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Home My WebLink About12-1395KML LAW GROUP, P.C. SUITE 5000 - BN Y MELLON INDEPENDENCE CENTER C 3 701 MARKET STREET PIULADELPMA, PA 19106 Go (866)413-2311 M W W W.KMLLA W(:RO1TP.COM r- BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plainti ff vs. PAUL GETHOUAS Mortgagor(s) and Record Owner(s) 662 State Street Lemoyne, PA 17043 Defendant(s) NOTICE IN THE COURT OF ;C C7 OF Cumberland CO?gN 5 r-- CIVIL ACTION - LA7 n? r7 N r° P"AS CJ 7-2 ACTION OF MORTGAGE FORECLOSURE No. /01./'395 01vilTe-rot CIVIL ACTION: MORTGAGE FOR + p n I.lP 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 the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 2 Liberty Avenue /? Carlisle, PA 17013 `0 4103.75 PA ATT`/ C'?'1?15.'?7?70?1 [055 LEGAL SERVICES INC ?'Jaz e 8 Irvine Row ° Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE El. DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT RESOURCES AVAILABLE FOR HowoWNERS IN FORECLOSURE; ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http•//www philadelphiafed org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionnkmllaw roue com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 111141FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGAWRECLOSURE 1. Plaintiff is BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP,-7105 Corporate Drive, PTX B-209, Plano, TX 75024. 2. The name(s) and address(es) of the Defendant(s) is/are PAUL GETHOUAS, 662 State Street, Lemoyne, PA 17043, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On June 15, 2009 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR BANK OF AMERICA, N.A., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on June 25, 2009 as Instrument # 200921555. The mortgage has been assigned to: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP by assignment of Mortgage recorded on October 12, 2011 as Instrument # 201128234. The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for January 01, 2011 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$86,406.53 $94,490.7b 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. Interest from 12/01/2010 through 02/29/2012 at 5.0000% .......................$5,400.45 Per Monthly interest rate at $360.02 Late Charges from 01/01/2011 to 02/29/2012 ...............................................$25.20 Escrow ...................................................................................................... .$1,541.51 Property inspections ......................................... .............................................. $60.00 Suspense balance .....--• ................................................................................. ($53.95) Suspense balance ...................................................................................... ($338.98) Reasonable Attorney's Fee .......................................................................$1.450.00 8. Plaintiff is not seeking a judgment of personal liability (or an "in Mrsonam' judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose has been sent to Defendants by certified mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copy of such Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $94,490.76, together with interest at the rate of $360.02, per month and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: KMYJLAW GROUP, P.(!. Michael McKeever Pa. ID 56129 ___,,,:Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Ann E. Swartz Pa. ID 201926 Jill P. Jenkins Pa_ ID 306588 Attorneys for Plaintiff VERIFICATION _ ~ . FH C'y < ,hereby states that 6 Ake " ' J n <,•vT of Bank of America, N.A., successor by merger to BAC Home Loans Servicing L.P., Plaintiff in this matter, tha ie semis 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 oku ux knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C_S. Sec. 4904 relating to unsworn falsification to authorities. Date: 1'6?6< y,kzy ?? . e: Ems: itle: #111141FC - PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 E?chibitA Exhibit A Legal Description 662 State St Lemoyne, PA 17043 Parcel No.: 12-21-0267-349 ALL-THAI CERTAIN piece or parcel of land situate in the Borough of Lemoyne, formerly East Pennsboro Township, County of Cumbedond and State of Pennsylvania, bounded and descnbed as follows, to wit: BEGINNING at a point on the southerly One of the State Road one hundred and seven- tenths (100.7) feet measured in a westerly direction from the southwest corner of the State Road and a 20 foot alley, thence in a southerly direction along the westerly One of Lot No. 87 on the plan of lots hereinafter mentioned one hundred seventy-eight (178) feet to a point on the northerly line of another 20 foot alley, thence in a westerly direction along the north *-Iiine of said last mentioned 20 foot alley seventeen and one-half (17'% ) feet, more or less, to a point; thence in a northerly direction along a Fne running through the center of the partition wail of the double house erected on this and on the acWning lot one hundred seventydive (175) feet, more or less, to a point on the southerly One of Stag Road; thence in an easterly direction along the southerly One of the State Road seventeen and one half (17'A ) feet, more or less, to a point, the place of beginning; Being the easterly half of Lot No. 86, in the Plan of lots known as Plan No. 3, North Riverton, said plan being recorded in the Office for recording of deeds, etc_ in and for the County of Cumbeiiand in Plan Book 6, Page 60. Exhibit (B EXhibit has been redacted to remove all personally identifiable information or non-public information Bankof America 40- mom Lem A.Q Bar 660694 Da9ad, TX 752664694 Send Payments ro: P.O. Box 15222 Wfmi grm, OF f9896-5222 January 3, 2011 Paul Gethouas 662 State St Lemoyne, PA 170431535 Account No.:IW5127 662 State St Lemoyne, PA FHA(VA Case A: 4419182766703 NOTICE OF WENT TO FORECLOSE 13AG Home Loans Seulcing, LP (heneinafler`BAC Home Loans