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HomeMy WebLinkAbout12-2605UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 ATTORNEY FOR PLAINTIFF . ,.. - __ ? C.,, 856-669-5400 leadin2s i ,udren.com Bank of America, N.A. COURT OF COMMON PLEAS C/O Bank of America, N.A., as successor by merger to CIVIL DIVISION BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. CHRISTIE L. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 JASON J. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 Defendant(s) CUMBERLAND County NO. COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING 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. aruk i o3. ? Sid ?? aa?a S;V T EP a-11y LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las 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 SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is Bank of America, N.A.. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems, Inc. Assignee: Bank of America, N.A., Successor By Merger to BAC Home Loans Servicing, LP FKA Countrywide Home Loans Servicing, LP Date of Assignment: 02/01/2012 Recorded Date: 02/07/2012 Book/Instrument #: Instrument # 201203709 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Jason J. Bonawitz and Christie L. Bonawitz (hereinafter 'Defendants"), are the owners of property located at 1917 Esther Drive, (North Middleton Township), Carlisle, PA 17013, by virtue of Deed dated 05/27/2004 and recorded 05/28/2004 in Official Records Book 263 at Page 1298 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 06/14/2007, Defendant(s) and/or their predecessor: JASON J. BONAWITZ AND CHRISTIE L. BONAWITZ promised to pay to the order of H&R Block Mortgage Corporation , the principal sum of $128,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/14/2007, Defendant(s) and/or their predecessor: JASON J. BONAWITZ AND CHRISTIE L. BONAWITZ to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., acting solely as a nominee for H&R Block Mortgage Corporation, the Property which is the subject of this action. The Mortgage was recorded on 06/26/2007 in Official Records Book 1997 at Page 1037. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 10/01/2011, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance Accumulated Interest (due from 09/01/2011 to 04/25/2012) Accumulated Late Charges Escrow Deficit/(Reserve) Title Report Attorney Fees- Estimated Property Inspections NSF Charges Grand Total $121,552.02 $5,126.96 $121.56 $12,379.48 $325.00 $1,300.00 $60.00 $40.00 $140,905.02 The above figures are calculated as of 04/25/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.50000 %. The per diem interest accruing on this debt is $21.58 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $40.52. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $140,905.02 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UD W OFFICES, P.C. BY: Sherri J. Braunstein, Esquire PA ID 90675 ?,2-14 12 16:03 FROM-Premier abstracts 737545 1{e6 Feb 15 2012 04:13am0012.0017 P012/217 T- 072 P1, F-013 LEGAL DESCR PTION ALL THAT CERTAIN PIECE OR PARCEL OF LAND TOGETHER WITH THE IMPROVEMENTS THEREON SITUATE IN THE NORTH MIDDLETON TOWNSHIP, CUMBERLANO COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: HEING LOT No, 4 ON PLAN NO.4 OF MOLL MANOR AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY IN BOOK 20, PAGE 68; CONTAINING 85 FEET ALONO ESTHER DRIVE, HAVING Q DEPTH ALONG THE SOUTH OF 125 FEET, A WIDTH IN THE REAR OF $5 FEET, AND A DEPTHI ALONG THE NORTH OF 125 FEET. BEING IMPROVED WITH A DWELLING KNOWN AS NO. 1917 ESTHER DRIVE. TAX ID V. 29-16-1094.100 BY FEE SIMPLE DEED FROM DAVID N. HINAMAN, JR., AND KATHRYN L. HINAMAN AS SET FORTH IN DEED BOOK 263, PAGE 1298 AND RECORDED ON 51 WDI34, CUMBERLAND COUNTY RECORDS. THE SOURCE DEED AS STATED ABOVE 18 THE LAST RECORD OF VESTING FILED FOR THIS PROPERTY. THERE HAVE BEEN NO VESTING CHANGES SINCE THE DATE OF THE= ABOVE RsFERENCE:D SOURCE. certify this I.; Ill Cumberla'TIC ` 7% t Ell UDRENLA W OFFICES, P. C. WOODCREST CORPORATE CENTER MARS J. UDREN, ESQUIRE III WOODCREST ROAD NJ MANAGING ATTORNEY SUITE 200 CHERRYHILL, NEW JERSEY 08003-3620 8S6. 669. 5400 TINA MARIE RICA FAX.• 856. 669. 5399 OFFICE ADUPUSTRATOR FREDDIE MAC PENNSYLVANIA DESIGNATED COUNSE March 6, 2012 CERTIFIED MAIL RETURN RECEIPT REQUESTED ARTICLE 47011 1570 0001 9751 2511 Jason J. Bonawitz 1917 Esther Drive Carlisle, PA 17013 RE: Mortgage Loan dated June 14, 2007 NOTICE OF INTENTION TO FORECLOSE Dear Mortgagor: The Mortgage serviced/held.by BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO SAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP (hereinafter we, us or ours) on your property located at 1917 Esther Drive, Carlisle, PA 17013 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $810.32 for the months of October 1, 2011 through December 1, 2011 and $2,143.05 for the months of January 1, 2012 through March 1, 2012. The last assessed late charge on this account was $40.52 at a late charge rate of 5!k for each delinquent payment(s). As of today, late charges have accrued to the total amount of $121.56. Other charges including Property Inspection Fees, Return Payment Fees and an Escrow Deficiency have accrued at the total amount of $7,649.16. 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 $16,630.83. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $16,630.83, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made to UDREN LAW OFFICES, P.C. EXHIBIT A WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise the lender's 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, the lender also intends to instruct our firm to start a lawsuit to foreclose your mortgaged property. if the mortgage is foreclosed your mortgaged property will be sold by the Sheriff or other similar official to pay off the mortgage debt. If you cure the default before we 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 the lender, which may also include our reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. The lender 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 (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's or other similar official 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 Sheriff's or other similar official's sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff's or similar official 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 the following number: (856) 669-5400. This payment must be 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 or other similar official 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 or other similar official sale, a lawsuit could be started to evict you. You shall, have the right to assert in the foreclosure proceedings, the non-existence of a default or any other defense that you may have to acceleration or foreclosure. 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. UDREN LAW OFFICES, P.C. CC: First Class Mail NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 WOODCREST CORPORATE CENTER Ill WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 (856) 669-5400 .?i 4? f ?i CJ f3.i :? p....? IL V °?- c. lr (?'t r J?M (Domesfic Mail Only i Ln Lc I For del ivery information visit our webs ite at vjww. usps.com, N i'L1 rtx a ti ,. Aso im t. 8 _ ? f "' + ' =z m s + . s Ln Ln Postage ? CerllHed Fee f- r? Postmark „?,.?... © C3 C3 C7 RoWm Receipt Fee (Endorsement Required) Here O O Fee e t icled D u I= Cl r ire d) (E nd t Acq LLn LLn Total Postage & Fees a ? s? O Sent - . , .?..?..? ---- C -r-----M. _ . n ' PO lb. , r ? .. ?- ------- ----------------- - .. sum i-'-f H r iz7 o i-f a4 M may) W O(".. ? r ? V f- M W ai ?y C) ,u oca Q 4j Q) cr ? p LU H C ?- w J? sCC, ?E+ERj+ Jerry rr,? (a 0) (d ¢7 tj z? ,o aa ww?UL 0 6 4N ?O Ln i n.i LI N ff'I rl 0 C7 0 C] t1'1 r r-q r- C1 m E 5 I E S c 0 0 N 2 r= r eo M O G7 a m i :E i i i 'I'M, W'Oow uuo, Sri IAeg 'INVINOdW1 113U IOU S, ;direi isod,9141 iP aio ua wwisod P'il a V. wa;uaslopua t1nP s,sessejppe ;o11.ppu ue JO=! ,nJB1 aleoednpec :w asiopi-13 'ae1 'od Sd)1dfa;uja P1gO o1 ''Al6mlap WOMPPP UP BOA ;Pe1d 'sefgEnjPA 1NHHnSNI ON a "01 Pef)fua!D u Rvi patgue7 a uOurey lunpadeul tap to Picogi V a POP; enbiun y iaoaj 6w11eu, lfeW pa?lljjg3 BankefAmerlea 1w PRESORT Hwetoans First-Class Mail PO Box 9048 U.S. Postage and a Temecula. CA 925849648 Fees WSO 2257703497 Send Payments to: P,O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to: PO Box 5176, MS SV3143 Simi Valley. CA 93065 20^^.120 -? Christie L Bonawitz 1917 Esther Dr Carlisle. PA 17013-1028 ix-9 P3 14456LGPA^.. '.4(X)', rA24.20'.' BankofAmerica -00- MOM Loam P. O. Box 942073 Snnr Valiey, CA 93094-1268 Christie L Bonawitz 1917 Esther Dr Carlisle, PA 17013-1028 Send Payments to PO. Box 15222 Wilmington, DE 9686-5222 December 1. 