pickup MECHANICSBURG PA 17055 March 27, 2013 11:02 am
Arrival at Unit MECHANICSBURG PA 17055 March 27, 2013 8:14 am
Depart USPS Sort Facility HARRISBURG PA 17107 March 27, 2013
Processed through USPS Sort Facility HARRISBURG PA 17107 March 27, 2013 4:42 am
Depart USPS Sort Facility LANCASTER PA 17604 March 27, 2013
Processed through USPS Sort Facility LANCASTER PA 17604 March 26, 2013 12:47 pm
Depart USPS Sort Facility PHILADELPHIA PA 19176 March 25, 2013
Processed at USPS Origin Sort Facility PHILADELPHIA PA 19176 March 25, 2013 10:21 pm
Accepted at USPS Origin Sort Facility PHILADELPHIA PA 19103 March 25, 2013 9:06 pm
Electronic Shipping Info Received March 25, 2013
USPS has not verified the validity of any email addresses submitted via its online Track&Confirm tool.
For more information, or if you have additional questions on Track&Confirm services and features, please visit the
Frequently Asked Questions (FAQs) section of our Track & Confirm tool at
http://www.usps.com/shipping/trackandconfirmfaqs.htm.
y AFFIDAVIT OF SERVICE(FHLMC)
PLAINTIFF CUMBERLAND COUNTY
' NATIONSTAR MORTGAGE,LLC •,
PHS#274682
DEFENDANT SERVICE TEAM/sal
ANTHONY M.SCIORTINO COURT NO.: 11-8218-CIVIL
HEATHER A.SCIORTINO
SERVE ANTHONY M.SCIORTINO AT: TYPE OF ACTION
485 HEISEY ROAD XX Notice of Sheriff's Sale
MECHANICSBURG,PA 17055-9773 SALE DATE:06/05/2013
****PLEASE POST THE PROPERTY***
**PLEASE POST PROPERTY IN ACCORDANCE WITH THE
COURT ORDER**
SERVED
Served and made known to ANTHONY M. SCIORTINO,Defendant on the__�day of 6 J� 20 at
o'clockp_.M.,at 485 HEISEY ROAD,MECHANICSBURG,PA 1.7055-9773,in the manner d sd cribed below:
Defendant personally served.
Adult family member with whom Defendant(s)reside(s).
Relationship is
Adult in charge of Defendant's residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s)reside(s).
Agent or person in charge of Defendant's office or usual place of business.
an officer of said Defendant's company.
XX Other: POSTED THE PROPERTY
Description: Age Height Weight Race Sex Other
I, \ '.S a competent adult,hereby verify that I personally posted the property with a true and correct
copy of the otice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the
address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
DATE: 3 NAME: qA n
PRINTED NA E: eV QVV 0 wk
TITLE: 6�C.eSI `�e �v
NOT SERVED
On the day of 20 ,at o'clock_.M.,I, a competent adult hereby
state that b Pendant T F UND because:
Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant)
No Answer on at at
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Lawrence T.Phelan,Esq.,Id.No.32227
Francis S.Hallinan,Esq.,Id.No.62695
Daniel G.Schmieg,Esq.,Id.No.62205
Michele M.Bradford,Esq.,Id.No.69849
Judith T.Romano,Esq.,Id.No.58745
Jenine R.Davey,Esq.,Id.No.87077
Lauren R.Tabas,Esq.,Id.No.93337
Jay B.Jones,Esq.,Id.No.86657
Andrew L.Spivack,Esq.,Id.No.84439
Chrisovalante P.Fliakos,Esq.,Id.No.94620
Courtenay R.Dunn,Esq.,Id.No.206779
Allison F.Zuckerman,Esq.,Id.No.309519
Melissa J.Cantwell,Esq.,Id.No.308912
Mario J.Hanyon,Esq.,Td.No.203993
A,a
PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberland
Jackie Cox,Sales Director, of The Sentinel, of the County and State aforesaid,being duly
sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the
Borough of Carlisle,County and State aforesaid,was established December 13th,1881,
since which date THE SENTINEL has been regularly issued in said County, and that the
printed notice or publication attached hereto is exactly the same as was printed and
published in the regular editions and issues of
THE SENTINEL on the following day(s):
March 27,2013
COPY OF NOTICE OF PUBLICATION
j
NOTICE OF SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS Affiant further deposes that he/she is not
OF CUMBERLAND COUNTY,PENNSYLVANIA
NO.11-8218-CIVIL interested in the subject matter of the
NATIONSTAR MORTGAGE,LLC aforesaid notice or advertisement, and that
VS.
