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HomeMy WebLinkAbout11-9556SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -F lug Sheriff FI?.EQ-'?.u ??tttt. ul- I HE PR0TH0N0TA1_81 Jody S Smith Chief Deputy 2012 JAN 10 PM 4: 11 Richard W Stewart CUMBERLAND COUNTY Solicitor ?'?? PENNSYLVANIA The Bank of New York Mellon Case Number vs. 2011-9556 Susan E. Hutchens (et al.) SHERIFF'S RETURN OF SERVICE 01/05/2012 05:36 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 5, 2012 at 1736 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Susan E. Hutchens, by making known unto herself personally, at 337 Fulton Street, Enola, Cumberland County, Pennsylvania 17025 its contents and a the same time handing to her personally the said true and correct copy of the same. MICHAEL BARRICK, DEPUTY 01106/2012 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: Susan E. Hutchens, 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 Susan E. Hutchens. Request for service at 5 Marshall Drive, Camp Hill, Pennsylvania 17011 is vacant. Susan E. Hutchens currently resides at 337 Fulton Street, Enola, Pennsylvania 17025. SHERIFF COST: $64.00 January 06, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF {6 CcumySuite Shenff. Telecscft. Irn,;. MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff File No.: 45.16528 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3 Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY M ?m No.: 11-9556 Civil '. - `- CIVIL ACTION ' C- MORTGAGE FORECLOSU RE w_ MOTION FOR ALTERNATIVE SERVICE PURSUANT TO PENNSYLVANIA R.C.P. 430 TO THE HONORABLE JUDGE OF SAID COURT: AND NOW, comes Plaintiff, by its attorney Patrick J. Wesner, Esquire and moves this Honorable Court for an Order permitting Alternative Service upon the Defendant, James T. Hutchens, Original Mortgagor by posting and tacking the Complaint and all subsequent pleadings that require personal service on the premises known as 5 Marshall Drive, Camp Hill, PA 17011 (the "Premises") and by regular and certified mail to the Premises and all known addresses for the Defendant pursuant to Pennsylvania Rule of Civil Procedure 430 and avers in support thereof: 1. Plaintiff filed suit against the Defendants in Mortgage Foreclosure. 2. Plaintiff is the mortgagee. {00495113} 3. Plaintiff has attempted to effectuate service of the Complaint upon Defendant, James T. Hutchens, Original Mortgagor. Service was attempted on the Defendant at the mortgaged property address of 5 Marshall Drive, Camp Hill, PA 17011. A copy of the Sheriff's Return is attached herto and marked as Exhibit "A." 4. Service was also attempted on the Defendant, James T. Hutchens, Original Mortgagor at 159 Timberland Trail, Ringgold, GA 30736. A copy of the Return is attached hereto and marked as Exhibit "B." 5. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. A copy of the Affidavit of Reasonable Investigation is attached to the Affidavit submitted herewith and made a part hereof as Exhibit "C." Said investigation provides no new address information for the Defendant. 6. Plaintiff has attempted to ascertain the present address of the Defendant, but has been unable to do so. 7. Pennsylvania Rule of Civil Procedure 430 permits service of process in Mortgage Foreclosure Actions by regular and certified mail and by posting at the mortgaged premises. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order permitting service upon said Defendant, James T. Hutchens, Original Mortgagor by posting and tacking the Complaint and all subsequent pleadings that require personal service on the premises known as 5 Marshall Drive, Camp Hill, PA 17011 (the "Premises") and by regular and certified mail to the premises and all known addresses for the Defendant. Respectfully submitted, MILSTEAB-k ASS IATES, LLC Patrick J. esner, Esquire Attorney ID 03145 {00495113} MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3 Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor Defendants. Attorney for Plaintiff File No.: 45.16528 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 11-9556 Civil CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT IN SUPPORT OF MOTION FOR ALTERNATIVE SERVICE STATE OF NEW JERSEY COUNTY OF CAMDEN SS I, Patrick J. Wesner, Esquire, being duly sworn according to law, hereby depose and say that the facts set forth below are true and correct to the best of my knowledge, information and belief. 1. Plaintiff filed suit against the Defendants in Mortgage Foreclosure. 2. Plaintiff is the mortgagee. 3. Plaintiff has attempted to effectuate service of the Complaint upon Defendant, James T. Hutchens, Original Mortgagor. Service was attempted on the Defendant at the mortgaged property address of 5 Marshall Drive, Camp Hill, PA 17011. A copy of the Sheriffs Return is attached herto and marked as Exhibit "A." {00495113} 4. Service was also attempted on the Defendant, James T. Hutchens, Original Mortgagor at 159 Timberland Trail, Ringgold, GA 30736. A copy of the Return is attached hereto and marked as Exhibit "B." 5. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. A copy of the Affidavit of Reasonable Investigation is attached to the Affidavit submitted herewith and made a part hereof as Exhibit "C." Said investigation. provides no new address information for the Defendant. 6. Plaintiff has attempted to ascertain the present address of the Defendant, but has been unable to do so. 7. Pennsylvania Rule of Civil Procedure 430 permits service of process in Mortgage Foreclosure Actions by regular and certified mail and by posting at the mortgaged premises. Milstead & Associates, LLC {00495113} MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff File No.: 45.16528 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK, AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED No.: 11-9556 Civil CERTIFICATES, SERIES 2007-BC3 Plaintiff, CIVIL ACTION Vs. MORTGAGE FORECLOSURE Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor Defendants. MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR ALTERNATIVE SERVICE 1. INTRODUCTION This matter comes before the Court upon the Motion of Plaintiff, for an order permitting substituted service pursuant to Pa. R.C.Pro. 430(a) upon the Defendant, James T. Hutchens, Original Mortgagor (the "Defendant") in this mortgage foreclosure action. II. FACTS Plaintiff filed suit against the Defendants in Mortgage Foreclosure. Plaintiff is the mortgagee. Plaintiff has attempted to effectuate service of the Complaint upon Defendant, James T. Hutchens, Original Mortgagor. Service was attempted on the Defendant at the mortgaged property address of 5 Marshall Drive, Camp Hill, PA 17011. A copy of the Sheriff's Return is attached herto and marked as Exhibit "A." {00495113} Service was also attempted on the Defendant, James T. Hutchens, Original Mortgagor at 159 Timberland Trail, Ringgold, GA 30736. A copy of the Return is attached hereto and marked as Exhibit "B." Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. A copy of the Affidavit of Reasonable Investigation is attached to the Affidavit submitted herewith and made a part hereof as Exhibit "C." Said investigation provides no new address information for the Defendant. Plaintiff has attempted to ascertain the present address of the Defendant, but has been unable to do so. Pennsylvania Rule of Civil Procedure 430 permits service of process in Mortgage Foreclosure Actions by regular and certified mail and by posting at the mortgaged premises. III. LEGAL ARGUMENT According to Pa. R.C.Pro. 430(a), a plaintiff may petition the court to provide an alternative method of service if the plaintiff cannot effectuate service upon the Defendant. The rule requires the affidavit presented in support of the motion for alternative service to state "the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made." Pa.R.C.Pro. 430(a). The purpose of this procedure is to provide proof that a good faith effort has been made to effect service under normal methods. Rule 430 provides in pertinent part: If service cannot be made under the applicable rule the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why {00495113} service cannot be made. Pa.R.Civ.P. 430(a). It is well settled that, pursuant to Pa.R.Civ.P. 430(a), a method of substituted service which is reasonable calculated to give actual notice depending upon "what is reasonable under the circumstances, considering the interest at stake and the burden of providing notice" is acceptable. Romeo v. Looks, 369 Pa. Super. 