2011 Account No.: 163092262 Property Address: 1917 Esther Dr Carlisle, PA 17013-1028 Current Servicer: Bank of America. N.A. NOTICE OF INTENT TO FORECLOSE MORTGAGE Este es un aviso importante respecto a su derecho de ocupar su casa. Favor de traducirlo de inmediato. (This is an important notice concerning your right to live in your home. Have it translated at once.) Our records indicate that you transferred all or a part of your interest in the above referenced property and/or allowed your mortgage loan to be assumed; however, you were not released from contractual liability for the loan. Therefore, you are still contractually responsible for repayment of this debt. We regret to advise you that this loan is in default, and we are prepared to initiate foreclosure proceedings. The following letter was sent to the current owner of the property: The MORTGAGE held by Fannie Mae (hereinafter we, us or ours) on your property located at 1917 Esther Dr Carlisle, PA 17013-1028 IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of., Monthly Charaes: 10/0112011 $2,430.96 Late charges and other charges have also accrued to this date in the amount of $81.04 Late Charaes: 10/0112011 $81.04 Other Charges: Uncollected Late Charges: Uncollected Costs: Partial Payment Balance: $0.00 $40.00 d um TOTAL DUE: $2,552.00 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, s $2,552.00. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $2,552.00, 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, and made at Bank of America, N.A. at P.O. Box 15222, Wilmington, DE 19886-5222. 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 attomeys 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 550.00. 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 (30) day period, you will not be required to pay attomey'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 (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs 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 This communication is from Bank of America. NA., the servicer of your home loan. Please write your account number on all sec es and corescondence. 'Vie may oharge you a I -a;ofup to 570.00)tor any payment returned or rejected by your fnancia instdution, sublact to applicable In. C"? 44§ P._Q4 Al 140P+.'i?,94*0'l Payment hntruOm- Account Number 163092262.1 • Chem peyabie to Bank Of Make your Che Christie L Bonawitz Balarx Due fa charges lister above: $2,552.00 as of December t ,2011. Amerea. NA 1917 Esther Or Please update Email nfamal., on the reverse sloe of l-ds x'JI%Hi. • Dort send cash " easemdudecoupon wfnyour Carlisle, PA 17013-1028 Ad rx,. ,ay,nem Anxpa' BLOW For all full month payment periods, addma?a merest, ralculaadcn a moMhry basis. Accordingly, merest for all fuli months, !nctud,rg February, is caiwlated as Bank of America, N.A. 3),'380 of annual Interest, irrespective of ' PO BOX 15222 ?rea'c r the actual number of days m Inc month. Fnr pats merdhs, interest is calculated Wilmington, DE 19886-5222 Tote daily on Ina basis of a 385 day year. 1$90-669-0102 163092262100000255200000255200 1: 58 6 9 900 581: 1 6309 2 2 6 2112 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 safe. 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 the following number. 1-800-669-0102. 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 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. ff 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. Bank of America. N.A., the servicer of your home loan, is required by law to inform you that this communication is from a debt collector. This communication is from Bank of America. N.A, the servicer of your home loan. E-mail use: Providing your e-mail address below will allow us to send you information on your account. Account Number: 163092262 Christie L Bonawiu E-mail address: How we post your payments: All accepted payments of principal and irdaresi will be applied to the longest outstanding installment due. unless otherwise expressly prohibited or limred by law. I you submit an amount in addition to your scheduled monthly amour-,, we will apply your payments as follows: Ill to outstanding monthly payments c' principal and interest, (i6 escrow deficiencies, (Iii) late charges and other amounts you owe in connection with your loan and (iv) to reduce the outstanding principal balance your loan. Please specify if you want an additional amourt applied to future payments.. rather than principal reduction. Postdated checks: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the date wit?en on the check as a condition of a repayrnern plan. Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home Home A federal government program that allows you to repay the loan on newly agreed upon terms, which Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or Modification extending the term of the loan. You may be eligible for this program if you meet the following Program requirements: (RAMP) • The home is your primary residence and you currently live in it. • The amount you owe on the first mortgage is equal to or less than $729,750 for a single-family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403.400 for a 4 unit property • You have experienced a hardship that has impacted your income. For example, a significant increase in your mortgage payment OR reduction in your income OR other hardship. • Your mortgage was obtained before Jan. 1, 2009. • Your payment on your first mortgage (including principal, interest, taxes, insurance and homeowner's association dues, if applicable) is more than 31 % of your current gross income. To calculate this, divide your first mortgage payment by your gross income (income before taxes). Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the loan up Reinstatement to date until the day of your foreclosure sale. Repayment A temporary agreement which allows for the repayment of the unpaid, past due amount along with Plan regular mortgage payments. This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments for a Forbearance period of time, to allow you to re-establish your ability to make the required payments. Agreement Loan Repay the loan on newly agreed upon terms, which may include lowering the interest rate, placing Modification amounts past due at the end of the loan, and/or extending the term of the loan. (non-RAMP) Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you (FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home ....... Home .......... ......... .. ....... .. ....... Designed to help borrowers who are eligible for the Home Affordable Modification Program (HAMP) Affordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the Foreclosure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agreement Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short Preforeclosure sale, you sell your properly for less than the total amount owed on the loan (subject to agreement by Sale your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (non-HAFA) foreclosure. Deed in Lieu of Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not Foreclosure able to sell the properly through a short sale. With a deed in lieu of foreclosure, you agree to (non-HAFA) voluntarily transfer ownership of your property to us in order to avoid foreclosure. rLi.1z We are here to help you. Please call us today. 2257703497 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notification adjunta para obtener mas information Cuando Ilame, tenga la information de sus ingresos y gastos disponibles para quo podamos discutir cual opcion(es) pueden funcionar para usted. Opciones a considerar si su objetivo es permanecer en su casa Home Affordable Un programa del gobierno federal que le permite pagar el prestamo bajo los nuevos terminos Modification acordados, que pueden incluir la reduction de la tasa de interes, agregando la cantidad adeudada Program (HAMP) al final del prestamo, y / o extender el plazo del prestamo. Usted puede ser elegible para este programa si cumpte con :os siguientes requisitos. • La casa es su residencia principal y actualmente vive en ella. • La cantidad adeudaca en la primera hipoteca debe ser igual o menos que $729,750 dolares para una vivienda unifamiliar, $934,200 dolares para una propiedad de 2 unidades, $1,129,250 dolares para una propiedad de 3 unidades o $1,403.400 para una propiedad de 4 unidades • Ha experimentado una dificultad que ha afectado sus ingresos. Por ejemplo, un aumento significativo en su pago hipolecario O reduction de sus ingresos U otras dificullades. • Obtuvo su hipoteca antes del 01 de enero 2009. • Su pago de la primera hipoteca (incluyendo principal, interes, impuestos, seguro y cuotas de asociacion de propietarios, si se aplica) debe ser mes del 31 % de sus ingresos brutos actuates. Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes de impuestos). Restablecimiento Si usted puede traer sus pagos del prestamo hipotecario al d ia, se le aceptaran los fondos del Prestamo necesarios pare que el prostamo este at dia hasta la fecha de la venta judicial. Plan de Pago Un acuerdo temporal que permite el pago de la cantidad adeudada, cantidad del pago atrasadc junto con los pagos regulares de la hipoteca. Esto puede incluir principal, interes, honorarios y/o costos aplicados a su prestamo. Acuerdo Un acuerdo por el cual nos comprometemos a no proceder con la ejecucion hipotecaria y/o Temporal de coleccion de pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia hater los pagos requeridos. Modificacidn de Pagar el prestamo bajo los nuevos terminos acordados, que puede incluir la reduction de la Casa Prestamo de interes, agregando la cantidad adeudada at final del prestamo, y/o extender el plazo del (no por medio prestamo, de HAMP) Reclamo Parcial Si usted tiene un prestamo de la Administration Federal de Vivienda (FHA) y sus pagos estan (solamente vencidos, pero ahora puede hater sus pagos regulares mensuales de la hipoteca, este programa prestamos de la est& diserfado Para que su prestamo este at dia mediante la creation de una segunda hipoteca ? FHA) gravamen sobre su propiedad por la cantidad adeudada Opciones a considerar si no puede o no desea quedarse en su casa Home l Disefiado para ayudar a los prestatarios que son elegibles para el Programa de Home Affordable Affordable Modification (HAMP), pero no tuvieron exito en obtener una modification permanente a traves del Foreclosure programa. HAFA ofrece la posibilidad de una yenta corta y, si no tiene exito, una entrega de Alternatives escritura para evitarjuicio nipotecario. Una venta coda es una,transaccion en la que usted vende su Program propiedad por menos de la cantidad adeudada en el prestamo (sujeto a previo acuerdo de su (HAFA) administrador / prestamista / inversionista), resultando en la liberation de nuestro derecho de retencion sobre su propiedad y evitar la ejecucion hipotecaria. Una entrega de escritura para evitar juicio hipotecario es una transaction en la que usted este de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecucion hipotecaria. Venta Cortal Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retencion de Venta antes de hogar. Con una venta corta, usted vende su propiedad por menos de la cantidad total adeudada en Ejecucion el prestamo (sujeto a un acuerdo por su administrador / prestamista I inversionista), resultando en la Hipotecaria (no liberation de nuestro derecho de retencion sobre su propiedad y evitando la ejecucion hipotecaria. por medio de HAFA) Entrega de Se ofrece a los prestatarios que no son elegibles para HAMP u otras altemativas de retencion de Escritura Para hogar, y que no pudieron vender la propiedad a traves de una venta corta. Con una entrega de Evitar Juicio escritura para evitar juicio hipotecario, usted esta de acuerdo a transferir voluntariamente las Hipotecario escrituras de su propiedad a nosotros para evitar la ejecucion hipotecaria. (no por medio de HAFA) Estamos aqu% para avudarle. Por favor llamenos hoy. UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501. AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadines(a)udren.com Bank of America, N.A. Plaintiff V. CHRISTIE L. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 JASON J. BONAWTTZ 1917 ESTHER DRIVE CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. VERIFICATION a hereby states that he he is &%tn my e V(es1 den-f of Bank of America, N.A., Plaintiff in this matter, that he/&is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/e knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: 4? U" - ? hvm'0'11? f Name: Mc d y Do Ndi m rmatj Title: Af i5fa n+ Vice 12t ej i deYff Company: Ba n r- of Amer i co, NA MJU #: 12020439 CASE #: 12020439-1 FORM 1 -- Pj( (? O? JY1Q(t CA IU . • r- 1 i IN THE COURT OF COMMON PLEAS M CUMBERLAND COUNTY, PENNSYLVAI-M ". ? : r ' - - Plaintiff(s) - r U ?ASUn vs. ?_ wi bo IGI,J Z Cif1 ` L efendant(s) 19'c?(P&5Civil s NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty, (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. R ctfuily subrn'tted:??/ " Date Signature of Counsel for Plaintiff Sherri J. Braunstein, Esquire PA ID 90675 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip:. is the property for sale? Yes ? No E] Listing date: Price: $_ Realtor Name: Realtor Phone:_ Borrower Occupied? Yes ? No ? Mailing Address (if different): Citv: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender: _ Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: How long? State: Zip: -- Home: Cell: Office: Other: How long? Date You Closed Your Loan: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names. location of court. case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile 42: Model: Year: Amount owed: Value: Other transportation (automobiles boats, motorcycles): Model: Year: Amount owed: Value_ Monthly Income Name of Employers: 1. _ Additional Income Description (not wages): I , monthly amount: 2 monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mort a e Utilities Car Payment(s) Condo/Nei h. Fees Auto Insurance Med. not covered) Auto fuel/re airs Other prop. a ent Install. Loan Pa yment Cable TV Child. Support/Alien. Spending Money _ Da y/Child Care/Twit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: (`nnnepInr- Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, _ , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I,'We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past Z bank statements V Proof of any expected income for the last 45 days Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) FORM 3 mZ6 Cc? tu -14 . 1 : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plaintiff(s) vs. 4 ?.Sv? - for ??: ?z Defendant(s) Civil" REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: ] . Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; Defendant has been served with a "Notice of Residential Mort gage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. 1 understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Legal Representative Signature of Defendant Signature of Defendant Date Date Date UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadin2sa.udren.com Bank of America, N.A. 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. CHRISTIE L. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 JASON J. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 Defendant(s) TO THE PROTHONOTARY: ?..? t E'!J??(1 no v iiD COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. ?oS Clurl , a a i I ENTRY OF APPEARANCE Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Esquire; Paige M. Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass, Esquire; Kassia Fialkoff, Esquire; Elizabeth L. Wassall, Esquire on behalf of the Plaintiff, in the above-captioned matter. UDRE AW?jOFFIC/E?Sd,P.C Sherri I Braunstein, Esquire PA ID 90675 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ? N(- I 3 Richard W Stewart Ci11MBDL,aQ COWiTY Solicitor P w Ni N S Y LVAN I A Bank of America, NA Case Number vs. Christie L. Bonawitz (et al.) 2012-2605 SHERIFF'S RETURN OF SERVICE 05/03/2012 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: Christie L. Bonawitz, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Christie L. Bonawitz. Request for service at 1917 Esther Drive, Carlisle, Pennsylvania 17013 is vacant. Deputies were advised, Christie L. Bonawitz is thought to be residing at 5496 Union Deposit Road, Harrisburg, Pennsylvania. 05/03/2012 10:55 AM - Jason Vioral, Sergeant, who being duly sworn according to law, states that on May 2, 2012 at 1055 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Jason J. Bonawitz, by making known unto himself personally, at the Cumberland County Sheriffs Office 1 Courthouse Square, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. Deputies were advised, 1917 Esther Drive, Carlisle, Pennsylvania 17013 is vacant. Jason J. Bonawitz currently resides at 1941 Ritner Highway, Shippensburg, Pennsylvania 17257. DEPUTY JASnERSL, SHERIFF COST: $55.00 SO a•r May 03, 2012 ROW R ANDERSON, SHERIFF . COW *y& MC ,her if f E .c 1 1, FORM 1 (? jan l? o? rrk( cep Plaintiff(s) VS. "?' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANI:?1, bo nGuJ tZ r- -Cr1; ?,$n?:tw -ato 6S efendant(s) Civil - ,,. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court. which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled. you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Date Reg ctfully subm tted: 1 'TSignature of Counsel for Plaintiff) Sherri J. Braunstein, Esquire PA ID 90675 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your _ Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different) City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: State: Zip: Yes ? No ? Listing date: Price: $_ Realtor Phone:_ Yes ? No ? Home: Cell: Home: Cell: Office: Other: How long? First Mortgage Lender: Type of Loan: Loan Number: _ Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: _ Loan Number: Total Mortgage Payments Amount: S Date of Last Payment: Primary Reason for Default: State: Zip: Office: Other: How long? State: Zip: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ? No ? If yes. provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Model: Year: _ Amount owed: Value: Other transportation. (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. I J. Additional Income Description (not wages): I . monthly amount: 2 -monthly amount: Borrower Pay Days: Co-Borrower Pay Days: _ Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUN'T' Mortgage Food 2" Morta e Utilities Car Payment(s) Condo/Nei h. Fees Auto Insurance Med. not covered) Auto fuel/re airs Other prop. payment Install. Loan Pa yment Cable TV Child Support/Alien. Spending Money I Day/Child Care/Twit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax:_ Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income V+ Past 2 bank statements 11 Proof of any expected income for the last 45 days ^\1 Copy of a current utility bill 1I Letter explaining reason for delinquency and any supporting documentation (hardship letter) Phone: Date 1? Listing agreement (if property is currently on the market) FORM 3 Qom, ? "l1y` C)? Cc? fu. A I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY.. PENNSYI..VANIA Plaintiff(s) vs. ?Z , Defendant(s) CIVLL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; ?. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Signature of Defendant's Counsel/Appointed Legal Representative Signature of Defendant Date Date Signature of Defendant Date UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Dleadin2sr udren.com Bank of America, N.A. C/O Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. CHRISTIE L. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 JASON J. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF r C0 j coo C r'7 to lap j 3 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. la'a(Do5 COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING 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. TRUE COPY FROM RECORD In Testimony whereof, 1 here unto set my hand and the,seal of said Court at Carlisle, Pa. This SO day of , 24 otho t r)o ?J/w LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE,. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUMCIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is Bank of America, N.A.. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor: Mortgage Electronic Registration Systems, Inc. Assignee: Bank of America, N.A., Successor By Merger to BAC Home Loans Servicing, LP FKA Countrywide Home Loans Servicing, LP Date of Assignment: 02/01/2012 Recorded Date: 02/07/2012 Book/Instrument #: Instrument # 201203709 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Jason J. Bonawitz and Christie L. Bonawitz (hereinafter "Defendants"), are the owners of property located at 1917 Esther Drive, (North Middleton Township), Carlisle, PA 17013, by virtue of Deed dated 05/27/2004 and recorded 05/28/2004 in Official Records Book 263 at Page 1298 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 06/14/2007, Defendant(s) and/or their predecessor: JASON J. BONAWITZ AND CHRISTIE L. BONAWITZ promised to pay to the order of H&R Block Mortgage Corporation, the principal sum of $128,200.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 06/14/2007, Defendant(s) and/or their predecessor: JASON J. BONAWITZ AND CHRISTIE L. BONAWITZ to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., acting solely as a nominee for H&R Block Mortgage Corporation, the Property which is the subject of this action. The Mortgage was recorded on 06/26/2007 in Official Records Book 1997 at Page 1037. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 10/01/201.1, and all subsequent payments have not been made, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges, if any, indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance Accumulated Interest (due from 09/01/2011 to 04/25/2012) Accumulated Late Charges Escrow Deficit/(Reserve) Title Report Attorney Fees- Estimated Property Inspections NSF Charges Grand Total $121,552.02 $5,126.96 $121.56 $12,379.48 $325.00 $1,300.00 $60.00 $40.00 $140,905.02 The above figures are calculated as of 04/25/2012: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.50000 %. The per diem interest accruing on this debt is $21.58 and that sum should be added each day after the above date. The late charge is subject to adjustment if more fully described as such in the note and mortgage. The late charge rate on the subject note should be added in accordance to the terms of the note and mortgage charged monthly at $40.52. 7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $140,905.02 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UD W ICES, P.C. t BY. f Sherri J. Braunstein, Esquire PA ID 90675 Feb 15 20 12 04:13am P012/017 02-14-' 12 10: 03 ROM-Premier Abstracts 7175454106 T-072 :P0012/0017 F-013 LEGAL DESCRIPTION PIECE ALL THAT CERTAIN D THEREON TOGETHER WITH THE IMpRoV5MFNTS NORTH MIDDLETON TOWNSKP. CCUMBERLANDCOUNTY PENNSYLNIA, BOUNDED NDDESCRBED S IN THE FOLLOWS: BEING LOT No, 4 ON PLAN NO.4 OF N:OLL MANOR AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS COLWY 65 CONTAINING PAGE 20, AND ALONG DEPTH ALONG THE NORTHING DEPTH OF 25 IVE. ALONG THE CUMBERLANDH OF FEET, A WIDTH IN TTHE REAR OF $5 FEEFEET FEET. BEING IMPROVED WITH A DWELLING KNOWN AS NO. 1917 ESTHER DRIVE. TAX I? It 28-16-1084-100 S Ste' FORTH IN DEED 0©QK ? PAGE 1298 AND REFROM DAVID N. COED ON 5J2?flQ?4CUMBERLAND ?:OtJNTY RECORDS. 263, THE SOURCE DEED AS STATED ABOVE IS THE LAST RECORD OF VESTING FILED FOR AVE BEEN NQ VESTING CHANGES SINCE THE DATE OF THE ©VE REFERENCED SOURCE PROPERTY. THERE H Certify tt,,is f UDREN LA W OFFICES, A C. WOODCREST CORPORATE CENTER MARK J. UDREN, ESQUIRE 111 WOODCREST ROAD NJ MANAGING ATTORNEY SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 856. 669. 5400 TINA MARIE RICH FAX, 856. 669. 5399 OFMCB ADM/NNTRATOR FREDDIE MAC PENA'SYLVANL4 DESIGNATED COUNSE March 6, 2012 CERTIFIED MAIL RETURN RECEIPT REQUESTED ARTICLE 47011 1570 0001 9751 2511 Jason J. Bonawitz 1917 Esther Drive Carlisle, PA 17013 RE: Mortgage Loan dated June 14, 2007 NOTICE OF INTENTION TO FORECLOSE Dear Mortgagor: The Mortgage serviced/held-by BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP (hereinafter we, us or ours) on your property located at 1917 Esther Drive, Carlisle, PA 17013 IS IN SERIOUS DEFAULT because you have not made the monthly payments of $810.32 for the months of October 1, 2011 through December 1, 2011 and $2,143.05 for the months of January 1, 2012 through March 1, 2012. The last assessed late charge on this account was $40.52 at a late charge rate of 5o for each delinquent payment(s). As of today, late charges have accrued to the total amount of $121.56. Other charges including Property Inspection Fees, Return Payment Fees and an Escrow Deficiency have accrued at the total amount of $7,649.16. 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 $16,630.83. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $16,630.83, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either- by cash, cashier's check, certified check or money order, and made to UDREN LAW OFFICES, P.C. BIT A WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NEW JERSEY 08003-3620 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise the lender's 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, the lender also intends to instruct our firm to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff or other similar official to pay off the mortgage debt. If you cure the default before we 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 the lender, which may also include our reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees. The lender 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 (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's or other similar official 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 Sheriff's or other similar official's sale could be held would be approximately six months from the date of this letter. A notice of the date of the Sheriff's or similar official 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 regnired payment will be by calling us at the following number: (856) 669-5400. This payment must be 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 or other similar official 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 or other similar official sale, a lawsuit could be started to evict you. You shall have the right to assert in the foreclosure proceedings, the non-existence of a default or any other defense that you may have to acceleration or foreclosure. 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. UDREN LAW OFFICES, P.C. CC: First Class Mail NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 (856) 669-5400 T r'; LLJ lT; yx?+i 01 47 y `w N ? F• 1 s 0_ . O n: Ja?t"Jem Y ON Postal CERTIFIED MA ILi, REC EIPT ? a (Domestic .. .. Ln N RJ r F r1 >n r- Ln r Postage 8 0-" Er CergBed Fee r-l r-l Postmark Q 0 p Q Retum Receipt Fee Mrdcreament R*Qww) Here M 0 Reahictwl Delivery Fee ?..?? (EndoreertrerM Aegrnred) -` C! Q N L n N Total Postage 5 Fees a r3 o ?-. --- r? r- or Po eoz No. i t _-.------ -- - - - - ---------------------------------- w o o W i-4 Lu U t? W 4) ?.: ¢c y ; U a: cc L4 U U) W M L C) Lu L - if? -+ D H C wiz Z) M: H a00 Fi J0,' !Q 01 Z riU ?1- O 0a LLl ? LL L ? ? r C Q o • e N ?O?pp Os a r=1 Ln i ru Ln 1 r- >r-1 ? a O m C cm ? c O fJ7 U E N a 0 ? N m 2, ?tl m Lam' li m i N T Z 0 N IL Gm6nv,009: uuo, ch laeg =dNVLHGdWl leu lau sl ldlaoei tsod a41 1e ego uO >}lewlsod a 11 w Y. luawesiopuo llne s,eessajppe '0I4ppe ue son a meal elmllldnpac =_w asiopuS aaf 'OJ Sd?]dlooeb alyo o.L '/Mnlfep tuogfppe ue 10J ;eafd 'seiganieh INVdnSNl ON a B! IMIN pagfua7 w " Real pamliaO w WWOU due4adurl lap 10 Wooaa y w Ruapf enblun b' lanai oumew v w Plyd BanketAnlt rie8 PRESORT °w First-Gass Mail U.S, Postage and "icivisca i P0 Box 9 Temecula. CA 92569-9048 WSO Send Payments to: P.O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to: PO Box 5170. MS SV314B Simi Valley. CA 93065 ! v5? 2257703457 Christie L Bonawitz 1917 Esther Dr Carlisle, PA 17013-1028 201!',201 C3 A45BLCP,'' A[Q;i M24,211 BankiufAmerica home Loans PC. Box 942073 Sant Valley, CA 93£194-1288 Send Payments to P 0. Box 15222 Wilmington. DE 1988E-5222 December 1, 2011 Christie L Bonawitz 1917 Esther Dr Carlisle, PA 17013-1028 Account No.: 163092262 Property Address: 1917 Esther Dr Carlisle. PA 17013-1028 Current Servicer: Bank of America, N.A. NOTICE OF INTENT TO FORECLOSE MORTGAGE Este as un aviso importante respecto a su derecho de ocupar su rasa. Favor de traducirlo de inmediato. (This is an important notice concerning your right to live in your home. Have it translated at once.) Our records indicate that you transferred all or a part of your interest in the above referenced property and/or allowed your mortgage loan to be assumed; however, you were not released from contractual liability for the loan. Therefore, you are still contractually responsible for repayment of this debt. We regret to advise you that this loan is in default, and we are prepared to initiate foreclosure proceedings. The following letter was sent to the current owner of the property: The MORTGAGE held by Fannie Mae (hereinafter we, us or ours) on your property located at 1917 Esther Dr Carlisle, PA 17013-1028 IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of., Monthly Charoes: 10/0112011 $2,430.96 Late charges and other charges have also accrued to this date in the amount of $81.04 Late Charoes: 10/0112011 $81.04 Other Charoes: Uncollected Late Charges: $0.00 Uncollected Costs: $40.00 Partial Payment Balance: ($000) TOTAL DUE: $2,552.00 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 $2,552.00. You may cur; this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $2,552.00, 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, and made at Bank of America, N.A. at P.O. Box 15222, Wilmington, DE 19886-5222. 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 attomeys 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 (30) 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 (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs 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 earlier: date that such a This communication is from Bank of Amedra. NA., the servicer of your home loan. Pieria wnie your account number on al'i m ics and ccrrescondenoa. ile: may mange ru a fee lot up is 349.0CIfor any payment resumed o, rejected oy your franca ini suclea to aponmble In '-'44` I oP d 141T4'. [,eadas° Paymsrc ln,[ructlons, Account Number: 163092262-1 Ma a yo r check pavabe n 6anK of Christie L Boni Balance Due for charges listca above: $2,552.00 as of December t. 2011, Arnenca. N.A. 1917 Esther D, Fiwsa um-?> email •rio..-maims un me rew,5e sin- of m?, z oo:-... Resease ucorn • Ple :ndude cupcn wd!r;ow Carlisle. PA 17013-1028 Ad:Ntra' : cevmeni +-nnair ELOP<' Fcr all fuo ri payment period=_. gynq,?y,,?: f1 ? u '?I[?['1'II[I[I""I[?1?[rl.rrl l??rrl llll[rr?[,rrrll'[I II'?f"I e. mn• l monfhs. Amordrtgl wrest for atf l l mdudug Fems-i. is ceiemeted as 30rffii0 of annual Merest. irresorxtrve cl the actual number of days in ine moon Bank of America. N.A. PO BOX 15222 wren Tc!a' For Data roomi roars. is ratculahd Wilmington. DE 19886-5222 _ dairy on rte pasts of a 355 piny year 1$00-669-0102 16309226210000 0255200000255200 1: 58c9900 581: 1 6 309 2 26 2 11 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 safe. 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 the following number. 1-800-669-0102. 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 propertv after the Sheriffs sale, a lawsuit could be started to evict yow. 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 it no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. Bank of America, N.A., the servicer of your home loan, is required by law to inform you that this communication is from a debt collector. This communication is from Bank of America. N.A. the servicer of your home loan. E-mail use: Fmviding your e-mail address below will allow us to send you information on your axnmt. Axount Number: 163092262 Chnsde L Bcnaw'iR E-mail address Now we post your payments: All accepted payment principal and interest will be applied to the longest outstanding mstalimen: due unless otherwise expressly prohibited or limned by law. you subm¢ an amount in adddion to vour scheduled monthly amount we will apps your pa?inenis as follows: (i) tr, outstanding monthly payments principal and mteres , (i5 escrow deficiancaas 06 lase charges and other amounts you ewe in connecocn wit your loan and (iv) m reduce the outstanding principal balance cf your loan. Please specify if you want an additional amount applied to future payments.. rather than principal reduction Postdated checks: Postdated checks will be processed on the date receivec unless a loan counselor agrees ;o honor the date VmIIeri on the check as a condition of a repayment plan. Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home ....... ... .. VIR.,i:K.:.... ............::. .:... i... .,•,... .:Y: .. ...................... ..... ... .. ... :.. Home A federal government program that allows you to repay the loan on newly agreed upon terms, which Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or Modification extending the term of the loan. You may be eligible for this program if you meet the following Program requirements: (RAMP) • The home is your primary residence and you currently live in it. • The amount you owe on the first mortgage is equal to or less than $729,750 for a single-family home, $934,200 for a 2 unit property. $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have experienced a hardship that has impacted your income. For example, a significant increase in your mortgage payment OR reduction in your income OR other hardship. • Your mortgage was obtained before Jan. 1, 2009. • Your payment on your first mortgage (including principal, interest, taxes, insurance and homeowner's association dues, if applicable) is more than 31 % of your current gross income. To calculate this, divide your first mortgage payment by your gross income (income before taxes). Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the loan up Reinstatement to date until the day of your foreclosure sale. Repayment A temporary agreement which allows for the repayment of the unpaid, past due amount along with Plan regular mortgage payments. This may include principal, interest, fees.. and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments for a Forbearance period of time, to allow you to re-establish your ability to make the required payments. Agreement Loan Repay the loan on newly agreed upon terms, which may include lowering the interest rate, placing Modification amounts past due at the end of the loan, and/or extending the term of the loan. (non-RAMP) Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you (FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due Options to consider if you cannot or do not wish to stay in your home ? ? ? }:+ ?: ,: :y w':?:?^yYji.'.:'..v:: .:.. `•.'•.•`:.'?:.:•5.'::•.:'':'.'?i:i ?{;,:.:!:`:':::': ?%???'iifi:?'"^i';:;' `: ?::: `:.y:?l':' ?;':::::;`::';i ..........: ....................................................................... Home Designed to help borrowers who are eligible for the Home Affordable Modification Program (HAMP) Affordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the Foreclosure option of a short sale and.. if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agreement Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short Preforeclosure sale, you sell your properly for less than the total amount owes on the loan (subject to agreement by Sale your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (non-HAFA) foreclosure. Deed in Lieu of Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not Foreclosure able to sell the property through a short sale. With a deed in lieu of foreclosure, you agree to (non-HAFA) voluntarily transfer ownership of your property to us in order to avoid foreclosure. .1, MIQ We are here to help you. Please call us today. 2257703497 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Liame al numero que aparece en la notificaci& adjunta para obtener mas information Cuando Ilame, tenga Is information de sus ingresos y gastos disponibles pars que podamos discutir cual opci6n(es) pueden funcionar pars usted. Opciones a considerar si su objetivo es permanecer en su casa .. ... .:i :.:: i;. . ... ..... K.: .. :.::.. : . .::. Home Affordable Un programs del gobierno federal que le permite pagar el prestamo bajo los nuevos terminos Modification acordados, que pueden incluir la reducci6n de Is tasa de interes, agregando Is cantidad adeudada Program (HAMP) al final del prestamo, y / o extender el plazo del prestamo. Usted puede ser elegibie pars este programs si cumple con los siguientes requisitos. • La casa es su residencia principal y actualmente vive en ella. • La cantidad adeudada en Is primera hipoteca debe ser igual o menos que $729,750 d6lares para una vivienda unifamiliar, $934,200 d6lares pars una propiedad de 2 unidades, 51,129,250 d6lares pars una propiedad de 3 unidades o $1,403,400 pars una propiedad de 4 unidades • Ha experimentado una dificultad que ha afectadc sus ingresos. Por ejemplo, un aumento significalivo en su pago hipotecario O reducci6n de sus ingresos U otras dificultades. • Obtuvo su hipoteca antes del 01 de enero 2009. • Su pago de Is primera hipoteca (incluyendo principal, interes, impuestos. seguro y cuotas de asociaci6n de propietarios, si se aplica) debe ser mas del 31 % de sus ingresos brutos actuates. Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes de impuestos). Restablecimiento Si usted puede traer sus pagos del prestamo hipotecario al d ia. se le aceptaran los fondos del Prestamo necesarios pars que el prestamo este al dia hasta Is fecha de Is vents judicial. Plan de Pago Un acuerdo temporal que permite el pago de Is cantidad adeudada, cantidad del pago atrasadc junto con los pagos regulares de Is hipoteca. Esto puede incluir principal, interes, honorarios y/o costos aplicados a su prestamo. Acuerdo Un acuerdo por el cual nos comprometemos a no proceder con Is ejecuci6n hipotecaria y/o Temporal de colecci6n de pagos por un periodo de tiempo, pars permitirle que restablezca su habi lidad de Tolerancia hacer los pagos requeridos. Modification de Pagar el prestamo bajo los nuevos terminos acordados, que puede incluir Is reducci6n de Is lass Prestamo de interes, agregando Is cantidad adeudada al final del prestamo, y/o extender el plazo del (no por medio prestamo, de HAMP) Reclamo Parcial Si usted tiene un prestamo de Is Administraci6n Federal de Vivienda (FHA) y sus pagos estan (solamente vencidos, pero shore puede hacer sus pagos regulares mensuales de Is hipoteca, este programs prestamos de Is est6 disenado pars que su prestamo este al dia mediante Is creaci6n de una segunda hipoteca FHA) gravamen sobre su propiedad por Is cantidad adeudada. Opciones a considerar si no puede o no desea quedarse en su casa 2:z>%lEi Woo EM Home Disehado pars ayudar a los prestatarios que son elegibles pars el Programs de Home Affordable Affordable Modification (HAMP), pero no tuvieron exito en obtener una modificaci6n permanente a traves del Foreclosure programs. HAFA ofrece Is posibilidad de una vents corta y, si no tiene exito, una entrega de Alternatives escritura pars evitar juicio hipotecario. Una vents corta es una•transacci6n en Is que usted vende su Program propiedad por mends de Is cantidad adeudada en el prestamo (sujeto a previo acuerdo de su (HAFA) administrador / prestamista / inversionista), resultando en Is liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar Is ejecuci6n hipotecaria. Una entrega de escritura para evitar iuicio hipotecario es una transacci6n en Is due usted esta de acuerdo de transferir voluntariamente as escrituras de su propiedad a nosotros con el fin de evitar Is ejecuci6n hipotecaria, Vents Corta/ Se ofrece a los prestatarios que no son elegibles pars HAMP u otras alternatives de retenci6n de Vents antes de hogar. Con una vents corta.. usted vende su propiedad por menos de Is cantidad total adeudada en Ejecucion el prestamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultando en la Hipotecaria (no liberaci6n de nuestro derecho de retenci6n sabre su propiedad y evitando is ejecuci6n hipotecaria. por medio de HAFA) Entrega de Se ofrece a los prestatarios due no son elegibles Para HAMP u otras alternatives de retenci6n ae Escritura Para hogar, y que no pudieron vender Is propiedad a traves de una vents corta. Con una entrega de Evitar Juicio escritura Para evitar juicio hipotecario. usted esta de acuerdo a transferir voluntariamente as Hipotecario escrituras de su propiedad a nosotros para evitar Is ejecuci6n hipotecaria. (no por medio de HAFA) Estamos aqu% pars avudarle. Por favor Ilamenos hoy. UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675 PAIGE M. BELLINO, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadinesAudren.com Bank of America, N.A. Plaintiff V. CHRISTIE L. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 JASON J. BONAWITZ 1917 ESTHER DRIVE CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. VERIFICATION hereby states that he he is V e Nesl6Cof of Bank of America, N.A., Plaintiff in this matter, that he/& is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/ e?i knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: k `! 3G'/ Name: fVJG ((Y Do Chi'mGr1 Title: RSONnt 0CC J21 CSi a6Y14 Company: 80 1'l r- C)f Afinef I CC?,11, A MJU #: 12020439 CASE #: 12020439-1 UDREN LAW OFFICES, P.C. WOODCRESST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America, N.A. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. CHRISTIE L. BONAWITZ; et al T,t NO. 12-2605 ?. , Defendant(s)'ri r- PRAECIPE TO REINSTATE COMPLAINT -c -- ; ?' TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: UDREN LAW OFFICES, P.C. BY: Attorneys for Plaintiff ESc. EUZAB HIO 77M O floc PQ AI-1 e t aq jm ?# a??o9-a UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF lk WOODCREST CORPORATE CEN3'XW_r i-\ I lot 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ,,, AID COUkliI Bank of America, N.A. Plaintiff V. CHRISTIE L. BONAWITZ; et al ?'i OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 12-2605 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint on the above-captioned matter. DATE: (,-; / 1 -,? / la. UDREN LAW OFFICES, P.C. BY: 4?_S? Attorneys for Plaintiff KASSIA FIALKOFF, ESQUIRE PA ID 310530 0 at mil/ 7S d Q? ck# 3ova9 SHERIFF'S OFFICE OF CUMBERLAND COUNTY_ ?