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Home My WebLink About12-1795UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2s(n?udren.com Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP C/O Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. DWIGHT TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 JACQUELINE TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF '7) ?..., 2: cr" i``a? "' c s ?. ( c c) `=F t COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. e(VO COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING E- ava'r -u os.1s=>d C ?- if 9>,s 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. 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 dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, ST NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O ' LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems, Inc. Assignee: Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP FKA Countrywide Home Loans Servicing, LP Date of Assignment: 09/06/2011 Recorded Date: 09/16/2011 Book/Instrument #: Instrument # 201125784 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Dwight Terry and Jacqueline Terry (hereinafter "Defendants"), are the owners of property located at 1615 Matthew Road, (East Pennsboro Township), Camp Hill, PA 17011, by virtue of Deed dated 05/09/2002 and recorded 05/21/2002 in Official Records Book 251 at Page 3888 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 01/09/2007, Defendant(s) and/or their predecessor: DWIGHT TERRY AND JACQUELINE TERRY promised to pay to the order of Countrywide Home Loans, Inc., the principal sum of $99,000.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 01/09/2007, Defendant(s) and/or their predecessor: DWIGHT TERRY AND JACQUELINE TERRY to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., acting solely as a nominee for Countrywide Home Loans, Inc., the Property which is the subject of this action. The Mortgage was recorded on. 01/23/2007 in Official Records Book 1980 at Page 3734. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 03/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $99,362.59 Accumulated Interest (due from 02/01/2011 to 03/19/2012) $4,219.88 Accumulated Late Charges $75.39 Escrow Deficit/(Reserve) $1,686.88 Title Report $325.00 Attorney Fees- Estimated $1,300.00 Property Inspections $165.00 Grand Total $107,134.74 The above figures are calculated as of 03/19/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 3.75000 %. The per diem interest accruing on this debt is $10.18 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $25.13. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $107,134.74 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. BYN? V,%'?? ?? ?- HARRY S. REESE, ESQUIRE -,r 'n iin501 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 11 I WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsriudren..com Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff V. DWIGHT TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 JACQUELINE TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. VERIFICATION hereby states that h she is Mi 1 -eSt? of Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP, Plaintiff in this matter, that hshe is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hi er knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: '?s " ? I- t). 7 OK I Nam C7cd cl,oV Q,p Cva, Iw r- N Title: p!O- & Company: MJU #: 12010054 CASE #: 12010054-1 WAA o r /? c c?Q N. A- Jan 6 2012 02:09am P014/015 01-05-'12 14:00 FROM-Premier Abstracts 8005456163T-296 P0014/0015 F-968 r EXHIBIT A ALL THAT CERTAIN TRACT OR PIECE OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED ANA DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT AT THE SOU'T'HEASTERLY CORNER OF GLENWOOD DRIVE (EAST) AND MATTHEW ROAD; THENCE ALONG THE SOUTHERLY LINE OF GLENWOOD DRIVE (EAST) NORTH 67 DEGREES 50 MINUTES EAST, 95 FEET TO A POINT AT DIVIDING LINE BETWEEN LOT NOS. 11 AND 12, BLOCK "K" ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 02 DEGREES 10 MINUTES EAST 96.31 FEET TO A POINT AT DIVIDING LINE BETWEEN LOT NOS. 12 AND 13, BLOCK "K" ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 79 DEGREES 30 MINUTES SOUTH 94.05 FEET TO A POINT ON THE EASTERLY LINE OF MATTHEW ROAD AFORESAID; THENCE ALONG THE SAME IN AN ARC HAVING A RADIUS OF 184.03 FEET TO A POINT IN A NORTHERLY DIRECTION TO THE RIGHT 26.77 FEET TO A POINT; THENCE FURTHER ALONG THE EASTERLY (ERRONEOUSLY OMITTED IN PRIOR DEED) LINE OF MATTHEW ROAD, NORTH 2 DEGREES 10 MINUTES WEST, 83.27 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 12, BLOCK "K", IN PLAN NO, 3 OF 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. BEING KNOWN p,W. W g#3V1 ": ?1 f 15 MATTHEW ROAD. SUBJEC, NEVERTHELESS, TO ALL EASEMENTS, '+ R88*I6T,IONS; 0,iMBRANGES AND OT14ER MATTERS OF RECORD OR TF'' IT'RHICH A PHYSWAL INSPECTION OR SURVEY OF THE PREMISES WOULD REVEAL. I`: g$INC, ?E SAML'PREMISES WHICH JACKIE GONZALES, SINGLE WOMAN ANT] DWIGHT TERRY, SINGLE MAN, BY DEED DATED FEBRUARY 14, 2000, AND RECORDED FEBRUARY 25, 2000, IN THE RECORDER OF DEEDS OFFICE IN AND FOR C"ERLAND COUNTY, PENNSYLVANIA IN RECORD BOOK 216, PAGE 704, GRANTED AND CONVEYED UNTO VICTOR GONZALES AND DWIGHT TERRY. THIS IS A CONVEYANCE BETWEEN FATHER AND DAUGHTER AND IS THEREFORE EXEMPT FROM REALTY TRANSFER TAX. ADDRESS, 1615 MATTHEW RD.; CAMP HILL, PA 17011 TAX MAP OR PARCEL ID NO.: 09-16-1050-245 I= U36546909-61HPIO MORTGME N(t 9 8 0 PG 3 7 5 1 LOM# IOM-178314 U3 Recordings BankofAmerica -41110. PRESORT Loans First-Class Mail U.S. Postage and PO Bopx?9048 Temecula, CA 92589-9048 Fees Paid 7196 9006 9295 1704 6696 Send Payments to. P.O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 Dwight Terry 1615 Matthew Rd Camp Hill, PA 17011-1165 20110502-7 EXHIBIT A BLQPA 1 12870 12123@010 Bankof America 141.p- Nestle Loans P.O. Box 660694 Dallas, TX 75266-0694 Send Payments to: P.O. Box 15222 Wilmington, DE 1 9 8 86-5222 May 2, 2011 Dwight Terry 1615 Matthew Rd Camp Hill, PA 17011-1165 Certified Mail: 7196 9006 9295 1704 6696 Return Receipt Reauested Regular Mail Account No.: 153761261 Property Address: 1615 Matthew Rd Camp Hill, PA 17011-1165 Current Servicer: BAC Home Loans Servicing, LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaae on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached Paaes The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM fHEMAPI may be able to help to save your home This Notice explains how the proaram works. To see It HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselina Aaencv This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCI6N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Dwight Terry PROPERTY ADDRESS: 1615 Matthew Rd Camp Hill. PA 17011-1165 LOAN ACCT. NO.: 153761261 ORIGINAL LENDER: CURRENT LENDER/SERVICER: BAC Home Loans Servicina. L.P. a subsidiary of Bank of America. N.A. This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan Please write your account number on all checks and correspondence. We may charge you a fee (of up to $40.00)for any payment returned or rejected by your financial instilution, subject to applicab'e law. BLQPAI 12870 12123120 10 Payment Instructions: Account Number: 153761261-4 • Make your check payable to BAC Dwight Terry Balance Due for charges listed above: $2,345.42 as of May 2, 2011. Home Loans Servicing, LP 1615 Matthew Rd Please update ama I information on the reverse side ofthis mupon. - Don1 send cash Please include couponwith your Camp Hill, PA 17011-1165 =ionaf payment PAndpaf BLQPAI For all full month payment periods. Adddfo al interest is calculstedon a monthly basis. I I I l I I ( I I 1 I l rr e Accordingly, interest for all full months, r r r I ?'I? III' II?'? I'I 1'??1? 111 III ?'1 II'I'?1"II"?"?I scrow including February, is calculated as BAC Home Loans Servicing, LP 301360 of annual interest, irrespective of p' the actual number of days in the month. p0 BOX 1 5222 Tote! For parfial months, interest is calculated Wilmington, DE 19886-5222 daily on the basis of a 365 day year. 1-800-669-66554 153761261400000234542000234542 is 58 6 9 900 581: i 5 3 76 1 26 &0 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of desianated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within Thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1615 Matthew Rd Camp Hill, PA 17011-1165 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Charges: 03/01/2011 Late Charaes: 03/01/2011 Other Charges: Uncollected Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) $2,243.90 $50.26 $50.26 $0.00 ($0.00) $2,345.42 This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. E-mail use: Providing your e-mail address below will allow us to send you information on your account. Account Number: 153761261 Dwight Terry E-mail address: How we post your payments: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (i) to outstanding monthly payments of principal and interest, (ii) escrow deficiencies, (iii) late charges and other amounts you owe in connection with your loan and (iv) to reduce the outstanding principal balance of your loan. Please specify if you want an additional amount applied to future payments, rather than principal reduction. Postdated checks: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the date written on the check as a condition of a repayment plan. HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,345.42 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: BAC Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222. You can cure any other default by takina the following action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements underthe mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: BAC Nome Loans Servicing, LP Address: P. O. Box 660694 Dallas, TX 75266-0694 Phone Number: 1-800-669-6654 Fax Number: 1-817-230-6811 Contact Person: MS TX2-977-01-13 Attention: Loan Counselor We are currently developing a process to ensure secure email communications for your Home Retention inquiries. In the interim, please contact us at the telephone number or address provided. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, BAG Home Loans Servicing, LP may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before June 1, 2011, BAC Home Loans 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 BAC Home Loans Servicing, LP. Our basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least '/z of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through BAC Home Loans Servicing, LP even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with BAC Home Loans Servicing, LP, you must contact us immediately. If you request assistance, BAC Home Loans Servicing, LP will need to evaluate whetherthat assistancewill be extended to you. In the meantime, BAC Home Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by June 1, 2011 as outlined above will result in the acceleration of your debt. If your loan is currently being evaluated for a loan modification, forbearance or other loan assistance solution, this notice will not cancel or delay that evaluation process. However, it is important that you promptly respond to all requests made in connection with your evaluation for a loan assistance solution, including all requests for you to contact us and any documentation required. If you do not comply with these requests in a timely manner, it may cause your loan to enter the foreclosure process as indicated in this notice. If your loan is not eligible for a loan assistance program, please note this letter will continue to serve as notice of our right to initiate foreclosure. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-6654. This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. Attachment: Itemization of Charges and Fees Monthly Charaes: Late Charaes: Other Charaes: 03/01/2011 - 05/31/2011 03/01/2011 - 04/30/2011 Uncollected Late Charges: Partial Payment Balance: $748.30 $2,244.90 $25.13 $50.26 $50.26 0.00 TOTAL DUE: $2,345.42 This communication is from RAC Home Loans Servicing, LP, the Bank of America company that services your home loan. 7196 9006 9295 1704 6696 CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.5112227 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home ..:............. ............... :.:::::::.::::::........,,..,:.:..::..:::::::::.:::::::...::.:::.::::::.?::::. ?::::::::., :.:...................................:.....,.........................? Home A federal government program that allows you to repay the loan on newly agreed upon terms, which Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or Modification extending the term of the loan. You may be eligible for this program if you meet the following Program requirements: (HAMP) • The home is your primary residence and you currently live in it. • The amount you owe on the first mortgage is equal to or less than $729,750 for a single-family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have experienced a hardship that has impacted your income. For example, a significant increase in your mortgage payment OR reduction in your income OR other hardship. • Your mortgage was obtained before Jan. 1, 2009. • Your payment on your first mortgage (including principal, interest, taxes, insurance and homeowner's association dues, if applicable) is more than 31 % of your current gross income. To calculate this, divide your first mortgage payment by your gross income (income before taxes). Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the loan up Reinstatement to date until the day of your foreclosure sale. Repayment A temporary agreement which allows for the repayment of the unpaid, past due amount along with Plan regular mortgage payments. This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments for a Forbearance period of time, to allow you to re-establish your ability to make the required payments. Agreement Loan Repay the loan on newly agreed upon terms, which may include lowering the interest rate, placing Modification amounts past due at the end of the loan, and/or extending the term of the loan. (non-HAMP) Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you (FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home Home Designed to help borrowers who are eligible for the Home Affordable Modification Program (HAMP) Affordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the Foreclosure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agreement Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short Preforeclosure sale, you sell your property for less than the total amount owed on the loan (subject to agreement by Sale your service Mender/investor), resulting in the release of our lien on your home and avoidance of (non-HAFA) foreclosure. Deed in Lieu of Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not Foreclosure able to sell the property through a short sale. With a deed in lieu of foreclosure, you agree to (non-HAFA) voluntarily transfer ownership of your property to us in order to avoid foreclosure. We are here to help you. Please call us today. 7196 9006 9295 1704 6696 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece on la notificacion adjunta para obtener mss informacion Cuando Ilame, tongs la informacidn de sus ingresos y gastos disponibles pars que podamos discutir cual opcidn(es) pueden funcionar pare usted. Opciones a considerar si su objetivo es permanecer en su casa opewippOn Home Affordable Un programa del gobierno federal que le permite pagar el pr6stamo bajo los nuevos tbrminos Modification acordados, que pueden incluir la reducci6n de la tasa de inter6s, agregando la cantidad adeudada Program (HAMP) al final del pr6stamo, y / o extender el plazo del pr6stamo. Usted puede ser elegible para este programa si cumple con los siguientes requisitos: . La rasa es su residencia principal y actualmente vive en ella. . La cantidad adeudada en la primera hipoteca debe ser igual o menos que $729,750 d6lares pare una vivienda unifamiliar, $934,200 d6lares para una propiedad de 2 unidades, $1,129,250 d6lares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades . He experimentado una dificultad que ha afectado sus ingresos. Por ejemplo, un aumento significativo en su pago hipotecario O reducci6n de sus ingresos U otras dificultades. . Obtuvo su hipoteca antes del 01 de enero 2009. • Su pago de la primera hipoteca (incluyendo principal, inter6s, impuestos, seguro y cuotas de asociaci6n de propietarios, si se aplica) debe ser m6s del 31 % de sus ingresos brutos actuales. Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes de impuestos). Restablecimiento Si usted puede traer sus pagos del pr6stamo hipotecario al dia, se le aceptar6n los fondos del Prbstamo necesarios para que el pr6stamo este al dia hasta la fecha de la venta judicial. Plan de Pago Un acuerdo temporal que permite el pago de la cantidad adeudada, cantidad del pago atrasado junto con los pagos regulares de la hipoteca. Esto puede incluir principal, inter6s, honorarios y/o costos aplicados a su pr6stamo. Acuerdo Un acuerdo por el cual nos comprometemos a no proceder con la ejecuci6n hipotecaria y/o Temporal de colecci6n de pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia hacer los pagos requeridos. Modificaci6n de Pagar el pr6stamo bajo los nuevos t6rminos acordados, que puede incluir la reducci6n de la tasa Pr6stamo de inter6s, agregando la cantidad adeudada al final del pr6stamo, y/o extender el plazo del (no por medio pr6stamo. de HAMP) Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos estbn (solamente vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, este programa prestamos de la estS diseriado para que su pr6stamo este al dia mediante la creaci6n de una segunda hipoteca / FHA) gravamen sobre su propiedad por la cantidad adeudada. Opciones a considerar si no puede o no desea quedarse en su casa Home Diseriado para ayudar a los prestatarios que son elegibles para el Programa de Home Affordable Affordable Modification (HAMP), pero no tuvieron 6xito en obtener una modificaci6n permanente a trav6s del Foreclosure programa. HAFA ofrece la posibilidad de una venta corta y, si no tiene 6xitc, una entrega de Alternatives escritura pare evitar juicio hipotecario. Una venta corta es una transacci&n en la que usted vende su Program propiedad por menos de la cantidad adeudada en el pr6stamo (sujeto a previo acuerdo de su (HAFA) administrador / prestamista / inversionista), resultando en la liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una entrega de escritura para evitar juicio hipotecario es una transacci6n en la que usted estb de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. Venta Corta/ Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci6n de Venta antes de hogar. Con una venta corta, usted vende su propiedad por menos de la cantidad total adeudada en Ejecucion el pr6stamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultando en la Hipotecaria (no liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitando la ejecuci6n hipotecaria. por medio de HAFA) Entrega de Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci6n de Escritura Para hogar, y que no pudieron vender la propiedad a travbs de una vents corta. Con una entrega de Evitar Juicio escritura para evitar juicio hipotecario, usted est6 de acuerdo a transferir voluntariamente las Hipotecaric escrituras de su propiedad a nosotros pare evitar la ejecuci6n hipotecaria. (no por medio de HAFA) Estamos aqui para ayudarle. Por favor llamenos hoy. Bankef America -jew. PRESORT Home Loana First-Class Mail PO Box 9048 U.S. Postage and Temecula, CA 92589-9048 Fees Paid ?196 9006 9295 1704 6689 Send Payments to: P.O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to: PO Box 5170, MS SV314B Simi Valley, CA 93065 20^,10502-7 ??I?'lull'I'ICI'?ll?ill?lllll"'Il??llll?'