608, 616 (1987). The instant matter is a mortgage foreclosure action. Clearly, service upon the Defendant at the property subject to the action and to all known addresses of Defendant and by publication is reasonably calculated to provide notice to the Defendant in light of the efforts already made by the Plaintiff to effectuate personal service. Plaintiff has attached an affidavit to its Motion which sets forth the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant. The Motion and the affidavit illustrate that Plaintiff has made a good faith effort to effectuate service under normal methods. Substituted service in this instant is appropriate under Pa.R.Civ.P. 430(a). IV. CONCLUSION For the foregoing reasons, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint and all subsequent pleadings which require personal service by certified and regular mail to all known addresses of Defendant and by posting at the mortgaged premises. Patric a er, Esquire Attorney I N .: 203145 {00495113} MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff File No.: 45.16528 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3 Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 11-9556 Civil CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATION OF SERVICE I, Patrick J. Wesner, Esquire, hereby certify that I have served a true and correct copy of Plaintiff's Motion for Alternate Service to the following person or their attorney of record. xx'X Regular First Class Mail Certified Mail Other Date Served: June 2012 TO: James T. Hutchens, Original Mortgagor James T. Hutchens, Original Mortgagor 5 Marshall Drive 159 Timberland Trail Camp Hill, PA 17011 RinggoW,,GA 30736 _ n r, Esquire ID No 203145 {00495113} EXHIBIT "A" {00495113} SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4p1'(N,yi of ?aiuLcr'I,1j?¢ OFFICE OF THE SHERIFF X16. I6?sa Jody S Smith Chief Deputy Richard W Stewart Solicitor The Bank of New York Mellon Case Number vs, Susan E. Hutchens (et al.) 2011-9556 SHERIFF'S RETURN OF SERVICE 01/05/2012 05:36 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 5, 2012 at 1736 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Susan E. Hutchens, by making known unto herself personally, at 337 Fulton Street, Enola, Cumberland County, Pennsylvania 17025 its contents and a the same time handing to her personally the said true and correct copy of the same. MICHAEL BARRICR, DEPUTY 01/06/2012 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: Susan E. Hutchens, 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 Susan E. Hutchens. Request for service at 5 Marshall Drive, Camp Hill, Pennsylvania 17011 is vacant. Susan E. Hutchens currently resides at 337 Fulton Street, Enola, Pennsylvania 17025. SHERIFF COST: $64.00 January 06, 2012 (c) CO MySWte Sheriff, Teleosoit, Inc. SO ANSWERS, RON R ANDERSON, SHERIFF EXHIBIT "B" {00495113} 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 B&R PHONE: (215) 546-7400 FAX: (215) 985-0169 801t1C!/ tOI PiO?Qi/IOYaII/ IaC. The Bank of New York Mellon, et al _VS_ Susan E. Hutchens, et al COURT National Association of Professional Process Servers r_- Philadelphia Association of Professional Process Servers Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 11-9556-Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: B&R Control # CS089791 -1 Reference Number 45.16528 SERVICE INFORMATION On 5 day of January, 2012 we received the Mortgage Foreclosure Complaint for service upon James T. Hutchens, Original Mortgagor at 159 Timberland Trail Ringgold, GA 30736 *** Special Instructions *** Q Served Date Time Accepted By: In the manner described below. Personally served. Adult. family member. Relationship is Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging ? Agent or person in charge of office or usual place of business Other Description of Person Age Height Weight _ - Race Other X Not Served Date Time ?S ;119 Not Served Information 7 Moved 17 Unknown 0 No Answer Kvacant 0 Other Sex ENTERED The Process Server, being duly sworn, ------ -? Sworn to and subscribed before me this deposes and says that the facts set forth herein are true and correct to the best of their day of knowledge, information and belief. RECD*j --- Process Server/Sheriff C' L i 554 DIV c Notary Public Law Firm Phone (856)482-1400 Fo ServeBy Date 1/29/2012 Mary Dominach Milstead and Associates Filed Date 12/30/2011 220 Lake Drive East #301, Woodland Falls Corp. Park Cherry Hill, NJ 08002 ORIGINAL 005VC EXHIBIT "C" {00495113} RMT SERVICES LLC "Yon Seek and We Find" Number: 45.16528 Plaintiff. Bank of America County: Cumberland Date: August 10, 2011 Vs Defendant: Susan Hutchens James T. Hutchens Person to Locate James T. Hutchens XXX-XX-XXXX AFFIDAVIT OF GOOD FAITH INQUIRY LAST KNOWN ADDRESS 1) 5 Marshall Drive, Camp Hill, PA 17011 2) 159 Timberland Trail, Ringgold, GA 30736 SEARCH OF LOCAL TAX AUTHORITY Inquiry with local tax office was inconclusive due to the lack of records available for Cumberland County. INQUIRY OF THE CREDIT BUREAU Inquiry with credit bureau, confirms the most current mailing address for James T. Hutchens as address #2 listed above. Please see document attached. SEARCH OF LOCAL PHONE DIRECTORY AND OPERATOR INQUIRY The ie' lephone company operator has address #2 above listed to James T. Hutchens, but a phone number is unavailable. (423) 987-6073, (706) 639-77200, (423) 315-1280, & (717) 732-7268 are four phone numbers used from the credit bureau listings. VERBAL TELEPHONE INOUMNS/CONTACTS: (423) 987-6073: 8-8-11 at 12:24 p.m. message: person you called is not accepting calls at this time (706) 639-7720: 8-8-11 at 12:20 p.m. message: person you called has a voice mail that has not been set up yet. (423) 315-1280: 8-8-11 at 12:25 p.m. female had no idea (717) 732-7268: 8-8-11 at 12:24 p.m. not in service Neighbors closest to 5 Marshall Drive & 159 Timberland Trail 3 Marshall Drive: 8-8-11 at 12:30 p.m. answering machine 4 Marshall Drive, Apartment 19K: 8-8-11 at 12:31 p.m. male had no idea 106 Timberland Trail: 8-8-11 at 12:29 p.m. answering machine 126 Timberland Trail: 8-8-11 at 12:28 p.m. answering machine 184 Timberland Trail: 8-8-11 at 12:28 p.m. fast busy signal I CERITFY UNDER PENALTY OF PERJURY, THAT THE FOREGOING IS TRUE AND CORRECT, TO B OF MY KNOWLEDGE. I UNDERSTAND FALSE STATEMENTS `HEREIN ARE MADE SUBJECT TO THE PENALTIES RELATING TO CATION 1y A SM l1 t4 ' AFFiArrr: _ SID ?3 D?A? ?' Wayne Hubet'1'7gyp 9717 Inquiry - SSN: First Name: james Last Name: hutchens Middle Initial: t Street: 5 marshall drive City: camp hill State: pa Zip: 17011 Tracking Field 1: Tracking Field 2: lot JAMES HUTCHENS 587-XX-XXXX 06/13/1962 159 TIMBERLAND TR (423) 987-6073 05/09/2011 RINGGOLD, GA 30736 JAMES HUTCHENS 159 TIMBERLAND TR (706) 639-7720 01/31/2011 RINGGOLD GA 30736 , f 587-XX-XXXX JAMES T HUTCHENS I 159 TIMBERLAND TR - 12!16/2010 06/13/1962 RINGGOLD, GA 30736 587-XX-XXXX JAMES T HUTCHINS 159 TIMBERLAND TRL (423) 987-6073 10/04/2010 RINGGOLD, GA 30736-4554 JAMES T HUTCHINS 587-XX-XXXX 159 TIMBERLAND TRL (423) 315-1280 10/04/2010 RINGGOLD, GA 30736-4554 587-XX-XXXX JAMES T HUTCHINS 159 TIMBERLAND (423) 315-1280 09/30/2010 RINGGOLD, GA 30736 JAMES HUTCHENS 587-XX-XXXX 159 TIMBERLAND TR 08/26/2010 02/13/1962 RINGGOLD, GA 30736 JAMES HUTCHENS 587-XX-XXXX 159 TIMBERLAND TR 07/22/2010 02/13/1962 RINGGOLD, GA 30736 587-XX-XXXX JAMES T HUTCHENS 159 TIMBERLAND TR 06/18/2010 RINGGOLD, GA JAMES HUTCHENS 159 TIMBERLAND TRAIL 587-XX-XXXX 05/14/2010 06/13/1962 RINGGOLD, GA 30736 JAMES T HUTCHENS 587-XX-XXXX 159 TIMBERLAND TRL 05/12/2010 06/13/1962 RINGGOLD, GA 30736 JAMES THOMAS HUTCHENS 587-XX-XXXX 159 TIMBERLAND TRL 05/12/2010 06/13/1962 RINGGOLD, GA 30736 ` JAMES T HUTCHENS SR 159 TIMBERLAND TR 04/19/2010 RINGGOLD, GA 30736 JAMES THOMAS HUTCHENS 587-XX-XXXX 159 TIMBERLAND TRL 04/05/201 0 06/13/1962 RINGGOLD, GA 30736 JAMES THOMAS HUTCHENS 587-XX-XXXX 159 TIMBERLAND TRL 01 /27/2010 06/13/1962 RINGGOLD, GA 30736 JAMES T HUTCHENS _ 587-XX-XXXX 159 TIMBERLAND TRL 01/05/2010 06/13/1962 RINGGOLD, GA 30736 JAMES T HUTCHENS 587-XX-XXXX' 159 TIMBERLAND TRIAL 11/11/2009 RINGGOLD, GA 30736 JAMES HUTCHENS 587-XX-XXXX 159 TIMBERLAND TRIAL 11/11/2009 06/13/1962 RINGGOLD, GA 30736 JAMES HUTCHENS 587-XX-XXXX 159 TIMBERLAND TR . 10/12/2009 RINGGOLD, GA 30736 587-XX-XXXX JAMES T HUTCHENS 159 TIMBERLAND RINGGOLD, GA 30736 08/18/2009 587-XX-XXXX: 06/13/1962 JAMES T HUTCHENS 159 TIMBERLAND TR (423) 315-1280 02/26/2009 RINGGOLD, GA 30736 587-XX-XXXX 06/13/1962 JAMES T HUTCHENS 159 TIMBERLAND TR 02/26/2009 ( RINGGOLD, GA 30736 587-XX-XXXX. 06/13/1962 JAMES HUTCHENS 159 TIMBERLAND TR 02/26/2009 RINGGOLD, GA 30736 587-XX-XXXX JAMES T HUTCHENS 159 TIMBERLANE TRAIL RINGGOLD, GA 30736 02/19/2009 587-XX-XXXX JAMES HUTCHENS 159 TIMBERLANE TR (423)315-128 0 - 02/03/2009 06/13/1962 RINGGOLD, GA 30736 587-XX-XXXX JAMES HUTCHENS 159 TIMBERLANE TR --?.....-.....-.