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HomeMy WebLinkAbout12-3064 ' .- f1711 to ? J UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ALAN M. MINATO, ESQUIRE - ID#75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 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 AGNES MOMBRUN, ESQUIRE - ID#309356 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Bank of America, N.A. CIO Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. MARK E. GOULD 8 MAYBERRY LANE MECHANICSBURG, PA 17050 MICHELE M. GOULD 8 MAYBERRY LANE MECHANICSBURG, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. l v1- 'b" COMPLAINT IN MORTGAGE FORECLOSURE owd S ? ?? ?.a8SSb4??14 S 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. 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 SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TE.LEFONO 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 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: 12/02/2011 Recorded Date: 12/12/2011 Book/Instrument #: Instrument # 201134478 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Mark E. Gould and Michele M. Gould (hereinafter 'Defendants"), are the owners of property located at 8 Mayberry Lane, (Silver Spring Township), Mechanicsburg, PA 17050, by virtue of Deed dated 07/30/2004 and recorded 08/03/2004 in Official Records Book 264 at Page 2461 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property") 3. On 07/30/2004, Defendant(s) and/or their predecessor: MARK E. GOULD AND MICHELE M. GOULD promised to pay to the order of Countrywide Home Loans, Inc, the principal sum of $ 226,592.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 07/30/2004, Defendant(s) and/or their predecessor: MARK E. GOULD AND MICHELE Al. GOULD to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc., acting solely as a nominee for Countrywide Home Loans, Inc., the Property which is the subject of this action. The Mortgage was recorded on 08/03/2004 in Official Records Book 1875 at Page 4463. 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 09/01/2011, 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 $202,658.92 Accumulated Interest (Due from 08/01/2011 to 05/03/2012) $8,994.68 Accumulated Late Charges $201.06 Property Inspection $90.00 Title Report $325.00 Attorney Fees $1,300.00 Grand Total $213,569.66 The above figures are calculated as of 05/03/2012: 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 5.87500 %. The per diem interest accruing on this debt is $32.53 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 $67.02. 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 $213,569.66 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadines@udren.com Bank of America, N.A. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County V. MARK E. GOULD 8 MAYBERRY LANE MECHANICSBURG, PA 17050 NO. MICHELE M. GOULD 8 MAYBERRY LANE MECHANICSBURG, PA 17050 Defendant(s) ??,,,,?, VERIFICATION S u''ngn N iiw tfYlw hereby states that he/ he is AS5WM ?f? ??SIC1Qr1? of Bank of America, N.A., Plaintiff in this matter„ that heA ohis 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 er knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: -M( _A_, a0l a1 _ Jkftw om" Name :.5 nnDA Nv.p V1dvwr Title: A-aA?*nr)4 1gQt ?rfSld vNV Company: Bank of America, N.A. MJU #: 12030115 CASE #: 12030115-1 _. __ ....v.. .. .. '?tl: J. •?A C]JV J'_A'J.V'-? _CC•?•-+.??•_. V,_ .. ?.f ., CJV1V! vvV w L LVV EXHIBIT A. LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in the Township of Silver spring, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the eastern line of Mayberry lane (50 foot right of way), at the southwestern comer of Lot No. 29 on the hereinafter mentioned Plan of Lots; THENCE along the southern One of Lot No. 29, North 84 degrees 59 minutes 52 seconds East, a distance of 274.72 feet to a point at line of lands now or formerly of John Erdis; THENCE along said Erdis lands, South 48 degrees 43 minutes 37 seconds East, a distance of 18.68 feet to a point at line of lands now or late of Herald D. Stoner, THENCE along the western line of said Stoner lands, South 42 degrees 03 minutes 58 seconds West, a distance of 183.81 feet to a point at the northeastem comer of Lot No. 31 on the hereinafter mentioned Plan of Lots; THENCE along the northern line of Lot No, 31, North 72 degrees 05 minutes 02 seconds West, a distance of 181.17 feet to a point on the eastern line of Mayberry Lane; THENCE along Mayberry Lane by a curve to the left having a radius of 150 feet, an arc distance of 70.00 feet to a point, the place of BEGINNING. BEING Lot No. 30 on the Final Major Subdivision Plan of Section 2, part B, Brandywine Village as recorded in the Cumberland County Recorder's Office in Flan Book 32, page 100, UNDER AND SUBJECT to a 16 foot storm sewer easement along property line of Lot No. 30 and Lot No. 31, Section No. 2, part B, Brandywine Village, described in accordance with survey prepared by Robert G. Hartman, Jr., Registered Surveyor, dated November 11, 1983, described as follows, to wit: BEGINNING at a point on the southern right of way line of Mayberry Lane, said point being located 363.17 feet In an easterly direction from the North end of a 7.92 feet arc connecting the eastern right of way line of Mayberry lane, a 50 foot right of way to the northern right of way line of Longview Road, a So foot right of way; THENCE from the point of beginning along the southern right of way line of Mayberry Lane on an arc of a curve curving to the left, having a radius of 175 feet and an arc length of 16.006 feet to a point; THENCE through Lot No. 30, South 72 degrees 06 minutes 02 seconds East, a distance of 133.66 feet to a point; THENCE through Lot 30 and Lot 31, South 48 degrees 38 minutes 35 seconds East, a distance of 46.80 feet to a point on the rear property line of Lot 31; THENCE along same, South 42 degrees 03 minutes 58 seconds West, a distance of 16 feet to a point; THENCE through Lot 30, North 4S degrees 38 minutes 35 seconds West, a distance of 43.28 feet to a point; THENCE through same, North 72 degrees 05 minutes 02 seconds West, a distance of 130.33 feet to a point, the point of BEGINNING. NG THE SAME PREMISES which James R. Lauer and Barbara J. Lauer, by deed dated 2004 and intended to be recorded simultaneously herewith in the Office of the of ed9 of Cumberland County, granted and conveyed unto Mark E. Gould and Michele M. ul dgagors herein. I Certify this to be recorded In Cumberland County PA "" Recorder of Deeds BadkofAmerica _41111, Moms Loans PO Box 9048 Temecula, CA 92589-9048 Send Payments to: P.O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to., PO Box 5170, MS SV314B Simi Valley, CA 93065 7196 9006 9295 5583 2503 20111101-7 Mark E Gould 8 Mayberry Lane Mechanicsburg, RN 17050-2762 PRESORT First-Class Mall U.S. Postage ;and Fees Paid WSO B L QPA 1 12870 12/2312010 Bankof America I , ? r Maine Loans P.O. Box 942073 Simi Valley, CA 93094-1288 Send Payments to: P.O. Box 15222 Wilmington, DE 19886-5222 November 1, 2011 Mark E Gould 8 Mayberry Lane Mechanicsburg, PA 17050-2762 Certified Mail: 7196 9006 9295 5563 2503 Return Receipt Reauested Regular Mail Account No.: 65214042 Property Address: 8 Mayberry Lane Mechanicsburg, PA 17050-2762 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 trasladar 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 Bank of America, N.A., on behalf of the Noteholder, (hereinafter we, us or ours) on your property located at 8 Mayberry Lane Mechanicsburg, PA 17050-2762 IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of- Monthly Charges: 09/01/2011 $4,021.14 Late charges and other charges have also accrued to this date in the amount of $134.04 Late Char 09/01/2011 $134.04 Other Charaes: Uncollected Late Charges: Uncollected Costs: Partial Payment Balance: $0.00 $0.00 ($0.00) TOTAL DUE: $4,155.18 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 $4,155.18. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,155.18, 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 attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. This communication is from Bank of America, N.A., the servicer of your home loan. Please write your account number on all checks and correspondence. We may charge you a fee (of up to $40.00) for any payment returned or rejected by your financial institut ion, subject to applicable law. BLDPAI 12970 12/2312010 P¦yment Instructions: Account Number: 65214042-7 • Make your check payable to Bank of Mark E Gould Balance Due for charges listed above: $4,155.18 as of November 1 2011 America, N.A- • Don1 send cash 8 Mayberry Lane , . Please update e-mail information on the reverse side ofthis cou Pon • Please include coupon with your payment Mechanicsburg, PA 17050-2762 Aadal PA BLQPAI ndpel For all full month payment periods, i t t i l l d AddAi n eres s ca m ate on a monthly basis. Accordingly, interest for all full months, I I I I I' I I I I I I I" I I I I I' I I" I I I I I I I" I I I I I I I I I I "III "' I I I I I' 1111' I I onal Escrow including February, is calculated as Bank of America N A 301360 of annual interest, irrespective of the actual number of days in the month. , . . PO BOX 15222 c^ For partial months, interest is calculated Wilmington, DE 19886-5222 7a? daily on the basis of a 365 day year. M.D cul 1-800-669-6654 065214042700000415518000415518 1:58 6 9 900 581:65 21L.01.211• 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 changes then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. 