HomeMy WebLinkAbout12-1879KML LAW GROUP, P.C. r F E (.'jq
SUITE 5000-BNVMELLON INDEPENDENCE CENTER •, e° r ` `' C s011'{?`a i'
701 MARKET STREET
PHILADELPHIA, PA 19106 r 1 t! 7 P p. 0.k `'
(866) 413-2311"'
vw.rr r . m?uni ro l?n1U -- -- . . • n t+!'1 13.j '{ 1 f
THE BANK OF NEW YORK MELLON TRUST
t! 1.1
COMPANY, N.A., AS UNDERLYING TRUSTEE Folk
THE FDIC 2011 -N 1 ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
r r .? ! : R' THE COURT OF COMMON PLEAS
L'V;rIt
OF Cumberland COUNTY
CIVIL ACTION - LAW
Plaintiff
vs.
JENNIFER CASTRO
Mortgagor(s) and Record Owner(s)
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
NOTICE
ACTION OF MORTGAGE FORECLOSURE
No.dc(a, 07 -( ?(vi
CIVIL ACTION: MORTGAGE
FORECI.0?;-`M
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
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
defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner
de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA Q
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CiYwk ?ID3.7S pd a
??c97
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website http://www.phfa.orgjconsumers/homeowners/real.aVx.
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http://www.12hiladelphiafed.org/foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretentiongkmllaw roup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 110891FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS UNDERLYING
TRUSTEE FOR THE FDIC 2011-N1 ASSET TRUST, c/o Nationstar Mortgage, LLC, 350 Highland
Drive, Lewisville, TX 75067.
2. The name(s) and address(es) of the Defendant(s) is/are JENNIFER CASTRO, 310 Virginia Road,
Mechanicsburg, PA 17050, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises
hereinafter described.
On July 02, 2009 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter
described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR
GRAYSTONE MORTGAGE, which mortgage is recorded in the Office of the Recorder of Deeds of
Cumberland County on July 08, 2009 as Instrument #200923582. The mortgage has been assigned to:
THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS UNDERLYING TRUSTEE
FOR THE FDIC 2011-N1 ASSET TRUST by assignment of Mortgage. Plaintiff is the real party in
interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage and
Assignment(s) are matters of public record and are incorporated by this reference in accordance with
Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to
attach documents to pleadings if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for August 01, 2011 and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance ..................................................................................$149,958.23
Interest from 07/01/2011 through 02/29/2012 at 5.0000% ......... ..............$4,998.64
Monthly Interest Amount $624.83
Escrow ......................................................................................... ..............$1,597.13
Property Inspections ................................................................... ...................$67.45
Property Preservation .................................................................. .................$505.00
BPO ............................................................................................. ................... $95.00
$157,221.45
Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
9. Notice of Intention to Foreclose has been sent to Defendants by certified mail, as required by Act 6 of
1974 of the Commonwealth of Pennsylvania, on the date set forth in the true and correct copy of such
Notice attached and incorporated as Exhibit "B".
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $157,221.45,
together with monthly interest amount of $624.83 and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and
Pennsylvania law, including but not limited to attorney fees and costs, until the Mortgage is paid in full, and for
the foreclosure of the Mortgage and Sheriff s,Sc3asof the Property'---,r
By:
KNXLAW GROUP C.
Michael McK ver Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Ann E. Swartz Pa. ID 201926
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
VERIFICATION
Jayme Towner , as Limited Vice President for Nationstar Mortgage,
LLC as attorney-in-fact for The Bank of New York Mellon Trust Company, N.A., as underlying
Trustee for the FDIC 2011-N1 Asset Trust do hereby verify that I am authorized to and do make
this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my information and belief. I understand that false
statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
Date: 6) h J?a
ltd - r
Jayme Towner
Assistant Secretary
# 110891 FC - JENNIFER CASTRO
310 Virginia Road Mechanicsburg, PA 17050
Ey,hibitA
ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County,
Pennsylvania, bounded and described in accordance with a survey road by D.P.
Raffensperger Associates, dated January 2, 1979, as follows, to wit:
BEGINNING at a point on the western side of Virginia Road, said point being 80.0 feet
south of Delbrook Road; thence along the western side of Virginia Road, South 04 degrees
00 minutes East 63.40 feet to an iron pin; thence South 86 degrees 00 minutes West, 120.0
feet to an iron pin; thence North 04 degrees 00 minutes West, 3.4 feet to an iron pin; thence
along Lot No. 16 of the hereinafter mentioned Plan, North 24 degrees 26 minutes 30 seconds
East, 68.23 feet to an iron pin; thence along Lot No. 1, North 86 degrees 00 minutes East,
87.50 feet to the western side of Virginia Road, the place of BEGINNING.