ANTHONY M.SCIORTINO and HEATHER A.SCIORTINO i all allegations in the foregoing statement as NY NOTICE NOTICE TOF ANTHOOF S SALE SCIORTINO
REAL PROPERTY t to time,place and character of publication
ar ue.
Being Premises:485 HEISEY ROAD,MECHANICSBURG,PA 17055-9773 q
Being in MONROE TOWNSHIP,County of CUMBERLAND,Commonwealth
of Pennsylvania,22-11-0280-095
improvements consist of residential property.
Sold as the property of ANTHONY M.SCIORTINO and HEATHER A.
SCIORTINO
Your house(real estate)at 485 HEISEY ROAD,MECHANICSBURG,PA
17055-9773 is scheduled to be sold at the Sheriffs Sale on 06/05/2013 at
10:00 AM,at the CUMBERLAND County Courthouse,1 Courthouse
Square,Carlisle,PA 17013,to enforce the Court Judgment of$266,598.78
obtained by,NATION STAR MORTGAGE,LLC(the mortgagee),against the Sworn to d subscribed before me this
above premises. ,
PHELAN HALLINAN,LLP
Attorney for Plaintiff [,�J
Notary Public
My commission-expires:
NOTARIAL SEAL
BAMBI ANN HECKENDORN
Notary Public
CARLISLE BOROUGH, CUMBERLAND CNTY
My Commission Expires Jan 27, 2014
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 5, 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 Coyn , Editor
SWORN TO AND SUBSCRIBED before me this
5 day of April, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 26,2014
y r
C y.
CUMBERLAND LAW JOURNAL
NOTICE OF SHERIFF'S SALE
In the Court of Common Pleas of
Cumberland County,Pennsylvania
NO. 11-8218-CIVIL
NATIONSTAR MORTGAGE,LLC
vs.
ANTHONY M.SCIORTINO and
HEATHER A. SCIORTINO
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
NOTICE TO: ANTHONY M. SCIOR-
TINO
Being Premises: 485 HEISEY
ROAD, MECHANICSBURG, PA
17055-9773.
Being in MONROE TOWNSHIP,
County of CUMBERLAND, Com-
monwealth of Pennsylvania, 22-11-
0280-095.
Improvements consist of residen-
tial property.
Sold as the property of ANTHONY
M. SCIORTINO and HEATHER A.
SCIORTINO.
Your house (real estate) at 485
HEISEY ROAD, MECHANICSBURG,
PA 17055-9773 is scheduled to be
sold at the Sheriff's Sale on June
5, 2013 at 10:00 A.M., at the CUM-
BERLAND County Courthouse, 1
Courthouse Square, Carlisle, PA
17013, to enforce the Court Judg-
ment of $266,598.78 obtained by,
NATIONSTAR MORTGAGE, LLC
(the mortgagee), against the above
premises.
PHELAN HALLINAN, LLP
Attorneys for Plaintiff
Apr. 5
10
SHERIFF'S OFFICE OF CUMBERLAND €COUNTY
Ronny R Anderson ry ! P�
,� f I P R 0 E N0 l_
ri iy
Sheriff p i�'O i
Jody S Smith 1013 AUG 27 AM : �57
Chief Deputy
Richard W Stewart - CUMBERLAND COUNTY
Solicitor OFFICE of"rHE SHERIFF PENNSYLVANIA
Nationstar Mortgage LLC
vs. Case Number
Heather A. Sciortino (et al.)
2011-8218
SHERIFF'S RETURN OF SERVICE
01/02/2013 05:35 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 485 Heisey Road, Mechanicsburg, PA 17055,
Cumberland County.
01/10/2013 05:18 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 HILDA WAY(MOTHER),
who accepted as"Adult Person in Charge"for Heather A. Sciortino at 223 S. Enola Drive#A, East
Pennsboro Township, Enola, PA 17025, Cumberland County.
01/23/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: Anthony Michael Sciortino, but was unable to locate the
Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the
above titled action, as"Not Found" at 485 Heisey Road, Mechanicsburg, PA 17055, defenant is not
known at address per post office, neighbor has not seen
defendant at address for months.
02/21/2013 As directed by Francis S. Hallinan, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/5/2013
02/21/2013 Affidavit of Service to Lienholders Filed in Sheriffs Office
06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He
sold the same for the sum of$1.00 to Attorney Francis Hallinan, on behalf of Federal Home Loan
Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $1,046.33 SO ANSWERS,
August 19, 2013 RbNW R ANDERSON, SHERIFF
(c)CountySuite Sheriff:Telecsoft,Inc
£, BAND OF AMERICA,N.A. SUCCESSOR BY MERGER COURT OF COMMON PLEAS
TO BAC TIOME.LOANS SERVICING, L.P. F/K/A
COUNTRYWIDE HOME LOANS SERVICING, L.P. CIVIL DIVISION
Plaintiff
NO.: 11-8218-CIVIL
V.
