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HomeMy WebLinkAbout11-8273 PHELAN HALLINAN & SCHMIEG, LLP Vivek Srivastava, Esq., Id. No.202331 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 275419 BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO. TX 75024 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff NO. it- $a 73 0I mTexpi v. CUMBERLAND COUNTY JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 mm .2m ° =-n Defendants cn? - c CIVIL ACTION - LAW z c a - COMPLAINT IN MORTGAGE FORECLOSURE i m ^' C C:>rl" *4a. oo p A grrY C011614007 & a60 &("83 File #: 275419 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 #: 275419 Plaintiff is BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/29/2007 JEREMY C. KREBS and JENNIFER R. KREBS 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. 200730105. By Assignment of Mortgage recorded 05/03/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201112853. 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 10/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified File #: 275419 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 08/15/2011: Principal Balance $148,174.74 Interest $18,829.45 09/01/2009 through 08/15/2011 Late Charges $528.44 Property Inspections $235.00 Escrow Deficit $2,760.93 TOTAL $170,528.56 7 8 Plaintiff is not seeking a judgment of personal liability (or an in 12ersonam 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. File #: 275419 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $170,528.56, 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. PHELA LLINAN & SCHMIEG, LLP By: Vivek Srivas va, Esquire Attorney for Plaintiff File #: 275419 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen, County of Cumberland, Commonwealth of Pennsylvania, known and numbered as Lot No. 122, on a Plan for 'Bowmans Hill', dated March 29, 1993, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Subdivision Plan Book 65, Page 139, and amended Phase I Final Subdivision Plan of Bowmans Hill, recorded October 8, 1993, in Plan Book 66, Page 145, more fully bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bumble Bee Hollow Road at the southwest corner of Lot No. 121; thence North 77 degrees 31 minutes 17 seconds East, a distance of 130.06 feet to a point, being the southeast corner of Lot no. 121; thence South 19 degrees 06 minutes 02 seconds East, a distance of 80.54 feet to a point at the northeast corner of Lot No. 123; thence South 77 degrees 31 minutes 17 seconds West, a distance of 139.35 feet to a point on the eastern side of Bumble Bee Hollow Road; thence North 12 degrees 28 minutes 43 seconds West, a distance of 80 feet to the point and place of BEGINNING. UNDER AND SUBJECT, NEVERTHELESS, to the same conditions, restrictions, exceptions and reservations as exist by virtue of prior recorded instruments, deeds and conveyances. PROPERTY ADDRESS: 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581 PARCEL # 42-29-2456-019 File #: 275419 VERIFICATION 'jx t l?l?`u2tJm?" hereby states that he/she is (-e of, BANK OF AMERICA, N.A., Plaintiff in this matter, that he/she is 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 his/her 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. Name: ?-'n c:cw DATE: Title: BANK OF AMERICA, N.A. File #: 275419 Name: KREBS File #: 275419 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor awtiXtr of 411+ubrr/444 '{'fF O-70'i? FICCE 2111 NOV 18 Ali 10: 56 CUMBERLAND COUNTY PENNSYLVANIA Bank of America, NA vs. Jeremy C. Krebs (et al.) Case Number 2011-8273 SHERIFF'S RETURN OF SERVICE 11/15/2011 04:52 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on November 15, 2011 at 1652 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer R. Krebs, by making known unto Jeremy Krebs, adult in charge at 2313 Bumble Bee Hollow Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. 2g GERALD WORTHINGTON, DEPUTY 11/15/2011 04:52 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on November 15, 2011 at 1652 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeremy C. Krebs, by making known unto himself personally, at 2313 Bumble Bee Hollow Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same, I L/ja ?-- - JA I&, 0qhj,%V=LX, GE LD W RTHINGT , DEPUTY SHERIFF COST: $64.00 November 16, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) GountySuite Sheriff , T7eleosoft. Irc; TH;: pp0THONOTAn1 PHELAN HALLINAN & SCHMIEh, LLP Attorney for Plaintiff Robert W. Cusick, Esq., Id. No. 8019310 12 3 hN 13 AM 10- 16 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. SB/M TO CUMBERLAND COUNTY BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS COURT OF COMMON PLEAS SERVICING, LP VS. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS : CIVIL DIVISION : No. 11-8273 CIVIL TERM 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 JEREMY C. KREBS A/K/A JEREMY KREBS, and JENNIFER R. KREBS A/K/A JENNIFER KREBS, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint TOTAL $170,528.56 $170,528.56 I hereby certify that (1) the Defendants' last known address is 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date 1 ! VZ/ . Cusick, Esquire a?}.r ??, So pd 4?7 Attorney for Plaintiff N ysyi? DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ' I I ?I Ia PHS # 275419 PROTHONOTARY 275419 PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION VS. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS : No. 11-8273 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant JEREMY C. KREBS A/K/A JEREMY KREBS is over 18 years of age and resides at 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581. (c) that defendant JENNIFER R. KREBS A/K/A JENNIFER KREBS is over 18 years of age and resides at 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date k Robert W. Cusick, Esquire Attorney for Plaintiff 275419 (Rule of Civil Procedure No. 236) - Revised BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS CIVIL DIVISION No. 11-8273 CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on o2 By: If you have any questions concerning this matter please contact: Robert W. Cusick, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** BANK OF AMERICA, N.A. S/B/M TO BAC HOME COURT OF COMMON PLEAS LOANS SERVICING, LP F/K/A COUNTRYWIDE CIVIL DIVISON HOME LOANS SERVICING, LP NO. 11-8273 CIVIL TERM V. Plaintiff CUMBERLAND COUNTY JEREMY C. KREBS, A/K/A JEREMY KREBS JENNIFER R. KREBS, A/K/A JENNIFER KREBS Defendant(s) TO: JEREMY C. KREBS, A/K/A JEREMY KREBS 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 DATE OF NOTICE: December 9.2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES PHS # 275419 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 717) 249-3166 By. Ro . Cusick, Esquire Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 275419 BANK OF AMERICA, N.A. S/B/M TO BAC HOME COURT OF COMMON PLEAS LOANS SERVICING, LP F/K/A COUNTRYWIDE CIVIL DIVISON HOME LOANS SERVICING, LP NO. 11-8273 CIVIL TERM Plaintiff V. CUMBERLAND COUNTY JEREMY C. KREBS, A/K/A JEREMY KREBS JENNIFER R. KREBS, A/K/A JENNIFER KREBS Defendant(s) TO: JENNIFER R. KREBS, A/K/A JENNIFER KREBS 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 DATE OF NOTICE: December 9.2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES PHS # 275419 TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 717) 249-3166 B Cusick, Esquire Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 275419 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-8273 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, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From JEREMY C. KREBS A/K/A JEREMY KREBS, JENNIFER R. KREBS A/K/A JENNIFER KREBS (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: $170,528.56 L.L.: S.50 Interest from 1/14/12 to Date of Sale ($28.03 PER DIEM) - $4,064.35 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $203.50 Other Costs: Plaintiff Paid: Date: 2/13/12 David D. Buell, Prot onot (Seal) Deputy REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 308877 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, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff v JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 01/14/2012 to Date of Sale ($28.03 per diem) TOTAL Note: Please attach description of property. PHS # 275419 c3 ct ee 4 430 u << aD NO.: 11-8273 CIVIL TERM CUMBERLAND COUNTY C) $170,528.56 o n _.. r? r. n i i - $4,064.35 rn t r -Uri 2O 1 92.91 C? Cy r-3 C n Hallinan & Schmieg, LLP Michael Kolesnik, Esq., Id. No.308877 nev for Plaintiff x.0215 -2?w d sa u. Ctc,* // s3(e?.;2 d, 11 ss'p Rda-7Uclq? wf I a ?;g -7ks'."'ej w w w p wp o 00 C) co.)? w? w? ? QOo a d N O F t? W 00 W p U 0 d O .-, ? w O ?