Having thereon erected a 1 % story brick and aluminum siding dwelling known as No. 310
Virginia Road.
BEING Lot No. 2 and the northern 3.4 feet of Lot 3, Block C, Plan No. 2 Del-Brook Manor,
recorded in Plait Book 7, Page 8, Cumberland County Records.
BEING known as 310 Virginia Road (Hampden Township) Mechanicsburg, PA 17055.
E.,xhibit B
Exhibit has been redacted to remove all personally identifiable information or non-public information
Nationstar Mortgage, LLC
PO Box 9095
Temecula, CA 92589-9095
Send Payments to:
Nationstar Mortgage
PO Box 650783
Dallas, TX 75265-0783
7196 9006 9295 7401 6175
20120126-160
11 ...I1,1111ll Ill nlnlnllllllnlllllllll.l'.-I'll'...nlln#Il1
JENNIFER CASTRO
310 VIRGINIA RD
MECHANICSBURG, PA 17050-3067
PRESORT
First-lass Mail
U.S. Postage and
Fees Paid
WS0
PA_ACT6
G A*-,
ht0 R J C, A GC
01/26/2012
JENNIFER CASTRO
310 VIRGINIA RD
MECHANICSBURG, PA 17050-3067
Loan Number: X6448
Property Address: 310 VIRGINIA RD
MECHANICSBURG, PA 17050
Sent Via Certified Mail
7196 9006 9295 7401 6175
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear JENNIFER CASTRO:
The MORTGAGE held by Nationstar Mortgage, LLC (herein as "Nationstar Mortgage, LLC ") (hereinafter
we, us or ours) on your property located at:
310 VIRGINIA RD
MECHANICSBURG, PA 17050
IS IN SERIOUS DEFAULT because you have not made the monthly payment (s) and other charges for the
months of 08/01/2011 through 01/26/2012 as follows:
The total amount now required to cure this default, or in other words, get caught up in your payments, as of the
date of this letter, is $7,653.07.
Next Payment Due Date
Total Monthly Payments Due:
Late Charges:
Other Charges:
TOTAL YOU MUST PAY TO CURE DEFAULT:
Uncollected NSF Fees:
Other Fees:
Corporate Advance Balance:
Unapplied Balance
08/01/2011
$6,854.14
$266.48
$0.00
$0.00
$532.45
($0.00)
$7,653.07
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of $7,653.07, plus any additional monthly payments and late charge which may fall due during this
period. Such payment must be made either by cash, cashier's check, certified check or money order.
PA_ACT6
Page] of 4
7L96 9006 9295 7401 6175
Please include your loan number and property address with your payment and send to:
Nationstar Mortgage, LLC
350 Highland Drive
Lewisville, TX 75067
Attn: Default Management
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our
attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged
property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you
cure the default before they begin legal proceedings against you, you will still have to pay the reasonable
attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to
whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day
period, you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the thirty 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 foreclosure
sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges
then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform
any other requirements under the mortgage).
It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6)
months from the date of this notice. A notice of the date of the Sheriff 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 will be by calling us at 1-888-480-2432. This payment must be in cash,
cashier's check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict
you.
You have additional rights to help protect your interest in the property. YOU 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 (YOU MAY HAVE
THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE
ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT
MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the same position as if no default had occurred.
However, you are not entitled to this right to cure your default more than three times in any calendar year.
PA_ACT6
Page 2of4 7196 9006 9295 7401 6175
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Nationstar Mortgage, LLC offers
consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These
services are provided without cost to our customers. You may be eligible for a loan workout plan or other
similar alternatives. If you would like to learn more about these programs, you may contact the Loss Mitigation
Department at 1-888-480-2432, Monday - Friday 8:00 A.M. - 7:00 P.M. Central Time. WE ARE VERY
INTERESTED IN ASSISTING YOU.
FEDERAL LAW REQUIRES US TO ADVISE YOU THAT NATIONSTAR MORTGAGE, LLC IS A DEBT
COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR
IS SUBJECT TO TITS AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR
INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN
ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. iF YOU ARE
REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND
s TELEPHONE NUMBER
PA ACT6
Page 3of4 7196 9006 9295 7401 6175
Attention Service members and dependents: The Federal Service members' Civil Relief Act ("SCRA') and
certain state laws provide important protections for you, including prohibiting foreclosure under most
circumstances. If you are currently in the military service, or have been within the last nine (9) months, AND
joined after signing the Note and Security Instrument now in default, please notify Nationstar Mortgage, LLC
immediately. When contacting Nationstar Mortgage, LLC as to your military service, you must provide
positive proof as to your military status. If you do not provide this information, it will be assumed that you are
not entitled to protection under the above-mentioned Act.