ANTHONY M. SCIORTINO CUMBERLAND COUNTY
HEATHER A. SCIORTINO
Defendant(s) PHS #274682
AFFIDAVIT PURSUANT TO RULE 3129.1
BANK OF AMERICA,N.A.SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,L.P.F/K/A
COUNTRYWIDE HOME LOANS SERVICING,L.P.,Plaintiff in the above action,by the undersigned attorney,sets forth as of the
date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 485 HEISEY
ROAD,MECHANICSBURG,PA 17055-9773.
1. Name and address of Owner(s)or reputed Owner(s):
Name Address(if address cannot be reasonably
ascertained,please so indicate)
ANTHONY M.SCIORTINO 485 HEISEY ROAD
MECHANICSBURG,PA 17055-9773
HEATHER A.SCIORTINO 223 SOUTH ENOLA DRIVE#A
ENOLA,PA 17025
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
SAME AS ABOVE
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the
sale.
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
7: Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may
be dffected by the sale:.
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 485 HEISEY ROAD
MECHANICSBURG,PA 17055-9773
ANTHONY M. SCIORTINO 300 NORTH 2ND STREET
C/O RICHARD S. FRIEDMAN, ESQUIRE SUITE 402
HARRISBURG,PA 17101
ANTHONY M SCIORTINO,PRO SE 485 HEISEY ROAD
MECHANICSBURG,PA 17055-9773
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S. DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 17108-1754
FEDERAL BUILDING
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
Date: Y�'z By: 0---�
Phe a linan & Schmieg,LLP
J 4ichael Kolesnik, Esq., Id.No.308877
torney for Plaintiff
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS
BAC HOME LOANS SERVICING, L.P. F/K/A
COUNTRYWIDE HOME LOANS SERVICING,L.P. CIVIL DIVISION
Plaintiff NO.: 11-8218-CIVIL
VS.
CUMBERLAND COUNTY
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
Defendant(s)
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: ANTHONY M. SCIORTINO HEATHER A. SCIORTINO
485 HEISEY ROAD 223 SOUTH ENOLA DRIVE #A
MECHANICSBURG, PA 17055-9773 ENOLA,PA 17025
*THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house(real estate) at 485 HEISEY ROAD,MECHANICSBURG,PA 17055-9773 is scheduled to
be sold at the Sheriff s Sale on 03/06/2013 at 10:00 AM in the Cumberland County Courthouse, South
Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$288,680.59 obtained by BANK OF
AMERICA,N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,L.P.F/K/A
COUNTRYWIDE HOME LOANS SERVICING, L.P. (the mortgagee) against you. In the event the sale is
continued, an announcement will be made at said sale in complidrice with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff s Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Slieriff s-Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling.215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this
has happened, you may call 215-563-7000.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff
gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. This schedule will state who will be receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the filing of the proposed schedule.
7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW
TO FIND OUT WHERE, YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
(800) 990-9108
LEGAL DESCRIPTION
All that certain parcel of land situate in the East side of Heisey Road, in the Township of Monroe,County of
Cumberland and Commonwealth of Pennsylvania,being known and designated as follows:
Parcel 1:
BE-GINNING at a concrete monument on the eastern dedicated right-of-way line of Heisey Road,T-560,at
line of Lot No. 22 on the hereinafter mentioned Plan of Lots;thence along the Eastern dedicated right-of-way
line of Heisey Road,T-560,North 00 degrees 27 minutes 40 seconds West,a distance of 100.47 feet to a
point;thence along Lot No.20 on the hereinafter mentioned Plan of Lots,North 89 degrees 36 minutes 55
seconds East,a distance of 199.13 feet to a point;thence along other lands now or formerly of Donald E.
Deckman and Marian R. Deckman,husband and wife, South 00 degrees 23 minutes 00 seconds East,a
distance of 100.47 feet to a point;thence along line of Lot No. 22 on the hereinafter mentioned Plan of Lots,
North 89 degrees 36 minutes 55 seconds West,a distance of 19899 feet to a concrete monument,the place of
BEGINNING.
Being Lot No. 21 on a Final Plan of Major Subdivision for Donald E.Deckman,prepared by Rodney Lee
Decker and Associates,dated October 21, 1986 and recorded in Subdivision Plan Book 51,Page 140.