Servicing, LP') servicesthe home loan described above on behalf of the holder of the promissory note (the 'Noteholder"). The home ban is in serious default because the required payments have not been made. The total amount now required to reinstate the loan as of the date at this letter is as follows: Monthly Charges: 1110112010 $650.53 12'018010 $1,32528 Late Charges: 11/012010 $26.02 12/012010 $26.51 Other Charges- Uncollected Late Charges: $86.87 Uncollected Costs: $30.00 Partial Payment Balance: ($141.01 TOTAL DUE: $2,003.33 You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter. To cure the defaut< BAC Home Loans Servicing, LP must receive the amount of $2,003.33, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due during this period. Such payment must be in the form of certified check, cashiers check or money order, and made payable to BAC°Home Loans Servicing; LP at P.O. Box 15222, Wilmington, DE 1988652222 U anycheck (or other payment) is returned to us for Insufficient funds or for airy other reason, 'good funds" will not have been received and the default will not have been cured. No etdenslon of time to care will be granted due to a returned payment If this default is not cured within THIRTY-FIVE (35) DAYS, the mortgage payments wll be accelerated. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to have the original mortgage paid off in monthly installments. B the fill payment of the amount of default is not made within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt If the default is cured before we begin legal proceedings against the collateral involved, BAC Home Loans Servicing, LP and the Noteholder will be entitled to collect the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started the reasonable attorney's fees will have to be paid even if they are over $50.00. Any attorney's fees will be added to whatever Is owed to us, which may also include our reasonable costs. If this default is cured within the Thirty-Five (35) day period, the attorney's fees wit not be required to be paid- YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If the default has not been cured within the Thirty-Five (35) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the foreclosure sale. To do so, the total due, as well as all reasonable attorney's fees and costs incurred in connection with the foreclosure sale (and any other requirements under the mortgage) must be performed. Your loan Is in default. Pursuantto your loan documents, BAC Home Loans Servicing, LP may, enter upon and conduct an Inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant If you do not cure the default prior to the Inspection, other This carni7mimtlon Is from aAC Horne Loans Servicing, LP, the Bank Di America comp" that senires your hone Ica,, P%_ ~G°?06 count FEirrlbe . 12 ur2yar drAPK b tDW Paul Ge4touas Balance Me far charges Isled above $2p0331 as of Jauary 3.2011. ,IP H.-L 662SteteST r+raaapdW-W:nor,.senmuerMrse:wransmipm,. - dqd • Plea nor i aeupmwi ye Z, L e noyne, PA dsr°"r Fa of cad ann4 paPaed psbda, Neon/m buibladwaaaaiiifbeu. Aamagy,:dvar br Mid a.@ , I I I I , i 111 111 1 141. 1 III 11') II)" '1?I")11 '11"I")')) 'I' )I) )I I)) ) Fly, a ualdaled as SAC Home Loans Servicing, LP 30080 it oftM nlneY, -WM1. d lhs adu01an6ar ddrp iaerorrorf, ISO BOX 15222 Tow Fa perfa mm?a :roar a donrad Vamington. DE 19886-5222 ddy an h bars or a M My ten. 1.890.669 4578 209925127000000200333000200333 1: 58 6 9 900 581: 2099 2 51 2 70 actions to protect the mortgagee's interest in the property (including. but not limited to, winterization, securing the property, and valuation services) may be taken. The costs of the above-descn-bed inspect-arcs and property preservation efforts Will be charged to your account as provided in your security interment. It is estimated that the earliest date that such a foreclosure sale could be held would be approximately six (6) months from the date of this letter. A notice of the date of the foreclosure sale will be sent to you before the sale. You may find out at any time exactly what the required payment Will be by calling us at the following number 1$00-6694578_ This payment must be in the form of cashier's check, certified check or money order and made payable to us at the address stated above. If this default is cured, the mortgage wfll be restored to the same position as if no default had occurred. However, the default may not be aired more than three (3) times in any calendar year. You should realize that a foreclosure sale will and your ownership of the mortgaged property and your right to remain in it. If you continue to live In the property after the Sheriffs sale, a lawsuit could be started to evict you. BAC Home, Leans Servicing, LP wants you to be aware of various options that may be available to you through BAC Home Loans Servicing, LP to prevent a foreclosure sale of your property. For example: - Repayment Plan: It is possible that you may be eligible for some form of payment assistance through BAG Home Loans Servicing, LP. Our basic plan requires that BAG Home Loans Servicing, LP receive, up front, at least % of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available, - Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the ban by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreelosure attemative, however, is limited to certain loan types. - Sale of Your Properly: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through BAG Home Loans Servicing, LP even if your home Is worth less than what is owed on it - Deed-in-Lieu: Or, If your property Is tree from other liens or encumbrances, and if the default Is due to a serous financial hardship which Is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure altematives with BAC Home Loans Servicing, LP, you must contact trs immediately. If you request assistance, BAC Home Leans Servicing, LP will need to evaluate whether that assistance Will be extended to