If you are experiencing financial difficulty, you should know that there are several options available to you that
may help you keep your home. You may contact a government approved housing counseling agency which
provides free or low-cost housing counseling. You should consider contacting one of these agencies
immediately. These agencies specialize in helping homeowners who are facing financial difficulty. Housing
counselors can help you assess your financial condition and work with us to explore the possibility of
modifying your loan, establishing an easier payment plan for you, or even working out a period of loan
forbearance. For your benefit and assistance, there are government approved homeownership counseling
agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call (800) 569-4287 or visit hqp://www.hud.gov/offices/hsgJsfh/hcc/hcs.cfm.
You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclosure
counseling agency. You may call the following toll-free number to request assistance from the Homeownership
Preservation Foundation: (888) 995-HOPE. If you wish, you may also contact us directly at 1-888-480-2432
and ask to discuss possible options.
This matter is very important. Please give it your immediate attention.
Sincerely,
Nationstar Mortgage, LLC
350 Highland Drive
Lewisville, TX 75067
1-888-480-2.432
PA_ACT6
Page4 of4 7196 9006 9295 7401 6175
Nationstar Mortgage, LLC
PO Box 9095
Temecula, CA 92589-9095
Send Payments to:
Nationstar Mortgage
PO Box 650783
Dallas, TX 75265-0783
M
7196 9006 9295 7401 6182
20120126-160
Jennifer Castro
1104 Louisa Ln
Mechanicsburg, PA 17050-7290
PRESORT
First-Class Mail
U.S. Postage and
Fees Pad
W SO
PA_ACT6
-.
at*io0 !" I ,r' -
MO81C,A
01/26/2012
Jennifer Castro
1104 Louisa Ln
Mechanicsburg, PA 17050-7290
Loan Number: _6448
Property Address: 310 VIRGINIA RD
MECHANICSBURG, PA 17050
Sent Via Certified Mail
7196 9006 9295 7401 6182
NOTICE OF INTENTION TO FORECLOSE MORTGAGE
Dear Jennifer Castro:
The MORTGAGE held by Nationstar Mortgage, LLC (herein as "Nationstar Mortgage, LLC ") (hereinafter
we, us or ours) on your property located at:
310 VIRGINIA RD
MECHANICSBURG, PA 17050
IS IN SERIOUS DEFAULT because you have not made the monthly payment (s) and other charges for the
months of 08/01/2011 through 01/26/2012 as follows:
The total amount now required to cure this default, or in other words, get caught up in your payments, as of the
date of this letter, is $7,653.07.
Next Payment Due Date
Total Monthly Payments Due:
Late Charges:
Other Charges:
TOTAL YOU MUST PAY TO CURE DEFAULT:
Uncollected NSF Fees:
Other Fees:
Corporate Advance Balance:
Unapplied Balance
08/01/2011
$6,854.14
$266.48
$0.00
$0.00
$532.45
($0.00)
$7,653.07
You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above
amount of $7,653.07, plus any additional monthly payments and late charge which may fall due during this
period. Such payment must be made either by cash, cashier's check, certified check or money order.
Wi
PA_ACT6
Page 1 of 4
7196 9006 9295 7401 6182
Please include your loan number and property address with your payment and send to:
Nationstar Mortgage, LLC
350 Highland Drive
Lewisville, TX 75067
Attn: Default Management
If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the
mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our
attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged
property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you
cure the default before they begin legal proceedings against you, you will still have to pay the reasonable
attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to
whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day
period, you will not be required to pay attorney's fees.
We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage.
If you have not cured the default within the thirty 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 foreclosure
sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges
then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform
any other requirements under the mortgage).
It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6)
months from the date of this notice. A notice of the date of the Sheriff 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 will be by calling us at 1-888-480-2432. This payment must be in cash,
cashier's check, certified check or money order and made payable to us at the address stated above.
You should realize that a Sheriff's sale will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict
you.
You have additional rights to help protect your interest in the property. YOU 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 (YOU MAY HAVE
THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE
ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT
MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY
ACTING ON YOUR BEHALF.
If you cure the default, the mortgage will be restored to the same position as if no default had occurred
However, you are not entitled to this right to cure your default more than three times in any calendar year-
PA ACT6
Page 2of4 7196 9006 9295 7401 6182
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, Nationstar Mortgage, LLC offers
consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These
services are provided without cost to our customers. You may be eligible for a loan workout plan or other
similar alternatives. If you would like to learn more about these programs, you may contact the Loss Mitigation
Department at 1-888-480-2432, Monday - Friday 8:00 A.M. - 7:00 P.M. Central Time. WE ARE VERY
INTERESTED IN ASSISTING YOU.