UNDER AND SUBJECT,NEVERTHELESS,to all rights of way,easements,restrictions and/or conditions
of record.
Parcel 2:
BEGINNING at a concrete monument set on the Easternmost dedicated right-of-way line of Heisey Road(T-
560), at the common point of adjoiner of Lots No. 20-A and No. 20-B on the hereinafter mentioned plan;
thence departing from said right-of-way and extending along Lot No.20-A,North eighty-nine(89)degrees
thirty-six(36)minutes fifty-five(55)seconds East,for a distance of one hundred ninety-nine and nineteen
hundredths(199.19)feet to a steel pin at other lands now or formerly of Donald E. Deckman and Marian R.
Decki-nan, husband and wife;thence extending along said land, South zero(00)degrees twenty-three(23)
minutes five(05)seconds East for a distance of fifty and twenty hundredths(50.20)feet to a steel pin at Lot
No. 21;thence extending along Lot No. 21, South eighty-nine(89)degrees thirty-six(36)minutes fifty-five
(55)seconds West,for a distance of one hundred nineteen and thirteen hundredths(119.13)feet to a steel pin
set on the Easternmost dedicated right-of-way line of Heisey Road;thence extending in and along said right-
of-way line,North zero(00)degrees twenty-seven(27)minutes forty(40)second West,for a distance of fifty
and twenty hundredths(50.20)feet to a concrete monument at Lot No 20-A,said monument marking the
place of BEGINNING.
BEING designated as Lot No. 20-B on an Amendment of a final plan of major subdivision prepared for
Donald E.Deckinan by Rodney Lee Decker and Associates,which Amendment is dated January 14,2004,
and recorded in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Plan
Book 89,Page 22.
TOGETHER with all and singular the buildings,improvements,ways,streets,alleys,driveways,passages,
waters,watercourses,rights,liberties,privileges,bereditaments and appurtenances,whatsoever unto the
hereby granted premises belonging,or in any wise appertaining, and the reversions and remainders,rents,
issues,and profits thereof, and all the estate,right,title,interest, property,claim and demand whatsoever of
Grantor(s), as well at law as in equity,of, in, and to the same.
w
TITLE TO SAID PREMISES VESTED IN Anthony M. Sciortino and Heather A. Sciortino, h/w,
by Deed from Anthony M. Sciortino, aka, Tony M. Sciortino and Heather A. Sciortino, h/w,
dated 01/06/2006, recorded 01/20/2006 in Book 272, Page 4225.
PREMISES BEING: 485 HEISEY ROAD,MECHANICSBURG,PA 17055-9773
PARCEL NO.22-11-0280-095
SHORT DESCRIPTION
By virtue of a Writ of Execution NO. 11-8218-CIVIL
BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, L.P. F/K/A COUNTRYWIDE HOME LOANS SERVICING, L.P.
vs.
ANTHONY M. SCIORTINO
HEATHER A. SCIORTINO
owner(s) of property situate in the TOWNSHIP OF MONROE, Cumberland County,
Pennsylvania, being
(Municipality)
485 HEISEY ROAD, MECHANICSBURG, PA 17055-9773
Parcel No. 22-11-0280-095
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
JUDGMENT AMOUNT: $288,680.59
Phelan Hallinan & Schmieg,LLP
Attorney for Plaintiff
161.7 JFK Boulevard, Suite 1400
Philadelphia,PA 19103
215-563-7000
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 11-8218 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due BANK OF AMERICA,N.A.SUCCESSOR BY
MERGER TO BAC HOME LOANS SERVICING,L.P.F/K/A COUNTRYWIDE HOME LOANS
SERVICING,L.P.Plaintiff(s)
From ANTHONY M.SCIORTINO AND HEATHER A. SCIORTINO
(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: $288,680.59 L.L.: $.50
Interest FROM 5/31/2012 TO DATE OF SALE($43.82 PER DIEM)-$12,269.60
Atty's Comm: % Due Prothy:$2.25
Atty Paid: $31r 14,.51'. Other Costs:
Plaintiff Paid:
Date: 11/13112 —+�� � �• ,d.Q
D
David D. B fl,Prothonotare
'a U*
(Seal)
Deputy
REQUESTING PARTY:
Name: JOHN MICHAEL KOLESNIK,ESQUIRE
Address: PHELAN HALLINAN&SCHMIEG,LLP
1617 JFK BLVD,SUITE 1400
PHILADELPHIA,PA 19103
Attorney for:PLAINTIFF
Telephone:215-563-7000
Supreme Court ID No.308877
TRUE COPY FROM RECORD
In Testimony whereof,I here unto set my hand
and the seal of said Court at Carlisle,Pa./)
T his_ 14 day of 20 / V
Prothonotary
On November 19, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Monroe Township , Cumberland County, PA,
Known and numbered as, 485 Heisey Road,
Mechanicsburg, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date; November 19, 2012
By:
Real Estate Coordinator
G- :11 V S i 1,0W ?IQZ
The Patriot-News Co.