- , j L Ronny R Anderson Sheriff t Jody S Smith tM 3- 2 ??? ". ? •.?i } Chief Deputy 4+t'eF r,1 i'?' rs l,vi i Richard W Stewart Solicitor Bank of America, NA (::,ase Number vs. : 0" 2-2505 Christie L. Bonawitz (et al.) SHERIFF'S RETURN OF SERVICE: 06/15/2012 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: Christie L. Bonawitz, but was unable to locate her in hig bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program according to law. 06/22/2012 03:55 PM - Dauphin County Return: And now June 22, 2012 at 1555 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christie L Bonawitz by making known unto herself personally, at 5496 Union Deposit Road, Harrisburg, Pennsylvania 17109 its contents and at the same time handing to her personally the said true and correct copy of the same. 06/28/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on June 2012 at 1100 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Christie L. Bonawitz. Request for service at 700 Nailor Dive Apartment 302, Camp Hill, Cumberland County, Pennsylvania 17011 is a secured address, and Deputies were unable to attempt service. The Camp Hill Postmaster has confirmed, Christie L Bonawitz receives her mail at this address. SHERIFF COST $83.00 June 28, 2012 SO ANSWERS, RONN R ANDERSON. SHERIFF Shelley RUM Real Fz e 1)c William T. Tully S licitor c? Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-'079 ph:(717)780-6590 fax (717)255-2889 Jack Duignan C hief Deputy Michael W. Rinehart 1\ ;, m5 sit Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin BANK OF AMERICA, N. %- AS S/B/M TO BAC HOME LOANS SLR`JICENG, LP VS CHRISTIE L. 13ONAWITZ Sheriffs Return No. 2012-T-1769 OTHER COUNTY NO. 2012-2605 And now: JUNE 22, 2012 at 3:55:00 :PM served the within REINSTATED COMPI,A INT IN MORTGAGI FORECLOSURE upon CHRISTIE L. BONAWITZ by personally handing to CHRISTIE L. BONAWITZ I true attested copy of the original REINSTATED COMPLAINT I?vi MORTGAGE FORECLOSi `RE and snaking known to him/her the contents thereof at 5466 UNIO?,,I DEK)SIT ROAD HARRISBURG PA 17109 Sworn and subscribed to before me this 25TH day of June, 2012 COMMONWEALTH: OF PENNSYLVANIA NOTARIAL SEAL. Kaaren M_ Hoffirnan, Notary Public Cis, of Harrisburg_ Dauphin County My Commission Expires August 17, 2014 So Answers. v Sheriff r o ril} C a r~,' . 13Y.4 1 r, . Deputy Sheriff Deputy: W CONWAY i Sheriffs Costs: `647.25 6/20129 R 2 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, N..A. Plaintiff ~~. CHRISTIE L. BONAWITZ, JASON J. BONAWIT7., Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS ~ '. _', CIVIL DIVISION ~ ~ - Cumberland County ~ ~- MORTGAGE FORECLOSURI -* ~ ~ ' ~; ; - ~. NO. 12-2605 AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.RC.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defe:ndant(s), CHRISTIE L. BONAWITZ, JASON J. BONAWITZ, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers~ Civil Relief Act. The Military Status Reports} is/are attached hereto as Exhibit .. A.. The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birl.h and''or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. Dated: October 18, 201.2 ~L ~.~ Attorney for Plaintiff Mark J. Udren, EsgaJire PA ID 04302 MJU#: 12020439 CASE#: 12020439-1 Department of Defense Manpower Data Center r /~'~~ ~~t~~ l~:~tcttt Y~zrsuant icy Ser~~~icern~~l~ C'i!4~ii I~e~ic~~:~c~ Last Name: BONAWITZ First Name: CHRISTIE Middle Name: Active Duty Status As Of: Oct-18-2012 f:esuhs as of : Ort-16-2012 08:05:05 SCRA 2.3 On Active Duty On Active Duty Status Dale Active Duty Stan Date _ Active Duty Eitd Date _ Status Service Component -_____- NP___- ~ NA No NA This response reflects ttie individuals' active duty status based on the Active Duty Status Date left Active Dury Within 367 Days of Active Duty Status Date Active Duty Start Date _ Active Duty End Date Status Service Component N!\ -____ NA NO _-_ NA This response reflects where the individual left active duty status within 367 days preceding [he Active Duty Status Date The Member or His/Her Unit Was Notified of a Future CaIV-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component -NA -- NA No T ---- NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicerriember or his/her unit receiving notification of future orders to report for Active Duty. ..- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington, VA 22350 ~XH1131~' ~ The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting Systefh (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 i {formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual 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 "oefenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verifcation, 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 hislher 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 o4 the active duty periods less than 30 consecutive days in length were available. In the casra of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corpsj. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted. but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: QEGABJVQR5 Department of Defense Manpower Data Center ~I1itLL ~x.L'~?t?~'I x "~, :~ 1'ursu~nt tee ~~x°~~~iorn€•a~h~r~ {:'i~{l ~eti~~~ ~.f~t Last Name: BONAWITZ First Name: JASON Middle Name: Active Duty Status As Of: Oct-18-2012 Results as of :Oct-16-2012 08:0625 SCRA 2.3 On Active Duty On Acfive Duty S[atus Dale - Active Duty Start Date Active Duty End Date Status ~ Servire Component NA NA ~ No NA This response reflects the individuals' alive duty status based on the Active Duty Status Dale Lefl Active Duty Within 367 Days of Active Duty Status Date - Active Duty Start Date Active Duty End Date Status ~ Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Dale The Member or HislHer Unit Was Notified of a Future Call-Up to Active Dury on Active Duty Status Date Order Notification Start Date Order Notification F_nd Dale Status Service Component NA i NA ~ No ~ -_ , _ _ NA This response reflects whether the individual or his/her unit has received early notification to repoq for active duty Upon searching the data banks of the Department of Defense INanpower 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). Thls status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ~' ...- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington, VA 22350 ~~`~®`~ a`~,^'. The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Repor.}ng SystePh (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 aoove, or any family member. friend, or representative asserts in any manner that the individual was on active duty for the active duty status date. or is otherwise entitled to the protections of the SCRA. you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http:Nwww.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). 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 actrve 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 F:eserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This incudes Navy Training and Administration of the Reserves (TARs). Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applie:> to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader ~n some cases and inclu9es 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 deefined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducteC, but who have not actually begun active duty or actually reported for induction. Tire 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 ender the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate iD: 02ACMS93Q6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i n cyst? csta�ut��p �j Jody S Smith i Chief Deputy i Richard W Stewart Solicitor r r�Or KE L r C t y{fig 7 L S YLi ANijr; Nationstar Mortgage LLC vs. Case Number Christie L. Bonawitz (et al.) 2012-2605 SHERIFF'S RETURN OF SERVICE 01/03/2013 11:39 AM-Deputy Ronald Hoover, 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: Jason J. Bonawitz at 1941 Ritner Highway, Shippensburg, PA 17257, Cumberland County. 01/07/2013 06:50 PM - Deputy Jason Kinsler, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 1917 Esther Drive, Carlisle, PA 17013, Cumberland County. 