FEDERAL LAW REQUIRES US TO ADVISE YOU THAT NATIONSTAR MORTGAGE, LLC IS A DEBT
COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR
IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR
INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN
ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE
REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND
TELEPHONE. NUMBER
PA_ACT6
Page 3of4 7196 9006 9295 7401 6192
Attention Service members and dependents: The Federal Service members' Civil Relief Act ("SCRA') and
certain state laws provide important protections for you, including prohibiting foreclosure under most
circumstances. If you are currently in the military service, or have been within the last nine (9) months, AND
joined after signing the Note and Security Instrument now in default, please notify Nationstar Mortgage, LLC
immediately. When contacting Nationstar Mortgage, LLC as to your military service, you must provide
positive proof as to your military status. If you do not provide this information, it will be assumed that you are
not entitled to protection under the above-mentioned Act.
If you are experiencing financial difficulty, you should know that there are several options available to you that
may help you keep your home. You may contact a government approved housing counseling agency which
provides free or low-cost housing counseling. You should consider contacting one of these agencies
immediately. These agencies specialize in helping homeowners who are facing financial difficulty. Housing
counselors can help you assess your financial condition and work with us to explore the possibility of
modifying your loan, establishing an easier payment plan for you, or even working out a period of loan
forbearance. For your benefit and assistance, there are government approved homeownership counseling
agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call (800) 569-4287 or visit hqp://www.hud.gov/offices/hsg/sfh/hcc/hcs.cfm.
You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclosure
counseling agency. You may call the following toll-free number to request assistance from the Homeownership
Preservation Foundation: (888) 995-HOPE. If you wish, you may also contact us directly at 1-888-480-2432
and ask to discuss possible options.
This matter is very important. Please give it your immediate attention.
Sincerely,
Nationstar Mortgage, LLC
350 Highland Drive
Lewisville, TX 75067
1-888-480-2432
PA_ACT6
Page4 uN 7196 9006 9295 7401 6182
rshibit C
Prepared by:
Carl Kelso
Nationstar Mortgage LLC
350 Highland Drive
Lewisville, Texas 75067
Parcel/Tax ID#: 10210279334
ASSIGNMENT OF MORTGAGE
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR
GRAYSTONE MORTGAGE, P.O. Box 2026, Flint, MI 48501, (Assignor), for and inconsideration of the sum
of S 1.00 and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell,
assign and transfer to THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS UNDERLYING
TRUSTEE FOR THE FDIC 2011-NI ASSET TRUST, 350 Highland Drive, Lewisville, TX 75067 (Assignee),
all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and
the indebtedness secured by the mortgage:
Executed JENNIFER CASTRO, Mortgagor(s)
Bearing date of. 2nd ofJuly, 2009 Amount Secured: $155,138.00;
Recorded on: 8th of July, 2009 in Instrument #20923582; in the Recorder of Deeds Office of Cumberland
County, Commonwealth of Pennsylvania ("Mortgage")
Property: 310 VIRGINIA RD, MECIIANICSBURG, PA 17050
Together with the note or obligation described in the Mortgage endorsed to the assignee,("Note") and all moneys
due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and
assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of
redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever.
Assignee certifies that the precise address of THE BANK OF NEW YORK MELLON TRUST COMPANY,
N.A., AS UNDERLYING TRUSTEE FOR THE FDIC 2011-NI ASSET TRUST, is c/o Nationstar Mortgage
LLC, 350 Highland Drive, Lewisville, TX 75067.
Assignor, by its appr1riate corporate officers, has executed and sealed with its corporate seal this Assignment of
Mortgage on this 7 day of 20_
MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. AS NOMINEE FOR GRAYSTONE
MORTGAGE
(Affix Corporate Seal) Z' Z (SEAL)
Name: amie Baker
Title: Assistant Secretary
s s:
STATE OF TEXAS )
COUNTY OF DENTON)
BE IT REMEMBERED, that on this .3 day of ?0 t2, before me,
the subscriber, a Notary Public personally appeared kAAF to me known, t4 ho being duly
sworn, did say that he/she is the Assistant Secretary of MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. AS NOMINEE FOR GRAYSTONE MORTGAGE, who I am satisfied are the persons who
signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered
the same as such officers aforesaid, and that the within instrument is the voluntary act and deed of such corporation
made by virtue of a Resolution of its Board of Directors.
Notary Publi
My commission expires: d 24
:gUo' ERIC RAY ACKLIN
,?'' * . I Notary Public. State of Texas
My Commission Expires
DeComber 15, 2015
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
G
F°' ED-O I IC°
0111 T HE Pri OT?10. "r'J IArt Y
«12 APR 27 AM 9: 51
CUM8'RL;,,,ND COUNTY
PENNSYLVANIA
The Bank of New York Mellon Trust Company Case Number
vs.
