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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) aM? g , s? a y 3. oo C?1^ 3g OU Ij << 10 3, ?S"` 11. 791 `, o 4'p ?iE PROTHQNO-TA-1 So it ;j a So ti i/ 2012 JUL -2 AM 11:08 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 ??-75137 wr 1 sSc?? rA W a a o'o off za O U w x H W x H x hW z O ? H O?Q 3Qz z?~ woo oQ? zQQ xz a 0 U z O a 3 o W ? O O W ,a oxa O CZ3 U oq F, ., ?LZ> z,? °? o (! U W tb ti ? a ? w Q x a V a 0 J 3 j U ? c n.r7ad O?.x :de~v az y? aaa? ??? r' .C x? r 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 Phil d l hi ; a?.: HE p???Nnr??rA a e p a, ? ? 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 ,. °.~. I~``,.. yi ~ ~",3 r k . ~ t €.~. ~... 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 1 __.__._.. .. _. J. .. _ Q Q -_ ~ m O ~ `O ~ _N m _ ~ ^ ^rn _ rn W~y ~ ~ p ~ p -' O00 ' ~ ~ , ~ ~ ~' N i ~ ~ ~~ "~ i uo9 ~ ~ O `.~ N O i o- i ~ ~ ~ ~ a ~ fA ~ /~__ _- N O ~ ~j i(w11{1 O O o Q O ~ ~ ~ • i C O _ . ~ ~ C 0 . o c~ • ~ ~ ~ y ~ ~i w ~ '~ a. ~ ~ ¢ Y W -- - ---- > ,,a a 00 ~ ~ ¢ Z ~ 'Q ~ U~l ~ ~" _ ~goN z _ o ~ E F- =o c v ~~o~a oo g Zd~~ UQ g°~~~ ~`° ~ ' LL ~c~naw ~'° <~. o $ ao C'3 W Y fA c a =O(n~ J Q~ _~ ``~ L 0~ o m a° Q N Q J ~r~~ Z p Hco ~ O O? t ~ m v '~ ~ m c ~$ ~ ~ ' 1 ~ E Z W .~ ~. ~ 0 ~ ~ U _ ~ g ~ ~ ~ o ~ ~ ~ c 5 ~ ~ W m W m J ~ ^ 8'm~ ~ ~ E A O o ¢¢¢w ^~~^ U LL G ~ ~ E ~ m .~ d W ~ ~ m ° (A r ~ ~ E ~ O ~ O Qm H i m o o o U ~ ~ W~ n ~ o E W O Q p m a { m m~ W E o~~ r U N¢ ~L~ p~U.a I z W Z O~ W P M ~ i ~ ~ a oO gy U U m= i I ~~ I i _ 's m i z' ~ m 7 Z F° ~ 0 fA W Q o CC d a ~ ~Q 8 ~ Y J N p a o m U 0 O W m a~ m m W ~g ° i~ ~ ~ o ~~ O ~ p = p~ lR rn~ n r- N Ch ~ ~ c0 I~ CC r- ~ c a c O a m 0 c O a a U N 0 N a T +) D 'S c 0 U a ~ g ~ N m j ~ ~ U Q r: U ~ ~ W Z ~+- O Z fA ,- W n. r ~ N ` O q I ~" ~ •N o ~. ~ O ~ , ~ ~ ? '~~ f N ~ e N j ~' Lp I j `~~ ~ 1 ~ ~ ~ T ` ~ ~ I O . ~ ~ ~ O I ~ ~ 'M ~ ~ ~, • D O ' 0 C c ,~w v/ I W Q i V a S a ~-- ~ ~~. - -- ,r e ro N a U c8 + ~ a 'a~ c~~ ~ a ~~ 0 X ~~ ~~ LL Q~ 0'8 d~ _ _ ° ~ a e $ a° c °° a o~ $ ~' ' is ~ ~ U ~ ~ ~ ~ ~ o ~~ R ~ ~ ~ $~cu a[¢ain ~ ^^^o ~. Z o Z ~ m a u 8 0~~ ~ ~0~ . ~' ~ a =° a Kati ~ ~ ~ aaiQ ¢L°m¢ ~ N `o _ _ ~a IL ~ Sm,~a LL ~ 0 N E~ ~~ ~ S.~ . ed p) O ro C~ i ~ o ~ _ ~~~~~ n.cna 2« v aY aoa _~~ t°~ ~ a c~ ^~O~ ~ ~ C ~~ ~ V~ 01 N C z~ mL ~ o ~ ~ o 1 U m O N ~ ~ c~ ~ ~ a ~ (0 N ` _ 's c ~ O C a ~ 7 ~ O a U ' U.. E z ~ a 'o ~-m ~ ~ ~ ea W Z o ~~ N d ~~ ~a ' tJ ~ E ~ o vim, g ~° a ~ ~ ac ~_ g g~$Yl ~a m U ~ w ig ~p~ ~gto ~ M tL '~ ~ rn ~ a ~ ~ N ~ ''~ x o Z ~ ~ ~ a i w a v ~ ci c p r ~ o ~ •- W a .- ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~9~~~y, pt l~u;~5~,r~~a ~~ , S ~~~ 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