1-800-669-6654. 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. !f 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: 65214042 Mark E Gould E-mail address: How we post your payments: All accepted payments of principal and Interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (i) to outstanding monthly payments of principal and interest, (Ii) escrow deficiencies, (iii) late charges and other amounts you owe in connection with your loan and (iv) to reduce the outstanding principal balance of your loan. Please specify if you want an additional amount applied to future payments, rather than principal reduction. Postdated checks: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the data written 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 ...... .....> <;.T:::i;;.TT;:; :TT<T::.:i }}}r:: v .......•............:T`.:ivi:iiiiviv<CV:i::L{:iiVii:i{:vv:?'.:;}':';.i'?•?t!?ii:::::;:::iiii} v: i::::vvv:;i:-i:::::.4: ii}} ii'{ii:T : i i i ' ' • .... :..................... ..... ........ ; :::::w ::::::::::::: }::: T:•: TTT iii•: v: v.: ?::.:: ?::::. T:ii^iTTi: ?: :i iT i{•TTTT 2< iiiiiii: T:iii•i . .: .:..:::::........:.::::::..::.:.:.....::.:.:::: y i i....••::.:::::<: ciwi i i•,•.••r:..:i:iiL:di:.:yyyy:i:!o.::::.yy ? i i»i•iti<[:::T?: :::::iiT:• i:::> `>:$jjL:^}:y:::[ i:y:i:rf• i:::::::?:::j. iay.:•T:::: Home A federal government program that allows you to repay the loan on newly agreed upon terms, which Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or Modification extending the term of the loan. You may be eligible for this program if you meet the following Program requirements: (RAMP) • The home is your primary residence and you currently live in it. • The amount you owe on the first mortgage is equal to or less than $729,750 for a single-family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for, a 4 unit property • You have experienced a hardship that has impacted your income. For example, a significant increase in your mortgage payment OR reduction in your income OR other hardship. • Your mortgage was obtained before Jan. 1, 2009. • Your payment on your first mortgage (including principal, interest, taxes, insurance and homeowner's association dues, if applicable) is more than 31 % of your current gross income. To calculate this, divide your first mortgage payment by your gross income (income before taxes). Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the loan up Reinstatement to date until the day of your foreclosure sale. Repayment A temporary agreement which allows for the repayment of the unpaid, past due amount along with Plan regular mortgage payments. This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments for a Forbearance period of time, to allow you to re-establish your ability to make the required payments. Agreement Loan Repay the loan on newly agreed upon terms, which may include lowering the interest rate, placing Modification amounts past due at the end of the loan, and/or extending the term of the loan. (non-RAMP) Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you (FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home Home Designed to help borrowers who are eligible for the Home Affordable Modification Program (HAMP) Affordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the Foreclosure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agreement Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short Preforeclosure sale, you sell your property for less than the total amount owed on the loan (subject to agreement by Sale your 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. kwdiz Wa_ We are here to help you. Please call us today. 7196 9006 9295 SS83 2S03 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Llame al n6mero que aparece en la notificacibn adjunta para obtener mcis informacion Cuando llame, tenga la informacibn de sus ingresos y gastos disponibles para quo podamos discutir cual opc16n(es) pueden funcionar pare usted. Opciones a considerar si su objetivo es permanecer en su casa Home Affordable :...., :..... : Un programa del gobierno federal que le permite pagar el pr6stamo bajo los nuevos t&rminos Modification acordados, que pueden incluir la reducci6n de la tasa de inter6s, agregando la cantidad adeudada Program (HAMP) al final del pr6stamo, y / o extender el plazo del pr6stamo. Usted puede ser elegible para este programa si cumple con los siguientes requisitos: • La casa es su residencia principal y actualmente vive en ella. • La cantidad adeudada en la primera hipoteca debe ser igual o menos que $729,750 d6lares para una vivienda unifamiliar, $934,200 d6tares para una propiedad de 2 unidades, $1,129,250 d6lares para una propiedad de 3 unidades c $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 hipotecario O reducci6n de sus ingresos U otras dificultades. • Obtuvo su hipoteca antes del 01 de enero 2009. • Su pago de la primera hipoteca (incluyendo principal, inter6s, impuestos, seguro y cuotas de asociaci6n de propietarios, si se aplica) debe ser m6s del 31 % de sus ingresos brutos actuates. Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes de impuestos). Restablecimiento Si usted puede traer sus pagos del pr6stamo hipotecario al dia, se le aceptar6n los fondos del Pr6stamo necesarios para que el pr6stamo este al dia hasta la fecha de la venta judicial. Plan de Pago Un acuerdo temporal que permite el pago de la cantidad adeudada, cantidad del pago atrasado junto con los pagos regulares de la hipoteca. Esto puede incluir principal, inter6s, honorarios y/o costos aplicados a su pr6stamo. Acuerdo Un acuerdo por el cual nos oomprometemos a no proceder con la ejecuci6n hipotecaria y/o Temporal de colecci6n de pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia hacer los pagos requeridos. Modificacidn de Pagar el pr6stamo bajo los nuevos t6rminos acordados, que puede incluir la reducci6n de la tasa Pr6stamo de inter6s, agregando la cantidad adeudada al final del pr6stamo, y/o extender el plazo del (no por medio pr6stamo. de HAMP) Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos est6n (solamente vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, este programa prestamos de la est6 diserliado para que su pr6stamo este al dia mediante la creaci6n de una segunda hipoteca / FHA) gravamen sobre su propiedad por la cantidad adeudada. Opciones a considerar si no puede o no desea quedarse en su casa :. . Home Diser)ado para ayudar a los prestatarios que son elegibles para el Programa de Home Affordable Affordable Modification (HAMP), pero no tuvieron 6xito en obtener una modificaci6n permanente a trav6s del Foreclosure programa. HAFA ofrece la posibitidad de una venter corta y, si no tiene 6xito, una entrega de Alternatives escritura para evitar juicio hipotecario. Una venta corta es una transacci6n en la que usted vende su Program propiedad por menos de la cantidad adeudada en el pr6stamo (sujeto a previo acuerdo de su (HAFA) administrador / prestamista / inversionista), resultando en la liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una entrega de escritura para evitar juicio hipotecario es una transacci6n en la que usted est3 de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. Venta Corta/ Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci6n de Venta antes de hogar. Con una vents corta, usted vende su propiedad por menos de la cantidad total adeudada en Ejecucion el pr6stamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultando en la Hipotecaria (no liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitando la ejecuci6n hipotecaria. por medio de HAFA) Entrega de Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci6n de Escritura Para hogar, y que no pudieron vender la propiedad a trav&s de una venta corta. Con una entrega de Evitar Juicio escritura para evitar juicio hipotecario, usted est6 de acuerdo a transferir voluntariamente las Hipotecario escrituras de su propiedad a nosotros para evitar la ejecuci6n hipotecaria. (no por medio de HAFA) Estamos aqui para ayudarle. Por favor llamenos hoy. mankof America PRESORT First-Class Mail Noma Loans U.S. Postage and PO Box 9048 Fees Paid Temecula, CA 92 58 9-9 048 WSO 7196 9006 9295 5583 2497 Send Payments to: P.O. Box 15222 Wilmington, DE 19886-5222 Send Correspondence to: PO Box 5170, MS SV314B 20111101-7 Simi Valley, CA 93065 .11 -1[-11111111IIIIIII1" IIV d w 11.111. 