^ d GG a ? ? y ? U? U x ? O pn ? ?s o ?W a t 1 11 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen, County of Cumberland, Commonwealth of Pennsylvania, known and numbered as Lot No. 122, on a Plan for 'Bowmans Hill', dated March 29, 1993, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Subdivision Plan Book 65, Page 139, and amended Phase I Final Subdivision Plan of Bowmans Hill, recorded October 8, 1993, in Plan Book 66, Page 145, more fully bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bumble Bee Hollow Road at the southwest corner of Lot No. 121; thence North 77 degrees 31 minutes 1.7 seconds East, a distance of 130.06 feet to a point, being the southeast corner of Lot No. 121; thence South 19 degrees 06 minutes 02 seconds East., a distance of 80.54 feet to a point at the northeast corner of Lot No. 123; thence South 77 degrees 31 minutes 17 seconds West, a distance of 139.35 feet to a point on the eastern side of Bumble Bee Hollow Road; thence North 12 degrees 28 minutes 43 seconds West, a distance of 80 feet to the point and place of BEGINNING. UNDER AND SUBJECT, NEVERTHELESS, to the same conditions, restrictions, exceptions and reservations as exist by virtue of prior recorded instruments, deeds and conveyances. TITLE TO SAID PREMISES IS VESTED IN Jeremy Krebs and Jennifer Krebs, h/w, by Deed from Stephen A. Vergot, single man, dated 05/27/2005, recorded 06/01/2005 in Book 269, Page 764. PREMISES BEING: 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581 PARCEL NO. 42-29-2456-019 PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. No.308877 , "1i"'" iC 1617 JFK Boulevard., Suite 1400 One Penn Center Plaza ??O? Philadelphia, PA 19103 1 FEB 13 Am 215-563-7000 UMBEL AN44 D??ppC,,NUNT `? BANK OF AMERICA, N.A. SUCCESSOR B?GETt TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-8273 CIVIL TERM CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 490 relating to unsworn falsification to authorities. By: PKla`n Hallinan & Schmieg, LLP ohn Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: 11-8273 CIVIL TERM JEREMY C. KREBS A/K/A JEREMY KREBS CUMBERLAND COUNTY JENNIFER R. KREBS A/K/A JENNIFER KREBS . Defendant(s) PHS # 275419 AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581. I . Name and address of Owner(s) or reputed Owner(s): r Name Address (if address cannot be reasonably ascertained, please so indicate) rya - CO n o ter JEREMY C. KREBS A/K/A JEREMY KREBS 2313 BUMBLE BEE HOLLOW ROAD =? C ' c) MECHANICSBURG, PA 17055-5581 -,eD w JENNIFER R. KREBS 2313 BUMBLE BEE HOLLOW ROAD A ? A/K/A JENNIFER KREBS MECHANICSBURG, PA 17055-5581 C n ? CIl .r 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 cre ditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) PA STATE EMPLOYEE CREDIT UNION I CREDIT UNION PLACE HARRISBURG, PA 17110 PA STATE EMPLOYEE CREDIT UNION METTE, EVANS & WOODSIDE C/O MELISSA L. VAN ECK, ESQUIRE 3401 N FRONT ST HARRISBURG, PA 17110 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) COUNTRYWIDE BANK, FSB. COUNTRYWIDE BANK, FSB. MS SV-79 DOCUMENT PROCESSING P.O. BOX 10423 VAN NUYS, CA 91410-0423 1199 NORTH FAIRFAX ST. STE. 500 ALEXANDRIA, VA 22314 COUNTRYWIDE BANK, FSB. 730 HOLIDAY DRIVE FL 4 BLDG 8 C/O COUNTRYWIDE HOME LOANS, INC. PITTSBURGH, PA 15220 D/B/A AMERICA'S WHOLESALE LENDER ATTN: PATRICIA L. CONLEY MERS, AS NOMINEE FOR COUNTRYWIDE P.O. BOX 2026 .BANK, FSB. FLINT, MI 48501-2026 MERS, INC. FORMERLY - 3300 SW 34TH AVENUE, SUITE 101 OCALA, FL 34474 MERS, INC. 1901 E. VOORHEES ST., SUITE C DANVILLE, IL 61834 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) BOWMANS HILL HOMEOWNERS ASSOC BOWMANS HILL HOMEOWNERS ASSOCIATION, INC. A NONPROFIT CORPORATION 2395 ROLLING HILLS DR MECHANICSBURG, PA 17055-9210 2411 ROLLING HILLS DR MECHANICSBURG, PA 17055-9207 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 BANK OF AMERICA, N.A. MERS, AS NOMINEE FOR BANK OF AMERICA, N.A. DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 1800 TAPO CANYON ROAD MAIL ID #CA6- 914-01-43 SIMI VALLEY„ CA 93063 P.O. BOX 2026 FLINT, MI 48501-2026 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE 228 WALNUT STREET DISTRICT OF PA HARRISBURG, PA 17108 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: Ai Hallinan & Schmieg, LLP Michael Kolesnik, Esq., Id. No.308877 ney for Plaintiff BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO : COURT OF COMMON PLEAS BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE : HOME LOANS SERVICING, LP : CIVIL DIVISION Plaintiff NO.: 11-8273 CIVIL TERM c VS. -g 3 r.; a. CUMBERLAI oxNrv : JEREMY C. KREBS A/K/A JEREMY KREBSn ,4, JENNIFER R. KREBS A/K/A JENNIFER KREBS r-M _CZ) Defendant(s) n?.• =-, zo r ?. :3 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY cn' TO: JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREE 2313 BUMBLE BEE HOLLOW ROAD 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 MECHANICSBURG, PA 17055-5581 "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 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055- 5581 is scheduled to be sold at the Sheriff's Sale on 06/06/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $170,528.56 obtained by BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the 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 vale of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-8273 CIVIL TERM BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP vs. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS owner(s) of property situate in the TOWNSHIP OF UPPER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581 Parcel No. 42-29-2456-019 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $170,528.56 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen, County of Cumberland, Commonwealth of Pennsylvania, known and numbered as Lot No. 122, on a Plan for 'Bowmans Hill', dated March 29, 1993, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Subdivision Plan Book 65, Page 139, and amended Phase I Final Subdivision Plan of Bowmans Hill, recorded October 8, 1993, in Plan Book 66, Page 145, more fully bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bumble Bee Hollow Road at the southwest corner of Lot No. 121; thence North 77 degrees 31 minutes 17 seconds East, a distance of 130.06 feet to a point, being the southeast corner of Lot No. 121; thence South 19 degrees 06 minutes 02 seconds East, a distance of 80.54 feet to a point at the northeast corner of Lot No. 123; thence South 77 degrees 31 minutes 17 seconds West, a distance of 139.35 feet to a point on the eastern side of Bumble Bee Hollow Road; thence North 12 degrees 28 minutes 43 seconds West, a distance of 80 feet to the point and place of BEGINNING. UNDER AND SUBJECT, NEVERTHELESS, to the same conditions, restrictions, exceptions and reservations as exist by virtue of prior recorded instruments, deeds and conveyances. TITLE TO SAID PREMISES IS VESTED IN Jeremy Krebs and Jennifer Krebs, h/w, by Deed from Stephen A. Vergot, single man, dated 05/27/2005, recorded 06/01/2005 in Book 269, Page 764. PREMISES BEING: 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581 PARCEL NO. 42-29-2456-019 5 BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F'K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS I. 'i . err ???r; •?? ??, ? ?:? EMNSlfL A i i", Court of Common Pleas Civil Division CUMBERLAND County No.: 11-8273 CIVIL TERM Defendants RULE AND NOW, this a day of /92,L,-2012, 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 Plaintiffs 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. 275419 Allison F. Wells, Esq., Id. No.309519 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 TEL: (215) 563-7000 FAX: (215) 563-3459 JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS V A/K/A JENNIFER KREBS 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 ("er/t 6 Ala, led 31.; ? 275419 IZj? li 275419 ,. j .^ r- 1w "EDO -:10N Phelan Hallinan & Schmieg, LLP Dana Ostrovsky, Esq., Id. No.83921 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 22,12 APR -4 M 9*- CUMBERLAND COUNT''.` PENNSYLVANIPATTORNEY FOR PLAINTIFF BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff vs. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS Defendants Court of Common Pleas Civil Division CUMBERLAND County No.: 11-8273 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's March 28, 2012 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. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 Phelan Hallinan & Schmieg, LLP DATE: By: 1? Dana Ostrov y, Esquire Attorney foolaintiff 275419 AFFIDAVIT OF SERVICE (FHLMC) _ PLAINTIFF CUMBERLAND'JI i" E ? ? + SESLVI? NGMLP F/K/A COUNTRYWIDE HOME LOANS LOANS PHS # 27 419' ' 0 ?? ? ? i i SERVICING, LP 20 APR 10 AM 10* 0 DEFENDANT SERVICE TEAM/ lxh JEREMY C. KREBS A/K/A JEREMY KREBS COURT N0U t% NT Y JENNIFER R. KREBS A/K/A JENNIFER KREBS PENNSYLVANIA SERVE JENNIFER R. KREBS A/K/A JENNIFER KREBS AT: TYPE OF ACTION 2313 BUMBLE BEE HOLLOW ROAD XX Notice of Sheriff's Sale MECHANICSBURG, PA 17055-5581 SALE DATE: June 6, 2012 SERVED Served and made known to JENNIFER R. KREBS A/K/A JENNIFER KREBS, Defendant on the day of FC-4%°' 7 ,20 1a, at ;oo, o'clock t. M., at f ( KowEQ Or, hlkO*Nlcs &lA6,1 PAS in the manner described below: ? Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _ Other: _ Descri tion: Age c? S Height 5?4• Weight Race W Sex -f' Other I, CC, 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 unswom falsification to authorities. T A DATE: D4I q ( (a- NAME: 4A ") 4 ? -W) PRINTED NAME: RD P4-f_,0 6 to u- TITLE: 'Ph Cipr,S &r v E2 _ Vacant - Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused NOT SERVED On the _ day of , 20_, at o'clock _. M., Defendant NOT FOUND because: Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF ?o Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 AFFIDAVIT OF SERVICE (FHLMC) -?w?Ca /? i " " i PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SftVECING, LP F/K/A COUNTRYWIDE HOME LOANS PHS # 275419 SERVICING, LP DEFENDANT SERVICE TEAM/ lxh JEREMY C. KREBS A/K/A JEREMY KREBS COURT NO.: 11-8273 CIVIL TERM JENNIFER R. KREBS A/K/A JENNIFER KREBS SERVE JEREMY C. KREBS A/K/A JEREMY KREBS AT: TYPE OF ACTION 2313 BUMBLE BEE HOLLOW ROAD XX Notice of Sheriff's Sale MECHANICSBURG, PA 17055-5581 SALE DATE: June 6, 2012 SERVED Served and made known to JEREMY C. KREBS A/K/A JEREMY KREBS, Defendant on the ,20 I at Oe , o'clock A. M., at 11 Ka wEt C?