you, In the meantlme, BAC Home Loans Servicing, LP will pursue all of Its rights and remedies under the loan documents and as permitted by law, unless It agrees otherwise In writing. Failure to bring your loan current or to enter Into a written agreement by February 7, 2011 as outlined above will result in the acceleration of your debt- Time is of the essence. if you have any questions conceming this notice, please contact Loan Counseling Center immediately at 1$00-6694578. This conunumcafon is from BAC Horne Loans Somang, LP. the Banc of America comp" teat services your home loan, Email use: Pmrdng ywr emsl address bebw.i alumr ms b send you idarraim an you aaaumt . A®umrtNaribrrAMOSM - Pad Gatahes EtrmN eddma: ?' ? mfP yllw paysn?! All aoceptad Dafaaa ? txoutladR ahd ihrest wl he appried b 10e loniW OLWN q hsad meht due, unlew a nurse -P-* "o, or limited by law. K you sarbnd an amass in oddtioo to your adedubd mortlty amount ra wi apply your Mpeurbm es "Mr t7 b adata ckv Mon" paynhahte of wirE nandhlaneatMBarrow'deliendes, fail late daaages erW oCmr amounts you on In counaSon wsfh your loan ad M to radaai 1he woto,*q pahdpe balance of yore bou Please apairy r you wagon add - amaut al"M to Lire paphhaads, rataufhan pdndpal roAw*n Postdated dhwLa: Posldalsd dm cke and be processed on Me dare rweired broke a ban canahdor agrees to honor he dab whom on the dhed as a our dlun of a repw}nal plan. e>..reta.?l;a 'H PRESORT irst-Class Mall Postage am and PO BOX W48 rnevis rA 9204.90M I IIY? ?? ? ? U S FFees Pad 7e WSO 2244635136 Srnd Payments to: P.O. am 1422 Wi' Tkgton, DE 19AA&5222 S..d Cor-pondewe !o- PO Box 5170, MS SV314B Sins Valley, GA RVIl .ri I "M 2011010.4-7 ll.i,q.lltl..ptuly.rlltl?lilrllllult.ll,.nll4l.l.lu,,.tl Paul Gethouas 662 State St Lemoyne, PA 17043-1535 SLWA2 1= O IMIO SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy .' 4?1?1??' of t'_stlrl?irt?{ 4 2912 MAR 16 °M 3: 3 5 Richard W Stewart Solicitor CUMBERLAND CG?UhJ' Y PENNSYLVANIA Bank of America, NA vs. Case Number Paul Gethouas 2012-1395 SHERIFF'S RETURN OF SERVICE 03/08/2012 04:11 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 8, 2012 at 1611 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Paul Gethouas, by making known unto himself personally, at 662 State Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. RYAN BURGETT, D SHERIFF COST: $44.00 March 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF xi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP a 7105 Corporate Drive c PTX B-209 a Plano, TX 75024 Plaintiff crs No 12-1 W vs. PAUL GETHOUAS . .? -73 ZI: -'' ( (Mortgagor(s) and Record Owner(s)) 5 662 State Street :r; E Lemoyne, PA 17043 - i > Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against PAUL GETHOUAS by default for want of an Answer. Assess damages as follows: Debt Interest - 12/01/2010 to 04/19/2012 Total (Assessment of Damages attached) $95,080.76 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecip was ail or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after th oc ed and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.Q. 1 By UP,P.C. Qv?? Sb pd a? ichael cKeever Pa. ID 56129 _Jay E. 'tz Pa. ID 26769 U ?+ -Lisa Lee a. ID 78020 -Kristin Murtha Pa. ID 61858 {? ?. alJ 9 -David Fein Pa. ID 82628 t" Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff AND NOW 1'-??T 1 o? 3 1 a Judgment is entered in favor of BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F CO RYW HOME LOAN SERVICING, LP and against PAUL GETHOUAS by default for want of an Answer a damag sess the sum of $95,080.76 as per the above certification. W. 4% Prothonotary Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plaintiff No. 12-1395 VS. PAUL GETHOUAS (Mortgagors and Record Owner(s)) 662 State Street Lemoyne, PA 17043 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D. Buell Prothonotary By: Deputy If you have any questions concerning the above, please contact: KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 111141FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE AREATTF.MPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 30, 2012 TO: PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 In the Court of N.A. SB/M TO BAC HOME LOANS SERVICING, LP BANK OF AMERICA Common Pleas , F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP of Cumberland County 7105 Corporate Drive CIVIL ACTION -LAW FIX B-209 Plano, TX 75024 Plaintiff' Action of VS. Mortgage Foreclosure PAUL GETHOUAS (Mortgagor(s) and Record Owner(s)) Term 662 State Street No. 12-1395 Lemoyne, PA 17043 Defendant(s) TO: PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 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 FO RTii AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE. OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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 LAWYF,R_ 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 FEl : OR NO FEE. CUMBERLAND COUNTY BAR. ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 r B}° I{III. UP, P.C. W Keever Pa. ID 56129 Lisa Let Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 --VTiII P. Jenkins Pa. ID 306588 215-825-6360 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plaintiff vs. PAUL GETHOUAS (Mortgagor(s) and Record owner(s)) 662 State Street Lemoyne, PA 17043 Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 12-1395 Please enter Judgment in favor of BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, an a i st PAUL GETHOUAS for failure to file an Answer in the above action within (20) days from the date of service of a lai , in the sum of $95,080.76. By: , KTA I P.C. Mich Mc ver Pa. ID 56129 Jay E. 'vitz . ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenins Pa. ID 306588 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 50 an that name(s) and last known address(es) of the Defendant(s) is/are PAUL GETHOUAS, 662 State Street Legneil 7Q43;T By: L" V - KML R , P.C. _Michae McKeev r Pa. ID 56129 _Jay E. 