2020 Technology Pkwy e a r10 "'' ews
Suite 300
Mechanicsburg, PA 17060 Now you know
Inquiries - 717-256-8213
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
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology 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 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.
2011-8218 ChdI
Bank of America,NJ This ad ran on the date's)shown below:
Vs 01/22/13
Anthony Michael Sclo 0
Heather A.sclortino 01/29/13
Atty; Francis S.Hallinan 02/05113
By virtue of a Writ of Execution NO.
11-8218-CIVIL
BANK OF AMERICA, N.A. . . . . . .
. . . . . . . . . .
SUCCESSOR BY MERGER TO BAC
HOME LOANS SERVICING,L.P.F/K/A
COUNTRYWIDE HOME LOANS Sworn to and subscribed before his 14 day of February, 2013 A.D.
SERVICING,L.P
VS. r
ANTHONY M.SCIOMINO
HEATHER A.SCIORnNO
owner(s) of property situate in the lic
TOWNSHIP OF MONROE,Cumberland
County,Pennsylvania,being
(Municipality) (7r
485 HEISEY ROAD,
MECHANICSBURG,PA 17055-9773 COMMONWEALTH OF PENNSYLVANIA
Parcel No.22-11-MO-095 11 Notarial Seal Public
(Acreage or street address) Holly Lynn Warfel,Notary
Improvements thereon: RESIDENTIAL Washington Twp.,Dauphin county
DWELLING commission Expires Dec.12,2016
al CIAJION Of N
JUDGMENT AMOUNT$288,680-59 MEMBER,PENNSYLVANIA AsSocIATTION 01F
V.."t Patriot Xtws
Now you know
2020 Technology Parkway STE 300
Mechanicsburg,PA 17060-9498
(717)255-8237
BILL TO: Cumberland County Sheriffs Office
Cumberland County Court House
Carlisle, PA 17013
ACCT.# 2260
DUPLICATE BILL
Date Description gale# Size Rate Net Cos
Of Ad
01/22/13 Sheriff Sale 8218 511 $20.00 $ 102.20
01/29/13 Sheriff Sale 8218 5.11 $20.00 $ 102.20
02105/13 Sheriff Sale 8218 5.11 $20.00 $ 102.20
Notary Fee $5.00
TOTAL DUE FOR THIS SALE: . $ 311.60
Kc
CUMBERLAND LAW JOURNAL
Writ No. 2011-8218 Civil
Bank of America,NA
VS.
Anthony Michael Sciortino,
Heather A. Sciortino
Atty.: Francis S. Hallman
By virtue of a Writ of Execution
NO. 11-82I8-CIVIL,BANK OFAMER-
ICA,N.A.SUCCESSOR BY MERGER
TO BAC HOME LOANS SERVICING,
L.P. F/K/A COUNTRYWIDE HOME
LOANS SERVICING, L.P vs. AN-
THONY M.SCIORTINO,HEATHER A.
SCIORTINO owner(s)of property situ-
ate in the TOWNSHIP OF MONROE,
Cumberland County, Pennsylvania,
being 485 HEISEY ROAD,MECHAN-
ICSBURG,PA 17055-9773.
Parcel No.22-]]-0280-095.
Improvements thereon:RESIDEN-
TIAL DWELLING.
JUDGMENT AMOUNT:$288,680-
.59.
96
f
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
sa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
8 day of Februar 2013
r
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
1,Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which Federal Home Loan Mortgage Corporation is the grantee the same having
been sold to said grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution
issued on the 13th day of November, A.D., 2012, out of the Court of Common Pleas of said County as
of Civil Term, 2011 Number 8218, at the suit of Bank of America,NA S/B/M to BAC Home Loans
Servicing L P F/K/A Cojjnq32y1:de Home Loans Servicing L P against Anthony M. Sciortino and
Heather A. Sciortino,is duly recorded as Instrument Number 201328475.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 1-2 day of
Jj.A7
A.D. ,2
Recorder of Deeds
Cumberland County,Caffiste,PA
"t Comm' the First Monday of Jan.2014
MYCOMM*