-,M636iy,ej641A , i the manner described below: _ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is J 1 ? C-_ . _ 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: _ V to"i% svP-&,? A TITLE: p4ck% SEAve?, NOT SERVED On the _ day of , 20_, at o'clock _. M., Defendant NOT FOUND because: Vacant - Does Not Exist _ Moved _ Does Not Reside (Not Vacant) No Answer on at at o`t 1 S F day of MCD i` Gi A c-) O ?e- p C -i Descri tion: Age 366 Height ?5'4 `' Weight (56 Race W Sex r 1- Other C11 I, X11 A44ti.., 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. 44 61,4- FOvND T DATE: .2W ' I INVE47-t64rW DISu e S TmPr I I K6WEA Cr. PRINTED NAME: jQX/kt.b MO L•L 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. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 ---t 10 BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff V. JEREMY C. KREBS, A/K/A JEREMY KREB S, and JENNIFER R. KREBS, A/K/A JENNIFER KREBS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 11-8273 CIVIL TERM IN RE: MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this 24`x' day of April, 2012, upon consideration of Plaintiff s Motion To Make Rule Absolute, and no answer to the Rule To Show Cause issued on March 27, 2012, having been filed, 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 captioned 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 $148,174.74 Interest through June 6, 2012 $26,617.71 Per Diem $26.32 Late Charges $528.44 ' Cost of Suit and Title $892.00 _ Property Inspections $295.00 ', ?`- Escrow Deficit $4,687.19 Cn TOTAL $181,195.08 > BY THE COURT, - 73 -t ct, -/ red( Christylee L. Peck, J. ?' Alison F. Wells, Esq. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Attorney for Plaintiff ? Jeremy C. Krebs A/K/A Jeremy Krebs Jennifer R. Krebs A/K/A Jennifer Krebs 2313 Bumble Bee Hollow Road Mechanicsburg, PA 17055-5581 Defendants, pro Se :rc evp" e5 M", led ??25Ii a R' 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 Attorney for Plaintiff '.? E 1 A t p n1 .-) 9 it _ ? ((? ?; fl COUNT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A. S/B/M TO BAC HOME CUMBERLAND COUNTY LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION V. No.: 11-8273 CIVIL TERM JEREMY C KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached )wfre?q,.Rxh ". Date: Z. IMPORTANT NOTICE: This property is be sold in the absence of a representative hael Kolesnik, Esquire for Plaintiff at the direction of the plaintiff. It may not e plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present . at the sale. PHS # 275419 W a Q N O N O m Q N ¢ a o J oD y N Cl C13 ?L¢ G o y. M U .? r: a..?OOa N E z N U_ b ? 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Up W ° a a W a'? y ? >, C.O F+? a Oa¢ ¢ ¢ ? OQ ¢a O Gd?x?"` E' a CGf?z E-O a?p aO 1 F- Qx? Qx? z >„ a N?u?i W a va z .<M zM xE-> zo'" tx?? 3?,v ?a' 3..U p z>=Z a? z Q zzx aa.w p i 4 zC)Zpv? 0 F= F O vipgE- C4 z O vi pa E- C4 z •. v?fs7> x?z ¢A?, E-wfs'y ?w W D 9" WM Q,° O O?w Ov?O¢ O?'a O?F°? wpa w 0 a ° ¢ w ¢U¢ w FN FO -. V? OG1N? GaNt. uz > U •. Q UU¢t?CL ?CLGL r GFwGrr ? + C -rA Or -.rL" R+ toc i k -X -K -K i iC it •k •k X -% -K K i -k i -K i •X -X -K i K ,Q k -K -K •K -% •% -k -K K •% -K n " T O d ?' u 00 a o -? o bq ? (/] N M U N O co 0. C N N Q co 0. O a? ici Cn u C Lc, y ? O C a °0 r L G b ro a Vr zQo SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~; ; . Sheriff ~ = c- ~~ ,' _ ~,~tti~ ~t t aniG - = ~, ~. Jody S Smith ~°'~ c~~F~'t~ ~ ~ ~ Chief Deputy _ . `. k ~ ~,~.~~ 3 1.; Pi r ~c ~ .~ ~I~ Richard W Stewart ..i ~;~~~ ~•i~~ ,,,__,~-; Solicitor ;,~. ~ _ _ _ _ -~ ~ ~ ~ ~ ~ i t, ~ ! +~ ~ ~ t. ~ e E Bank of America, NA vs. Case Numbe Jeremy C. Krebs (et al.) 2011-8273 SHERIFF'S RETURN OF SERVICE 03/21/2012 08:04 PM -Deputy Shawn Gutshall, being duly sworn according to law, states service was performed y posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled actin , upon the property located at 2313 Bumble Bee Hollow Road, Upper Allen Township, Mechanicsburg, A 17055, Cumberland County. 