'vitz Pa. 26769 _Lisa Pa. ID 7 020 Kristina Murtha Pa. ID 61858 _David Fein Pa. ID 82628 -,Thomas Puleo Pa. ID 27615 fJill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 12/01/2010 through 04/19/2012 Reasonable Attorney's Fee Late Charges Escrow Property inspections Suspense balance Suspense balance $86,406.53 $5,990.45 $1,450.00 $25.20 $1,541.51 $60.00 ($53.95) ($338.98) $9f,040.76 By. AW , P.C. Mic el M eever Pa. ID 56129 Jay . Kivit Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff AND NOW, this X"? day of nl 2012 damages are assessed as above. C+ Pro Prothy 12-1395/111141FC IN THE COURT OF COMMON PLEAS OF CU BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff VS. PAUL GETHOUAS Defendant(s) MBERLAND COUNTY, PENPjSYI.XAMA 12-1395 NO =- '- . - ) r. C ?t ? . , VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, PAUL GETHOUAS, has a last known residence of 662 State Street, Lemoyne, PA 17043. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn sift ation authorities. t Date U By: KML L UP, P.C. Michael M eever Pa. ID 56129 Lisa Lee PaVID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 11 Department of Defense Manpower Data Center Statu__ R ep eit Pur_uanttcl the Servicemember? Civil belief Act Last Name: GETHOUAS First Name: PAUL Date Of Interest: Apr-19-2012 Results as of : Apr-19-2012 11:18:29 Active Duty End Date Status Service Component On Active Duty On Date of In2test No NA This response reflects the individual's active duty status based on the Date of Interest. Left Active Duty Within 367 Days of Dale Of hAerest No NA This response reflects whether the individual left active duty status within 367 days preceding the Date of Interest. The Mernber or HWNer Unit Was Notified of a. Future C&Wp to Active Duty on Date of Interest I 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 date of interest as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, 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. Aal A r__W AJI - 4? 0 - A?&44- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the date of interest, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: hftp:Hwww.defenselink.milffaq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the date of interest and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). If you obtain additional information about the person (e.g., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Date of Interest (2) Whether the individual left Active Duty status within 367 days preceding the Date of Interest (3) Whether the individual or his/her unit received early notification to report for active duty on the Date of Interest. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and date of interest provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: null WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-1395 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From PAUL GETHOUAS (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: $95,080.76 L.L.: $.50 Interest FROM 4/20/12 TO DATE OF SALE PER DIEM AT $11.80 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $195.25 Other Costs: Plaintiff Paid: Date: 6/7/2012 David D. Buell, Prothonotary (Seal)' LLLt?Is ? ?l.,r..L Deputy REQUESTING PARTY: Name: KRISTINA MURTHA, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 61858 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 4 . ?:.: t y KML Law Group, P.C. Suite 5000 - BNY Independence Center A J? . 701 Market Street ' Philadelphia, PA 19106-1532 215-627-1322 .d°4 ?S Y'I ?/??? Attorney for Plaintiff BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP IN THE COURT OF COMMON PLEAS 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. Plaintiff PAUL GETHOUAS Mortgagor(s) and Record Owner(s) 662 State Street Lemoyne, PA 17043 of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 12-1395 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 4/20/2012 to Date of Sale per diem at $11.80 (Costs to be added) S ?? av CBf Io3.?S n<< So Hit o? S0 u N a ? gS.aS ? a ra C0713,91(4 ?2-9 9-1 1L31(P $95,080.76 By: - KML LAW GRO P P.C. Michael I cKeeve . ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff IAlr?l a-F R?-T,ss'?l W a O O cn u N ?y -O za O U W x F 4 W W ? Ox xW H °z? oz ?Qu zw w UWvzz? w?O U w> oW x? ?Q 0 a z O H H i U w 3 ? d C) W 0 W b ca C7 Cod ? c Q o ?D ? a. to W t o ? U w 9 a U a 3 1.4 x L r ID U M U L) a v 0 ?SxQwN x° kf) ALL THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, formerly East Pennsboro Township, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southerly line of the State Road one hundred and seven-tenths (100.7) feet measured in a westerly direction from the southwest corner of the State Road and a 20 foot alley; thence in a southerly direction along the westerly line of Lot No. 87 on the plan of lots hereinafter mentioned one hundred seventy-eight (178) feet to a point on the northerly line of another 20 foot alley; thence in a westerly direction along the northerly-line of said last mentioned 20 foot alley seventeen and one-half (17 1/2 ) feet, more or less, to a point; thence in a northerly direction along a line running through the center of the partition wall of the double house erected on this and on the adjoining lot one hundred seventy-five (175) feet, more or less, to a point on the southerly line of State Road; thence in an easterly direction along the southerly line of the State Road seventeen and one half (17 '/z) feet, more or less, to a point. the place of beginning; Being the easterly half of Lot No. 86, in the Plan of Lots known as Plan No. 3, North Riverton, said plan being recorded in the Office for recording of deeds, etc. in and for the County of Cumberland in Plan Book 6, Page 60. TAX PARCEL # 12-21-0267-349 BEING KNOWN AS: 662 State Street, Lemoyne, PA 17043 MUNICIPALITY: Borough of Lemoyne, formerly East Pennsboro Township Being the same premises by deed dated 06/15/2009, given by John E. Hamaker, Jr. a single man and Peggy A. Hamaker, a single woman to Paul Gethouas, single man and recorded 06/25/2009 in Instrument # 200921553. IN THE COURT OF COMMON PLEAS OF Ct BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff vs. PAUL GETHOUAS Defendant(s) IMBERLAND COUNTY, PENNS34.VWNIA 710-; NO. 12-1395 n CD c r7'. VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That the above named Defendant, PAUL GETHOUAS, has a last known residence of 662 State Street, Lemoyne, PA 17043. 