--------- 2/02/2009 06/13/1962 RINGGOLD, GA 30736. 587-XX-XXXX JAMES T HUTCHENS 159 TIMBERLANE T 01/29/2009 RINGGOLD, GA 30736 587-XX-XXXX 06/01 /1962 JAMES T HUTCHENS 159 TIMBERLAND TRAIL 11 /14/2008 RINGGOLD, GA 30736 587-XX-XXXX JAMES HUTCHENS 159 TIMBERLAND TR RINGGOLD GA 30 6 (423) 315-1280 11/10/2008 , 73 587-XX-XXXX JAMES THOMAS HUTCHENS 07/08/2008 06/13/1962 1505 EMMING LN ROSSVILLE, GA 30741 JAMES HUTCHENS 587-XX-XXXX: 1505 EMMING LANE 05/23/2008 ROSSVILLE, GA 30741 JAMES T HUTCHENS 587-XX-XXXX 1505 EMMING LANE LAKE AP PK 04/15/2008 ROSSVILLE, GA 30741 JAMES HUTCHENS 587-XX-XXXX 1505 EMMING LN 10/09/2007 ROSSVILLE, GA 30741 JAMES T HUTCHENS 587-XX-XXXX 1505 EMMING 10/03/2007 ROSSVILLE, GA 30741 JAMES HUTCHENS { 587-XX-XXXX 1505 EMMING LA 10/02/2007 06/13/1962 ROSSVILLE, GA 30741 ? JAMES HUTCHENS E I 587-XX-XXXX 1505 EMMING 09/13/2007 ROSSVILLE, GA 30741 JAMES HUTCHENS 587-XX-XXXX: 15 MARSHALL DR 04/30/2007 CAMP HILL, PA 17011 JAMES T HUTCHENS 587-XX-XXXX` 4583 NURSERY RD 04/28/2007 06/13/1962: DOVER, PA 17315 JAMES T HUTCHENS 587-XX-XXXX. 5 MARSHALL DR 04/07/2007 06/01 /1962 CAMP HILL, PA 17011 JAMES T HUTCHENS 5 MARSHALL DR 2/16/2006 I ^ CAMP HILL, PA 17011 l JAMES T HUTCHENS 587-XX-XXXX 06!13/1962 5 MARSHALL DR CAMP HILL, PA 17011 (717) 979-6073 12/13/2006 587-XX-XXXX 06/13/1962 JAMES HUTCHENS 5 MARSHEL DR CAMP HILL, PA 17011 11 /30/2006 587-XX-XXXX JAMES T HUTCHENS 5 MARSHALL DR (717) 732-7268 u 07/18/2006 06/13/1962 CAMP HILL, PA 17011 587-XX-XXXX' JAMES T HUTCHENS 5 MARSHALL DR 06/21/2006 CAMP HILL, PA 17011 587-XX-XXXX 06/13/1962 JAMES HUTHCHENS 5 MARSHALL DR (717) 732-7268 06/08/2006 CAMP HILL, PA 17011 i MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 OF iHE?ItDTF10N0TAR'( 2012 JUL 26 AM 10: 41 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2407-BC3 Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor Defendants. AMENDMENT TO MOTION FOR ALTERNATE SERVICE Pursuant to Cumberland County Local Rule 208.3(a)(2) and Rule 208.3(a)(9), please be of the following: Pursuant to Local Rule 208.3(a)(2) - No Judge has ruled upon any other issue(s) in the matter for the above captioned case. Pursuant to Local Rule 208.3(a)(9) - No concurrence of any opposing counsel of record wE sought as Plaintiff s Counsel is unable to locate said Defendants for service. Also, no counsel record has filed an entry of appearance with this Court for said Defendants. Respectfully submitted, MILSTEAD & ASSOCIATES, LLC B COURT OF COMMON PLEAS CUMBERLAND' COUNTY No.: 11-9556 Civil CL% ACTION MORTGAGE FQ ML F Attorney D ;T."203145 MILSTEAD & ASSOCIATES, LLC Michael J. Mdatad, Esq michwi@milstadlaw.com Richard M. MilgMad, Esq richard@o"endhtw.com Nelson Dia , Esq. PA & NJ ndiaz®mdsteadlaw.com Mary Harbert-Bell, Esq. PA & NJ mharbeert®mdstadlaw.com Patrick Wegner, Esq. PA & NJ pweerw@milgteadlaw.com Mark E. Herrera, Esq. PA & NJ mhwrwa@milsteadlaw. com Ryan A Gower, Esq. PA & NJ rgower@nWstadlaw.com Liss Ann fhonw, Sr. Forecbwre Administrator *Of Counsel July 25, 2012 Office of the Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: The Bank of New York Mellon vs. Susan E. Hutchens, et al. Case No.: 11-9356 Civil Dear Sir/Madam: Philadelphia ddress: 235 South i Street Philadelphia, 19107 Please Reply To: NJ Pffice FILE #: 45.16528 Enclosed please find an Amendment to Plaintiff's Motion for Alternate Service that was filed with this Court. Please file the original and forward same to the Court Administration to add in with our Motion for Alternate Service that was previously filed. Kindly forward a time-stamped copy of same to our office in the enclosed self-addressed envelope provided for your convenience. If you have any questions or need additional information, please feel free to contact me. Thank you for your attention in this matter. Very truly yours, ke Heather Forrest Salmon Paralegal Enclosures Attorneys at Law Woodland Falls Corporate Park 220 Lake Drive East, Ste 301 Cherry Hill, New Jersey 08002 TEL (856) 482-1400 FAX (856) 482-9190 {00495133} THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATE HOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff V. SUSAN E. HUTCHENS, Original Mortgagor and Real Owner and JAMES T. HUTCHENS, Original Mortgagor, Defendants a- q - IF-10 IWZ &00* IN THE COURT OF COMMON PLEAS THE NINTH JUDICIAL DISTRICT NO. 2011-9556 CIVIL TERM IN RE: MOTION FOR ALTERNATIVE SERVICE PURSUANT TO PENNSYLVANIA R.C.P. 430 ORDER OF COURT AND NOW, this 2W day of August, 2012, upon consideration of Pla Motion for Alternative Service, it is ordered and directed that service of the Compla# in this case upon Defendant James T. Hutchens, may be made (1) by First Class Ond Certified Mail, return receipt requested, no signature required at the last kn address, 5 Marshall Drive, Camp Hill, Pennsylvania 17011 and 159 Timberland Tt ail, Ringgold, Georgia 30736, with service to be deemed complete upon mailing; (2)1 by posting a copy of the same on the most public portion of the property located aft 5 Marshall Drive, Camp Hill, Pennsylvania 17011; and (3) by publication once in Cumberland County Law Journal and once in a newspaper of general circulatiod in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers to Defendant James T. Hutchens may be served by POSTING on the most public portion of the aforesaid Marshall Drive premises AND FIRST-CLASS MAIL at the aforesaid Marshall Drive address, with service to I be deemed complete upon mailing. PAPERS REQUIRED TO BE SERVED UPON DEFENDANT SUSAN I E. HUTCHENS shall be made pursuant to the applicable Pennsylvania Rules of Procedure and Cumberland County Rules of Procedure. BY THE COURT, Thomas A. Placey, C.P.J. Distribution: s Patrick J. Wesner Es q. ' Milstead & Associates, LLC 220 Lake Drive East, Suite 301 ?;, .. Cherry Hill, NJ 08002 r/ For Plaintiff C James T. Hutches 5 Marshall Drive Camp Hill, PA 17011 James T. Hutchens 159 Timberland Trail Ringgold, GA 30736 Susan E. Hutchens 337 Fulton Street Enola, PA 17025 SPY *?a :led s/a/.a /zlu MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff, Vs. _ i( a a ~' ~ ~ _, ,AJ ~ ~ ~vt~i}~ ! I tUi ~,t. 7 L ~f~Y i~ ~ ~~~~~ ~ ~~t~7`~fv , M in Attorney for a i File No. 45.16528 .COURT OF COMMON PLEAS CUMBERLAND COUNTY i ' r:_ y-.a ~-;~ ~, e ~ rv ~: -,~ - ..r T i ~ f w' No.: 11-9556 Civil ~ r== =; , ; ~- ~{ y Praecipe to Reinstate Comnlaint~ `~ ~` _~ -~ ~- `~' Mort~ase Foreclosure -- ~ ~~ ~, ~`. Susan E. Hutchens, Original Mortgagor " ~ ,ay -; ~~~ and Real Owner and James T. Hutchens, ~ '-~~ = - Original Mortgagor, Defendants. TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure for the above captioned matter. MILSTEAD & ASSOCIA Attorney ID No. X03 LLC D ~ .~ ~~ , ~sra a~ ~~~ 9 (~ t~a~~ Qb~l u3 ~.~ a~3 a~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~`,t~., of ~uniG,,rr.t~r~ ~1~: ~,N ~_.~.~. qtr t-~~.;~ PEN~dSYLVAt~fA The Bank of New York Mellon Case Number vs. Susan E. Hutchens (et al.) 2011-9556 SHERIFF'S RETURN OF SERVICE 11/15/2012 06:16 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: James T. Hutchens, pursuant to Order of Court by "Posting" the premises located at 5 Marshall Drive, East Pennsboro Township, Camp Hill, PA 17011 with a true and correct copy according to law. __.. RYAN BURGETT, DE SHERIFF COST: $49.00 November 16, 2012 SO ANSWERS, '"--- RON ~ R ANDERSON, SHERIFF it MILSTEAD & ASSOCIATES, LLC ,4` °_`, �' lA' BY: Patrick J. Wesner,Esquire 2013 MAR 22 ID No. 203145 ��� 220 Lake Drive East, Suite 301 ;�t '4 &ANUGOUNTY Cherry Hill,NJ 08002 Ptg SMA N I Ak (856)482-1400 Attorney for Plaintiff File No. 45.16528 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK,AS i CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, No.: 11-9556 Civil Plaintiff, Vs. Praeciae to Reinstate Complaint in Mortgage Foreclosure Susan E.Hutchens,Original Mortgagor and Real Owner and James T. Hutchens, Original Mortgagor, Defendants. TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure for the above captioned matter. MILSTEAD &ASSOCIATES, LLC 'ck es it Attorney ID No. 03 45 , a MILSTEAD & ASSOCIATES, LLC 1 : 1,1 1),.,, BY: Patrick J. Wesner, Esquire Attorney for Plaintiff -'i+3 J 'E 26 i V II: 6 ID No. 203145 -.1i f�nl_As10 COUNTY 220 Lake Drive East, Suite 301 PENNSYLVANIA Cherry Hill,NJ 08002 (856) 482-1400 File # 45.16528 THE BANK OF NEW YORK MELLON ' COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK, AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3 No.: 11-9556 Civil Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor Defendants. AFFIDAVIT OF SERVICE I, Patrick J. Wesner, Esquire, say that Defendant, James T. Hutchens Original Mortgagor, was served with the Complaint in Mortgage Foreclosure via Publication in the Patriot News on April 9, 2013 and in the Cumberland Law Journal on April 12, 2013 pursuant to the terms of the Court Order. The Proof of Publication is attached hereto as Exhibit "A". 