03/28/2012 04:41 PM -Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estat Writ, Notice and Description, in the above titled action, by making known its contents and at the same 'me personally handing a true copy to a person representing themselves to be JEREMY KREBS-HUSBAN RB, who accepted as "Adult Person in Charge" for Jennifer R. Krebs at 232 W. Lisburn Road, Upper Allen, Mechanicsburg, PA 17055, Cumberland County. 03/28/2012 04:41 PM -Deputy Robert Bitner, being duly sworn according to law, served the requested Real Estat Writ, Notice and Description, in the above titled action, by making known its contents and at the same t me personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jere y C. Krebs at 232 W. Lisburn Road, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland Cou ty 04/26/2012 Order to reassess damages, $ 181,195.08 06/06/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice h d been given according to law, he exposed the within described premises at public venue or outcry at th Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on June 06, 2012 at 10: 0 AM. He sold the same for the sum of $1.00 to Attorney Francis Hallinan, on behalf of Federal Home Lo n Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $879.16 SO ANSWERS, July 20, 2012 RON R ANDERSON, SHERIFF P~ Sr ~ ~, ~~ d ~v ~l ~ ~. ~ P ~ ~ ~~ ~ ~. ~'-~ ~- /~1 ~, . BANK OF AMERICA,I~1.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff v. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS Defendant(s) COURT OF COMMON~PLEAS CIVIL DIVISION NO.: 11-8273 CIVIL CUMBERLAND CO PHS # 275419 AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/~ COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by the undersigned attorney, sets forth the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 2313 BUM HOLLOW ROAD, MECHANICSBURG, PA 17055-5581. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JEREMY C. KREBS A/K/A JEREMY KREBS 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 JENNIFER R. KREBS 2313 BUMBLE BEE HOLLOW ROAD A/K/A JENNIFER KREBS MECHANICSBURG, PA 17055-5581 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 Name Address (if address cannot be reasonably ascertained, please indicate) PA STATE EMPLOYEE CREDIT UNION 1 CREDIT UNION PLACE HARRISBURG, PA 17110 PA STATE EMPLOYEE CREDIT UNION METTE, EVANS & WOODSIDE C/O MELISSA L. VAN ECK, ESQUIRE 3401 N FRONT ST HARRISBURG, PA 17110 4. Name and address of last recorded holder oi~every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) COUNTRYWIDE BANK, FSB. MS SV-79 DOCUMENT PROCESSING P.O. BOX 10423 VAN NUYS, CA 91410-0423 COUNTRYWIDE BANK, FSB. 1199 NORTH FAIRFAX ST. STE. 500 ALEXANDRIA, VA 22314 of the date ,E BEE sold: COUNTRYWIDE BANK, FSB. 730 HOLIDAY DRIVE FL 4 BLDG 8 C/O COUNTRYWIDE HOME LOANS, INC. PITTSBURGH, PA 15220 D/B/A AMERICA'S WHOLESALE LENDER ATTN: PATRICIA L. CONLEY MERS, AS NOMINEE FOR COUNTRY WIDE BANK, FSB. MERS, INC. MERS, INC. P.O. BOX 2026 FLINT, MI 48501-2026 FORMERLY - 3300 SW 34TH AVENUE, SUITE lOl OCALA, FL 34474 1901 E. VOORHEES ST., SUITE C DANVILLE, IL 61834 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be sale. Name Address (if address cannot be reasonably ascertained, please indicate) BOWMANS HILL HOMEOWNERS ASSOC 2395 ROLLING HILLS DR MECHANICSBURG, PA 17055-9210 BOWMANS HILL HOMEOWNERS ASSOCIATION, INC. A NONPROFIT CORPORATION 2411 ROLLING HILLS DR MECHANICSBURG, PA 17055-9207 Name and address of every other person of whom the plaintiff has knowledge who has any interest in the be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT BANK OF AMERICA, N.A. MERS, AS NOMINEE FOR BANK OF AMERICA, N.A. 2313 BUMBLE BEE HOLLOW ROAD MECHANICSBURG, PA 17055-5581 1800 TAPO CANYON ROAD MAIL ID #CA6- 914-01-43 SIMI VALLEY„ CA 93063 P.O. BOX 2026 FLINT, MI 48501-2026 DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 13 NORTH HANOVER STREET CARLISLE, PA 1.7013 P.O. BOX 2675 HARRISBURG, PA 17105 by the which may INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 ~~ U.S. DEPARTMENT OF JUSTICE FEDERAL BUILDING, P.O. BOX 11754 U.S. ATTORNEY FOR THE MIDDLE 228 WALNUT STREET DISTRICT OF PA HARRISBURG, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my person~l knowledge or information and belief. I understand that false statements herein are made subject to tl~e penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification Date: ~~ By: BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO COURT OF COMMON FLEAS BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff NO.: vs. CIVIL DIVISION .273 CIVIL TI CUMBERLAND CO JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JEN IFER KREE 2313 BUMBLE BEE HOLLOW ROAD 2313 BUMBLE BEE HOLLOW R AD