Jennifer Castro 2012-1879
SHERIFF'S RETURN OF SERVICE
04/25/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Jennifer Castro, but was unable to locate her in his
bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the
defendant Jennifer Castro. Request for service at 310 Virginia Road, Mechanicsburg, Pennsylvania
17050 is vacant. The Mechanicsburg Postmaster has confirmed, Jennifer Castro has moved and left no
forwarding address.
SHERIFF COST: $43.00 SO ANSWERS,
April 26, 2012 RbNWY- R ANDERSON, SHERIFF
KML Law Group P.C.'`
SUITE 5000 -BNY INDEPENDENCE 3ENTEIZ
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
l t , : ?371 IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
? p?Kt L` All
THE BANK OF NEW YORK MELLON TRUST
COMPANY, N.A., AS UNDERLYING TRUSTEE
FOR THE FDIC 2011-N1 ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
vs.
JENNIFER CASTRO
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 2012-1879 Civil
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
By: W _
W GROUP, P.C.
Mi I el cKeever Pa. ID56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay E. Kivitz Pa. ID 26769
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
S
a?} aIl.iSpd °?'1
CI?'? 1ltlel q
??2-7 soa7
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
?Q??,a11? ?i# 4utt?Ltrj??t?
.. :e 4.1 D-OFFi4Jf...
PROTHCNO
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
2812 MAY 24 AM 8: 16
'UMSERLAND COUNT`.'
PENNSYLVANIA
The Bank of New York Mellon Trust Company
vs.
Jennifer Castro
Case Number
2012-1879
SHERIFF'S RETURN OF SERVICE
05/15/2012 07:42 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on May 15,
2012 at 1942 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Jennifer Castro, by making known unto herself personally, at 1104 Louisa
Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time
handing to her personally the said true and correct copy of the same.
DENPf FRY, DEP
SHERIFF COST: $38.00
May 18, 2012
SO ANSWERS,
ZRON R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoff, Inc.
In the Court of Common Pleas of Cumberland County
THE BANK OF NEW YORK MELLON TRUST COMPANY,
N.A., AS UNDERLYING TRUSTEE FOR THE FDIC 2011-N1
ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
vs.
JENNIFER CASTRO
(Mortgagor(s) and Record Owner(s))
310 Virginia Road
Mechanicsburg., PA 17050
Defendant(s)
PRAECIPE FOR JUDGMENT
'
c
1 a
No. 2012-187. *''
c._ ?,-rt
.._
nr" t ?
c
r?
co
> C7 x" G7'"ti t
. C%
CO
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against JENNIFER CASTRO by default for want of an Answer.
Assess damages as follows:
Debt
Interest from 6/27/2012 to
Date of Sale per diem at $20.83
Total
(Assessment of Damages attached)
$159,679.39
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe as Ticed r delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the d faulu d and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C. P,.
W
I e.
- l er 1P Pa,. ID 5 D 5
Mi ael Mc Bever 6129
Jay Kivitz it. ID 26769
Lisa Lee Pa. ID 78020
_Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua 1. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
a v 6?d 69H'
`? Attorneys for Plaintiff
AND NOW 1 "'x _ Q)0 ( a , Judgment is entered in favor o HE
TEE HE FDIC 20 - 1
Y' vhw.14,
BANK OF NEW YORK MF,LLO TRUST COMPANY, N.A., AS UNDERL GTR
ASSET TRUST and against JENNIFER CASTRO by default for want of an Ans and d Ns R.sed in the
$159,679.39 as per the above; certification. /A .
ary
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS UNDERLYING TRUSTEE FOR THE FDIC
2011-N1 ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
No. 2012-1879 Civil
vs.
JENNIFER CASTRO
(Mortgagors and Record Owner(s))
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
David D. Buell
Prothonotary of Cumberland County
1 Courthouse Squ
Carlisle, PA 17013`. ~-?
Prothonotary
Imo` 1 a- By: " ."
Deputy
If you have any questions concerning the above, please contact:
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
110891FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NO"[`ICE: June 6, 2012
TO:
JENNIFER CASTRO
310 Virginia Road
Mechanicsburg, PA 17050
THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A.,
AS UNDERLYING TRUSTEE FOR THE FDIC 2011-NI ASSET
TRUST
350 Highland Drive
Lewisville,'IX 75067 Plaintiff
VS.
JENNIFER CASTRO
(Mortgagor(s) and Record Owner(s))
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
TO: JENNIFER CASTRO
310 Virginia Road
Mechanicsburg, PA 17050
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 2012-1879 Civil
UWPORTANT 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO ORTELEPHONE 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.
CUMBhRL AND (X)UNtY BAR ASSOCIATION
2 Liberty Avenue
Carlisle. PA 17013
LEGAL SERVICES INC
8 lrvine Row
Carlisle, PA 17013
717-243-9400
P.C.
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
215-825-6360
Attorneys for Plaintiff
By:: t v?