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 18Pa.C.S. § 4904 relating to unsworn falsification to authorities. C\ /7 I' Patrick . +f esner, E'quir rf Attorney ID #20314/5 LI {00228975} 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 12, 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. Marie Coyne, ditor ( Lis SWORN TO AND SUBSCRIBED before me this 12 day of April, 2013 110_—:. -4.1(/ d A,./...; C . Notary h`,JTARIAL SEAL DEBORAH A COLLINS Notary Puulic CARLISLE BOROUGH,CUMBERLAND COUNTY ---- My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY Court of Common Pleas, BE ABLE TO PROVIDE YOU WITH Cumberland County INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES No. 11-9556 Civil TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. THE BANK OF NEW YORK Cumberland County MELLON fka THE BANK OF Bar Association NEW YORK,AS TRUSTEE 32 S. Bedford Street FOR THE BENEFIT OF THE Carlisle, PA 17013 CERTIFICATEHOLDERS OF THE (717) 249-3166 CWABS INC.,ASSET-BACKED (800) 990-9108 CERTIFICATES, SERIES 2007-BC3 PATRICK J.WESNER,ESQUIRE Plaintiff Attorney ID#203145 vs. MILSTEAD&ASSOCIATES, LLC Susan E. Hutchens, Original Attorneys for Plaintiff Mortgagor and Real Owner, Woodland Falls James T. Hutchens, Corporate Park Original Mortgagor 220 Lake Drive East Defendants Suite 301 Cherry Hill, NJ 08002 TO: James T. Hutchens, Original (856)482-1400 Mortgagor Apr. 12 TYPE OF ACTION:CIVIL ACTION/ COMPLAINT IN MORTGAGE FORE- CLOSURE. PREMISES SUBJECT TO FORE- CLOSURE: 5 Marshall Drive, Camp Hill,PA 17011. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your defenses or objections in writing to the court.You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE 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 INFORMA- TION ABOUT HIRING A LAWYER. 11 The Patriot-News Co. toixv 2020 Technology Pkwy patriotXews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 MILSTEAD &ASSOCIATES, LLC ATTN: HEATHER FORREST 220 LAKE DRIVE E. SUITE 301 CHERRY HILL NJ 08002 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 _^ CoCounty of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday general circulation, printed and published at 1900 Patriot Drive, in the City, County and State MILSTEADB ASSOCIATES,LLC ews and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, By:Patrick J.Wesner,Esquire en continuously published ever since; Attorney ID#203145 Woodland Fails Corporate.Park ce or publication which is securely attached hereto is exactly as printed and published in their regular 220 Lake Drive East,Suite 301 Cherry HIII,NJ 08002 unity Weekly editions which appeared on the date(s) indicated below. That neither she nor said or 482.1400 Attorney Plaintiff !subject matter of said printed notice or advertising, and that all of the allegations of this statement as File No.45.16528 ' THE BANK OF NEW YORK MEL- ter of publication are true; and LON FKA THE BANK OF ASTRU TEE FOR THE BENE IT OF ial knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on THE CERTIFICATEHOLDERS OF THE CWABS INC.,CAS ET-BACKED .;o. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the CERTIFICa�Plaintiff, ES 2007-BC3 rectors of the said Company and subsequently duly recorded in the office for the Recording of Deeds Susan E.Hutchens,Original Menge- uphin in Miscellaneous Book"M", Volume 14, Page 317. gar and Real Owner James T.Hutchens,Original Mortga- gor This.ad# 0002 • 2• .n on the dates shown below: • Defendants COURT OF COMMON PLEAS April 09, 2013 CUMBERLAND COUNTY -- No.: TO: James T.Hutchens,Original Mortgagor T Hut TYPE OF ACTION: CIVIL ' ACTION/COMPLAINT IN MORT- GAGE FORECLOSURE • MISES SUBJECT TO FORECLO *SURE Sworn to and subscribed before me this 10 day of April, 2013 A.D. 5 Marshall Drive,Camp Hill,PA 17011 NOTICE If you wish to defend,you must enter a written appearance personally or by at- tki1 ` 1 torney and file your defenses or obiec. _, lions in writing to the court. You are, Otary PU C warned That If you fail to do so the case may proceed without you and a judg- ment may be entered against you with- out further notice for the relief request- ed by the Plaintiff:You may lose money or property or other rights Important to. you. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER ATONCE. IF COMMONWEALTH OF PENNSYLVANIA YOU DO NOT HAVE A LAWYER,'GO TO OR TELEPHONE THE OFFICE Notarial Seal SET FORTH BELOW. THIS OFFICE •CAN PROVIDE YOU WITH INFORMPr Holly Lynn Warfel,Notary Public TION ABOUT HIRING A LAWYER. Washington Twp.,Dauphin County IF YOU CANNOT AFFORD TO HIRE My Commission Expires Dec.12,2016 A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH IN- • MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES FORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERV- ICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE: Cumberland County Bar.Association 32 S.Bedford Street Carlisle,PA 17013 717-249-3166 800-990-9108 The Patriot-News Co. JaftiotNews 2020 Technogy Pkwy Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 MILSTEAD &ASSOCIATES, LLC ATTN: HEATHER FORREST 220 LAKE DRIVE E. SUITE 301 CHERRY HILL NJ 08002 STATEMENTALL CHARGES ARE NET ACCT# NAME AD ORDER# DATE EDITION ADDTL. INFO. TYPE OF CHARGE AMOUNT 61071 MILSTEAD&ASSOCIATES,LLC 0002255293 04/09/13 REGULAR BOLD TEXT CHARGE $4.00 61071 MILSTEAD&ASSOCIATES, LLC 0002255293 04/09/13 REGULAR BASIC AD CHARGE $402.50 AFFIDAVIT CHARGE $5.00 TOTAL: $411.50 This is not an invoice. Please do not remit payment from this Statement. An invoice will be generated at the end of the month. --Thank you. NOTE: This Statement replaces the Order Confirmation which we previously sent with Proofs of Publication MILSTEAD&ASSOCIATES,LLC BY:Robert W.Williams,Esquire i ; 1 ID No.315501 t ( i� � , 220 Lake Drive East, Suite 301 I',j € f_ i #� Cherry Hill,NJ 08002 Cl . , �1• ;o•(856)482-1400 Attorney for Plaintiff „f¢ _^ L.File Number: 71.16528 '�'= ;,,L1-,,L.,41,10 COUNTY THE BANK OF NEW YORK MELLON FKA THE ' COURT OF commoriiiitiMsYLVA NIA BANK OF NEW YORK,AS TRUSTEE FOR THE CUMBERLAND COUNTY BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES,SERIES 2007-BC3 7105 Corporate Drive No.: 11-9556 Civil Plano,TX 75024, Plaintiff, Vs. Susan E.Hutchens,Original Mortgagor and Real Owner 337 Fulton Street Enola,PA 17025 and James T.Hutchens,Original Mortgagor 159 Timberland Trail, Ringgold,GA 30736 5 Marshall Drive Camp Hill,PA 17011, Defendants PRAECIPE FOR JUDGMENT,IN REM,FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter Judgment, in rem, in favor of Plaintiff and against Susan E.Hutchens,Original Mortgagor and Real Owner,James T.Hutchens,Original Mortgagor,Defendants,for failure to file an Answer on Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and sale of the mortgaged premises,and assess Plaintiffs damages as follows: As forth in Complaint $186,575.02 Interest 12/17/11 through 02/05/14 $29,442.30 TOTAL $216,017.32 I hereby certify that(1)the addresses of the Plaintiff and Defendants are as shown above and(2)that notice has been given in accordance with Rule 237.1.copy atta Robert W.Williams,Esquire Atto for P • If 1.1.7) . fr , DAMAGES A' HEREBY ASSESSED AS INDICATED �`'jet) ' . DATE: /0 *�1p.SO P i d alk PROTHONOTARY -P#36iN3a -1,10-06e. lo-l)c 1 n t led Is MILSTEAD& ASSOCIATES, LLC BY: Patrick J. Wesner,Esquire ID No. 203145 220 Lake Drive Fast, Suite 301 Cherry Hill,NJ 08002 (856) 482-1400 Attorney for Plaintiff Our file number: 45.16528 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FICA THE BANK OF NEW YORK,AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE No.: 11-9556 Civil CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner and James T. Hutchens, Original Mortgagor Defendants. TO: Susan E.Hutchens, James T. Hutchens, James T. Hutchens, Original Mortgagor and Original Mortgagor Original Mortgagor Real Owner 159 Timberland Trail„ 5 Marshall Drive 337 Fulton Street, Ringgold,GA 30736 Camp Hill; PA 17011 Enola, PA 17025 DATE OF NOTICE: June 12,2013 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOT[CE IS SENT TO YOU [N 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 BANKRU?TCY,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 claims set forth against you. Unless you act within ten (10) days from the date of this notice,a judgment may be entered {00020971? Page l of 2 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 10 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 717-249-3166 MILSTEAD &ASSOC[AT -S, LLC 13y:Pat• . TY esne squire 4-ID-No. 203145 Attorney for Plaihtif i {0020971} Page 2 of 2 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary To: Susan E. Hutchens, Original Mortgagor and Real Owner 337 Fulton Street Enola, PA 17025 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK,AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE No.: 11-9556 Civil CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner, and James T. Hutchens, Original Mortgagor, Defendants NOTICE PURSUANT TO RULE 236 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Robert W. Williams, ESQ. 315501 MILSTEAD &ASSOCIATES, LLC 856-482-1400 Notice Pursuant To Fair Debt Collection Practices Act This is an attempt to collect a debt and any information obtained will be used for that purpose. 