MECHANICSBURG, PA 17055-5581 MECHANICSBURG, PA 17055-55 1 * *THIS FIltM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION BTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BAN UPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT NLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, P 17055- 5581 is scheduled to be sold at the Sheriff's Sale on 06/06/2012 at 10:00 AM in the Cumberland Coun Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $170,528.56 btained by BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVIC G, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP (the mortgagee) against you. In the ev nt 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, cos s and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x 230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the j dgment if the judgment was improperly entered. You may also ask the Court to postpone the sale for good c se. 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 RIG TS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. ~ 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find' out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate 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 prop~rty 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 th~ 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 schedul of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) ays after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection 'n his office. This schedule will state who will be receiving that money. The money will be paid out in acc rdance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with t ~e 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 imme lately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT H E A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED ELO TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-8273 CIVIL TERM BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP vs. JEREMY C. KREBS A/K/A JEREMY KREBS JENNIFER R. KREBS A/K/A JENNIFER KREBS owner(s) of property situate in the TOWNSHIP OF UPPER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581 Parcel No. 42-29-2456-019 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $170,528.56 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Township of Upper Allen, County of Cumberland, Commonwealth of Pennsylvania, known and numbered as Lot No. 122, on a Pla for 'Bowmans Hill', dated March 29, 1993, and recorded in the Office of the Recorder of Deed in and for Cumberland County, in Subdivision Plan Book 65, Page 139, and amended Phase I Final Subdivision Plan of Bowmans Hill, recorded October 8, 1993, in Plan Book 66, Page 14 more fully bounded and described as follows, to wit: BEGINNING at a point on the eastern side of Bumble Bee Hollow Road at the southwest co er of Lot No. 1.21; thence North 77 degrees 31 minutes 17 seconds East, a distance of 130.06 fee to a point, being the southeast corner of Lot No. 121; thence South 19 degrees 06 minutes 02 seconds East, a distance of 80.54 feet to a point at the northeast corner of Lot No. 123; thence South 77 degrees 31 minutes 17 seconds West, a distance of 139.35 feet to a point on the east rn side of Bumble Bee Hollow Road; thence North 12 degrees 28 minutes 43 seconds West, a distance of 80 feet to the point and place of BEGINNING. UNDER AND SUBJECT, NEVERTHELESS, to the same conditions, restrictions, exceptions and reservations as exist by virtue of prior recorded instruments, deeds and conveyances. TITLE TO SAID PREMISES IS VESTED IN Jeremy Krebs and Jennifer Krebs, h/w, by L from Stephen A. Vergot, single man, dated 05/27/2005, recorded 06/01/2005 in Book 269, 764. PREMISES BEING: 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581 PARCEL NO. 42-29-2456-019 WRIT.OF E7ECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-8273 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, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From JEREMY C. KREBS A/K/A JEREMY KREBS, JENNIFER R. KREBS A/K/A JENNIFER KREBS (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: $170,528.56 L.L.: $.50 Interest from 1/14/12 to Date of Sale ($28.03 PER DIEM) - $4,064.35 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $203.50 Plaintiff Paid: Date: 2/13/12 (Seal) Other Costs: ~.3~ David D. Deputy REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone : 215-563-7000 Supreme Court ID No. 308877 TRUE COPY FROI~A In Testimony whereof, I here i end the syyeal of said Court~at This J~3.- daY ~ -r-/-w~,--~-n° ~~ ~ ~. :CORD set rr,y hand isle, Pa. 20 ~.