KM GROUP
is ael McKeever Pa. ID 56129
110891F'C
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
DATE', OF THIS NOTICF: June 6, 2012
TO: JENNIFER CASTRO
1104 Louisa Lane
Mechanicsburg, PA 17050
THE BANK. OF NEW YORK MELLON TRUST COMPANY, N.A.,
AS UNDERLYING TRUSTEE FOR THE FDIC 201 I-N1 ASSET
TRUST
350 Highland Drive
Lewisville, TX 75067 Plaintiff
vs_
JENNIFER CASTRO
(Mortgagor(s) and Record Owner(s))
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
I O: JENNIFER CASTRO
1104 Louisa Lane
Mechanicsburg, PA 17050
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 2012-1879 Civil
U"ORTANT 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 Y01J ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE_ IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
By: r7liffif
ROUP, P.C_
Mich del McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa_ ID 82628
Thomas Puleo Pa. ID 27615
_:KXII P. Jenldns Pa. ID 306588
215-825-6360
Attomeys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THE BANK. OF NEW YORK MELLON TRUST COMPANY,
N.A., AS UNDERLYING TRUSTEE FOR THE FDIC 2011-N1
ASSET TRUST
Plaintiff
vs.
JENNIFER CASTRO
Defendant(s)
NO. 2012-1879 Civil
VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1.. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website
operated by the United States Department of Defense (https://www.dmdc.osd.mil/apl?i/scra/scraHome.do)
for the following individual(s): JENNIFER CASTRO, has a last known residence of 1 104 Louisa Lane,
Mechanicsburg, PA 17050. The following information was used to search the DMDC (check all that
apply):
X Last Name
X First Name
_X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A. 4904 relati g to unswom
Date
to
KML I. Kw OUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. 205047
:?__J,ill P. Jenkins Pa. 113306588
Attorneys for Plaintiff
Department of Defense Manpower Data Center
statues Report
F'unu;ant to Seruieememt Civil Relief Act
Last Name: CASTRO First Name: JENNIFER
Active Duty Status As Of: Jun-26-20.12
12esults as of : Jun-26-2012 01:09:33
SCRA 22.1
Active Duty Start Date Active Duty End Date Status Service Component
On Active Duty On Active Duty Status Date
N,4 NA _ No NA
This response reflects the individuals' active duty status based on the Active Duty Status Dale
Leff Active Duty within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End
E E Status Service Component
NA NA
tE No _ - NA
_
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the individual or hislher unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
00
)6t WI 4t4 A??_
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 (Di is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the, individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: hftp://www.defenselink.mil/faq/pis/PC0913LDR.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).
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 call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (Ai 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 (NOAH Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SC:RA 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: DNHDF4FB2F
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attornev for Plaintiff
THE BANK OF NEW YORK MELLON TRUST
COMPANY, N.A., AS UNDERLYING TRUSTEE FOR
THE FDIC 2011-N1 ASSET TRUST
350 Highland Drive
Lewisville. TX 75067
Plaintiff
vs.
JENNIFER CASTRO
(Mortgagor(s) and Record owner(s))
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
ORDER FOR JUDGMENT
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 2012-1879 Civil
Please enter Judgment in favor of THE 13ANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS
UNDERLYING TRUSTEE FOR THE FDIC 2011-N1 ASSET TS, angainst JENNIFER CASTRO for failure to file
an Answer in the above action within (20) days from the date of ti of Complaint, in the sum of $159,679.39.
By: '
lv? GROUP, P.C.
lic el cKeever Pa. ID 56129
Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 618,58
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is
THE BANK OF NEW YORK MELLON TRUST COMPANY, .A., .AS U DERLYING TRUSTEE FOR THE FDIC
2011-N1 ASSET TRUST 350 Highland Drive Lewisville, TX 40674d the name(s) and last known address(es) of the
Defendant(s) is/are JENNIFER CASTRO, 1104 Louisa Lane Aasbl g PA 17050;
By:
ROUP, P.C'.
56129
Mi ever Pa. ID
T
Jay a. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
_Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
interest from 07/01/2011 through
06/26/2012
$149,958.23
$7,456.58
Escrow
Property Inspections
Property Preservation
BPO
$1,597.13
$67.45
$505.00
$95.00
1615,9,49.39
By:- /,-I ill L/ rLYJL4
KML UP, P.C.
Micha 1 McK ever Pa. ID56129
Jay E. ivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
AND NOW, this ? day of ?1)14 2012 damages ar assessed as above.