3. That inquiry has been made with the Department of Defense as to the military status of each of the Defendants in this action. A copy of the Military Status Report is attached. 4. The Defendant is not in the military service of the United States of America as defined by the Servicemembers Civil Relief Act as amended. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date_ By: KML LAW GR?L .C. Michael McKeev r P . ID 56129 Lisa Lee Pa. ID 78 20 KKristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Department of Defense Manpower Data Center status Repott Pursuant to Servteemembers Civil Relief Act Last Name: GETHOUAS First Name: PAUL Active Duty Status As Of: May-31-2012 Results as of : May-31-2012 11:16:10 SCRA 2.2 Active Duty Start Dab Active Duty End Date Status Service Component On Active Duty On Active Duty Status Date 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 o(Active Duty Status Dale 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 HisM14er Unit Was Notified of a Future Ca#JJp to Active Duty on Active Duty Status Date Order Notification Start Date Omer Nottficstbn 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. r?. ,c Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: hftp:/Avww.defenselink.miVfaglpis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual leftActive Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(9 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: 2MDQ2LK106 "L Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. PAUL GETHOUAS (Mortgagor(s) and Record Owner(s)) 662 State Street Lemoyne, PA 17043 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 12-1395 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 above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 662 State Street Lemoyne, PA 17043 1.Name and address of Owner(s) or Reputed Owner(s): PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 2. Name and address of Defendant(s) in the judgment: PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 -L `l ?gJ f? JERLAiiD CO-r'" L 5 Y I JkoIfRT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 44. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 662 State Street Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my 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. DATED: (0 ° ( A L By: KML L4KV G O P, C. Michael McKeeve .5 AD 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 4?Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 12-1395 KML Law Group, P.C. 'rr?-? 1 r= z Suite 5000- BNY Independence Center' `?" 701 Market Street f ?$"? - 7 Philadelphia, PA 19106 29 (215) 627-1322 `- ``"EOERL1AND COURT'_ Attorney for "FNNSYl N VA r1 BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County PAUL GETHOUAS Mortgagor(s) and Record Owner(s) 662 State Street Lemoyne, PA 17043 Defendant(s; Docket No. 12-1395 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GETHOUAS, PAUL PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 Your house at 662 State Street, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 05, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $95,080.76 obtained by BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 12-1395 1. The sale will be cancelled if you pay to BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may he able to stop the sale by filing a petition asking the Court to strike or open 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. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT TAKE PLACE. I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 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 within thirty (30) days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: htti)://www.i)hiladelr)hiafed.or2/foreclosure/ 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 .. 12-1395 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 111141FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 for Plaintiff 2012 JUN -7 Ail II= BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOAI SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plaintiff vs. PAUL GETHOUAS Mortgagor(s) and Record Owner(s) 662 State Street Lemoyne, PA 17043 Defendant(s) of Cumberland County C17VIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 12-1395 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. ok, By: KML LAW GRO , P.C. Michael McKeev a. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff '"D COUNT ac YL VA 41,4 IN THE COURT OF COMMON PLEAS K1VIL Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff r ' ~+ ~:, T:~, ; { ~, ~, ,, ('; u z `r~ ~J• ~ i ..,~ ~L\\,~'/'~'i~ ~;~7tlr'~'rti, ' .. i I s .l 1 ~ ~' ~f ~ f"8 ~ .p9 BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 No. 12-1395 THIS LAW FIItM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a mortgage upon the premises 662 State Street, Lemoyne, PA, 17043, hereinafter, the "mortgaged premises". 2. Defendant, PAUL GETHOUAS, is the mortgagor and real owner of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, Alyk Oflazian, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. 4. The last known address of Defendant, Paul Gethouas, is 662 State Street, Lemoyne, PA IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 17043 from our investigative search. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant, Paul Gethouas, at the mortgage premises, 662 State Street, Lemoyne, PA, 17043. The Sheriff's return states the Defendant moved from the property. The Defendant did not leave a forwarding address with the Post Office. No other information provided. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Paul Gethouas. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendant, Paul Gethouas, by posting the premises and certified and regular mail to the Defendant's last known address. ~~ By: KML LAVA GRO , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Ji1l~enkins Pa. ID 306588 .~lyk Oflazian Pa. ID 312912 Attorneys for Plaintiff Affidavit of Good Faith Investigaton At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 111141FC AttomeylLaw Firm: KML LAW GROUP, P.C Subject Name: PAUL GETHOUAS Property Address: Street: 662 State Street City: Lemoyne State: PA Zip: 17043 Skip Results: Date of Birth: ~~ ProVest File Number. 3425819 Last Known Address (as of 10/8/2012) Street: 662 STATE ST City: Lemoyne State: PA Zip: 17043 1535 Death Record Search As of 10108f2012, the Social Security Administration has no death record on file for Paul Gethouas. Soda) Secxrtlty Number [X] Verifed [ ]Not Verified SSN# XXX-XX-XX95 Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation. Business Records Search No verifiable business records found. Creditor Header Inquiry The latest address from the credit header info is: Address: 662 STATE ST, LEMOYNE, PA 17043 1535 Departrnertt of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. ehide Records Search' Drivers Lloense Information Search No current records found. Govemmental'"'+ Non-governmental Pr+afessior~ Licenses Search No current records found. Freedom Of lnfornation Act Inquiry The following addresses were sent to the United States Postal inspector at the Made to U.S. Postal Service zip code listed with no return information to date: 662 STATE STREET ~ LEMOYNE ~ PA ~ 17043 ~ CUMBERiAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Enquiry of Relatives, 717-731-8618: Spoke with possible neighbor, Marjorie Miess, does not know Neighbors, 8 Friends defendant. 717-612-0106: Called possible neighbor, Florence Shuey, there was no answer. Comments: 717-649-9128: Called number listed to defendant, Paul Gethouas, there was n answer. ____-- " Uala not avaUable In AL, AK, l:A, HI, NH, UK, F'A, VA, WA. ° HIStOnCal Data In GV, Ut, IU, IL, KY, LA, MU, MA, M5, MU, NH, NU, SG, WV. + Data available in CO, CT, DE, FL, ID, IL, KY, LA, ME, MD, MA, MI, MN, MS, MO, NN, ND, OH, SC, TN, TX, WV, WI, WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Under penalties of perjury, I deGare that I have read the foregoing affidavit and that the facts stated in it are true. STATE OF FLORIDA COUNTY OF HILLSBOROUGH ~ Gianna Hernandez Sworn to or affirmed and signed before me on this ~ day of rJ~-~ J~ _7 Provest Services LLC (Seal) I,~` 10/8/2012 J68fiUA N. PIME@ITEL My ~ oft=7aida No. EE 970 0 24~ ~1S Signature f Notary Public ~1l1Jvs- ~~wteMY~- Printed Name of Notary Public ~rsonally Known ( )Produced as identification SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Qu~t1' o; ~:crn~G;~~fj~ Bank of America, NA Case Number vs. 2012-1395 Paul Gethouas, Jr SHERIFF'S RETURN OF SERVICE 09/28/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Paul Gethouas, Jr., but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 662 State Street, Lemoyne, PA 17043, per neighbor, on 8/29!12, defendant moved from this address 3 weeks ago, defendant did not leave a forwarding with the post office. SHERIFF COST: $915.20 SO ANSWERS, October 25, 2012 RONN R ANDERSON, SHERIFF K1VIL Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/KIA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024" vs. PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 12-1395 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Notice of Sheriffs Sale against Defendant, Paul Gethouas, which the Sheriff has been unable to personally serve upon Defendant, Paul Gethouas. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Notice of Sheriff's Sale upon Defendant, Paul Gethouas, by posting the premises and certified mail and regular mail to the Defendant's last known address. By: L GRO , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jil .Jenkins Pa. ID 306588 yk Oflazian Pa. ID 312912 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 CERTIFICATE OF SERVICE of Cumberland County No. 12-1395 Lourdes Gerena, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, Paul Gethouas this ~ of November, 2012, by first class l~ mail, postage prepaid. PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 By: IN THE COURT OF COMMON PLEAS KML Law Group, P.C.' Lourdes Gerena, Legal Secretary Direct Phone: 215-825-6338 BANK OF AMERICA, N.A. SB/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. PAUL GETHOUAS 662 State Street Lemoyne, PA 17043 ORDER ~. _, OF Cumberland COU~'Y ~ ; CT3 -r ,~ ~ rn z ~~._ c.~ 4 12-1395 ~~ a '~' ~°"' r- ~' ~~ ~ ~w ,: AND NOW, this ~ day o~yW~" ~ 12, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, Paul Gethouas, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriff's Sale upon Defendant, Paul Gethouas, by posting a copy of the Notice upon the premises 662 State Street, Lemoyne, PA, 17043, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the mortgaged premises, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to the mortgaged premises and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, Paul Gethouas, by sending copies of same to the mortgaged premises by certified and regular mail and by posting the premises. Service is complete upon mailing. BY THE COURT: J. Distribution list: /Michael T. McKeever, Esquire, Suite 5000 - BNY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 PAUL GETHOUAS, 662 State Street Lemoyne, PA 17043 ~~~~ IN THE COURT OF COMMON PLEAS SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith t Ra Chief Deputy -- Richard W Stewart :•JM, Ltsi jJ ( (�J • Solicitor OFFICE OF THE SHERIFF r E N S Y LV 4.!I r 1 Nationstar Mortgage LLC Case Number vs. Paul Gethouas, Jr 2012-1395 SHERIFF'S RETURN OF SERVICE 09/28/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Paul Gethouas, Jr., but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 662 State Street, Lemoyne, PA 17043, per neighbor, on 8/29/12, defendant moved from this address 3 weeks ago, defendant did not leave a forwarding with the post office. 