7.) • OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary To: James T. Hutchens, Original Mortgagor 159 Timberland Trail, Ringgold, GA 30736 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK, AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE No.: 11-9556 Civil CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner, and James T. Hutchens, Original Mortgagor, Defendants NOTICE PURSUANT TO RULE 236 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Robert W. Williams, ESQ. 315501 MILSTEAD & ASSOCIATES, LLC 856-482-1400 Notice Pursuant To Fair Debt Collection Practices Act • This is an attempt to collect a debt and any information obtain - 'll b ed folly purposes cd9 touit,"4 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary To: James T. Hutchens, Original Mortgagor 5 Marshall Drive Camp Hill, PA 17011 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK,AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE No.: 11-9556 Civil CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner, and James T. Hutchens, Original Mortgagor, Defendants NOTICE PURSUANT TO RULE 236 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: Robert W. Williams, ESQ. 315501 MILSTEAD & ASSOCIATES, LLC 856-482-1400 Notice Pursuant To Fair Debt Collection Practices Act This is an attempt to collect a debt and any information obtained will be used for that purpose. 4114 , 47) . MILSTEAD & ASSOCIATES, LLC BY: Robert W. Williams, Esquire ID No. 315501 220 Lake Drive East, Suite 301 Cherry Hill,NJ 08002 (856) 482-1400 Attorney for Plaintiff File Number: 71.16528 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK,AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED No.: 11-9556 Civil CERTIFICATES, SERIES 2007-BC3, Plaintiff, Vs. Susan E. Hutchens, Original Mortgagor and Real Owner and James T. Hutchens, Original Mortgagor, Defendants VERIFICATION OF NON-MILITARY SERVICE Robert W. Williams, Esquire, hereby certifies that he is attorney for the Plaintiff in the above-captioned matter, and verifies the following facts to the best of his information and belief: 1. inquiry has been made with the Department of Defense, and it has been determined that Defendants are not in the Military or Naval Service of the United States or its Allies, and/or do not fall within the provisions of the Servicemembers Civil Relief Act of 2003, 50 USC App.§ 501 2. defendant, Susan E. Hutchens, Original Mortgagor and Real Owner, is over 18 years of age, 3. defendant, James T. Hutchens, Origina ∎ 4 : gagor, is over 18 ye.r of age, 1 DATE: I410 1 Ro.-rt W. Williams, Esquire Department of Defense Manpower Data Center Results as of:Feb-07-2014 05:00:28 AM SCRA 3.0 4 r iaa Y:. r J Status Report _ ", Pursuant to Servicemembers Civil Relief Act Last Name: HUTCHENS First Name: JAMES Middle Name: T. Active Duty Status As Of: Feb-07-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA . 'No •.. NA This response reflects the Individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. )1101 )41. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 `Department of Defense Manpower Data Center Results as of:Feb-07-2014 05:00:44 AM SCRA 3.0 '• Status Report st /' ° Pursuant to Servicemembers Civil Relief Act Last Name: HUTCHENS First Name: SUSAN Middle Name: E. Active Duty Status As Of: Feb-07-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - -No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Da s of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA 'NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No ` ' NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. )4. 4 . Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 MILSTEAD &ASSOCIATES, LLC BY: Robert W. Williams, Esquire ID No. 315501 220 Lake Drive East, Suite 301 Cherry Hill,NJ 08002 (856) 482-1400 Attorney for Plaintiff File No. 71.16528 THE BANK OF NEW YORK MELLON FKA COURT OF COMMON PLEAS THE BANK OF NEW YORK,AS TRUSTEE CUMBERLAND COUNTY FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS No.: 11-9556 Civil INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3 CIVIL ACTION MORTGAGE FORECLOSURE Plaintiff, Vs. Susan E.Hutchens,Original Mortgagor and Real Owner James T.Hutchens,Original Mortgagor Defendants CERTIFICATE OF SERVICE I, Robert W. Williams, Esquire, do hereby certify that the Complaint in Mortgage Foreclosure was served upon Defendants, Susan E. Hutchens, Original Mortgagor and Real Owner, James T. Hutchens, Original Mortgagor on April 12, 2013 by the Cumberland County Sheriff. A copy of the Service Returns are attached hereto and made a part hereof as Exhibit «A„ 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 18Pa.C.S. § 4904 - at'ng to unsworn falsification to authorities. Robert W. Williams, Esquire Attorney for Plaintiff THE BANK OF NEW YORK MELON f/k/a �j' ,.UU 11 THE BANK OF NEW YORK, AS TRUSTEE r r u o.,, FOR THE BENEFIT CF THE all y` CERTIFICATE HOLDERS OFT::-iE CWABS INC., ASSET-BACKED CERTIF=GATES, SERIES 2007-BC3, IN THE COURT OF COMMON PLEAS OF Plaintiff THE NINTH JUDICIAL DISTRICT v. SUSAN E. HUTCHENS, Original Mortgagor and Real Owner and JAMES T. HUTCHENS, Original.Mortgagor, Defendants NO. 2011-9556 CIVIL TERM IN RE: MOTION FOR ALTERNATIVE SERVICE PURSUANT TO PENNSYLVANIA R.C.P. 430 ORDER OF COURT AND NOW, this 2.PP day of August, 2012, upon consideration of Plaintiff's Motion for Alternative Service, it is ordered and directed that service of the Complaint in this case upon Defendant James T. Hutchens, may be made (1) by First Class and Certified Mail, return receipt requested, no signature required at the last known address, 5 Marshall Drive, Camp Hill, Pennsylvania 17011 and 159 Timberland Trail, Ringgold, Georgia 30736, with service to be deemed complete upon mai ing; (2) by posting a copy of the same on the most public pertion of the property located at 5 Marshall Drive, Camp Hill, Pennsylvania 17011; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules cf Civil Procedure and Cumberland County Rules of Procedure. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff o.�t at ;utf•ty,��� Jody S Smith Chief Deputy • Richard W Stewart Solicitor oFF3cE,wF n. 4t rF,ifF ( (9, S—t The Bank of New York Mellon Case Number vs. Susan E. Hutchens (et al.) 2011-9556 SHERIFF'S RETURN OF SERVICE 11/15i2012 06:16 PM-Deputy Ryan Burgett being duly sworn according to law, served the requested Complaint h Mortgage Foreclosure upon the within named Defendant, to wit: James T. Hutchens,pursuant to Orde-of Court by'Posting"the premises bcated at 5 Marshall Drive, East Pennsboro Township, Camp Hill, PA 17011 wits a true anc correct copy according to law. RYAN BURGETT,DEPUTY- SHERIFF COST:$49.03 SO ANSWERS, t,Y November 16, 2012 RON14( R ANDERSON,SHERIFF (c)CcuntySute Sheriff Teleosof,Inc. • SUBSEQUENT papers to Defendant James T. Hutchens may be served by POSTING on the most public portion of the aforesaid Marshall Drive premises AND FIRST-CLASS MAIL at the aforesaid Marshall Drive adcress, with service to be deemed complete upon mailing. PAPERS REQUIRED TO BE SERVED UPON DEFENDANT SUSAN E. HUTCHENS shall be made pursuant to the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. BY THE COURT, Thomas A Placey, C.P.J. Distributior: r Patrick J. Wesner, Esq. -� ,� Iri_ ' Milstead &Associates, LLC -� 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 -n For Plaintiff r. N °•_I' James T. Hutches 5 Marshall Drive Camp Hill, PA 17011 James T. Hutchens 159 Timberland Trail Ringgold, GA 30736 Susan E. Hutchens 337 Fulton Street Enola, PA 17025 • 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 12, 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. (Lis Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 12 day of April, 2C13 Cd. ....- , , Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Pubic i CARLISLE BCROUGH,CUMBERLAND COUVTY My Comnission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY Court of Common Pleas, BE ABLE TO PROVIDE YOU WITH Cumberland County INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES No. 11-9556 Ci'i l TO ELIGIELE PERSONS AT A RE- DUCED FEE OR NO FEE. THE BANK OF NEW YORK Cumberland County MELLON fka THE BANK OF Bar AssDciaticn NEW YORK,AS TRUSTEE 32 S.Bedford Street FOR THE BENEFIT OF THE Carlisle PA 17013 CERTIFICATEHCLDERS OF'THE (717)249-3166 CWABS INC.,ASSET-BACKED (500)990-9108 CERTIFICATES, SERIES 2007-BC3 P.ATRICi J.WESNER,ESQUIRE Plaintiff Attorney ID#203145 vs. MILSTEAD&ASSOCIATES,LLC Susan K Hutchens,Original Attorneys for Plaintiff Mortgagor ark Real Owner, Woodland Falls James T.Hutchens, Corporate Park Original Mortgagor 220 Lake Drive East l Defendants Suite 301 Cherry Hill, NJ 08002 TO: James T. Hutchens, Original (856)482-1400 Mortgagor Apr. 12 TYPE OFACTION:CIVILACTiON/ COMPLAINT IN MORTGAGE FORE- CLOSURE. PREMISES SUBJECT TO FORE- CLOSURE: 5 Marshall Drive, Camp Hill,PA 17011. NOTICE If you wish to defend, you must enter a written appearance person- ally cr by attorney and file your defenses or objections in writing to the court.You are warned that if you fail tc do so the case may proceed without you and ajudgn.ent may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE 9 LAWYER, GO TO OR TELEPHONE'THE OFFICE SET FORTE BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA- TION ABOUT HIRING A LAWYER. 11 The Patriot-News Co. 2020 Technology Pkwy pattiOtmXtttlS Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries -717-255-8213 MILSTEAD &ASSOCIATES, LLC ATTN: HEATHER FORREST 220 LAKE DRIVE E. SUITE 301 CHERRY HILL NJ 08002 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 accorcing 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 en County of Cumberland, State of Pennsylvania, owner and publisher of The Patrict-News and The Sunday general circulation, printed and published at 1900 Patriot Dive, in the City, County and State NU LSTEIID d ASSOCIATES LLC ews and The Sunday Patriot-News were established March 4th, 1854, and Septenber 18th, 1949, By Patlfak.1 Wesner,Esquire en continuously published ever since; AttomeyD#2°3T45.„ -? WooitaridFalsCar}crotePark ce or publication which is securely attached hereto is exactly as printed and published in their regular Ch rryHUI11-1 00002 U7fe3o1 unity Weekly editions which appeared on the date(s) indicated bebw. That neither she nor said (856)482.140( AltorneyforP1eIntltt = subject matte of said printed notice or advertising, and that all of the allegations of this statement as F1leETAI.1628 LOTHFKANKOF EWY tNREktIVMY,OR14 .,terof publication are true, and AS TRUSTEE FORTE BENEFIT OF ial knowledge of the facts aforesaid and is duly authorized and empowered to veriy this statement on THE WAS F BAES¢T-BROOD '.;o. aforesaid by virtue and pursuant to a resolution unanimously p assed and ado 'ed severally by the CERTIFICATES SERIES 2091-ec3 rectors of the said Company and subsequently duly recorded in the office for the Recording cf Deeds Plaintff a bin in Miscellaneous Book"M', Volume 14, Page 317. Susai E.Hafdlens,Original Mortgo- P gor and Real Owner James T.Hut;hens Original Mango- gor This.ad# 0002 2 - -non the dates shown below: Defendants tOURT.OF COMMON PLEAS April OS,2013 CUMBERLANDCOUNrY NP` 11.9556 Civil TO: James T futchens,Originol MortgfoOr TYPE OF ACTION; CIVIL ACTION/COMPLAINT IN MORT- GAGE FORECLOSURE pREMISESSUBJ cT�T RECLO 'SURE Sworn to and subscribed before me this 10 day of April, 2013 A.D. - �€ ��;=����. 5 Marshall Drive Canp HIII,TA 17011 NOTICE , I If you wish toSiefefuL you must enter a wrlttenappegrer e.pertoflally a by at- torney and ille+ollt defenses or Malec- norm s ;� Lions Inwrltiap t 'the corrt you are,' warned thstIt.0uxglltcdoso ire case `OtaryPut c may pnceed lsethoct,y+OJ and a ludg- ment may be"ettered against.yon with-' out turner notice for the relief request- ed by the Plaintiff>.You maylose money or properfv or other rights important to. you YOU SHOULD TAKETHIS NOTICE TO YOUR LAWYERAT,ONCE,IF. COMMONWEALTH OF PENNSYLVANIA YOU OOP-1'0T T RAVE A LAWYEt,GO TO OR TELEPHONE THE OFFICE Notaral Seal SET.FORTH BELOW. THIS OFFICE - Holly Lynn Warfel,Notary Pubic CAN PROVIDEYOO WITH INFORMA Washington Twp,Dauphin my "IF YOU TION ABOUT IIiRtNG A LAWYER" g p.,Dau hin Cou "LAW'LAWYER,THIS OFFICE AFFORD rp MIRE My Commksion E>'pires Dec.12,2016 ABLE T0PROVIDE YOU WITH IN- ' MEMBER,PENNSILVANIAASSOCIATION OF VOTARIES FORMATION J,BOUTAGE NCI ES THAT IAAY OFFER LEGAL SERV- ICES TD ELIGIBLE PERSONSAT A REDUCED FEE OR NCEEE.. Cumberland County Bar Association 32 S.Bedford Street Carlisle,PA 17013 t. 717-249-3166 EM-o n-o1nR 0 o C*4 10 Le)C,1 CO 11,41 t CNA II I u_ C) o u_ t 0 c • N c) CNI r.n ,• to.4. YrI • : • •• • •• , • • • • — rn ▪ g --- F tri "c▪ d ▪ -• 61) =. g = \ \ % i9�- y \mow ° \ 0-j‘ 0 > ƒ 5D « � = f 20 \\2 = 2 »�I � /\y /± �� \\ * \ : 2, \ ' . : \ = \ 1 ,�.\ \. 0 r ��� � �� % / . , % Q �� *:1''',12, ---: : it,/ I'''. II • • 1 li Na CO N W r- c) O p p 0 r N co /.y�-- o lit■ i� � omo j �aOU a 0. 0 � ` o ° To ■ r ∎∎• a m J W oo � 0•' i 1.'.. • S. Ci 0 =ti 1-r ig I • i N O c7 N W 3 N �--O m l■ CO W W"W ill om 9 apLL to 0 LL O s t-.a rq � C141/Nn N o "c- c) og i. . _ ry: • 1 . .T . .3,,j;i." ■ I: l_ tf a , ' .La t c mW = inCY IMPOINNINMOIMIM `° _ o I ILL. �_ U c at --�_ N _.a P. =WAa i MILSTEAD & ASSOCIATES, LLC Jr THE 1' C TH-0-tio-�A t�_} BY: Robert W. Williams,Esquire �- I ID No. 315501 AH 11: o.5 220 Lake Drive East, Suite 301 CUMBERLAND COUNT` Cherry Hill,NJ 08002 PENNS YLV ' � (856)482-1400 Attorney for Plaintiff File Number: 71.16528 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK,AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, No.: 11-9556 Civil Plaintiff, Entry of Appearance Vs. Susan E. Hutchens, Original Mortgagor and Real Owner, and James T. Hutchens, Original Mortgagor, Defendant(s). ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Plaintiff, THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK,AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, in the above captioned matter. M & CIATES L Roe . Williams, tsquire Attorney ID No. 315501 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THE BANK OF NEW YORK MELLON FKA CIVIL ACTION THE BANK OF NEW YORK,AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS ; NO.: 11-9556 Civil INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, PRAECIPE FOR WRIT OF EXECUTION Plaintiff, (Mortgage Foreclosure) Vs. Susan E.Hutchens,Original Mortgagor and Real Owner and -TO -Ys s.1,i All that certain lot or parcel of land situate in the Township of East Pennsboro, County of Cumberland, Commonwealth of Pennsylvania, and being more particularly described as follows: Beginning at a point at the Northwesterly corner of Marshall Drive, which point is 184.49 feet West of the Northwesterly corner of Matthew Road and Marshall Drive, and at dividing line between Lots Nos. 9 and 10, Block G, on hereinafter mentioned Plan of Lots; thence along the Northwesterly line of Marshall Drive, in an arc having a radius of 250 feet in a Southwesterly direction to the left, 69 feet to a point at dividing line between Lots No. 8 and 9, Block G, on said Plan; thence along said dividing line North 46 degrees 14 minutes 30 seconds West 120.12 feet to a point at land now or late of Glenwood Park, Inc..; thence along same North 51 degrees 40 minutes East 101.82 feet to a point at dividing line between Lots Nos.9 and 10, Block G, on said plan; thence along said dividing line South 30 degrees 25 minutes 45 seconds East 120.12 feet to a point, the place of beginning. And being Lot No. 9, Block G, in Plan No. 3, Ridley park which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 14, Page 22. Title to said Premises vested in Susan E. Hutchens by Deed from James T. Hutchens and Susan E. Hutchens dated 3/28/2007 and recorded on 6/11/2007 in the Cumberland County Recorder of Deeds in Book 280, Page 2089. Being known as 5 Marshall Drive, Camp Hill,PA 17011 Tax Parcel Number: 09-16-1050-332 MILSTEAD&ASSOCIATES,LLC i . t % "', t ' BY Robert W.Williams,Esquire `f p W i ID No. 315501 t ; 1 E. Stow Road . :'i r E ; Marlton,NJ 08053 ( (856)482-1400 p ERL4No c°1-I 7 , Attorney for Plaintiff ENA S 'LVANIA File Number: 71.16528 THE BANK OF NEW YORK MELLON FKA COURT OF COMMON PLEAS THE BANK OF NEW YORK,AS TRUSTEE CUMBERLAND COUNTY FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES, No.: 11-9556 Civil SERIES 2007-BC3, Plaintiff, AFFIDAVIT OF SERVICE Vs. PURSUANT TO RULE 3129.1 Susan E.Hutchens,Original Mortgagor and Real Owner and James T.Hutchens,Original Mortgagor Defendants THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe for writ of execution was filed the following information concerning the real property located at 5 Marshall Drive, Camp Hill, PA 17011: 1. Name and address of Owners(s) or Reputed Owner(s): Susan E.Hutchens,Original