Pro Prothy
2012-1879 Civil/110891FC
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-1879 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due THE BANKS OF NEW YORK MELLON TRUST
COMPANY, N.A., AS UNDERLYING TRUSTEE FOR THE FDIC 201 I-NI ASSET TRUST
Plaintiff (s)
From JENNIFER CASTRO
(I ) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $159,679.39 L.L.: $.50
Interest FROM 6/27/2012 TO DATE OF SALE PER DIEM AT $20.83
Atty's Comm: Due Prothy: $2.25
Atty Paid: S244.00 Other Costs:
Plaintiff Paid:
Date: JIJLY 2, 2012 i
r ?
Da uell, Prothonota
(Seal) BY
Deputy
REQUESTING PARTY:
Name: JILL P. JENKINS, ESQUIRE
Address: KML LAW GROUP, P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 306588
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
Defendant(s)
THE BANK OF NEW YORK MELLON TRUST
COMPANY, N.A., AS UNDERLYING TRUSTEE FOR
THE FDIC 2011-NI ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
vs.
JENNIFER CASTRO
Mortgagor(s) and Record Owner(s)
310 Virginia Road
Mechanicsburg, PA 17050
By:
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
6/27/2012 to Date of
Sale per diem at
$20.83
(Costs to be added)
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CUWRLAND COWTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 2012-1879 Civil
$159,679.39
L 1J GROUP, P.C.
chael cKeever Pa. ID 56129
J E. K itz Pa. ID 26769
Lisa Lee Pa.. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua L Goldman Pa. 205047
__?Ljill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
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ALL THAT CERTAIN tract of land situate in Hampden Township, Cumberland County, Pennsylvania,
bounded and described in accordance with a survey made by D.P. Raffensperger Associates, dated
January 2, 1979, as follows, to wit:
BEGINNING at a point on the western side of Virginia Road, said point being 80.0 feet south of Delbrook
Road; thence along the western side of Virginia Road, South 04 degrees 00 minutes East 63.40 feet to an
iron pin; thence South 86 degrees 00 minutes West, 120.0 feet to an iron pin; thence North 04 degrees
00 minutes West, 3.4 feet to an iron pin; thence along Lot No. 16 of the hereinafter mentioned Plan,
North 24 degrees 26 minutes 30 seconds East, 68.23 feet to an iron pin; thence along Lot No.1, North 86
degrees 00 minutes East, 87.50 feet to the western side of Virginia Road, the place of BEGINNING.
Having thereon erected a 1112 story brick and aluminum siding dwelling known as No. 310 Virginia
Road.
BEING Lot No.2 and the northern 3.4 feet of Lot 3, Block C, [Ilan No.2 Del-Brook Manor, recorded in Plan
Book 7, Page 8, Cumberland County Records.
TAX PARCEL #:10-21-0279-334
BEING KNOWN AS: 310 Virginia Road, Mechanicsburg, PA 17050
MUNICIPALITY: HAMPDEN TOWNSHIP
Being the same premises by deed dated 07/02/2009, given by John E. Boardman and Heather L. Jay-
Boardman, husband and wife to Jennifer Castro and recorded 07/08/2009 in book Instrument
#:200923!i81.
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
PA 19106
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215-627-1322 2012 JUL ,
2 All 11:0
Attorney for Plaintiff 9
THE BANK OF NEW YORK MELLOW jq%
COMPANY, N.A., AS UNDERLYING TRUSTI
FOR THE FDIC 2011-N1 ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
of Cumberland County
JENNIFER CASTRO
(Mortgagor(s) and Record Owner(s))
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 2012-1879 Civil
THE 13ANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS UNDERLYING TRUSTEE FOR THE
FDIC 2011-N1 ASSET TRUST, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the
praecipe for the writ of execution was filed the following information concerning the real property located at:
310 Virginia Road
Mechanicsburg, PA 17050
LName and address of Owner(s) or Reputed Owner(s):
JENNIFER CASTRO
1] 04 Louisa Lane
Mechanicsburg, PA 17050
2. Name and address of Defendant(s) in the judgment:
JENNIFER CASTRO
1104 Louisa Lane
Mechanicsburg, PA 17050
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
4. Name and address of the last recorded holder of every mortgage of record:
WASHINGTON MUTUAL BANK, FA
11200 WEST PARKLAND AVENUE
MAILSTOP MWIA 107
MILWAUKEE, WI :53224
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
310 Virginia Road
Mechanicsburg, PA 17050
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 t*It, DATED: a. C.S. Section 4904 relating to unsworn
falsification to authorities. 1/9
By: P, P.C.
Pa. ID :56129
26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 2761:5
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
2012-1879 Civil
KML Law Group, P.C.
Suite 5000- BNY Independence Center
701 Market Street
Philadelphia, PA 19106
(215) 627-1322
Attorney for Plaintiff
W THE PRR
HONOUR
2012 JUL -2 Ali 11: pg
THE BANK OF NEW YORK MELLON TRUST
COMPANY, N.A., AS UNDERLYING TRUSTEE
FOR THE FDIC 2011-NI ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
vs.