- Prothonota ~' On February 14, 2012 the Sheriff levied upon the defendant's interest in the real. property situated in Upper Allen Township, Cumk~erland County, PA, known and numbered 2313 Bumble Bee Hollow Road, Mechanicsburg, PA 17055 more fully described on Exhibit"A"filed with this writ and by this reference incorporated herein. Date: February 14, 2012 By: For Claudia Brewbaker, Real Estate Coordinator b ~ =ZI c~ ~~ i ~~;~ I I Ql _. .. ~_. ,. CUMBERLAND LAW JOURNAL Writ No. 2011-82?3 Civil Term Bank of America, N.A. Successor by Merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP vs. Jeremy C. Krebs a/k/a Jeremy Krebs, Jennifer R. Krebs a/k/a Jennifer Krebs Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 11-8273 CIVIL TERM, BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP f/k/a COUNTRY- WIDE HOME LOANS SERVICING, LP vs. JTEREMY C. KREBS a/k/a JEREMY KREBS, JENNIFER R. KREBS a/k/a JENNIFER KREBS, owner(s) of property situate in the TOWNSHIP OF UPPER ALLEN, Cum- berland County, Pennsylvania, being 2313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581. Pazcel No. 42-29-2456-019. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $170,528- .56. PHELAN HALLINAN & SCHMIEG, LLP Attorneys for Plaintiff 1617 JFK Boulevard Suite 1400 Philadelphia, PA 19103 215-563-7000 79 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County an State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La' Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesl 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 regularl 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, April 27, May 4, and May 11, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumber Law Journal, a legal periodical of general circulation, and that he is not interested in the subj 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. ..--, L sa arie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 11 da of Ma 2012 G ~ , Notary /' i NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 :+~ ~ The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~be~latriot Neu-s Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and ; aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 1 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 daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she n~ Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this 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 ; behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted sev stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recordi in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown Sworn to apd ubscribed befor a this 2 ay of May, 2012 A.D. ~ ~~ otaiy'Public ~ COMMONWEALTH OF PENNSYLVANIA ~f the ~ the fhe Sunday tate th, 1949, heir regular ~r said tatement as tatement on orally by the ig of Deeds N: 04/27/12 05/04/12 05/11/12 Notarial Seal Sherrie L. Owens, Notary Public tower Parton Twp., Dauphin County My Commisslon Expires Nov. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2011.8273 Civil Term Bank of America, N.A. Successor by Merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP VS Jeremy C. Krebs a/kla Jeremy Krebs Jennifer R. Krebs a/k/a Jennifer Krebs qtly: Daniel Schmleg k3~ virtue of a Writ of Execution NO. l l- V'_73 C1VILTERM BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F,!K%A COUNTRYWIDE HOME LOANS 5'F.RVICING, LP as. JTF,REMY C. KREBS r1~'IUA JEREMY KREBSJENNIFER R. KREBS AJK'A JE'~INIFER KREBS owner(s) of property situate in the Tr )WNSHIP OF UPPER ALLEN, Cumberland County, Pennsylvania, being (Municipality) '313 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055-5581 Parcel No. 42-29-2456-019 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLINGJUDGMENT AMOUNT: ~;170,528.56Phelan Hallman & Schmieg,;,, IfD ~ Attorney for Plaintiff 1617 JFK Boulevard, Suite 14(Hl Philadelphia, PA ]9103 315-563-7000 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify the Sheriff s Deed in which Federal Home Loan Mortg_a egg Corp is the grantee the same having sold to said grantee on the 6 day of June A.D., 2012, under and by virtue of a writ Execution issued on the 13 day of February, A.D., 2012, out of the Court of Common Pleas of said County as of Civil 2011 Number 8273, at the suit of Bank of America N A. Successor by Merger to Servicii~ LP F/K/A Countrywide Home Loans Servicing LP against Jeremy L. Krebs A/K/A Jere Krebs Jennifer R. Krebs A/K/A Jennifer Krebs is duly recorded as Instrument Number 201224630. IN TESTIMONY WHEREOF, I have hereunto set m hand _~~ and seal of said office this ~y d y of A.D. o~ 0 1 c~ A ~kcorder of eeds Recorder dsribedard ~ tie. PA My Corm~sion ~ Fist o2 Jen. 2014