James T.Hutchens,Original James T.Hutchens,Original Mortgagor and Real Owner Mortgagor Mortgagor 337 Fulton Street 159 Timberland Trail, 5 Marshall Drive Enola,PA 17025 Ringgold,GA 30736 Camp Hill,PA 17011 2. Name and address of Defendant(s) in the Judgment: Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK,AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES,SERIES 2007-BC3 (Plaintiff herein) 7105 Corporate Drive Plano,TX 75024 4. Name and Address of the last recorded holder of every mortgage of record: THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK,AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3 (Plaintiff herein) 7105 Corporate Drive Plano,TX 75024 5. Name and address of every other person who has any record lien on the property: East Pennsboro Township 98 S. Enola Drive Enola,PA 17025 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: None Known 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenant/Occupant Department of Domestic Relations 5 Marshall Drive Cumberland County Courthouse Camp Hill, PA 17011 13 N. Hanover Street Carlisle,PA 17013 Commonwealth of Pennsylvania Department of Welfare East Pennsboro Township Tax Office P.O. Box 2675 98 S. Enola drive,Room 101 Harrisburg, PA 17105 Enola, PA 17025 Cumberland County Tax Bureau East Pennsboro Area School District 21 Waterford Drive, Suite 201 890 Valley Street Mechanicsburg, PA 17050 Enola, PA 17025 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1-4<160-ktik_ Robert W. Williams, Esquire Attorney for Plaintiff Date: 21121 1 � l MILSTEAD &ASSOCIATES, LLC BY: Robert W. Williams, Esquire rfc ..PP4� tr{'n 1(..t_ ID No. 315501 � ��' �' 1E. Stow Road c0iLi FEB25 APB +!: 32 Marlton,NJ 08053 CUMBERLAND EN (856)482-1400 PE NS YL COUNT"' ; Attorney for Plaintiff ANI, File Number: 71.16528 THE BANK OF NEW YORK MELLON COURT OF COMMON PLEAS FKA THE BANK OF NEW YORK,AS CUMBERLAND COUNTY TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE No.: 11-9556 Civil CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, NOTICE OF SHERIFF'S SALE OF Plaintiff, REAL PROPERTY PURSUANT TO PA.R.C.P.3129 Vs. Susan E. Hutchens, Original Mortgagor and Real Owner and James T. Hutchens, Original Mortgagor, Defendants TAKE NOTICE: Your house (real estate) at 5 Marshall Drive, Camp Hill, PA 17011, is scheduled to be sold at sheriff's sale on June 4,2014 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of $216,027.32 obtained by THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES, SERIES 2007-BC3. 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 cancelled if you pay to Milstead&Associates LLC, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 856-482-1400. 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 following page 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 bid price by calling Milstead &Associates at 856-482-1400. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a Deed to the Buyer. At that time,the Buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A Schedule of distribution of the money bid for your house will be filed by the Sheriff on a date specified by the Sheriff not later than thirty days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the Sale. YOU SHOULD TAKE THIS PAPER TO YOU 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 32 S. Bedford Street Carlisle,PA 17013 717-249-3166 71.16528 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S) Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor PLAINTIFF/SELLER: THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET- BACKED CERTIFICATES, SERIES 2007-BC3 DEFENDANT(S): Susan E. Hutchens, Original Mortgagor and Real Owner James T. Hutchens, Original Mortgagor PROPERTY: 5 Marshall Drive Camp Hill,PA 17011 (Improvements erected thereon) JUDGMENT AMOUNT: $216,027.32 CUMBERLAND COUNTY No.: 11-9556 Civil The above captioned property is scheduled to be sold at Sheriff's Sale on June 4,2014 at 10:00 am in the Commissioner's Hearing Room, Cumberland County Courthouse, Carlisle, PA 17013. You may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after the sale. Distribution will be made in accordance with the schedule unless exceptions are filed hereto within 10 days after the filing of the schedule. Sincerely, TIAL Robert W. Williams, Esquire MILSTEAD &ASSOCIATES, LLC 1 E. Stow Road Marlton,NJ 08053 71.16528 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-9556 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW YORK,AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC.,ASSET-BACKED CERTIFICATES,SERIES 2007-BC3 Plaintiff(s) From SUSAN E.HUTCHENS,JAMES T.HUTCHENS,ORIGINAL MORTGAGOR AND REAL OWNER (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: $216,027.32 L.L.: $.50 Interest FROM 2/6/14 TO DATE OF SALE AT$37.65 PER DIEM(6%) Atty's Comm: Due Prothy: $2.25 Atty Paid: $285.25 Other Costs: Plaintiff Paid: Date: 2/25/14 . 404.Lt2e1: _ikLe■ee-/ David D. Bu-11,Prothonot. ,/ (Seal) = ! ��. �/i/z_ ` Deputy REQUESTING PARTY: Name: ROBERT W.WILLIAMS,ESQUIRE Address: MILSTEAD&ASSOCIATES,LLC 1 E.STOW ROAD MARLTON,NJ 08053 Attorney for: PLAINTIFF Telephone: 856-482-1400 Supreme Court ID No.315501 MILSTEAD & ASSOCIATES, LLC BY: Robert W. Williams, Esquire ID No. 315501 1 E. Stow Road Marlton, NJ 08053 (856) 482-1400 Attorney for Plaintiff File No. 71.16528 n r r. THE Pj O flONOTAF, , 26I4 NH -2 PM 12: 56 CUMBERLAND NVACOUNT A THE BANK OF NEW YORK MELLON FKA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTIFICATEHOLDERS OF THE CWABS INC., ASSET-BACKED CERTIFICATES, SERIES 2007-BC3, Plaintiff, vs. Susan E. Hutchens, Original Mortgagor and Real Owner and James T. Hutchens, Original Mortgagor Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 11-9556 Civil AFFIDAVIT PURSUANT TO Pa.R.C.P. 3129.2 I, Robert W. Williams, Esquire, say: 1. By March 24, 2014, a copy of the Notice of Sheriff's Sale of Real Property was served upon the defendants, Susan E. Hutchens, Original Mortgagor and Real Owner and James T. Hutchens, Original Mortgagor. Copies are attached hereto and made a part hereof as Exhibit «A» 2. On March 5, 2014, a notice of Sheriff's Sale was served upon lien holders of record and interested parties by ordinary mail A copy of the certificate of mailing is attached hereto and made a part hereof as Exhibit "B". 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. § 4904 relating to unsworn falsification to authorities. Dated: May '_\ 2014 '4law *a Robe 7. . Williams, Esquire Attorney ID No. 315501 Milstead and Associates, LLC -l05 iUU I H 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215} 546-7400 FAX: (215) 985.0169 BetvfcesforPsofesrlonarelnc.eg for professionals inn.. The Bank of New York Mellon, et al VS - Susan E. Hutchens, et al COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: National Atso:M t:onof Phaado4ohlo'Assoctation ProtesslonarProcess Servers or Professional Pro essBerren COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 11 -9556 -Civil AFFIDAVIT OF SERVICE BIR Control # CS111066-1 Reference Number 71.16528 SERVICE INFORMATION On 5 day of March, 2014 we received the Notice of Sheriff Sale for service upon James T. Hutchens at 159 Timberland Trail Ringgold, GA 30736 ***Special Instructions *** -Served Date May. /0 aoiLi Time _ 6; U a% Accepted By: --)a.449.,..5 7 /i 4 ' ,Lo c In the manner described below. Personally served. Adult family member. Relationship is ri Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other Description of Person Age /7 Height & ID n Weight /'(7 Race [_'11kt(',etL1,,Sex Other e,. i ,', X81 yk:ed t ' r od Ji_ DI , 6 f ,_s©'Y 6 ED Not Served Date Not Served Information Time Li Moved 11 Unknown I I No Answer I I Vacant J I Other The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and belief. Process Server/844f Law Firm Phone (856)482-1400 James Scafide Milstead and Associates 1 East Stow Road Marlton, NJ 08053 • Fo +,,:ti{111!1/,,,l�I pnn CO3�. '', G',ter 4T . r r r r ~ A : ' — t '~! f day of . Lt ftr�i V1 c_7,0 t -m:A L. • o Ve Lid+ _ `e 1 ,� o:„.:,:;:itlini.t,y_.:_,:::,•••��',IPly Commis ion Expire eo ,7,Or to Public Sworn to and subscribed before me this ServeBy Date 3/17/2014 Filed Date SALE DATE 6/4/2014 ORIGINAL 064DB Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewa Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICI OP 114: The Bank of New York Mellon vs. Susan E. Hutchens (et al.) Case Numbe 2011-9556 SHERIFF'S RETURN OF SERVICE 03/24/2014 07:22 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Susan E. Hutchens at 337 Fulton Street, East Pennsboro Township, Enola, PA 17025, Cumberland County. 