?'I?lll??"?lilll?l?ll Jacqueline Terry 1615 Matthew Rd Camp Hill, PA 17011-1 165 ITJ BLQPA 1 12870 1212312010 Bankof America .41op. Home Leans P.O. Box 660694 Dallas, TX 75266-0694 Send Payments to: P.O. Box 15222 Wilmington, DE 1 9 6 66-5222 May 2, 2011 Jacqueline Terry 1615 Matthew Rd Camp Hill, PA 17011-1165 Certified Mail: 7196 9006 9295 1704 6689 Return Receipt Requested Regular Mail Account No.: 153761261 Property Address: 1615 Matthew Rd Camp Hill, PA 17011-1165 Current Servicer: BAG Home Loans Servicing, LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaae on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached panes The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP] may be able to help to save your home. This Notice explains how the proaram works To see H HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE, Take this Notice with you when you meet with the Counselina Aaency This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACI6N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCIBN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Jacqueline Terry 1615 Matthew Rd Camp Hill. PA 17011-1165 153761261. BAC Home Loans Servicina. LP, a subsidiary of Bank of America. N.A. This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. Please write your account number on all checks and correspondence. We may charge you a fee (of up to 340.00) for any payment returned or rejected by your financial institution, subject to applicable law. BLQPAI 12670 12123x2010 Payment Instructions: Account Number: 153761261-4 • Matte your cherx payable to BAC Jacqueline Terry Balance Due for charges listed above: $2,345.42 as of May 2, 2011. Home Loans Servicing. LP 1615 Matthew Rd Please update email ioformatior on the reverse side ofthis mupon. • Don1 send cash • Please indude coupon with your Camp Hill, PA 17011-1165 AddAlon21 payment Ponapat BLOPAi For all full month payment periods, Addfilataf interest ts calculated on a monthly basis. I r l l r l r l I r l r l J I I I'' I' I I ' " I I I ' I' ' I'I ' I n r l ri l l I r ' I I I' Escrow Accordingly, interest for all full months, I I I I I I I I I I I incuding February, is calculated as BAC Home Loans Servicing, LP 30x360 of annual interest, irrespective or G'?k the actual number of days in the month. PO BOX 1 5222 Total For partial months, interest is calculated Wilmington, DE 19886-5222 daily on the basis of a 365 day year. 1$00'-669$654 1537612614000002345 42000234542 1: 586"i 5181: IS 376 126 itl' HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for Thirty (30) days from the date of this Notice. During that time you must arrange and attend a `face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for Thirty (30) days after the date of this meeting. The names addresses and telephone numbers of desianated consumer credit counselina aaencies for the county in which the oroDerty is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within Thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act.. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1615 Matthew Rd Camp Hill, PA 17011-1165 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthiv Charoes: 03/01/2011 Late Charoes: 03/01/2011 Other Charoes: Uncollected Late Changes: Uncollected Costs: Partial Payment Balance: TOTAL DUE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) $2,244.90 $50.26 $50.26 $0.00 ($0.00) $2,345.42 This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. E-mail use: Providing your e-mail address below will allow us to send you information on your account. Account Number: 153761261 Jacqueline Terry E-mail address: How we post your payments: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (i) to outstanding monthly payments of principal and interest, (ii) escrow deficiencies, (iii) late charges and other amounts you owe in connection with your loan and (iv) to reduce the outstanding principal balance of your loan. Please specify if you want an additional amount applied to future payments, rather than principal reduction. Postdated checks: Postdated checks will be pmcessed on the date received unless a loan counselor agrees to honor the date written on the check as a condhion of a repayment plan. HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,345.42 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check certified check or money order made payable and sent to: BAC Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222. You can cure any other default by takina the followina action within THIRTY (30) DAYS of the date of this letter. (Do not use if not applicable) IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise Its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements underthe mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: BAC Home Loans Servicing, LP Address: P. O. Box 660694 Dallas, TX 75266-0694 Phone Number: 1-800-669-6654 Fax Number: 1-817-230-6811 Contact Person: MS TX2-977-01-13 Attention: Loan Counselor We are currently developing a process to ensure secure email communications for your Horne Retention inquiries. In the interim, please contact us at the telephone number or address provided. EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Your loan is in default. Pursuant to your loan documents, BAC Home Loans Servicing, LP may, enter upon and conduct an inspection of your property. The purposes of such an inspection are to (1) observe the physical condition of your property, (ii) verify that the property is occupied and/or (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and 7UR } This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be charged to your account as provided in your security instrument. If you are unable to cure the default on or before June 1, 2011, BAC Home Loans 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 BAC Home Loans Servicing, LP. Our basic plan requires that BAC 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 loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through BAC Home Loans Servicing, LP even if your home is worth less than what is owed on it. • Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing any of these foreclosure alternatives with BAC Home Loans Servicing, LP, you must contact us immediately. If you request assistance, BAC Home Loans Servicing, LP will need to evaluate whetherthat assistancewill be extended to you. In the meantime, BAC Home Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as permitted by law, unless it agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by June 1, 2011 as outlined above will result in the acceleration of your debt. If your loan is currently being evaluated for a loan modification, forbearance or other loan assistance solution, this notice will not cancel or delay that evaluation process. However, it is important that you promptly respond to all requests made in connection with your evaluation for a loan assistance solution, including all requests for you to contact us and any documentation required. If you do not comply with these requests in a timely manner, it may cause your loan to enter the foreclosure process as indicated in this notice. If your loan is not eligible for a loan assistance program, please note this letter will continue to serve as notice of our right to initiate foreclosure. Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at 1-800-669-6654. This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. Attachment: Itemization of Charges and Fees Monthly Charges: 03/01/2011 05/31/2011 Late Charaes: 03/01/2011 - 04/30/2011 Other Charaes: Uncollected Late Charges: Partial Payment Balance: @ $748.30 $2,244.90 @ $25.13 $50.26 $50.26 0.00 TOTAL DUE: $2,345.42 This communication is from RAC Home Loans Servicing, LP, the Bank of America company that services your home loan. 7196 9006 9295 1704 6689 CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 CCCS of Western PA 2000 Lingiestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 PA Interfaith Community Programs Inc 40 E High Street Gettysburg, PA 17325 717.334.1518 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 This communication is from BAC Home Loans Servicing, LP, the Bank of America company that services your home loan. Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home t«"`€ Home A federal government program that allows you to repay the loan on newly agreed upon terms, which Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or Modification extending the term of the loan. You may be eligible for this program if you meet the following Program requirements: (RAMP) • The home is your primary residence and you currently live in it. • The amount you owe on the first mortgage is equal to or less than $729,750 for a single-family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have experienced a hardship that has impacted your income. For example, a significant increase in your mortgage payment OR reduction in your income OR other hardship. • Your mortgage was obtained before Jan. 1, 2009. • Your payment on your first mortgage (including principal, interest, taxes, insurance and homeowner's association dues, if applicable) is more than 31 % of your current gross income. To calculate this, divide your first mortgage payment by your gross income (income before taxes). Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the loan up Reinstatement to date until the day of your foreclosure sale. Repayment A temporary agreement which allows for the repayment of the unpaid, past due amount along with Plan regular mortgage payments. This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments for a Forbearance period of time, to allow you to re-establish your ability to make the required payments. Agreement Loan Repay the loan on newly agreed upon terms, which may include lowering the interest rate, placing Modification amounts past due at the end of the loan, and/or extending the term of the loan. (non-RAMP) Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you (FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home Home Designed to help borrowers who are eligible for the Home Affordable Modification Program (RAMP) Affordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the Foreclosure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agreement Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short Preforeclosure sale, you sell your property for less than the total amount owed on the loan (subject to agreement by Sale your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (non-HAFA) foreclosure. Deed in Lieu of Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not Foreclosure able to sell the property through a short sale. With a deed in lieu of foreclosure, you agree to (non-HAFA) voluntarily transfer ownership of your property to us in order to avoid foreclosure. Ir.We are here to help you. Please call us today. 7196 9006 9295 1704 6689 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notification adjunta para obtener mas information Cuando Ilame, tenga to informaci6n de sus ingresos y gastos disponibles pare que podamos discutir cual opcidn(es) pueden funcionar pare usted. Opciones a considerar si su objetivo es permanecer en su casa ......................................... . ...................................................:..:..............................:..................................................................... ...................................... Home Affordable Un programa del gobierno federal que le permite pagar el prestamo bajo los nuevos terminos Modification acordados, que pueden incluir la reduccibn de la tasa de interes, agregando la cantidad adeudada Program (RAMP) al final del prestamo, y / o extender el plazo del prestamo. Usted puede ser elegible pare este programa si cumple con los siguientes requisitos: • La case es su residencia principal y actualmente vive en ella. • La cantidad adeudada en la primera hipoteca debe ser igual o menos que $729,750 dblares para una vivienda unifamiliar, $934,200 dblares pare una propiedad de 2 unidades, $1,129,250 dblares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades He experimentado una dificultad que he afectado sus ingresos. Por ejemplo, un aumento significativo en su pago hipotecario O reduccibn de sus ingresos U otras dificultades. • Obtuvo su hipoteca antes del 01 de enero 2009. • Su pago de la primera hipoteca (incluyendo principal, interes, impuestos, seguro y cuotas de asociacibn de propietarios, si se aplica) debe ser mes del 31 % de sus ingresos brutos actuates. Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes de impuestos). Restablecimiento Si usted puede traer sus pagos del prestamo hipotecario al dia, se le aceptaran los fondos del Prestamo necesarios para que el prestamo este al dia haste la fecha de la venta judicial. Plan de Pago Un acuerdo temporal que permite el pago de la cantidad adeudada, cantidad del pago atrasado junto con los pagos regulares de la hipoteca. Esto puede incluir principal, interes, honorarios y/o costos aplicados a su prestamo. Acuerdo Un acuerdo por el cual nos comprometemos a no proceder con la ejecucibn hipotecaria y/o Temporal de coleccibn de pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia hater los pagos requeridos. Modificaci6n de Pagar el prestamo bajo los nuevos terminos acordados, que puede incluir la reduccibn de la tasa Prestamo de interes, agregando la cantidad adeudada al final del prestamo, y/o extender el plazo del (no por medio prestamo. de RAMP) Reclamo Parcial Si usted tiene un prestamo de la Administracibn Federal de Vivienda (FHA) y sus pagos esten (solamente vencidos, pero ahora puede hater sus pagos regulares mensuales de la hipoteca, este programa prestamos de la este diseriado para que su prestamo este al dia mediante la creacibn de una segunda hipoteca / FHA) gravamen sobre su propiedad por la cantidad adeudada. Opciones a considerar si no puede o no desea quedarse en su casa ?("..+, :<::'<•::'iiiii:i:iiiiiiii: OWNS: n..:i:.?.:::.-:.-::::i.-:::::.[•:v ii i::.:j:':: Si ii 'iii:: i:: ii::: ;i:?::::... ?....:.... Home .:.:.:..::......:. :.. :...:.:..:...:..:::.. Diserliado para ayudar a los prestatarios que son elegibles para el Programa de Home Affordable Affordable Modification (RAMP), pero no tuvieron exito en obtener una modificacibn permanente a traves del Foreclosure programa. HAFA ofrece la posibilidad de una yenta corta y, si no tiene exito, una entrega de Alternatives escritura pare evitarjuicio hipotecario. Una venta corta es una transaccibn en la que usted vende su Program propiedad por menos de la cantidad adeudada en el prestamo (sujeto a previo acuerdo de su (HAFA) administrador / prestamista / inversionista), resultando en la liberacibn de nuestro derecho de retencibn sobre su propiedad y evitar la ejecucibn hipotecaria. Una entrega de escritura pare evitar juicio hipotecario es una transaccibn en la que usted este de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecucibn hipotecaria. Venta Corta/ Se ofrece a los prestatarios que no son elegibles pare HAMP u otras alternatives de retencibn de Venta antes de hogar. Con una venta corta, usted vende su propiedad por menos de la cantidad total adeudada en Ejecucion el prestamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultando en la Hipotecaria (no liberacibn de nuestro derecho de retencibn sobre su propiedad y evitando la ejecucibn hipotecaria. por medio de HAFA) Entrega de Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternatives de retencibn de Escritura Para hogar, y que no pudieron vender la propiedad a traves de una venta corta. Con una entrega de Evitar Juicio escritura para evitar juicio hipotecario, usted este de acuerdo a transferir voluntariamente las Hipotecario escrituras de su propiedad a nosotros para evitar la ejecucibn hipotecaria. (no por medio de HAFA) Estamos aqui para ayudarle. Por favor llamenos hoy. R O TH01`° O TA' UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a-).udren.com Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. DWIGHT TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 JACQUELINE TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 Defendant(s) TO THE PROTHONOTARY: «'2M R21 AN 10: 25 " 1MBERLAND COUNT`! PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. 'Pla' (?qS Clvil ENTRY OF APPEARANCE Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Elizabeth L. Wassall, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN LAW OFFICES, P.C. BY41MV B. REESE, ESQUIRE PA ID 310501 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?? ,,?t 4litrtl,prya„ Jody S Smith Chief Deputy 10,112 APR I I y 2: 1 Richard W Stewart Solicitor OF vs l ; c_ I ; i , Bank of America, NA vs. Case Number Dwight Terry (et al.) 2012-1795 SHERIFF'S RETURN OF SERVICE 04/02/2012 05:05 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 2, 2012 at 1705 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Dwight Terry, by making known unto himself personally, at 1615 Matthew Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. RONALD HOOVER, DEPUTY 04/02/2012 05:05 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 2, 2012 at 1705 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jacqueline Terry, by making known unto Dwight Terry, Husband of Defendant at 1615 Matthew Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. c_. RONALD HOOVER, DEPUTY SHERIFF COST: $59.00 April 04, 2012 SO ANSWERS, RON - R ANDERSON, SHERIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08!813-3620 856-669-5400 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. DWIGHT TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 JACQUELINE TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS c> CIVIL DIVISION Cumberland County rn r*+ MORTGAGE FORECLOSURE `"?v co 3>c-) :x mac: NO.2012-1795 ' a PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindlyy enter judgment in favor of the Plaintiff and against the Defendant(s), DWIGHT TERRY; JACQUELIl?TE TERRY; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Additional Late Charges Escrow Per Complaint Title Report Attorney Fees- Estimated Property Inspections Grand Total FROM TO $99,362.59 $4,219.88 03/20/2012 05/15/2012 $580.26 $75.39 03/20/2012 05/15/2012 $50.26 $1,686.88 $325.00 $1,300.00 $165,00 $107,765.26 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached her5t@-? AMY GLASS, ESQ. PA BAR # 308367 NJ BAR # 13862010 DAMAGES ARE Y ASSESSED AS INDICATI DATE: 0.va %x . CV - yo ?j a 1 ? i.A MJU#: 12010054 CASE#: 120100541 UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN X MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE NL BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadimasr udren.com Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP C/O Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75806 