11. Michele M Gould 8 Mayberry Lane Mechanicsburg, PA 17050-2762 EMEFtt M9 BL(W Al 12370 1212312010 Bankof America , Home Loans P.O. Box 942073 Simi Valley, CA 93094-1288 Michele M Gould 8 Mayberry Lane Mechanicsburg, PA 17050-2762 Send Payments to: P. 0, Box 15222 Wilmington, DE 19886-5222 November 1, 2011 Certified Mail: 7196 9006 9295 5583 2497 Return Receipt Reauested Regular Mail Account No.: 65214042 Property Address: 8 Mayberry Lane Mechanicsburg, PA 1 7 050-27 6 2 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 trasladar 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 Bank of America, N.A., on behalf of the Noteholder, (hereinafter we, us or ours) on your property located at 8 Mayberry Lane Mechanicsburg, PA 17050-2762 IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of.• Monthly Charges: 09/01/2011 $4,021.14 Late charges and other charges have also accrued to this date in the amount of $134.04 Late Charges: 09/01/2011 $134.04 Other Charaes: Uncollected Late Charges: Uncollected Costs: Partial Payment Balance: $0.00 $0.00 ($0.00) TOTAL DUE: $4,155.18 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 $4,155.18. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,155.18, 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 attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. This communication is from Bank of America, NA., the servicer of your home loan. Please write your account number on all checks and correspondence. We may charge you a fee (of up to $40.00) for any payment returned or rejected by your f narval institution, subject to applicable law. BLQPAI 12870 12/2372010 Payment Imtructlons: Account Number: 65214042-7 • Make your check payable to Bank of Michele M Gould Balance Due for charges listed above: $4,155.18 as of November 1, 2011. America, N.A. 8 Mayberry Lane Please update o-mail information on the reverse side of this mupon. • Donl send cash • Please include coupon with your Mechanicsburg, PA 17050-2762 payment Additional BLQPAI PAndpal For all full month payment periods, interest is calculatedon a monthly basis. rJl? rl rlr l lr l, ll l l ??rrrl?r llr ll l E Esao Accordingly, interest for all full months, l l l l l? rll l r ?krl' lrll ll, ?l,lrl?ll w including February, is calculated as Bank of America, N.A. 301360 of annual interest, irrespective of the actual number of days in the month. PO BOX 1 5222 rctal For partial months, interest is calculated Wilmington, DE 19886-5222 daily on the basis of a 365 day year. 1-800-669-6654 065214042700000415518000415518 1: 58 6 9 900 581:6 5 2 1 404 211$ 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 d6fadIt within the thirty (30) day period and foreclosure proceedings have begun, you still have the right to curs the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will Increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number. 1-800-669-6654. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest In the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. 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: 65214042 Michele M Gould E-mail address: How we post your payments: All accepted payments of principal and interest will be applied to the longest outstanding installment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply your payments as follows: (i) to outstanding monthly payments of principal and interest, (II) escrow deficiencies, (Iii) late charges and other amounts you owe in connection with your loan and (N) to reduce the outstanding principal balance of your loan. Please specify If you want an additional amount applied to future payments, rather than principal reduction. Postdated checks: Postdated checks will be processed on the date received unless a loan counselor agrees to honor the date written on the check as a condition of a repayment plan. 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-HAMP) Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you (FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home Home Designed to help borrowers who are eligible for the Home Affordable Modification Program (HAMP) Affordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the Foreclosure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agreement Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoidance of (HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short Preforeclosure sale, you sell your property for less than the total amount owed on the loan (subject to agreement by Sale your 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. UAW- We are here to help you. Please call us today. 7196 9006 9295 5583 2497 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Liame al numero que aparece en la notificaci6n adjunta para obtener mAs informaci6n Cuando (lame, tenga la informaci6n de sus ingresos y gastos disponibles para que podamos discutir cual opc16n(es) pueden funcionar pare usted. Opciones a considerar si su objetivo es permanecer en su casa ......................................... Home Affordable ..................................:.................................................................................:.............................................................., ....................... Un programa del gobierno federal que le permite pagar el pr6stamo bajo los nuevos t6rminos Modification acordados, que pueden incluir la reducci6n de la tasa de inter6s, agregando la cantidad adeudada Program (RAMP) al final del pr6stamo, y / o extender el plazo del pr6stamo. Usted puede ser elegible para este programa si cumple con los siguientes requisitos: La casa es su residencia principal y actualmente vive en ella. • La cantidad adeudada en la primera hipoteca debe ser igual o menos que $729,750 d6lares para una vivienda unifamiliar, $934,200 d6lares pare una propiedad de 2 unidades, $1,129,250 d6lares pare 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 hipotecario O reducci6n de sus ingresos U otras dificultades. • Obtuvo su hipoteca antes del 01 de enero 2009. a Su pago de la primera hipoteca (incluyendo principal, inter6s, impuestos, seguro y cuotas de asociaci6n de propietarios, si se aplica) debe ser m6s del 31 % de sus ingresos brutos actuales. Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes de impuestos). Resta bloc! m iento Si usted puede traer sus pagos del pr6stamo hipotecario al dia, se le aceptar6n los fondos del Pr6stamo necesarios para que el pr6stamo este al dia hasta la fecha de la venta judicial. Plan de Pago Un acuerdo temporal que permite el pago de la cantidad adeudada, cantidad del pago atrasado junto con los pagos regulares de la hipoteca. Esto puede incluir principal, inter6s, honorarios y/o costos aplicados a su pr6stamo. Acuerdo Un acuerdo por el r_ual nos comprometemos a no proceder con la ejecuci6n hipotecaria y/o Temporal de colecci6n de pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia hacer los pagos requeridos. Modificacidn de Pagar el pr6stamo bajo los nuevos t6rminos acordados, que puede incluir la reducci6n de la tasa Pr6stamo de inter6s, agregando la cantidad adeudada al final del pr6stamo, y/o extender el plazo del (no por medio pr6stamo. de RAMP) Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos estin (solamente vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, este programa prestamos de la est6 diserlado para que su pr6stamo este al dia mediante la creaci6n de una segunda hipoteca / FHA) gravamen sobre su propiedad por la cantidad adeudada. Opciones a considerar si no puede o no desea quedarse en su casa Home ........... Disehado para ayudar a los prestatarios que son elegibles pare el Programa de Home Affordable Affordable Modification (HAMP), pero no tuvieron 6xito en obtener una modificaci6n permanente a trav6s del Foreclosure programa. HAFA ofrece la posibilidad de una vents corta y, si no tiene 6xito, una entrega de Alternatives escritura pare evitar juicio hipotecario. Una venta corta es una transacci6n en la qua usted vende su Program propiedad por menos de la cantidad adeudada en el pr6stamo (sujeto a previo acuerdo de su (HAFA) administrador / prestamista / inversionista), resultando en la liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una entrega de escritura para evitar juicio hipotecario es una transacci6n en la que usted estb de acuerdo de transferir voluntariamente [as escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. Venta Corta/ Se ofrece a los prestatarios que no son elegibles pare HAMP u otras alternativas de retenci6n de Venta antes de hogar. Con una yenta corta, usted vende su propiedad por menos de la cantidad total adeudada en Ejecucl6n el pr6stamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultando en la Hipotecaria (no liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitando la ejecuci6n hipotecaria. por medio de HAFA) Entrega de Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci6n de Escritura Para hogar, y que no pudieron vender la propiedad a trav6s de una yenta corta. Con una entrega de Evitar Juicio escritura pare evitar juicio hipotecario, usted est6 de acuerdo a transferir voluntariamente las Hipotecario escrituras de su propiedad a nosotros para evitar la ejecuci6n hipotecaria. (no por medio de HAFA) Estamos aqui para ayudarle. Por favor llamenos hoy. Rol r, o? Amer,- FORM 1 1?A. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENN'SYLVAMA Plaintiff(s) VS. VV?K/ & Gur<tt 1 Defendant(s) of ' 3b? CiV i': i t-' r n NOTICE OF RESIDENTIAL MORTGAGE FORECLOSto _ DIVERSION PROGRAM l'ou 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 iegal 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 vour 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 or your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto. your iawyer 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 vour lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU STEPS REQUIRED BY THIS NOTICE. THIS PROGI /It //) 0- Date -]ACT QUICKLY AND TAKE THE F ulh sub Jtted /1 le oTCounsel'for Pla miff) AGM MQMdtWN, UIRE PA ID 309356 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet D ate Cumberland County Court of Common Pleas Docket BORROVTF.R 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 propert% for sale? Realtor Name: Borrower Occupied? Mailinu Address (if different) City: Phone Numbers Email: of people in household: Mailing Address: C ity: Phone Numbers: Email: 9 of people in household: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: S Date of -,ast Payment: _ Priman, Reason for Default: Date You Closed Your Loan: State: Zip: Yes ? No ? Listing date: Price. S_ Realtor Phone:_ Yes ? No ? State: Zip: Home: Office: Cell: Other: How long? Home: Cell: Office: Other: State: Zip: How long? Included Taxes & insurance: is the loan in Bankruptc,,` Yes ? No ? If yes, provide names. location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $_ Other Real Estate: S $ Retirement Funds: $ $_ invesuments: $_ $ ChecliinL: S Savings $ $_ Other $ $ Automobile #l: Model:- Year:_ Amount owed: Value: Automobile 42: Model: Year:_ Amount owed: Value: Other transportation (automobiles. boats. motorcycles): Model: Year: Amount owed: V alue Monthly Income Name of Emplovers: 3. Additional Income Description (not wages): 1. monthly amount: monthly amount: Borrower Pa-, Davs: Co-Borrower Pay Da?,'s: Monthiv Expenses: (Please only include expenses you are currentl` paying) EXPENSE AMOUNT EXPENSE AMOUNT 11 Mortgage Food 2"° Mortgage Utilities Car Pavment(s) Cond.o/Neigh. Fees Auto Insurance Med. (not covered Auto fuelireoairs Other prop. payment - {ncrali rnan T_111T1 1 l Cable TV _ Child Support'Alim. I Spending Monev Dav/Child Care.%Turt. i vole; E;Kuenscs 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: ('nnne lnr_ Phone (Office): Fax: Email: Have you made application for Homeowners Emergencv Mortzage Assistance Program (HEMAP) assistance? Yes 7,1 No If ves, please indicate the status of the application: Have you had anN prior negotiations with your lender or lender's loan sere icing Company to resolve your delinquency? Yes ! -r;o C If ves. 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: Phone: UWe. _ authorize the above named _ to use/rafer this information to my lender/servicer for the sole purpos; of evaluating my financial situation for possible mortgage options. h'We understand that I/we am/are under no obligation to use the services proVided by the above named Borrower Signature Date Co-Borrower Sianature Date Please forward this document along with the following information to lender and lender's counsel: i _\' Proof of income ?J Past 2 bank statements Proof of an)- expected income for the last 455 days ti Copy of a current utility, bill N Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property, is currently on the market) FORM 3 '? Pal THE COURT OF COMMON PLEAS OF ' , f q? CUMBERLAND COUNTY. PEN'?NSYL.VAN1A Plamtiff?sj ?i?? , vs. CW 11, Defendant(s) REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated .2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies ?i as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action, I ?. Defendant lives in the subject real property, which is defendant's primary j residence ,. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Pro(Tram" 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 unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Data Legal Representative Signature o Defendant Date Signaturc of Defendant Date t t! .S il 113 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ALAN M. MINATO, ESQUIRE - ID#75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 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 AGNES MOMBRUN, ESQUIRE - ID#309356 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Aleadinus@udren.com r J , Bank of America, N.A. COURT OF COMMON PLEAS 16001 North Dallas Parkway, Addison, TX 75006 CIVIL DIVISION Plaintiff CUMBERLAND County IV. MARK E. GOULD 8 MAYBERRY LANE MECHANICSBURG, PA 17050 MICHELE M. GOULD 8 MAYBERRY LANE MECHANICSBURG, PA 17050 Defendant(s) TO THE PROTHONOTARY: NO. ?? - ?uD 1 Ul ` ENTRY OF APPEARANCE Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J. Braunstein, Esquire; Paige M: Bellino, Esquire; Harry B. Reese, Esquire; Amy Glass, Esquire- Kassia Fialkoff, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; Agnes Mombrun, Esquire; on behalf of the Plaintiff, in the above-captioned matter. AGNI?S MOMBRUN, "M PA ID 109356 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputya Richard W Stewart Solicitor OF c Bank of America, NA vs. Mark E. Gould (et al.) Case Number 2012-3064 SHERIFF'S RETURN OF SERVICE 05/17/2012 08:07 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on May 17 2012 at 2007 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: Mark E. Gould, by making known unto himself personally, at 8 Mayberry Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. WN SHALL, D?EPHTY 05/21/2012 04:46 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 21, 2012 at 1646 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: Michele M. Gould, by making known unto herself personally, at 107 E. Allen Street, Unit 7, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $64.00 May 22, 2012 ems- C 7r' ..?..?.---- RYAN BURGETT, D SO ANSWERS, RON R ANDERSON, SHERIFF ;c'?outt?SuitaSF rIf (e?,,.osoft t; r 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. 16001 North Dallas Parkway Addison, TX 75006 Plaintiff v. MARK E. COULD 8 MAYBERRY LANE MECHANICSBURG, PA 17050 MICHELE M. COULD 107 EAST ALLEN STREET, UNIT 7 MECHANICSBURG, PA 17055 Defendant(s) ATTORNEY FOR PLAINTIFF ~... COURT OF COMMON PLEAS = ~ ~ ~ ' a :: ~__. _' CIVIL DIVISION ~L~.:, Cumberland County - ~ -- r .. _ .~, _` MORTGAGE FORECLOSURE .. `~'' "~ NO. 12-3064-Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), MARK E. COULD; MICHELE M. COULD; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: FROM TO Unpaid Principal Balance $202,658.92 Interest Per Complaint $8,994.68 Additional Interest 05/04/2012 10/12/2012 $_5,269.86 Late Charges Per Complaint $201.06 Additional Late Charges 05/04/2012 10/12/2012 $335.10 Property Inspection $90.00 Title Report $325.00 Attorney Fees $1,300.00 Grand Total $219,174.62 ~2 ~ ~ ~a" I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and 1;2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW O.F-FIDES, P.C. ~.". _ ... Atto y for laintiff atheri . Kn , E:sq ID 311 DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: _ n _ PRO PROT MJD#: 12030115 CASE#: 12030115-1 COSY Z ~ ~ 3 t .,. ~ ~ ~ ~ '.~ ~ ,`i,¢Jfs1~1 ~ iii ~r~9 l;`~;. 4.5 ~~,i~:k ~~tt'.d.~F~l, UDREN LA W OFFICES, P.C. BY: MARK J• UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ALAN M. MINATO, ESQUIRE -1D#75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 5ALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLING, ESQUIRE - ID#309091. HARRY B. REESE, ESQUIRE - II)#310501 AMY GLASS, ESQUIRE - ID#308367 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 AGNES MOMBRUN, ESQUIRE - ID#309356 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, N3 08003-3620 ATTORNEY FOR PLAINTIFF Bank of America, N.A. ,COURT OF COMMON PLEAS C10 Bank of America, N.A., as successor by merger ~ CIVIL DIVISION to BAC Home Loans Servicing, LI' 'CUMBERLAND Coizntq 1b001 North Dallas Parkway Addison, TX 75006 ', ~, ~ NO. ~ ~-' - 3000 ~ ~..,t vl ~ Plaintiff v. MARK E. GOUL.D 8 MAYBERRY LANE MECHANICSBURG, PA 17050 MICHELE M. GOULD 8 MAS'BERRY LANE MECHANICSBURG, PA 17054 Dcfendant(_s) COMPLAINT IN MORTGAGE FORECLOSURE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Bank of America, NA vs. Mark E. Gould (et al.) ~~r~~txr et ~ar3ra~r~.ffit~ ?. Case Number 2012-3064 SHERIFF'S RETURN OF SERVICE 05/17/2012 08:07 PM -Shawn Gutshail, Deputy Sheriff, who being duly sworn according to taw, states that on May 17 2012 at 2007 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: Mark E. Gould, by making known unto himself personalty, at 8 Mayberry Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. j ,- - ~/- ~•AWN SHALL, D 05/21!2012 04:46 PM -Ryan Burge#t, Deputy Sheriff, who being duly sworn according to taw, states that on May 21, 2012 at 1646 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; Michele M. Gould, by making known unto herself~personally, at 107 E. Alien Street, Unit 7, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. ~--~ ~ • RYAN i3URGETT, D SHERIFF COST: $64.00 SO ANSWERS, r May 22, 2012 RONI~I'~ R ANDERSON: SHERIFF ~cl CamrySuho 5neiifl. Te;ecsa',~ Ir,c y ~~ ~~ ~ ~ fi ( ~~ UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NT,b 08003-3620 856-669-_5400 Bank of America, I'J.A. ~ COURT OF COMMON PLEAS Plaintiff ~ CIVIL Dl`'ISION v. ~ Cumberland County MARK E. GOULD, MICHELE M. GOULD I MORTGAGE FORECLOSURE Defendant(s) NO. 12-3064-Civil TO: MARK E. GOULD 8 MAYSERRY LANE MECHANICSBLTRG, PA 17050 Date of Notice: September 17, 2012 IMPORTAl\TT NOTICE 1'OU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OB:~ECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A 3UDGMENT MAY BE ENTERED AGAINST YOt? WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER 'TO YOUR LAR'~"ER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHOIv~E 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 SERA%ICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR'_v0 FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 1701.3 {800) 990-9108 NOTIFICACION IMPORTANTE LISTED SE ENCUENTRA EN ESTADO :DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMl?~TO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER LISTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SFNTENCIA EN SU CONTRA, LISTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE L:LEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDLATAMENTE SI LISTED NO TIE;NE ABOGADO, O SI NO TIENE DINERO SU FICIENTE PARA T:AL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800} 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES AC'T, THIS LAVV FIRM IS DEEMED TO BE A DEBT COLLEC'T'OR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR TI3AT PURPOSE. UDR.EN LAW OFFICES, PC. ~~~ttorney for Plaintiff Katherine E. Knowlton, Esq FA ID 311713 Woodcrest Corporate Center 1 I 1 Woodcrest Road. Suite 200 Cherry Hill, New Jersey 08003-3620 MJU#: 12030115 CASE: 12030115-1 UDREN LAW OFFICES, P.C. W OODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 0$003-3620 856-669-5400 Bank of America, N.A. Plaintiff ~. MARK E. GOULD, MICHELE M. GOULD Defendants} TO: MICHELE M. GOULD 107 EAST ALLEN STREET, UNIT 7 MECHANICSBLTRG, PA 17055 Date of Notice: September 17, 2012 ATTORiV'EY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 12-3064-Civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE Y01J HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT POUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMEN'T` MAY BE ENTERED .AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOIJR PROPERTY OR OTHER. IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. TF YOIJ CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YUU WITH INFORMATION .ABOUT AGENCIES THAT MAY OFFER. LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 7 Liberty Avenue Carlisle, PA 17013 (800} 990-9108 NOTIFICACION IMPORTANTE tJSTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMLNO DE DIEZ {I O} DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER L'STED EN CORTE O ESCUCHAR PREUB.A ALGLTNA, DICTAR SENTENCIA EN SU CONTRA, LISTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI LISTED NO TIENE ABOGADO, 0 SI NO TIENE DINERO SZTFICIENTE PARR TAL SERVICIO, ~'AYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERTGUAR DONDE SE PtiEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 490-91(18 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATEON OBTAINED WILL BE USED FOR THAT PURPOSE, UDREN LAW OFFICES, PC. ~-- Attor~aey for Plaintiff Katherine E. Knowlton, Esq PA ID 313713 Woodcrest Corporate Center l I I Woodcrest Road, Suite 200 Cherry Hill., New Jersey 08003-3620 MJU#: 12030115 CASE#: 12030115-1 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@udren.com COURT OF COMMON PLEAS Bank of America, N.A. CIVIL DIVISION Plaintiff Cumberland County v. Mark E. Gould ;MORTGAGE FORECLOSURE Michele M. Gould Defendant(s) NO. 12-3064-Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), MARK E. GOULD, MICHELE M. GOULD, wholeach of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as 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 birth andior Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. -~ _...-, r :. i 1-~ -7 ~ .-.. .. ~~~;~ A torney for Plaintiff Katherine E. Knowlton, Esq PA 1D 311713 MJU#: 12030115 CASE#: 12030115-1 Rcsulle. as of :Oct-12-2012 07:23:21 Department of Defense Manpower Data Center SCRA 2.3 r ~.frr ~td~t~ RC}e l I ~i ~'~ ; Fursuat~t o S~n~ie~mern~ C'i~r~il ltei~l':~.ct __ ,, ~~,. Last Name: GOULD First Name: MARK Middle Name: Active Duty Status As Of: Oct-12-2012 On Active Duty On Active Dury Status Date Active Dury Start Date Active Duty End Date Status Service Component NA NA No NA ' This response reflects the individuals' alive duty status based on theActive Duty Status Date Lett Allive Duty Wdhin 367 Days of Active Duiy Status Date Active Duty Start Date Active Duty End Date Status Service Component NP. NA No NA This response reflects where the individual left active duty status within 367 days preceding the Actlve Duty Status Date The Member or His/Her Unit Was Notified of a Future Cal{-Up to Active Duty on Alive Duly Status Date Order Notification Start Date Order Notfication End Date Status Service Component NA NA No __ __NA _-_ _ This response reflects whether the individual or his/her unit has received eddy notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Actlve Duty. ..+ , ~` Mary M. Snavely-Dixon. Director Department of Defense -Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual Is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that. person`s Service via the "defenselink.mil" URL: http:!/www.defenselink.millfaglpis/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 70 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) `Nhether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his(her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the niformed 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 S(:RA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last Hama, 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: GEQNR84AUK Department of Defense Manpower Data Center f.-.-..' h~•~"s ~ ~- ;~ '~~ r Pursuanlt tc- S~r~~cemenYb ti~rrl ~t.~li~f 4cc Last Name: GOULD First Name: MICHELLE Middle Name: Active Duty Status As Of: Oct-12-2012 R.esuils as of :Oct-12-2012 07:25:34 SCRA 2.3 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reftectsthe individuals' active duty status based on the Active Duty Status Date Left Acfive 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 Date The Member or His/Her Unit Was Notified of a Future CaII-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense ItAanpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force. NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ~ ~,-~- Mary M. Snavely-Dlxon, Director Department of Defense Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: 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 verification, punitive provisions of the SCRA may be invoked against you. See 50 USG App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f} for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are far Title 10 and Title 14 active duty records for all the lniformed 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 pe~.~sons 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. Tne Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the fast 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, SSNldate of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: N5T2D4JNLN WRIT OF' EXECUTION and/or ATTACHMEI\IT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-3064 Civil CIVIL ACTION ~ 1,AW TO "THEE. SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N. A. Plaintiff (s) From MARK E. COULD, MICHELE M. COULD (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL, DESCRIPTION . (?) 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) oe 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: $219,174.62 L.L.: $.50 Interest. FROM 10/13/12 TO DATE OF SALE MARCH 6, 2013 ONGOING PER D[EM OF $32.53 TO ACTUAL DATE OF SALE INCLUDING IF SALE [S HELD ATA LATER DATE - $4,716.85 Atty's Comm: ~'io Atty Paid: $215.25 Plaintiff Paid: iS~a!) REQ~JES"TiNG PAR"TY Due Prothy: $2.25 Other Costs: ~~ ~} David D. Buell, Prothonotary Deputy Name: >:ATHF.RINE E. KNOWLTON, ESQUIRE Address: [1DREN LAW OFFICES, PC WOODCREST CORPORATE CENTER 1 11 WOODCREST ROAD, SUITE 200 CHERRY BILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 311713 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, N.I 08003-3620 856-669-5400 pleadings a~udren.com Bank of America, N.A. Plaintiff v. Mark E. Gould Michele M. Gould Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland Country MORTGAGE FORECLOSURE NO. 12-3064-Civil PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due Interest From 10/13/12 to Date of Sale March 6, 2013 Ongoing Per Diem of $32.53 to actual date of sale including if sale is held a a later date (Costs to be added) MJLJ#: 12030115 CASE#: 12030115-1 ~~~ ~~~ , S~ ~~ Ot _ ~~~~~ ;, >> ~_, ~_~ :. -- ~ 21.9,174.62 $ 4,716.85 UDREN LAW OFFICES, P.C. Attorney for Plaintiff Katherine E. Knowlton, Esq PA ID 311713 a S ~~ ~°~ c~. s~ ~~ ~ a~ a d~3 (,~~ ~ t ~ ~~ I ss~ UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF _- Bank of America, N.A. COURT OF COMMON PLEAS - Plaintiff ,CIVIL DIVISION ~~- =:~ _ v 'Cumberland County "' Mark E. Gould MORTGAGE FORECLOSURE Michele M. Gould .: _ - ~: -. Defendant(s) ', NO. 12-3064-Civil ~:~ ~, ..., - CERTIFICATE OF ACT 91 I hereby state that as the attorney for the Plaintiff in the above-captioned matter: Act 91 procedures have been fulfilled Premises is not subject to the provisions of Act 91 This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW O ~ CES2 P.C. - ~ =-=~ Attof`rley for Plaintiff Katherine E. Knowlton, Esq PA ID 311713 I 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(a,udren.com Bank of America, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION ~~- - ~~-~; ~~ -. ~• Cumberland County ' ~ ..