03/28/2014 07:46 PM - Dty RBurgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: James T. Hutchens, pursuant to Order of Court by "Posting" the premises located at 5 Marshall Drive, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County with a true and correct copy according to law. 03/28/2014 07:46 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was perforrned by posting a true copy of the requested ReaEstate WritNotice and Description, and Sale Handbill in the above titled action, upon the property located at 5 Marshall Dave, East Pennsboro - Township, Camp Hill, PA 17011, Cumberland County. SHERIFF COST: $1,397.95 SO ANSWERS, May 22,204 RONli R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleasoft, Inc, NAME AND ADDRESS OF SENDER INDICATE TYPE OF MAIL CHECK APPROPIATE BLOCK FOR POSTMARK AND DATE OF RECEIPT MILSTEAD & ASSOCIATES, LLC 1 East Stow Road Marlton, NJ 08054 X Certificate Mailing 0 insured 0 COD 0 Certified Mall Registered Mail: 0 With! 0 Wlthc4' ---- . _. I ,'. Affix stamp rr iu ®, her P0 M ';"f ,.�,�,.r,as,„ FROM if k es 003°76° MAR ZIP CODE wpri as ,-orIfinmte of bill: Line Number of Article Name of Addressee, Street, and Post -Office Address Postage Fee Handling Charge Act. Value (If Regis �e alCiawr BOWES r" .. "'` "• t"l(.'t031710GF3 „,.: b 0, x'�* . - ' MAILED 1 THE BANK OF NEW YORK MELLON FICA THE BANK OF NEW YORK, AS TRUSTEE FOR THE BENEFIT OF THE CERTiFICATEHOLDERS OF THE CWABS INC, ASSET-BACKED CERTIFICATES, SERIES 2007-BC3 7105 Corporate Drive PlanoLTX 75024 _ ". 05 2014 08053 .,. 4.,.. ,\ ) -V; 2 East Pennsboro TownshipC 98 S. Enola Drive Enols, PA 17025 R ' ro �A C v .. 2014 u �• . 3 Tenant/Occupant 5 Marshall Drive Camp Hill, PA 17011 a cS- ,„\' c -. Ml a; / --• �5�,. 4 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 5 Cumberland County Tax Bureau 21 Waterford Drive, Suite 201 Mechanicsburg, PA 17050 6 Department of Domestic Relations Cumberland County Courthouse 13 N, Hanover Street Carlisle, PA 17013 7 East Pennsboro Township Tax Office 98 S. Enola drive, Room 101 Enola, PA 17025 B East Pennsboro Area School District 890 Valley Street Enola, PA 17025 9 10 Total Number of Pieces Listed by Sender 8 POSTMASTER, {Name of receiving glfOr PER e ploye- di" ��� The full declaration of value is required on ail domestic and international registered mall, The maximum indemnity payable for nonnegotiable documents under Express Mail document reconstruction insurance is $50,000 per piece subject to a limit of $50,000 per occurrence. The maximum Indemnity payable on Express Mail merchandise insurance is $500. The maximum indemnity payable Is $25,000 for Registered Mail, $500 for COD and $500 for Insured Mail. Special handling charges apply only to Third- and Fourth -Class parcels. Special delivery service also Includes special handling service. �" - PS FORM 3877 71.16628iHutchens Notice of Sale FOR REGISTERED, INSURED, C.O.D., CERTIFIED, AND EXPRESS MAIL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED -OFFICE Sheriff THE PROTHOHOTA Y Jody S Smith Chief Deputy Richard W Stewart Solicitor Qt.11'3f7}f OFF GE OF' THE St ERIFF 2014 JUL 25 PH 2: 314 CUMBERLAND COUNTY PENNSYLVANIA The Bank of New York Mellon vs. Case Number Susan E. Hutchens (et al.) 2011-9556 SHERIFF'S RETURN OF SERVICE 03/24/2014 07:22 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Susan E. Hutchens at 337 Fulton Street, East Pennsboro Township, Enola, PA 17025, Cumberland County. 03/28/2014 07:46 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: James T. Hutchens, pursuant to Order of Court by "Posting" the premises located at 5 Marshall Drive, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County with a true and correct copy according to law. 03/28/2014 07:46 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 5 Marshall Drive, East Pennsboro - Township, Camp Hill, PA 17011, Cumberland County. 06/04/2014 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, 17013 at 1000 am on June 4, 2014. He sold the same for the sum of $1.00 to Attorney Robert Williams, on behalf of, The Bank of New York Mellon, F/K/A The Bank of New York, As Trustee for the Benefit of the Certificateholders of the CWABS Inc., Asset -Backed Certificates, Series 2007-BC3, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $1,043.41 SO ANSWERS, July 02, 2014 RONR ANDERSON, SHERIFF ;c) CountySu to Sheriff. Telecsott. Inc. i'.Ot pd - oJ a?-as---/q01c2. • sv pq - ab4 97,0 .3o10-5- On February 28, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Z" `"East Pennsboro Township, Cumberland County, PA, 1y) }� ;:c 0- C/) ) . :.1 as Exhibit "A" filed with this writ � 0 N Known and numbered as 5 Marshall Drive, Camp Hill, and by this Reference incorporated herein. Date: February 28, 2014 By: U6,a�3n^, Real Estate Coordinator - LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2011-9556 Civil Term The Bank of New York Mellon vs. Susan E. Hutchens James T. Hutchens Atty.: Robert W. Williams All that certain lot or parcel of Iand situate in the Township of East Pennsboro, County of Cumberland, Commonwealth of Pennsylvania, and being more particularly described as follows: Beginning at a point at the North- westerly comer of Marshall Drive, which point is 184.49 feet West of the Northwesterly comer of Matthew Road and Marshall Drive, and at dividing line between Lots Nos. 9 and 10, Block G, on hereinafter men- tioned Plan of Lots; thence along the Northwesterly line of Marshall Drive, in an arc having a radius of 250 feet in a Southwesterly direction to the left, 69 feet to a point at dividing line between Lots NO.8 and 9, Block G, on said Plan; thence along said dividing line North 46 degrees 14 minutes 30 seconds West 120.12 feet to a point at land now or late of Glenwood Park, Inc. thence along same North 51 de- grees 40 minutes East 101.82 feet to a point at dividing line between Lots Nos.9 and 10, Block G, on said plan; thence along said dividing line South 30 degrees 25 minutes 45 seconds East 120.12 feet to a point, the place of beginning. And being Lot No.9, Block G, in Plan No.3, Ridley park which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 14, Page 22. Title to said Premises vested in Susan E. Hutchens by Deed from James T. Hutchens and Susan E. Hutchens dated 3/28/2007 and recorded on 6/11/2007 in the Cum- berland County Recorder of Deeds in Book 280, Page 2089. 70 Being known as 5 Marshall Drive, Camp Hill, PA 17011. Tax Parcel Number: 09-16-1050- 332. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. AA", isa Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this da of Ma 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 - The Patriot -News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg,.PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he patriotNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News 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. 006,101- D * 3�e C'� aPaO 4 a� P h� •aa�d ao1\ ae ap pae Q ao o Gaa ao �d rO Pae�� ateaals dicaAl . oQ°ase p (apOD o11� t l\s mine rtes a la�Qp1. ti ma�`O aye Y� feet ,dsuM° aOa�aQ� ave�aa , Glens same *‘,.1 env b° tae» 7 :f►�d East 100. Q ea0 >,a4601,s04-' d°� se of line betw,ople U 6 0aoW n Ve9 G, on salt to Z . dividinginute45 s y{le9l�n`? 9ZsN'vv1of to a point, the y�ay�! assi�aaafdQ ink Pland et being 4,LZ L6$ �a oAt aW°S:4 a plan is recorde �cSj1111.1 sls �o a$ea�� ed the Recorder of°alay� Ssalppe�aall11t•oT1‘at�d Cumberland Cout• 5�� L050 609$5.6 O�i4,L Plan Book 14, Pad Premises vested in by Deed from Jame:, Susan. E. Hutchens and recorded on 6/ Cumberland Countyof Deeds in Book 280, Page 2089. Being known as 5 Marshall Drive, Camp Hill, PA 17011 Tax Parcel Number: 09-16-1050-332 This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 Sworn to . nd scribed before me thi of May, 2014 A.D. ubl COMM^yWEALTN OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER °ENNSvI_VANIA ASSn ATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bank of New York Mellon f/k/a Bank of New York as Trustee for the Benefit of the Certificateholders of the CWABS Inc, Asset Cert Series 2007-BC3 is the grantee the same having been sold to said grantee on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 25th day of February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 9556, at the suit of Bank of New York Mellon f/k/a Bank of New York as Trustee for the Benefit of the Certificateholders of the CWABS Inc Asset -Backed Cert Series 2007-BC3 against Susan E. Hutchens, Original Mortgagor & Real Owner and James T. Hutchens Original Mortgagor is duly recorded as Instrument Number 201416264. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 05- 1 day of �J U h{ , A.D. .Cl/C/ County, Caciisle,PA Recorder of Recorder of Deed , Cumberland nty, 8 O S My Commission Expires the First Monday of Jan. 201