Plaintiff V. DWIGHT TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 JACQUELINE TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF Rt9 =d ZC-Y -Orrl CD-n COURT OF COMMON PLtAS CIVIL DIVISION CUMBERLAND County NO. Po / a' -I 7' .S of /, / COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warmed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for, any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU' DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH ,BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of Jody S Smith Chief Deputy Richard W Stewart ,;a;, l- Yom. Solicitor OFFrE OF THro "RIFF Bank of America, NA vs. I Cass Number Dwight Terry (et al.) 2012-1795 SHERIFF'S RETURN OF SERVICE 04/0212012 05:05 PM - Ronald Hoover, Deputy Sheriff, who being duly swam according to law, states that on April 2, 2012 at 1705 hours, he served a true copy of the within Complaint in Mortgage Foreclosure,', upon the within named defendant, to wit: Dwight Terry, by making known unto himself personally, at 11615 Matthew Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same tinie handing to him personally the said true and correct copy of the same. RONALD HOOVER, DEPUTY 04/0212012 05:05 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 2, 2012 at 1705 hours, he served a true copy of the within Complaint in Mortgage Foreclosure; upon the within named defendant, to wit: Jacqueline Terry, by making known unto Dwight Terry, Husband of Defendant at 1615 Matthew Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. RONALD HOOVER, DEPUTY SHERIFF COST: $59.00 SO ANSWERS, April 04, 2012 RON R ANDERSON,' SHERIFF (C) CountySidle Smenf . TeleosoR, Irc. IUD ?O J UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 8564)69-5400 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff V. DWIGHT TERRY, JACQUELINE TERRY Defendant(s) TO: DWIGHT TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 Date of Notice: April 24, 2012 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-1795 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IlKPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA. POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA AI GUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TEENS ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. BY: Attorney for Plaintiff EUZAWN L WASiSALL, ES4 PA ID 77799 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#:1201NM CASE#:12010054-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER I I1 WOODrCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff V. DWIGHT TERRY, JACQUELINE TERRY Defendant(s) TO: JACQUELINE TERRY 1615 MATTHEW ROAD CAMP HILL, PA 17011 Date of Notice: April 24, 2012 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-1795 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA' DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO WMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRTTA ABAJO PARA AVERIGUAR DONDE SE PU'EDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UDREN LAW OFFICES, PC. BY: 1=?G Attorney for Plaintiff ELIZAS M L WASSAU, ESt, PA ID 7'7788 Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 12010054 CASE#: 12010054-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-65400 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff V. Dwight Terry Jacqueline Terry Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-1795 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), DWIGHT TERRY, JACQUELINE TERRY, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as ?ahibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. MJU#: 12010054 CASE#: 12010054-1 AMY GLASS, ESQ. PA BAR # 308367 NJ BAR # 13 862010 Resutis as d : May-15-2012 11:55:51 Department of Defense Manpower Data Center SCRA 2.1 Ii:?paart Pmt to Savrkememixrs Civil Rdief Act Last Name: Terry First Name: Jacqueline Active Duty Status Date May-15-2012 Active Duty End Dude shun S WOM Caegortsrd On A*" Duty On AdWe Daly Stalus Date NA No NA Pis response reflects are WWWuaW' active duty status based an the Active Duly Status Data Left Active Duly Min 367 Days of Aa6ve Duty elahn Oats NA No NA This response reltuts where ft Mdividual left active duty status wflhin 367 days precedtrp tM Acdve Duty Status Deis 'OnVernber or HbAiar Unh Was Nokiod d a Future Cai.Up to Adha Duly an Act** Duty sfatn Dale NA No - NA This response reflects whether the trdMdual or hiellver unk has received early natlflcadon to report for active duty Pon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status c the individual on the active duty status date 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 fixture orders to report for Active Duty. 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 at 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: httpJlwww.defenaelink.miVfaq/pis/PC09SLDR.html. 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). 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 Active Duty Status Date (2) Whetherthe individual left Active 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 cull 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 SARA 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: R6B0004FCH ReaulffiasoT:Mey,5zo,2RA Department of Defense Manpower Data Center scRA 2.1 2., I . ftws 40 R+apllart Pufuta& to Servicememll Civil Relief Act Last Name: T r First Name: Dwight Active Duty Status Date May-15-2012 Active Duly Ed DOM Statue Sembe compo"Ot On Adtee Duy On Adws Duty9Wus Date NA No NA This response reflects the individuals' active duty stabs based on the AcOvs Duty Status Date Loft Aahve DrgtriNitiirt 367 Darya of AcOvs Defy 9taau Dple NA No NA This response mIllecfa where the Wividual left active duty std wtil* 367 drys prscadnp the Ac#n Duty Status Dab lyre Mernber orll A Im Unh Was Nofted of s Futute Ces11p to Alga Duty on Actve Duty Stadue Dab NA No N4 This response nMeds wheeler the individual or Ftefhr unit has received early nod ftW to report for acute 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. 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 at 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 orgy 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: http://www.defenseiink.niiWaqipis/PCOgSLDR.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). 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 Active Duty Status Date (2) Whether the individual left Active 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 coo 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. Ail Active Guard Reserve (AGR) members must be assigned against an authorized mobilization positron 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 Tale 10 and Title 14 active duty records for all the Uniformed Services periods. Titre 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(dx1). 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: 3BEJRR9GO1 UDN LAW OFFICES, P.C. WOtDCREST CORPORATE CENTER 111 Wt,)ODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-3400 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff V. Dwight Terry Jacqueline Terry Defendant(s) a tLED-Ol' Fly, ?U T HIE PROTHONOTAW.( 2012 MAY 18 '>?; EY FOR PLAINTIFF CUMBERLAND COUNTY PENNSYLVANIA PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $107.765.26 Interest From 51 16?I?Q12 $ 1.150.34 to Date of Sale Seotember 5 2012 Ongoing Per Diem o f$10.18 to actual date of sale including if sale is held at a later date (Costs to be added) $ C. S') 0.v ?'a$•S?id ?`1 `sq.oo czr- 103.'15 "" C\.4 .< U 64 ;. S31)s c p ?* MJU#: 12010054 CASE: 12010054-1 LAW OFFICES, P.C. COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-1795 PA BA # 308367 NJ BAR # 13862010 'ja.J.s 6. Sp t C 04 09? fD E!4fa75q 1) WO vF ;Ussa6d F1LL0-0FO'! L THL_ R O T HO NO ATTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER7017 MAY 18 AM 10Y 39 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 CUMBERLAND COUNTY 856-669-5400 PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP Vk/a Countrywide Home Loans Servicing, LP Plaintiff V. Dwigbt Terry Jacqueline Terry Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 2012-1795 CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: r;? Act 91 procedures have been fulfilled II Premises is not subject to the provisions of Act 91 as this is an FHA insured mortgage This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. -- J3AK # 308367 NJ BAR # 13862010 UDREN LAW OFFICES, P.C. V06ODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff V. Dwight Terry Jacqueline Terry Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS M M z imp ?! CIVIL DIVISION , Cumberland County a MORTGAGE FORECLOSURE E5 CD NO. 2012-1795 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 1615 Matthew Road, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Dwight Terry 1615 Matthew Road Camp Hill, PA 17011 Jacqueline Terry 1615 Matthew Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Dwight Terry 1615 Matthew Road Camp Hill, PA 17011 Jacqueline Terry 1615 Matthew Road Camp Hill, PA 17011 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: East Pennsboro Township 98 S. Enola Drive Enola, PA 17025 4., Name and address of the last recorded holder of every mortgage of record: Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP Vk/a Countrywide Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 1615 Matthew Road Camp Hill, PA 17011 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: Federal Tax Lien Holders - None Condo/Homeowners Association None 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. sec. 4904 relating to unsworn falsification to authorities. DATED: 1lQ (' l/ MJU#: 12010054 CASE#: 12010054-1 AMY GLASS, ESQ. PA BAR # 3093,67 NJ BA* # I R6201 0 AM RSQ' PA 1, ;67 NJ BAR # 13 80200 F UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP Vk/a Countrywide Home Loans Servicing, LP Plaintiff V. DWIGHT TERRY, JACQUELINE TERRY Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS - CIVIL DIVISION W = Mme' Cumberland County -< z, o MORTGAGE FORECLOSURE -x n 3 ? Cl) NO. 2012-1795 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dwight Terry 1615 Mathew Road Camp Hill, PA 17011 Your house (real estate) at 1615 Matthew Road, Camp Hill, PA 17011 is scheduled to be sold at the Sheriffs Sale on September 5, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $107.765.