~'; Mark E.. Gould MORTGAGE FORECLOSURE _~ `~ Michele M. Gould - ,_ . :, _ Defendant(s) NO. 12-3064-Civil ~~ ~ = ~~ AFFIDAVIT PURSUANT TU 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: 8 Mayberry Lane, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Mark E. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 Michele M. Gould 107 East Allen Street, Unit 7 Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Mark E. Isould 8 Mayberry Lane Mechanicsburg, PA 17050 Michele M. Gould 107 East Allen Street, Unit 7 Mechanicsburg, PA 17055 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 l 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 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA :17055 Members 1st Federal Credit Union P.O. Box 40 Mechanicsburg, PA x.7055 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, FA 17013 Cumberland County Real Estate Tax Department 1 Courthause Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 Tenants/Occupants 8 Mayberry Lane Mechanicsburg, PA 1.7050 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Federal T'ax 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: UDREN LAW. Q~'-ACES, ~~C. f , ~-~ Attorney for Plaintiff Katherine E. Knowlton, Esq PA ID 311713 MJU#: 12030115 CASE#: 1203011.5-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY' HILL, NJ 08003-3620 856-669-5400 pleadings(a~.udren.com Bank of America, N.A. Plaintiff v, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County ,,:~. r==_ .: ~ ; ~,~> ~...J C::? ,__--, _.; T~ c_r . ., ;~==; - c..a ` MARK E. GOULD., MICHELE M. 'MORT'GAGE FORECLOSURE GOULD !, Defendant(s) ~' NO. 12-3064-Civil NOTICE OF SHERIFF'S SALE OF' REAL PROPERTY TO: Mark E. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 Your house (real estate) at 8 Mayberry Lane, Mechanicsburg, PA 17050 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 $219,174.62, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE 'TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To fmd out how much you must pay, you may call: 856 669-5400. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for goad. cause. You may also be able to stop the sale through other legal proceedings. You may need ari attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You maybe able to petition the Court to set aside 1:he 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 CANNO'C AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT' WHERE YC1U 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 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 ~. MARK E. COULD, MICHELE M. COULD, Defendant(s) ~~ ~ -~ ATTORNEY FOR. PLAINTIFF ~, _ 1 .. ~... (i a: _`,, ,t~ . COURT OF COMMON PLEAS CNIL DIVISION Cumberland County MORTGAGE FORECLOStJRE NO. 12-3064-Civil AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.RC.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), MARK E. COULD, MICHELE M. COULD, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers~ Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". They Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. Dated: October 22, 2012 c,,,.-, C~--~-- __ _ _ Attorney for Plaintiff Mark J. Udren, Esquire PA ID 04302 MJU#: 12030115 CASE#: 12030115-1 Department o` Defense Manpower Data ';,enter 71e~4~,i ~.t'~147T1 1-'fxisu~it 1t~ 5~r~t•~ic~cm°tzYbr~ ~'~r~~a Ttc~Ei~:~ .~~; .~,,~~ Last Name: COULD First Name: N;~:R4~: Middle Name: active Dutl~• Siacus ks Of: Oct-22-2012 Result, ~.; of C~ct-22-2012 08:08:52 SCRA 2.3 I On Active Duty On Active Duty Status Date __ _^_ Active Duty E~tart Date _' Active Dury End Date Status ~ _Service Component NF NA ~ No NA This response reflects the individuals' active duty status based on the Active Duty S[atus Date ~ Left Active Duty Within 367 Days of Active Dupe Status Date Active Dufy Start Date Active Duty End Date '~ Status Service Component NA NA Nc N~~ This response refects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HislHer Unit W as Notified of a Future Cali-Up to Active Duty on Active Dury Status Date ~._~._~__. _ i - Order Notification Start Date Order Notification End Dete j Status Service Component _-__-.._..___._ _.~_._ - t- -- ----._~_+--____._._.-_-...__-____..-_ NA NA ~ No N ^. This response reflects whether the individual or hislher unit has received early notification to report for active duty Upon searchina 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. NO{>/4. Public Health, and Coast Guardj. This status includes information on a Servicemember or hislher unit receiving notification of future orders to report for Active Duty. a~' r Mary M. Snavely-Dixon, Director Department of Defense -Manpower Daf,a Center 4800 Mark Center Drive.. Suite 04E25 Arlington, VA 22350 ~~~ The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (LEERS 1 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) (SCR;A) (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 ort active duty" responses. and has experienced only a small error rate. In the event the individual referenced ~:tbove. 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 obta n further verification of the person's status by contacting that person'::. Service via the "defenselink.mil" URl_: http:!/www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for :fie active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCF:A 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 staves within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notificafon to report for active duty on the Active Duty Status Date. fore informatlor~ on ",Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101 (d) (1 ). Prior to 2011) only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized motailization position in the unit they suppor+.. This includes Navy'i raining and Administration of the Reserves (TARS), iMarine 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 a' the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Unae the SCFt;~, is Broader it Some Cases Coverage under the :>CRA 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 Uniforrried Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 IJSC § 101(d)(1). Many times orders arc: 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 pn:~tect~ons 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 i:: E3~JKAOJ3K~~S Reruhs as of :Oct-22-2072 08:11:04 uepartment o` ~etense Manpower Qat~ tenter SCRA 2.3 :~liCllti ftr,~c~rL ~i k ~~ f'-sr~~t~T t~} ~~:r~~~ic~~rn~z~b:;r: {:~':~~ir T~.~:tic~.~~c: ~~: Last Name: OOU~D First Name: MlCFIEL Middle Name' Active Du`t`! Status As Of~ Oct-22-2012 { On Active Duty On Active Duty Status Date ~ __-- -~ Achve Duty Start Date _: Active Duty End Date _ Status _~ Service Component ~ NA NA ': No NA Thts response reflects the individuals' active duty status basetl on the Active Duty Status Date Left Active Duty Within 367 Days of Active Dury Status Date i-- ------'- I Active Duty Start Date Active Duy End Date Status ~ Service Component ' NA This response reflects where the individual left active duty s~ No NA i talus within 367 days precetl~ng fhe Active Duty Status Date _ ~~~~ The Member or HislHer Unit W as Notified of a Future CaN-Up to Active Duty on Agive Duty Status Date _. ~~ Order Notification Start Date Order Notification End Date !, Status Service Component { NA This'response reflects whether the individual or hislher u' No N:'. nit 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. NOA~'~. Public Health, and Coast Guard j. This status includes information on a Servicemember or his/her unit receiving notification of futura orders to report for Alive Duty. ~' Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive. Suite 04E25 Arlington. VA 2235C I~Xk-I I ~.