JENNIFER CASTRO
Mortgagor(s) and Record Owner(s)
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s,'
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Docket No. 2012-1879 Civil
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: CASTRO, JENNIFER
JENNIFER CASTRO
1104 Louisa Lane
Mechanicsburg, PA 17050
Your house at 310 Virginia Road, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs
Sale on Wednesday, December 05, 2012, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse
to enforce the court judgment of $159,679.39 obtained by THE BANK OF NEW YORK MELLON
TRUST COMPANY, N.A., AS UNDERLYING TRUSTEE FOR THE FDIC' 011-N1 ASSET TRUST
against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE
To prevent this Sheriffs Sale you must take immediate action:
2012--1879 Civil
1. The sale will be cancelled if you pay to THE BANK OF NEW YORK MELLON TRUST
COMPANY, N.A., AS UNDERLYING' TRUSTEE FOR THE FDIC 2011-Nil ASSET TRUST, the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call
our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call they Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
8_ You may contact the Foreclosure Resource Center: http://www.philadelphiafed.orWforeclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
2012-1879 Civil
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
0. Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD's website _www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
htjp.L//www.phfa.or,iz/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawgroup.corr.i.com. Call Seth at 215-825-6329 or fax 215--825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
1 10891 FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
KML LAW GROUP, P.C.
Suite 5000
BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
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THE BANK OF NEW YORK MELLON ~
COMPANY, N.A., AS UNDERLYING TF
FOR THE FDIC 2011-N1 ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
vs.
JENNIFER CASTRO
Mortgagor(s) and
Record Owner(s)
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
110891FC
CF: 03/26/2012
SD: 12/05/2012
$159,679.39
°` IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 2012-1879 Civil
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Keith C. Halili, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service
on the Defendants of the Notice of Sheriff Sale was made by:
Personal Service by the Sheriffs Offiee~eo~p~tlt (copy of return attached).
( ) Certified mail by KML Law Group, P.C. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing
attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER
( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by KML Law Group, P.C. (original receipt(s) for Certified Mail
attached).
( ) Published in accordance with court order (copy of publication attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by
ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section
4904.
Respectfully sub fitted
BY: Keith .Halili
Legal Assistant
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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The Bank of New York Mellon
vs. Case Number
Jennifer Castro 2012-1879
SHERIFF'S RETURN OF SERVICE
09/21/2012 08:33 PM -Deputy Ryan Burgett, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 310 Virginia Road, Hampden Township, Mechanicsburg, PA 17050,
Cumberland County.
10/02/2012 09:06 PM -Deputy Shawn Gutshalt, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Jennifer Castro at 1104 Louisa Lane, Hampden Township, Mechanicsburg, PA 17050, Cumberland
County.
SHERIFF COST: $909.20
October 25, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c) County5uite Sheriff. Teieosoft. Inc.
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
'THE BANK OF NEW YORK MELLON TRUST
COMPANY, N.A., AS UNDERLYING TRUSTEE
FOR THE FDIC 2011-N1 ASSET TRUST
350 Highland Drive
Lewisville, TX 75067
Plaintiff
vs.
JENNIFER CASTRO
Mortgagor(s) and Record Owner(s)
310 Virginia Road
Mechanicsburg, PA 17050
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CNIL ACTION -LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 2012-1879 Civil
SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129
THE BANK OF NEW YORK MELLON TRUST COMPANY, N.A., AS UNDERLYING TRUSTEE FOR THE
FDIC 2011-N1 ASSET TRUST, Keith C. Halili, an employee of KML Law Group, P.C., counsel of Plaintiff, sets forth as of
the date the praecipe for the writ of execution was filed the following information concerning the real property located at:
310 Virginia Road
Mechanicsburg, PA 17050
l.Name and address of Owner(s) or Reputed Owner(s):
JENNIFER CASTRO
1104 Louisa Lane
Mechanicsburg, PA 17050
2. Name and address of Defendant(s) in the judgment:
JENNIFER CASTRO
1104 Louisa Lane
Mechanicsburg, PA 17050
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
TOWNSHIP OF HAMPDEN
230 South Sporting Hill Road
Mechanicsburg, PA 17050
TOWNSHIP OF HAMPDEN
c/o Snelbaker & Brenneman
44 West Main Street, P.O. Box 318
Mechanicsburg, PA 17055
4. Name and address of the last recorded holder of every mortgage of record:
WASHINGTON MUTUAL BANK, FA
11200 WEST PARKLAND AVENUE
MAILSTOP MWIA 107
MILWAUKEE, WI 53224
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
maybe affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
310 Virginia Road
Mechanicsburg, PA 17050
I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: November Z 1, 2012
KML Law Group, P.C.
BY: Keith C. Halili
Legal Assistant