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S, LWS YOU MAY BE ABLE TO PREVENT THIS SEMRIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I . The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) \ I 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 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 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-1795 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From DWIGHT TERRY and JACQUELINE TERRY (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 posse=ssion 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: $107,765.26 L.L.: $.50 Interest from 5/16/2012 to Date of Sale September 5, 2012 - Ongoing per diem of $10.18 to actual date of sale including if sale is held at a later date - $1,150.34 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $210.25 Other Costs: Plaintiff Paid: Date: 5/18/12 1 David D. Buell, Pro onotary (S.eal) By: Deputy REQUESTING PARTY: Name: AMY GLASS, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 308367 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUTTE 200 CHERRY HILL, NJ 08003-3620 856-6&9-5400 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff v. DWIGHT TERRY JACQUELINE TERRY Defendant(s) ATTORNEY FOR PLAINTIFF c~ c rn~ COURT OF COMMON PLEAS ~~' CIVIL DIVISION ~ Cumberland County ~~ ~-~ MORTGAGE FORECLOSURE z N0.2012-1795 ~ AFFIDAVIT OF SERVICE PURSUANT TO Pa.RC.P.RULE 3129.1 Plaintiff, by its/his/her Attorney hereby verifies that: ~ ~i N ~ ~ ~ r~- c-~ 'v rn N ~~ ~v G ~ ~ri ....i m ,~- TA w "- ..~:. 1. A copy of the Notice of Sheriffs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date' of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s) by regular mail and certified mail on the d appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit " 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn to authorities. Dated ~i ~ ~- UDREN LAW OFFICES, P.C. BY~I Attu or a' ti HARRY B. REESE, ESQUIRE PA ID 310501 MN#: 12010054 CASE#: 12010054-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-6b9-5400 l3anK of America, N.A., successor byy merger to BAC Home Loans Servicin~,.LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff v. DWIGHT TERRY JACQUELINE TERRY Defendant(s) ATTORNEY FOR COURT OF COMMON PLEAS CNIL DNISION Cumberland County MORTGAGE FORECLOSURE N0.2012-1795 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): DWIGHT TERRY AND JACQUELINE TERRY PROPERTY: 1615 Matthew Road, Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 09/05/2012 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish t attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than days after sale. Distribution will be made in accordance with the schedule unless exceptions a filed thereto within 10 days after the filing of the schedule. MJU#: 12010054 CASE#: 12010054-1 EXN~81TA 3 .,. a L m 5' N N C _~ N O O c~ m a `. a~"'o T m m ~ q~ A W N ~ C m OD V W fT J- W N -+ ~ Z ~~ 'g ~ N N m ~ o'. s, $ o N '' m V . m ~~p 3 ~ a ~ vv Q~ ~~ W --n ~i Dn _ ~ ° ° ~ v v 1 ~, ~ v ~ Dn a ~ ~ ~ S 70 =~ rn ~ 2 ~ . ~ n ~ ~ ~ - _ ~ v = ~ ~ m -o _ a ~ ~i ~ ~ > ~ ~ ~m °''+ ~'a 5e ~ ~° $ mn n ~ -. ° N 4° + D v rt~ Dy 5c ~ m ~ m ~ ° °~ w "~ oa •~• t o ~ D1$y2~~1~216 ~ ~ i ^ ' .GJ ~ r r N ~ OL w~~ ~ ~. ~'~ ~ ~ ~~j~,~esr S~~ = osit~i Zo12 /Q Mailetl Frq ~ ~ Q$ ~ ~ M ~ e IZ ~ ~+'° ~+ :W~" , o ° 4 4 J • ~` ,y- ~~ _C ~ • ~ ~~ ~ Q ~ ~~8 '~g ~~ ~ ~ 01 _~~ s^ g ~ ~'~ O i ~ ~ ~ J ~~ b ~~~ ~ ~ ~. ~ ~~~ ~ ~~ ~ ~ ~, ~; ~~~ ~ ~ o ~ ~ w ~ ~ ~~ $ x ~~ g ~~ X 1 t6 A ~ . ~ ~ E ~, ' Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor _r __ T __ _,_ . SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~ uo~t~ttr of Luegbrrf~~10 ~ ~ ~,x,.l } Yp ~~~-i ~.~ 4FF4CE ~F THE SF'.ERIFF Bank of America, NA vs. Case Numbe Dwight Terry (et al.) 2012-1795 SHERIFF'S RETURN OF SERVICE 06/18/2012 06/18/2012 06/18/2012 01:19 PM -Deputy Amanda Cobaugh, being duly sworn according to law, states service was perform by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled ac for upon the property located at 1615 Matthew Road, Camp Hill, PA 17011, Cumberland County. 01:19 PM -Deputy Amanda Cobaugh, 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 THf3MAS VALL Y, SON OF JACQUELINE TERRY, who accepted as "Adult Person in Charge" for Dwight Terry at 1615 Matthew Road, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County. 01:19 PM -Deputy Amanda Cobaugh, 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 THd3MAS VALL SON OF JACQUELINE TERRY, who accepted as "Adult Person in Charge" for Jacqueline Terry at 16 5 Matthew Road, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County. SHERIFF COST: $924.20 July 17, 2012 SO ANSWERS, ~~~ RON R ANDERSOW, SHERIFF EXHIBIT B (c) CountySuite Sherrtf, Teleosott, lik;. _....-._ UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a?.udren.com Bank of America, N.A Plaintiff ATTORNEY" FOR PLAIN TIFF COURT OF COMMON PLEAS CNIL, DIVISION Cumberland County D~TGHT TERRI', JACQUELINE T'ERRl', MORTGAGE FORECLOSURI: Defendant(s) NO. 2012-1795 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.RC.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), DWIGHT TERRY, JACQUELINE TERRY, whoieach of whom is over 18 years of aQe is/are not in active military service as defined in the Servicemembers~ Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". T'he Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and;~or Social Securit~~ number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 1 S Pa.C.S. §4904 relating to unsworn falsification, to authorities. Dated: October 16, 2012 Attorne}~ for Plaintiff HARRY B. REESi-, PA 1D 3~10~~1 MJU#: 120100,4 CASE#: 12010054-1 I~,e~artr;~en~ ~~` Defer~sc N~anDOwer Data C,ente~~ ~tat>.:.~ ~~~~~ t -.~~ _~ }'-.~]t`s-.~1nt i~:~ ~:~r~ i~~;'~7~tb~~~ ~"~~~pl l~~.li~: ~~: ~x ''kA, .F ~~~ _as ~~"a' i IC __~~l' =first fvamG: D'{NIGNT (Viiddie ~~am, Active Duty/ ~tatu4 As O': ~Jct-16-2Q12 rt}'~~.;i t`.; a50! -. VCl-IG•LU IL IU:UU:JJ s~RA _ :~ On Active Duty On Active Dury Status Date Active Duty Start Date Active Duty End Date' Status Service Component T NH 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 i Active Duty End Date Status i service Component I 1 N:; NA No NA This response reflects where the Indivicual left active duty status within 367 days preceding the Active Duty Status Datev j The Member or His/Her Unit Was Notlfied of a Future Call-Up to Active Duty on Active Duty StaWs Date Order Notification Start.Date Order Notification End Date Status I Sennce Component ~ ~1.. '. NA ~ No NA `I ~~ ~ p duty ~, ' This response reflects whether the individual or his/her unit has received early notification to re ort for active Upon searching the data banks of the Department of Defense tv1anpower Data Center, based on the information that you provides. 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. NOAF., Public Health, and Coast Guardl This status Includes information on a 5ervicemember or hislher unit receiving notification of future orders to report. for Active Duty. I, ~. ~ Mary M. Snave{y-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington. VA 22350 ~JCF~1~,I~~` ~° The Defense Manpower Uata 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 eiigibiGty for military medical care and other eligibility- systems. The DcD strongly suppons the enforcement of the Servicemernbers Civil Relief Act (50 USC App. § 501 et seq, as amended] (SC;P,A,i (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 referenc,~d above, or any family member. friend. er representative asserts in any manner that the individual was on active duty for the active duty status date. cr i= 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 :7ervice via the "defenselink.mil" URL: http:!iwww.defenselink.mil/faglpis/PC09SLDR.html. If you have evidence the person was on active dut~,~ for the active duty status date and you fail 10 obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you See 50 ',JSC App. § 521(c). This response ref~ec[s the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2 i 1Nhether the individual left Active Duty status within 36~' days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notific;abo ~ to report for active duty on the Active Duty Staius Date. More inforfnatiol~ or "~cfiva 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 3G consecutive aays 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 aeclared by the President and supported by r=ederal funds. All Active Guard Reserve (AGR) members must be assigned against an autharized mobilization position in the unit they support. This includes Navy Training and Administraton ofi the Reserves (TARs). Marine Corps Active Reserve (ARsi and Coast Guard Reserve Program Administrator (RPAs) Active Guty 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,. CoveraaQ G per t-)~. SCI'~,G, is 3roader in ~~ome 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 ccvered 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 SCI~A 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 no! 