[. ~=~ The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS] database which is the official source of data on eligibility for military medical care and other eligibility s;:>tern~.. The DoD strongly supports the enforcement of the Setvicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCF;A) (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 references ,:above, or any family member. friend. or representative asserts in any manner that the individual was on active duty for the active duty status date. or is otherwise entitled to the protections of the SCRA. you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq(pis/PC09SLDR.html. If you have evidence the person was on active duty for l:he active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCF;A may be invoked against you. See 50 ISC 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 aays preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notificatian to report for active duty on the Actve Duty Status Date. More informal of~ or "AGti~re Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1 ). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includesc 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. Th;s includes Navy l raining and Administration of the Reserves (TARs), 1~larine Corps Active Reserve (ARs) and (;oast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). :,overage i.~nde;~ tl~e SCR/~ is Broader in Some uses Coverage under the SCRA is broader m same 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 l1SC § 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 p~ctections of the SCRA extend beyond the fast 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 protectec WARNING: TMs certificaie was provided based on a last name. SSN/date of birth, and active duty status date provided by the requester. Uroviding erroneous information will cause an erroneous certificate to be provided. ertificate iD i_;:SvVP69~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,t i Jody S Smith 4�ttt rtr�� n tit iLirio it"`.t Chief Deputy Q C f a AN 9: 45 Richard W Stewart Solicitor � �� .���_ .. , CUPtBERLAND c0,,jj4*rV PENNSYLVANIA Nationstar Mortgage LLC Case Number vs. Mark E. Gould (et al.) 2012-3064 SHERIFF'S RETURN OF SERVICE 01/03/2013 08:23 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 8 Mayberry Lane, Mechanicsburg, PA 17050, Cumberland County. 01/03/2013 08:23 PM - Deputy Ryan Burgett, 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: Mark E. Gould at 8 Mayberry Lane, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, 01/14/2013 07:42 PM -Deputy William Cline, 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: Michele M. Gould at 107 EAST ALLEN UNIT#7, Mechanicsburg, PA 17055, Cumberland County. 02/06/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $6,148.03 SO ANSWERS, April 30, 2013 RON R ANDERSON, SHERIFF QS- 1pd. e?3 . SID &L'ov- �our.yS..u,r:$hnr;il,Teie^snit:Inr. 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(a,udren.com Bank of America,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Mark E. Gould MORTGAGE FORECLOSURE Michele M. Gould Defendant(s) NO. 12-3064-Civil 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: 8 Mayberry Lane, Mechanicsburg, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Mark E. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 Michele M. Gould 107 East Allen Street, Unit 7 Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: Mark E. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 Michele M. Gould 107 East Allen Street, Unit 7 Mechanicsburg, PA 17055 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 i 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 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Members 1st Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 Members 1st Federal Credit Union P.O. Box 40 Mechanicsburg, PA 17055 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 8 Mayberry Lane Mechanicsburg, PA 17050 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: UDREN LAW QF-OF —,C. BY: Attorney for Plaintiff Katherine E. Knowlton, Esq PA ID 31171.3 MJU#: 12030115 CASE#: 12030115-1 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(k),udren.com Bank of America,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County MARK E. GOULD,MICHELE M. MORTGAGE FORECLOSURE GOULD Defendant(s) NO. 12-3064-Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mark E. Gould 8 Mayberry Lane Mechanicsburg, PA 17050 Your house(real estate) at 8 Mayberry Lane, Mechanicsburg, PA 17050 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$219,174.62, 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 the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 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 r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com Bank of America,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County MARK E. GOULD,MICHELE M. MORTGAGE FORECLOSURE GOULD Defendant(s) NO. 12-3064-Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Michele M. Gould 107 East Allen Street, Unit 7 Mechanicsburg, PA 17055 Your house(real estate) at 8 Mayberry Lane, Mechanicsburg, PA 17050 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$219,174.62, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICI ' ',F OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS -'PRIFF'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 the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 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 Sheriff s 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 lot of land situate In the Township of Silver spring, Cumberland County, Pennsylvania,more particularly bounded and described as follows: BEGINNING at a point on the eastern line of Mayberry lane (50 foot right of way),at the southwestem comer of Lot No.29 on the hereinafter mentioned Plan of Lots;THENCE along the southern One of Lot No. 29, North 84 degrees 59 minutes 52 seconds East, a distance of 274.72 feet to a point at line of lands now or formerly of John Erdis;THENCE along said Erdis lands,South 48 degrees 43 minutes 37 seconds East, a distance of 18.68 feet to a point at litre of lands now or late of Harold D. Starter; THENCE along the western One of said Stoner lands, South 42 degrees 03 minutes 58 seconds West, a distance of 183.81 feet to a point at the nartheastem comer of Lot No. 31 on the hereinafter mentioned Plan of Lots;THENCE along the northern tine of Let No. 31, North 72 degrees 05 minutes 02 seconds West,a distance of 181.17 feet to a point on the eastern line of Mayberry Lane;THENCE along Mayberry Lane by a curve to the left having a radius of 150 feet, an arc distance of 70.00 feet to a point,the place of BEGINNING. BEING Lot No. 30 on the Final Major Subdivision Plan of Section 2, part 6, Brandywine Village as recorded In the Cumberland County Recorder's Office in Plan Book 32,page 100. UNDER AND SUBJECT to a 16 foot storm sewer easement along property line of Lot No. 30 and Lot No. 31, Section No. 2, part 8, Brandywine Village, described in accordance with survey prepared by Robert G. Hartman,Jr.,Registered Surveyor, dated November 11, 1983,described as follows,to wit: SEGIMNING at a point on the southern right of way line of Mayberry Lane, said point being located 363.17 feet In an easterly direction from the North end of a 7.92 feet arc connacting the eastern right of way line of Mayberry lane, a 50 foot right of way to the northern right of way One of Longview Road,a 60 foot right of way; THENCE from the point of beginning along the southern right of way line of Mayberry Lane on an are of a curve curving to the left,having a radius of 17S feet and an arc length of 16.406 feet to a point;THENCE through Lot No.30, South 72 degrees 06 minutes 02 seconds East,a distance of 133.66 feet to a point; THENCE through Lot 30 and Lot 31, South 48 degrees 38 minutes 35 seconds East,a distance of 46.80 feet to a point on the rear property line of Lot 31;THENCE along same, South 42 degrees 03 minutes 58 seconds West, a distance of 16 feet to a point; THENCE through Lot 30, North 45 degrees 38 minutes 35 seconds West, a distance of 4328 feet t4 a point; THENCE through same,North 72 degrees 05 minutes 02 seconds West,a distance of 130.3:3 feat to a point,the point of BEGINNING. NO THE SAME? PREMISES which James R, Lauer and Barbara J. Lauer. by deed dated _, .2004 and intended to be recorded simultaneously herewith in the Office of the co of eels of Cumberland County,grunted and conveyed unto Mark E. Gould and Michele M. out ortgagors herein. BEING KNOWN AS: 8 MAYBERRY LANE, MECHANICSBURG, PA 17050 PROPERTY ID NO.: 38-21-0289-056 TITLE TO SAID PREMISES IS VESTED IN MARK E. GOULD AND MICHELE M. GOULD,HUSBAND AND WIFE BY DEED FROM JAMES R. LAUER AND BARBARA J.LAUER,HUSBAND AND WIFE DATED 07/30/2004 RECORDED 08/03/2004 IN DEED BOOK 264 PAGE 2461. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH,OF PENNSYLVANIA) NO, 12-3064 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 MARK E.GOULD,MICHELE M. GOULD (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: $219,174.62 L.L.:$.50 Interest FROM 10/13/12 TO DATE OF SALE MARCH 6,2013 ONGOING PER DIEM OF$32.53 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD ATA LATER DATE-$4,716.85 Atty's Comm: % Due Prothy:$2.25 Atty Paid: $215.25 Other Costs: Plaintiff Paid: Date: 10/16/12 f� David D.Buell,Prothonotary (Seal) B Deputy REQUESTING PARTY: Name: KATHERINE E. KNOWLTON,ESQUIRE Address: UDREN LAW OFFICES,PC WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No.311713 TRUE COPY FROt REset my and In Testimony'Nhe`Pof,t here unto set my and the seal of said Court at arlisie,PtL �1 ,, of�'201__--- This�daY Prothonotary On October 23, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, Known and numbered as, 8 Mayberry Lane, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 23, 2012 By: 01 Real Estate Coordinator v S s CUMBERLAND LAW JOURNAL Writ No. 2012-3064 Civil with survey prepared by Robert G. Hartman, Jr., Registered Surveyor, Bank of America, NA dated November 11, 1983,described vs. as follOWS.to wit: Mark E. Gould, BEGINNING at a point on the Michele M. Gould southern right of way line of May- berry Lane, said point being located Atty.: Mark Udren 363.17 feet In an easterly direction ALL THAT CERTAIN lot of land from the North and of a 7.92 feet situate In the Township of Silver arc connecting the eastern right of spring, cumberland county, Penn- way line of Mayberry lane, a 50 foot sylvania,more particularly bounded right of way to the northern right of and described as follows: way line of Longview Road,a 50 foot BEGINNING at a point on the right of way;THeNCe from the point eastern line of Mayberry lane(50 foot of beginning along the southern right right of way). at the southwestern of way line of Mayberry Lane on an corner of lot No. 29 on the hereinaf- arc of a curve curving to the left, ter mentioned Plan of lots;THENCE having a radius of 175 feet and an along the southern line of Lot No. arc length of 16.006 feet to a point; 29,North 84 degrees 59 minutes 52 THENCE through Lot No. 30, South seconds East, a distance of 274.72 72 degrees 05 minutes 02 seconds feet to a point at line of lands now fast a distance of 133.65 feet to a or formerly of John Erdis; THENCe point; THENCE through Lot 30 and along said Erdis lands, South 48 Lot 31,South 48 degrees 38 minutes degrees 43 minutes 37 seconds east 35 seconds East,a distance of 46.80 a distance of 18.68 feet to a point at feet to a point on the rear property line of lands now or late of Harold D. line of Lot 31;THENCE along same, Stoner, THeNCE along the western South 42 degrees 03 minutes 58 line of said Stoner lands, South 42 seconds West, a distance of 16 feet degrees 03 minutes 58 seconds West, to a point;THENCE through Lot 30, a distance of 183.81 feet to a point at North 48 degrees 38 minutes 35 the northeastern corner of Lot No.31 seconds West, a distance of 43.28 on Itle hereinafter mentioned Plan feet to a point; THENCE through of Lots;THENCE along the northern same, North 72 degrees 05 minutes line of Lot No. 31. North 72 degrees 02 seconds West a distance 130.33 05 minutes 02 seconds West, a dis- feet to a point,the point of Beginning, tance of 181.17 feet to a point on Being THE SAME PREMISES the eastern line of Mayberry Lane; which James R. Lauer and Barbara THENCE along Mayberry Lane by a J.Lauer by deed dated July 30,2004 curve to the left having a radius of and intended to be recorded simul- 150 feet,an arc distance of 70.00 feet taneously herewith In the Office of to a point,the place of BEGINNING. the of Deeds of Cumberland County, BEING Lot No.30 on the Final Ma- granted end conveyed unto Mark E. jor Subdivision Plan of Section 2,part Gould and Michele M. Gould Mort- B,Brandywine Village as recorded In gagors herein. the Cumberland County Recorder's BEING KNOWN AS: 8 MAYBER- Office in Plan Book 32,page 100. RY LANE, MECHANICSBURG, PA UNDER AND SUBJecT to a 16 foot 17050. storm sewer easement along property PROPERTY ID NO.: 38-21-0289- line of Lot No. 30 and Lot No. 31 056. Section NO.2, part B, Brandywine TITLE TO SAID PREMISES Village, described in accordance IS VESTED IN MARK E. GOULD 54 S t CUMBERLAND LAW JOURNAL AND MICHELE M GOULD, HUS- BAND AND WIFE BY DEED FROM JAMES R. LAUER AND BARBARA J. LAUER, HUSBAND AND WIFE DATED 07/30/2004 RECORDED 08/03/2004 IN DEED BOOK 264 PAGE 2461. 55 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. (1y Lisa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 8 day of February, 2013 i Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 2012.3064 CNN Bank of Amarlea,N,1 Vs Mark E.Gould . MMhela M.Gould Atty: Mark Udran ALL THAT CERTAIN lot of land situate In the TownsMp of Silver spring,Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the eastern line of Mayberry lane(50 foot right of way).at the southWestem cdrm of lot No.29 on the hereinafter'mentioned Ylan of lots; THENCE along the southern line of Lot No. 29,North 84 degrees 59 minutes 52 seconds East,a distance of 274.72 feet to.a point at line of lands now or formerly of John Erdis;' THENCE along saidEtdis lands, South 48 degrees 43 minutes 37 seconds east adistance of 18.68 feet to apoint at line of lands now or late of Harold D.Stoner, THENCE along the western line of said Stoner lands,South 42 degrees 03 minutes 58 seconds West,a dilam of 183.81 feet to it point at the nortWastom comer of Lot No.31 Itie$aeinaltar mentioned Plan Of Lots;THENCE akrq the nortbem line of Lot No.31.North 72 degrees 05 minutes 02 seconds West;a distance of 181.17 feet to a point on the ea"n WSS41hybeny Lane;THENCEalo%Maybcny Lane by a awe to tbe lefthaving a radius of 150 feet, i1O a�� , Maw= ma dr NNW t Brandywine Village as recorded In the Cumberland County Recorder's Offn in Plan Book 32,page 100, UNDER AND SUBJECT to a 16 foot storm sewer easement along property line of l of No.30 andIAN%31 Section N0.2, part B, Brandywine' agC,`descdbed in accordance with survey,�r.Wed by Robert G.Hartman,Jr.,RegistetedSurveyor,dated November 11,1963,desiribcd as foNOWS. towit. BEGINNING at a point on the southem right of way line of Mayberry Lane,said point being located M3.17 feet in an easterly direction from the North and of a 7.92 feet arc connecting the eastern r ght'dway line of Mayberry lane,a 50 foot right of way to the northern right of way line of Longview Road,a50 foot right ofway;THENCEftom the point of'bd&n*along the southern right of way_line of Mayberry Lane on an arc of a curve curving to the left,having a radius of 175 feet and'i arc length'of 16.006 feet to a point;THENCE through Lot No.30,South 72 degrees 05 minutes 02 seconds fast a dis*m of A33.65 feet to a point;THENCE'thtougli i if Fend Lot 31,South 48 degrees 38 minutes 35 seconds East,a distance of 46.80 feet to a point on the rear property line of Lot 31;THENCE along same,South 42 degrees 03 minutes 58 seconds West,a distance of 16 feet to a point;THENCE 06ugh 0",North 48 degrees 38 minutes 35 seconds West,a distance of 43.28 feet to a point;THENCE. through same,North 72 degrees 05 minutes 02 seconds Vilest a distance 130.33 feet to a point,the point of Beginning, Being THE SAME PREMISES which James R Lauer and Barbara J:Lauer by deed dated July,30,2004 and intended to be-recorded simultaneously,,herewith In the Office of the of Deeds`ofCumbgrbnd County,granted end conveyed unto Mark E. Gould and Michele M.Gould Mortgagors herein. BEING KNOWN AS: "8 MAYBERRY LANE,Mj_H CSBURG,PA 17050 PROPERTY ID NO.:38-21-0289-056 TnU TO SAID PREMISES IS VESTED IN MARK I?GOULD AND MICHELE i xv(ryCltlucr r1,rypyf Ucat3l�tf-pp lV!(V YM.7, to wit. BEGINNING at a Point on the southern right of way line of Lane Pointbeinglocated363.j7 t', easterly ao from the North and as 7.92 easfeet of co Mon nyJ a eastern right of way lace t try home;a 50 foot right of way to Ronda SOrnt of way line of(oy� the �tnghtofway;THEjv�fro�m point of Its opt he sou&m rot of way j Law arc of a gto� onau 4 a radius of It feet 11 16.006 feet to a Point;t o�I7 t h 4 02 Lot No,30,SWA seconds fa 7�de8 05 minutes a pointy�FNt Et 365 feet u:. 3;,South 48 3eand tot degrees 38 minutes 35 seconds East,adistanco X46.80 feet to a I e fat31;-ITMNCE 03 mintes a� T ?a dbtanoe� 16 t to 48 degrees 38 taintutes *s ds octh West;a distance,of 43.28 feet' a point;THENCE 02.ecuo ame,Nastat 72 dues 05 miniures Poi � of * ' tent tb a Being THE SAMg I'+1;EA"tSES' which Ian R w and f}arb a J Lauer o deed dated July 3p, - be recorded anA intended to sim tax Office of tlu .� In County,granted end°uaaaYed unrkEa anr!Michele M.Gould MoitSagors BEING KNOWN AS: 8 MAYBERRY IANE;MECUMCS$URG,PA 17050 PROPMt7y ID NO.:38-214Y289.a iIN MARK� SFS IS vsm r M GO II D HSBANND�AND ifflCHELE DEED FROM JAM M R A .AIdD Jg LR,HUSBAND AN RECORDED %030W IN DEED�?. 44 PAGE c\ ! E 10 isisaoa SLt 3X3ACp UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com Bank of America,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION c `.E V. Cumberland County w x; MARK E. GOULD; MICHELE M. MORTGAGE FORECLOSURE r*3 CD GOULD; et al Defendant(s) -0 c: NO. 12-3064-Civil PRAECIPE TO MARK SETTLED,DISCONTINUED AND ENDED -� AND SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above captioned matter SETTLED, DISCONTINUED AND ENDED AND JUDGMENT SATISFIED,upon payment of your costs only. DATED: UDREN LAW OFFICES, P.C. BY: Atto y r ai H RY B EESE, ESQUIRE ID 310501 MJU#: 12030115 CASE#: 12030115-1