03/04/2013 As directed by Mark Udren,Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 04/03/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Room 303, Carlisle, PA on April 3, 2013 at 10:00 a.m.. He sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,128.95 SO ANSWERS, May 23, 2013 RbNPrY R ANDERSON, SHERIFF ..cu^aS a Sh�r:t le: n`t,Irc UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings(i�udren.com Bank of America, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Christie L.Bonawitz MORTGAGE FORECLOSURE Jason J. Bonawitz Defendant(s) NO. 12-2605 AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Bank of America,N.A., Plaintiff in the above action,by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 1917 Esther Drive, Carlisle, PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Christie L. Bonawitz 5496 Union Deposit Road Harrisburg, PA 17109 Jason J. Bonawitz 1941 Ritner Highway Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: Christie L. Bonawitz 5496 Union Deposit Road Harrisburg, PA 17109 Jason J. Bonawitz 1941 Ritner Highway Shippensburg, PA 17257 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders -None 4. Name and address of the last recorded holder of every mortgage of record: Bank of America,N.A. 16001 North Dallas Parkway Addison,TX 75006 Sr Mortgage Holders - None Sovereign Bank 450 Penn Street Reading, PA 19602 5. Name and address of every other person who has any record lien on the property: Sr lien Holders-None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle,PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle,PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 1917 Esther Drive Carlilse, PA 17013 r ' 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Federal Tax Lien Holders-None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: LS-J z_ UDREN LAW ICES, P.C. BY: A ey for Plaintiff SALVATORE CARO=,ESQ MJU#: 12020439 CASE#: 12020439-1 PA IO 311050 ' r UI REN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings(a),udren.com Bank of America,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County CHRISTIE L. BONAWITZ,JASON J. MORTGAGE FORECLOSURE BONAWITZ Defendant(s) NO. 12-2605 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Christie L. Bonawitz 5496 Union Deposit Road Harrisburg, PA 17109 Your house (real estate) at 1917 Esther Drive, Carlisle, PA 17013 is scheduled to be sold at the Sheriffs Sale on March 6, 2013 at 10:00am at the'Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013, to enforce the court judgment of$144,474.10, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if+—e judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ALL THAT CERTAIN PIECE OR PARCEL OF LAND TOGETHER NTH THE IMPROVEMGMTS THEREON SITUATE IN THIS NORTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA,BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NO,4 ON PLAN NO,4 OF MOLL MANOR AS RECORDED IN THE OFFICE OF THE RECOR05 t OF DEEDS FOR CUMSERLANUU COUNTY IN BOOK 2l3,PAGE 88;CONTAINING 85 FEET ALONG ESTHER DRIVE,HAVING A DEPTH ALONG TIME SOUTH OF 125 FEET,A WIDTH IN THE REAR OF$5 FEET,AND A DEPTH ALONG THE NORTH OF 125 FEET, BEING IMPROVED VAS H A DWELLING KNOWN AS NO.1917 ESTHER DRIVE. TAX ID*29-16-1094-100 BY FEE SIMPLE DEED FROM DAVID N.HP~N,JR.,AND KATHRYN L.HINAMAN AS SET FORTH IN DEED BOOK 263,PAGE 1298 AND RECORDED ON WIP2004,CUMBERLAND COUNTY RECOMS. THE SOURCE DEED AS STA'T`ED ABOVE IS THE LAST RECORD OF VESTING FIi.ED FOR TWS PROPERTY,THERE HAVE SEEN NO VESTING CHARGES SINCE THE GATE OF THE ABOVE REFERENCES SOURCE. BEING KNOWN AS: 1917 ESTHER DRIVE, CARLISLE, PA 17013 PROPERTY ID NO.: 29-16-1094-100 TITLE TO SAID PREMISES IS VESTED IN JASON J. BONAWITZ AND CHRISTIE L. BONAWITZ, HIS WIFE, AS TENANTS BY THE ENTIRETY BY DEED FROM DAVID N. HINAMAN, JR. AND KATHRYN L. HINAMAN,HIS WIFE DATED 05/27/2004 RECORDED 05/28/2004 IN DEED BOOK 263 PAGE 1298. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 12-2605 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA,N.A., Plaintiff(s) From CHRISTIE L. BONAWITZ and JASON J. BONAWITZ (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $144,474.10 L.L.: $.50 Interest from 9/29/12 to 3/6/13 Ongoing per diem of$21.58 to actual date of sale including if sale is held at a later date -- $3,431.22 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $31x.15 Other Costs: Plaintiff Paid: Date: 10/2/12 David D. Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name: SALVATORE CAROLLO,ESQUIRE Address: UDREN LAW OFFICES,PC TRUE COPY FROM RECORD WOODCREST CORPORATE CENTER In Testimony whereof,I here unto set my hand and the sea6of said Court at Carlisle,Pa. 111 WOODCREST ROAD,SUITE 200 no This _pZ_ y of .20 Icz CHERRY HILL,NJ 08003-3620 r P prothonotary Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 311050 On October 19, 2012 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 1917 Esther Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 19, 2012 By: �--- Real Estate Coordinator i CUMBERLAND LAW JOURNAL Writ No. 2012-2605 Civil Bank of America,NA vs. Christie L.Bonawitz, Jason J. Bonawitz Atty.: Mark Udren All THAT CERTAIN piece or parcel of land together with the improve- ments thereon situate in the North Middleton Township Cumberland County Pennsylvania, bounded and described as follows: BEING Lot No.4 on Plan No.4 of Noll Manor as recorded in the Office of the Recorder of Deeds for Cum- berland County in Book 20. Page 68; Containing 85 feet along Esther Drive.having a depth along the south of 125 feet,a width in the rear of 85 feet, and a depth along the north of 1125 feet. Being improved with a dwelling known as No. 1917 Esther Drive.Tax ID:29-16-1094-100 by fee simple deed from David N. Hinaman Jr. and Kathryn L. Hinamin as set forth in Deed Book 263 Page 1298 and recorded on 5/28/2004; Cum- berland County Records. The Source Deed as stated above is the last record of vesting filed for this property. There have been no vesting changes since the date of the above referenced source. BEING KNOWN AS: 1917 Esther Drive, Carlisle,PA 17013. PROPERTY ID NO.: 29-16-1094- 100. TITLE TO SAID PREMISES is vest- ed in Jason J.Bonawitz and Christie L. Bonawitz, his wife, as tenants by the entirety by deed from David N. Hinaman, Jr. and Kathryn L. Hina- man, his wife dated 05/27/2004. Recorded 05/28/2004 in Deed Book 263 Page 1298. 23 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1, and February 8, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. sa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this da of Februar 2013 , Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 i The Patriot-News Co. 2020 Technology Pkwy Z4( atr1*otwXews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 i CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUiNJTY COURT HOUSE CA17-LISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. i M 101 IcoTION COPY This ad ran on the date(s)shown below: 2012.2605 Chill 01/22/13 Bank of Amerka, w 01/29/13 ChrW%L.Bo� �- Jamm J.son awft 02/05/13 Atty: Mark Udren- Ail THAT CERTAIN PIECE OR PARCEL OF LAND TOGETHER with THE . . . . . . . . . . . . . . . . . . . . IMPROVEMENTS THEREON SITUATE IN THE NORTH RDDLETON TOWNSHIP CUMBERLAND COUNTY Sworn a d ubscribed before this 4 day of Febr ary, 2013 A.D. PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEING LOT NOA ON PLAN NOA OF NoLL MANOR AS RECORDED iN Not Public THE OFFICE OF THE RECORDER { OF DEEDS FOR CUMBERLAND COUNTY IN BOOK 20. PAGE 68; CONTAINING 85 FEET ALONG WEALTH OF PENNSYLVANIA ESTHER DRIVE. HAVING•A DEPTH =Holly tarial Seal ALONG THE SOUTH OF 125 FEETA arfel,Notary Public WIDTH IN THE REAR OF 85 FEET wp.,Dauphin county AND A DEPTH ALONG THE NORTH n Expires Dec.12,2016 OF 1125 FEET BEING IMPROVED MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES WITH A DWELLING KtJOWN AS NO. 1917 ESTHER DRIVE.TAX ID: 29-16= 1094100 BY FEE SIMPLE DEED ,' N. HINAMAN JR.ANI'KATOW L HINAMIN AS SET FORTH IN a BOOK263 PAGE 1298AND RECD =• ON5/28/2004;CUMBERLAND COUNTY RECORDS. THE SOURCE DEED AS STATED ABOVE IS THE LAST RECORD OF VESTING FILED FOR, THIS PROPERTY.THERE HAVE BEEN NO VESTING CHANGES SINCE THE DATE OF THE ,ABOVE REFFERENCED SOURCE. , BEING KNOWN AS: 1917 ESTHER DRIVE,CARLISLE,PA 17013 PROPERTY ID NO.:29.16-1094100 TITLE TD SAID PREMISES IS VESTED IN JASON J. BONAWIU AND CHRISM L BONAWn HIS WIFE, AS,TENANTS BY THE ENTIRETY By DEED FROM DAVID N HINAMAN, X AND KATHRYN L.HINAMAN,HIS WIFE DATED 05/27/2004. RECORDED 05/28/2004 IN DEED BOOK 263 PAGE 1298. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS. I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 6th day of March A.D., 2013, under and by virtue of a writ Execution issued on the 2nd day of October,A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term,2012 Number 2605,at the suit of Bank of America,N.A. against Christie L. Bonawitz and Jason J. Bonawitz is duly recorded as Instrument Number 201318600. IN TESTIMONY WHEREOF, I have hereunto set my hand an sal of said office this day of A.D. i C order of Deeds Of and Cow%Ca&je,PA tiny Commission ires the Fog Monday of Jan.2014