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 las: dates of active duty. Those wno could rely on this certificate are urged to seek qualified ieoal 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/date of birth, and active duty status date provided bpi the reattester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate 1 ~~,2t"iLD~H R_~sults a> e' Oeh~16-2012 10:09'14 ~e~a~mern o'.,~ ~efiense hfanpower Data ~er~ter ' ~ SCRA 2.3 wl - , ~ ~l~1CL3.+ ~~q t',~C7 `~( ttrrf~ f ~) a ".~';~~~ ~3I~~u~n.~ 1~..~" ~~:I`'.~'14.~. ~1~1i1L+~I~.~ L.•~tr ~ I\r~~l w..~ ,"S..L ~?eo~, kx°~" ri!~st Name:.~.%~~OU`~lt~ f~liddl~ Name ~c;tive ~ut~r Sixtus ~~ Off: Oct-~ 6-2012 S On Active Duty On Active Duty Status Date «, I ------~- Active Duty Start Date Active Dury End Date j Status __ ____Servce Component ~ NF- NA I No NA This response reflects the individuals active duty status oasetl nn the Active Duty Status Date S Left Active Duty Within 367 Days of Active Duty Status Date _.__v -~._- i 1 Active Duty Start Date ~ Active Dury End Date { Status ermce Componen! L_._.__.__-.__-~_-.._.~__-_.- .-~ V.~ NA No hA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date Ortler Notification Start Date tJF The Member or HisMer Unit Was Notified of a Fufure Ca11-Up to Active Duty on Active Dury Status Date Order Not cation 1=nd Date i Status NA No This response reflects whether the individual or his/her unit has received early notificafion to report for active pub/ Service Component •~ c, Upon searching the Data banks of the Department of Defense Manpower Data Center, based on the information that you provicied the above is the status of the individual on the acfive duty status date as to all branches of the Uniformed Services (Army. Navy, Marine Corps, Air Forre. NC~AA. ?ublic Health, and Coast Guard . This status InGudes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ~' Mary M. Snavely-D xo^.. Director Department of Defense -Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington. VA 22350: The Defense Manpowe- 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 eligibilib- system=. The DoD strongly supports the enforcement of the Setvicemembers 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 httpaiwww.defenseiink.mil/faq/pis/PCC9SLDR.html. If you have evidence the person was on active duty for the active duty status date and ycu fail to obtain this additional Service verification, ounitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). Tnls response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status w;thin 367 days preceding the Active Duty Status Date (31 Whether the individual or his/her unit received early notification tc report for active duty on the Actroe Duh Status Date. ~~~ore in~~~rmarlf?:-~ ors "F;ctive ~ut~~ 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 ar the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emerges; ~, declared by the President and suooorted oy Federal funds. All Active Guard Preserve (AGR) members must be assigned against an aulhonzed mobilization position in the unit they suppor, This includes Navy Training and Administration of the Reserves (TARS). Marine Corps Active Reserve (ARsj and Coast Guard Reserve Program Admirnstrator fRPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissionea officer of the U.S. Public Health Service cr the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Cctve,aae anger the SC~;f~ 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 i. Many times oGaers are amended to extend the period of active duty, which would extend SCRA protections. Persons seekine to rely on th!s 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 oe 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 numoer of nrotectons of the SCRA extend beyond me last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that aft rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. °roviding erroneous information wily cause an erroneous certificate to be provided. CerfiTi;;ate `~ ?~.4r>~ ; 5O53r14 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronn R Anderson ~"~ ,. ~~ ~ ~ ~ ~- Sheriff - ~~~~,utin ttt 4~nurttF,~~,f~~~¢ '~ i ~`E<~ ~~~ ~ ~~~~ i.~,. ,' Jody S Smith ~, , ~ .- Chief Deputy ~-~l ~ c ~L~ `~ ~ ~~ _ Richard W Stewart ~~~,~~~~~ .~~~ W ~4~.~ i ~, Solicitor C ~~ "~ 5 Y L~ Bank of America, NA vs. Dwight Terry (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2012-1795 06/18/2012 01:19 PM -Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1615 Matthew Road, Camp Hill, PA 17011, Cumberland County. 06/18/2012 01:19 PM -Deputy Amanda Cobaugh, 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 THOMAS VALLEY, SON OF JACQUELINE TERRY, who accepted as "Adult Person in Charge" for Dwight Terry at 1615 Matthew Road, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County. 06/18/2012 01:19 PM -Deputy Amanda Cobaugh, 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 THOMAS VALLEY, SON OF JACQUELINE TERRY, who accepted as "Adult Person in Charge" for Jacqueline Terry at 1615 Matthew Road, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County. 08/29/2012 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/3/2012 10/02/2012 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/5/2012 12/03/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $906.05 SO ANSWERS, "_- December 03, 2012 RON R ANDERSON, SHERIFF s ~ ~ ~~, ~~ ~^33> ~` ~~3 ~a~ ~euni S u-. ~ She; i 1 I ~~rsoh, In^ 4 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST~ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a~udren.com ATTORNEY FOR PLAINTIFF Bank of America, N.A., successor by COURT OF COMMON PLEAS merger to BAC Home Loans Servicing, LP ' CNIL DIVISION f/k!a Countrywide Home Loans Servicing, ', Cumberland County LP Plaintiff ', MORTGAGE FORECLOSURE v. Dwight Terry Jacqueline Terry NO. 2012-1795 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k!a Countrywide Home Loans Servicing, LP, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, 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: 1615 Matthew Road, Camp Hill, PA 17011 1. Name and address of Owners} or reputed Owner(s): Dwight Terry 1615 Matthew Road Camp Hill, PA 17011 Jacqueline Terry 1615 Matthew Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Dwight Terry 1615 Matthew Road Camp Hill, PA 17011 Jacqueline Terry 1615 Matthew Road Camp Hill, PA 17011 3: Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: East Pennsboro Township 98 S. Enola Drive Enola, PA 17025 ti ~ 4. Name and address of the last recorded holder of every mortgage of record: Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Sr Mortgage Holders -None Jr Mortgage Holders -None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders -None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 1615 Matthew Road Camp Hill, PA 17011 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: Federal Tax Lien Holders -None Condo/Homeowners Association -None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that fa,~s~ statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: ~~ ' ~(! ~ ~/ BY CES, P.C. for Plai~itiff MJU#: 12010054 CASE#: 12010054-1 pA ; F~Q- NJ BAk ~ i ~ rib2010 AMY GLASS, ESQ. PA BAR # 30836? NJ BAR # t~~r,~0t0 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF pleadings(a,udren.com Bank of America, N.A., successor by ~I COURT OF COMMON PLEAS merger to BAC Home Loans Servicing, LP I CIVIL DIVISION f/k/a Countrywide Home Loans Servicing, ', Cumberland County LP Plaintiff v. DWIGHT TERRY, JACQUELINE TERRY Defendant(s) MORTGAGE FORECLOSURE 'i NO. 2012-1795 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Dwight Terry 1615 Matthew Road Camp Hill, PA 17011 Your house (real estate) at 1615 Matthew Road, Camp Hill, PA 17011 is scheduled to be sold at the Sheriffs Sale on September 5, 2012 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $107,765.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney`s fees. To find out how much you must pay, you may call: (856) 669-540Q. 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. I'ou may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed 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 fmd out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a shaze 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 30 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ALL THAT CERTAIN TRACT OR PIECE OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT AT THE SOUTHEASTERLY CORNER OF GLENWOOD DRIVE (EAST) AND MATTHEW ROAD; THENCE ALONG THE SOUTHERLY LINE OF GLENWOOD DRIVE (EAST) NORTH 87 DEGREES 50 MINUTES EAST, 95 FEET TO A POINT AT DIVIDING LINE BETWEEN LOT NOS. 11 AND 12, BLOCK "K" ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 02 DEGREES 10 MINUTES EAST 96.31 FEET TO A POINT AT DIVIDING LINE BETWEEN LOT NOS. 12 AND 13, BLOCK "K" ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 79 DEGREES 30 MINUTES SOUTH 94.05 FEET TO A POINT ON THE EASTERLY LINE OF MATTHEW ROAD AFORESAID; THENCE ALONG THE SAME IN AN ARC HAVING A RADIUS OF 184.03 FEET TO A POINT IN A NORTHERLY DIRECTION TO THE RIGHT 26.77 FEET TO A POINT; THENCE FURTHER ALONG THE EASTERLY (ERRONEOUSLY OMITTED IN PRIOR DEED) LINE OF MATTHEW ROAD, NORTH 2 DEGREES 10 MINUTES WEST, 83.27 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 12, BLOCK "K", IN PLAN NO. 3 OF 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. BEING KNOWN AND NUMBERED AS 1615 MATTHEW ROAD. UNDER AND SUBJECT, NEVERTHELESS, TO ALL EASEMENTS, RESTRICTIONS, ENCUMBRANCES AND OTHER MATTERS OF RECORD OR THAT WHICH A PHYSICAL INSPECTION OR SURVEY OF THE PREMISES WOULD REVEAL. ADDRESS: 1615 MATTHEW RD.; CAMP HILL, PA 17011 TAX MAP OR PARCEL ID NO.: 09-16-1050-246 AS DESCRIBED IN MORTGAGE BOOK 1980 PAGE 3734 BEING KNOWN AS: 1615 Matthew Road, Camp Hill, PA 17011 PROPERTY ID NO.: 09-16-1050-246 TITLE TO SAID PREMISES IS VESTED IN DWIGHT TERRY AND JACQUELINE TERRY, HUSBAND AND WIFE BY DEED FROM VICTOR GONZALES AND DWIGHT TERRY DATED 05/09/2002 RECORDED 05/21/2002 IN DEED BOOK 251 PAGE 3888. w " UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings(a~udren.com Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff v. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE DWIGHT TERRY, JACQUELINE TERRY Defendant(s) '' N0.2012-1795 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Jacqueline Terry 1615 Matthew Road Camp Hill, PA 17011 Your house (real estate) at 1615 Matthew Road, Camp Hill, PA 17011 is scheduled to be sold at the Sheriffs Sale on September 5, 2012 at IO:OOam at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $107,765.26, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (8561 669-5400. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling 856-669-5400. 2. You maybe 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 fmd out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe 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 30 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800)990-9108 ALL THAT CERTAIN TRACT OR PIECE OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT AT THE SOUTHEASTERLY CORNER OF GLENWOOD DRIVE (EAST) AND MATTHEW ROAD; THENCE ALONG THE SOUTHERLY LINE OF GLENWOOD DRIVE (EAST) NORTH 87 DEGREES 50 MINUTES EAST, 95 FEET TO A POINT AT DIVIDING LINE BETWEEN LOT NOS. 11 AND 12, BLOCK "K" ON THE HEREINAFTER. MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 02 DEGREES 10 MINUTES EAST 96.31 FEET TO A POINT AT DIVIDING LINE BETWEEN LOT NOS. 12 AND 13, BLOCK "K" ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE, NORTH 79 DEGREES 30 MINUTES SOUTH 94.05 FEET TO A POINT ON THE EASTERLY LINE OF MATTHEW ROAD AFORESAID; THENCE ALONG THE SAME IN AN ARC HAVING A RADNS OF 184.03 FEET TO A POINT IN A NORTHERLY DIRECTION TO THE RIGHT 26.77 FEET TO A POINT; THENCE FURTHER ALONG THE EASTERLY (ERRONEOUSLY OMITTED IN PRIOR DEED) LINE OF MATTHEW ROAD, NORTH 2 DEGREES 10 MINUTES WEST, 83.27 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 12, BLOCK "K", IN PLAN NO. 3 OF 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. BEING KNOWN AND NUMBERED AS 1615 MATTHEW ROAD. UNDER AND SUBJECT, NEVERTHELESS, TO ALL EASEMENTS, RESTRICTIONS, ENCUMBRANCES AND OTHER MATTERS OF RECORD OR THAT WHICH A PHYSICAL INSPECTION OR SURVEY OF THE PREMISES WOULD REVEAL. ADDRESS: 1615 MATTHEW RD.; CAMP HILL, PA 17011 TAX MAP OR PARCEL ID NO.: 09-16-1050-246 AS DESCRIBED IN MORTGAGE BOOK 1980 PAGE 3734 BEING KNOWN AS: 1615 Matthew Road, Camp Hill, PA 17011 PROPERTY ID NO.: 09-16-1050-246 TITLE TO SAID PREMISES IS VESTED IN DWIGHT TERRY AND JACQUELINE TERRY, HUSBAND AND WIFE BY DEED FROM VICTOR GONZALES AND DWIGHT TERRY DATED 05/09/2002 RECORDED 05/21/2002 IN DEED BOOK 251 PAGE 3888. WRIT OF EXECUTION and/or ATTACHMENT ' COMMONWEALTH OF~PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-1795 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From DWIGHT TERRY and JACQUELINE TERRY (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) y'ou 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) II'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: $107,765.26 L.L.: $.50 Interest from 5/16/2012 to Date of Sale September 5, 2012 -Ongoing per diem of $10.18 to actual date of sale including if sale is held at a later date - $1,150.34 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $210.25 Other Costs: Plaintiff Paid: Date: S/18/12 Davi ..Buell, Prothono ary (Seal) By; Deputy REQUESTING PARTY: Name: AMY GLASS, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER, 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 308367 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my head ~~nd the seQal of said Cou(yrt~a~t,C~a~rlisle, P~a~.1 This ._J Ct_. day of _~, 20 Lc~_ _ t Prot nctary ~~~ ~- ~, On May 22, 2012 the Sheriff levied upon the defendant's interest in the reaLproperty situated in East Pennsboro Township,: Cumberland County,. PA, Known and numbered as, 1615 Matthew Road, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 22, 2012 By: ~- ~..... Real Estate oordnator C1(~ i1'`,~~ l,~~ CUMBERLAND LAW JOURNAL Writ No. 201-1795 Civil Term Bank of America, NA vs. Dwight Terry Jacqueline Terry Atty.: Mazk Udren ALL THAT CERTAIN tract or piece of land situate in East Pennsbora Township, Cumberland County, Pennsylvania, being more particu- lazly bounded and described as fol- lows, to wit: BEGINNING at a point at the southeasterly corner of Glenwood Drive (East) and Matthew Road; thence along the southerly line of Glenwood Drive (East) North 87 degrees 50 minutes East, 95 feet to a point at dividing line between Lot Nos. II and 12, Block "K" on the hereinafter mentioned plan of lots; thence along said dividing line South 02 degrees 10 minutes East 96.31 feet to a point at dividing line between Lot Nos. 12 and 13, Block "K" on said plan; thence along said dividing line, North 79 degrees 30 minutes South 94.05 feet to a point on the easterly line of Matthew Road aforesaid; thence along. the same in an arc having a radius of 184.03 feet to a point in a northerly direction to the right 26.77 feet to a point; thence further along the easterly (errone- ously omitted in prior deed) line of Matthew Road, North 2 degrees LO minutes West, 83.27 feet to a point, the place of BEGINNING. BEING Lot No. 12, Block "K", in Plan No. 3 of Ridley Pazk, which plan is recorded in the Office of the Recorder of Deeds in and for Cum- berland County, Pennsylvania in Plan Book 14, Page 22. Being known and numbered as 1615 Matthew Road. UNDER AND SUBJECT, neverthe- less, to all easements, restrictions, encumbrances and other matters of record or that which a physical inspection or survey of the premises would reveal. ADDRESS: 1615 Matthewrd.; Camp Hill, PA 17011 Tax Map or Pazcel Id No.: 09-16-1050-246. As described in Mortgage Book 1980 Page 3734. BEING KNOWN AS: 1615 Mat- thew Road, Camp Hill, PA 17011. PROPERTY ID NO.: 09-16-1050-246. TITLE TO SAID PREMISES IS VESTED IN Dwight Terry and Jac- queline Terry, husband and wife by Deed from Victor Gonzales and Dwight Terry dated 05/09/2002 recorded 05/21/2002 in Deed Book 251 Page 3888. 103 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 27, August 3, and August 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. . ~.,~- sa Marie Coyne, Edi r SWORN TO AND SUBSCRIBED before me this 10 da of Au ust 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28. 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~he~atriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws 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. PUBLICATION COPY This ad ran on the date(s) shown below: 07/27/12 08/03/12 08/10/12 COMMONWEALTH OF PENNSYLVANIA f Notarial Seal !I Sherrie L. t~wens, Notary Public Lower Naxton ~{"wp., Dauphin County rIy Commissinn Expires Nov. 26, 2015 MEMBER, i'ENNSY!_VANIA ASSOCIATION OF NOTARIES ZO1~-7T~ k~t~1 ~~ ~Y :. Atgr; ~Ihrk Weh~rn All'IbstC'ItaetSar Pace E)f Land Situate In Fast Pennsboro Tb', Cumberland Comity, Pew, Baiag More Partia>Vdy Bounded Aal Desar'bed As Follows,'A~ ~; Begirm~g At AR~mt At T~ ~~' Corner OPGleawriod Drire~etj And Mattha-Road;1'6euooe Ake The .. Sautt7~ly Line OEC~SOOd Drive (FasE) North 87Ikgryes•58 M Bast, 95 Faert 'Ib A Poim At Dividipa Live Between Lot Nas, llAgd 12, "~" OnThe HereiaatbSSr Mentloned PLnOf Lod; Thence Said Dividing . line S~~Deg~eea 10 Bast 96.31 Feet , A Pb~ At Divadmg Ltoe Betwece Lot Noe.l2And 13, Biodr"K" On Said Plan; Throe Aks~ 94.05 Feet ToA;F~st On Thee 1~Soarh Line Of Matthex Rotd Afatesaid; Thea+ce Along.'I'ho S~se In AnAec IdA Radi~+0¢ k84.03 Feet ~ A Poiar la A Northerly Direction'Ib 1Tao Righi 26.77 Feet 1b A Point; Tbonceier Alm T~ Fa~rlq(Frmnegwly O~itoed m Prior Deed) Line Of Matthew Road, Alorth 2 Degrees 10 Minutes Wiest, 83,27 ged'!b A Point, The Ph~oe Of Be8~8• Being Lot No. I2„Biodt"It", Jn Phm No. 3~ Of Ridley Park,. Whk~-PhinIsltaetirorrded Irt The Office Of The Reoasder Of Deeds Ja Ia Plan Book 14, Page Z~ Iilhorm And Numbered As 16'15 Matthew Rand. Under And Subjecx, Ne~riheless,'IhAll Easements, Reatdgions,. Enp,mbranas And Other Matters OP Reoard tar That Whig A Physical Iospa~On Or Survey Of The Premises ®Vould Reveal, Address: 1615 MattheWi'd,; Camp,H01, Pa 17011'I~c Map Or ParcetId No.: (19-16- 1050-1A6 As Described In Mortgage Book 1980 Page 3734 Being Known As:1615 Matthew Road, Camp H~, Pa 17011 Property Id No.: 09- 16.1050.246 Title 1b Said Premixs Is vested In Dwight 'TerryAnd Jaoquetine lorry, Huefntnd And Wile By Deed From Vx~ Gonules And Dw~tht'li;rry Dated 031091~d02 Ranr~d OS/21/2002In Deed Book 251 Page 3888. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 _ CHERRY HILL,NJ 08003-3620 856-669-5400 plea dings udren.com Bank of America,N.A., successor by COURT OF COMMON PLEAS merger to BAC Home Loans Servicing,LP CIVIL DIVISION f/k/a Countrywide Home Loans Servicing, Cumberland County LP Plaintiff MORTGAGE FORECLOSURE _ V. m °#M ZI F DWIGFIT TERRY; JACQUELINE TERRY; NO. 2012-1795 et al o �. Defendant(s) ?C C) PRAECIPE TO WITHDRAW JUDGMENT AND DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above captioned matter as JUDGMENT WITHDRAWN and ACTION DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. DATED: UDREN LAW C. BY• A rney f, r Plaintiff MJU#: 12010054 CASE#.• 12010054-1 David Neeren, EsqUirc-,, PA I D 20422 13