10/04/2012 11:26 AM - Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 662 State Street, Lemoyne Borough, Lemoyne, PA 17043, Cumberland County. 12/04/2012 As directed by Kristina Murtha,Attorney for the Plaintiff, Sheriff's Sale Continued to 1/9/2013 01/09/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on January 9, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Kristina Murtha, on behalf of Bank of American, N.A., being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $1,106.40 SO ANSWERS/, June 06, 2013 RbNW R ANDERSON, SHERIFF -odId - a-mss pro 2- (c)CountySu(te Sheriff.Telecsaft.Inc. KML Law Group,P.C., Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A. S/B/M TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE IN THE COURT OF COMMON PLEAS HOME LOANS SERVICING,LP 7105 Corporate Drive of Cumberland County PTX B-209 Plano,TX 75024 Plaintiff CIVIL ACTION-LAW vs. PAUL GETHOUAS ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s) and Record Owner(s)) 662 State Street Lemoyne,PA 17043 Defendant(s) No. 12-1395 AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA,N.A. SB/M TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP,Plaintiff in the above action,by counsel, KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 662 State Street Lemoyne,PA 17043 1.Name and address of Owner(s)or Reputed Owner(s): PAUL GETHOUAS 662 State Street Lemoyne,PA 17043 2.Name and address of Defendant(s)in the judgment: PAUL GETHOUAS 662 State Street Lemoyne,PA 17043 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 662 State Street Lemoyne,PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my 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. DATED: By: KML G O P, .C. Michael McKeeve P 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 )CL—Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff . 12-1395 EAM Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A. S/B/M TO BAC HOME LOANS SERVICING,LP F/K/A IN THE COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS SERVICING,LP 7105 Corporate Drive of Cumberland County PTX B-209 Plano,TX 75024 CIVIL ACTION-LAW Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE PAUL GETHOUAS Mortgagor(s) and Record Owner(s) 662 State Street Docket No. 12-1395 Lemoyne,PA 17043 Defendants THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GETHOUAS,PAUL PAULGETHOUAS 662 State Street Lemoyne,PA 17043 Your house at 662 State Street,Lemoyne,PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday,December 05,2012,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$95,080.76 obtained by BANK OF AMERICA,N.A.S/B/M TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 12-1395 1. The sale will be cancelled if you pay to BANK OF AMERICA,N.A. S/B/M TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open 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. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below 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 NOT 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 price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 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 within thirty(30)days from the date of the Sheriffs 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 the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.or0foreclosure/ 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 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 12-1395 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 111141FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN piece or parcel of land situate in the Borough of Lemoyne, formerly East Pennsboro Township, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the southerly line of the State Road one hundred and seven-tenths (100.7) feet measured in a westerly direction from the southwest corner of the State Road and a 20 foot alley; thence in a southerly direction along the westerly line of Lot No. 87 on the plan of lots hereinafter mentioned one hundred seventy-eight (178) feet to a point on the northerly line of another 20 foot alley; thence in a westerly direction along the northerly-line of said last mentioned 20 foot alley seventeen and one-half(17 1/2 ) feet, more or less, to a point; thence in a northerly direction along a line running through the center of the partition wall of the double house erected on this and on the adjoining lot one hundred seventy-five (175) feet, more or less, to a point on the southerly line of State Road; thence in an easterly direction along the southerly line of the State Road seventeen and one half(17 I/2) feet, more or less, to a point. the place of beginning; Being the easterly half of Lot No. 86, in the Plan of Lots known as Plan No. 3, North Riverton, said plan being recorded in the Office for recording of deeds, etc. in and for the County of Cumberland in Plan Book 6, Page 60. TAX PARCEL# 12-21-0267-349 BEING KNOWN AS: 662 State Street, Lemoyne, PA 17043 MUNICIPALITY: Borough of Lemoyne, formerly East Pennsboro Township Being the same premises by deed dated 06/15/2009, given by John E. Hamaker, Jr. a single man and Peggy A. Hamaker, a single woman to Paul Gethouas, single man and recorded 06/25/2009 in Instrument#200921553. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-1395 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA,N.A.S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP Plaintiff(s) From PAUL GETHOUAS (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: $95,080.76 L.L.: S.50 Interest FROM 4/20/12 TO DATE OF SALE PER DIEM AT$11.80 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $195.25 Other Costs: Plaintiff Paid: Date: 6/7/2012 David D.Buell, Prothonota (Seal) Deputy REQUESTING PARTY: Name: KRISTINA MURTHA,ESQUIRE Address: KML LAW GROUP,P.C. TRUE COPY FROM RECORD SUITE 5000-BNY INDEPENDENCE CENTER In Testimony whereof, I here unto set my hand 701 MARKET STREET and the seal of said C urt at Carlisle,Pa. This�_day of V-1 P _,20 PHILADELPHIA,PA 19106-1532 Prot ho ary Attorney for: PLAINTIFF ,,� Telephone: 215-627-1322 Supreme Court ID No. 61858 On July 17, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA, known and numbered 662 State Street, Lemoyne, PA 17043 more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: July 17, 2012 By: 0 -C Claudia Brewbaker, Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2012-1395 Civil Term MUNICIPALITY: Borough of Lem- oyne, formerly East Pennsboro BANK OF AMERICA,NA Township. vs. Being the same premises by deed PAUL GETHOUAS,JR. dated 06/15/2009, given by John E. Hamaker, Jr. a single man and Atty.: Kristina Murtha Peggy A. Hamaker, a single woman ALL THAT CERTAIN piece or par- to Paul Gethouas, single man and cel of land situate in the Borough of recorded 06/25/2009 in Instrument Lemoyne, formerly East Pennsboro #200921553. Township, County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit: BEGINNING at a point on the southerly line of the State Road one hundred and seven-tenths (100.7) feet measured in a westerly direc- tion from the southwest corner of the State Road and a 20 foot alley; thence in a southerly direction along the westerly line of Lot No.87 on the plan of lots hereinafter mentioned one hundred seventy-eight (178) feet to a point on the northerly line of another 20 foot alley;thence in a westerly direction along the north- erly-line of said last mentioned 20 foot alley seventeen and one-half(17 1/2 ) feet, more or less, to a point; thence in a northerly direction along a line running though the center of the partition wall of the double house erected on this and on the adjoining lot one hundred seventy-five (175) feet, more or less, to a point on the southerly line of State Road; thence in an easterly direction along the southerly line of the State Road sev- enteen and one half (17 1/2) feet, more or less,to a point,the place of beginning;Being the easterly half of Lot No.86,in the Plan of Lots known as Plan No. 3, North Riverton; said plan being recorded in the Office for recording of deeds,etc.in and for the County of Cumberland in Plan Book 6,Page 60. TAX PARCEL# 12-21-0267-349. BEING KNOWN AS: 662 State Street,Lemoyne,PA 17043. 43 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952,and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9, 2012 Affiant fiuther deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. isa Marie Coyne, tditor SWORN TO AND SUBSCRIBED before me this 9 day of November. 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 i The Patriot-News Co. 2020 Tech,nol.ogy Pkwy Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-.255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says.. That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a 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. 1z�1395Chd�term This ad ran on the date(s) shown below: BANK OF AMERICA,NA 10/26/12 vs. PAUL GETHOUAS,JR 11/02/12 Ally; KrWpna Murtha ALLnW CEWN N piece or parcel of l 11/09/12 land situate in the Borough of Lemoyne, formerly Fast Pennsbom'Ibw'nshiP,County , of Cumberland and State of Pennsylvania, . . . :!. . . . . . . bounded and described as follows,to wit: yt' BEGINNING at a point on the southerly line of the State Road one hundred and Sw o an 'subscribed bef a th' day f November, 2012 A.D. seven-tenths(160.7)feet measured in a westerly direction from the southwest comer of the State Road and a 20 foot alley;thence in a southerly direction along l/ L the westerly line of Lot No.87 on the plan, Notary Public of lots hereinafter mentioned one hundredf' seventy-eight(178)feet to a point on the'' northerly line of another 20 foot alley; thence in awesterly direction along the. �^ northerly-lime of said last mentioned 20 foot alley seventeen and one-half(171/2 feet,more or less,to a point;thence in COMMONWEALTH OF PEN_NSYLVANIA northerly direction along a line running Notarial Seal t,m4*the center of the partition wall of Sherrie L.Owens,Notary Public the double house eregted on this and on I Lower Paxton Twp.,Dauphin County the adjoining lot one hundred seventy-five My Commission Expires Nov.26,2015 (175)feet,more or less,to a point on the MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES southerly line of State Road;thence in an easterly direction along the southerly line of the State Road seventeen and one hall (v%)feet,more or less,to a point,the tce of beginning;Being the easterly half of Lot No.86,in the Plan of Lots known as Plan No.3,North Riverton;said plan being recorded in the Office for recording of deeds,etc.iA and for the County of Cumberland in Plan Book 6,Page 60. TAX PARCEL#12-21-0267-349 BEING KNOWN AS:662 State Street, Lemoyne,PA 17043 MUNICIPALITY:Borough of Lemoyne,, formerly East Pennsbom TbwnshiP Being the same premises by deed dated 06/1,5/2009,given by John E.Hamaker,Jr.a single man and peggy A.Hamaker,a single woman to Paul Gethouss,single man and recorded 06/250M in Instrument#200921553. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bank of America N.A. is the grantee the same having been sold to said grantee on the 5th day of December A.D., 2012,under and by virtue of a writ Execution issued on the 7th day of June, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 1395, at the suit of Bank of America N.A. S/B/M to BAC Home Loans Servicing LP F/K/A CountrXwide Home Loans Servicing LP against Paul Gethouas is duly recorded as Instrument Number 241318597. IN TESTIMONY WHEREOF, I have hereunto set my hand and eal of said office this C day of A.D.�/0-- ecorder of Deeds ,= � 4