HomeMy WebLinkAbout12-3416UDREN LAW OFFICES, P.C.
BY: MARIK 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
SALVATO RE CAROLLO, ESQUIRE - ID011050
PAIGE M BELLING, ESQUIRE - ID#309091
HARRY 9. REESE, ESQUIRE - ID#310501
AMY GLASS, ESQUIRE - ID#308367
KASSIA #IALKOFF, ESQUIRE - ID#310530
ELIZABETH L. WASSALL, ESQUIRE - ID#77788
AGNES MOMBRUN, ESQUIRE - ID#309356
WOODCkEST CORPORATE CENTER
ATTORNEY FOR PLAINTIFF
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C-, -
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111 WOODCREST ROAD, SUITE 200
CHERRY', HILL, NJ 08003-3620
856-669-5400 pleadings@udren.com
Bank of America, N.A.
C/O Bank of America, N.A., as successor by merger
to BAC Home Loans Servicing, LP
16001 North Dallas Parkway
Addison,' TX 75006
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
NO. A g .391 ? ?Wi (
V.
SHELLER W. FULLER
2550 LAMBS GAP ROAD
ENOLA, PA 17025
ROBERT'', M. FULLER, JR.
2550 LAMBS GAP ROAD
ENOLA, PA 17025
Defendant(s)
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A ,LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
aJLkA '%1p3.7S?d &Ck?-?qs
? a7S ?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 ja corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su
persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la
demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor
del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted
puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
J
a
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
u
1. Plaintiff is Bank of America, N.A.. Plaintiff is the legal holder of the Mortgage that
is the subject of this Action. Plaintiff is either the current mortgagee of record, is the
legal holder of the Mortgage by virtue of being successor in interest to the current
mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of
Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of
Mortgage, it is by the following Assignments of Mortgage, all of which have either
been recorded or Plaintiff is in the process of formalizing the actual Assignment of
Mortgage in Plaintiffs favor:
Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Countrywide Home
Loans, Inc.
Assignee: Bunk of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a
Countrywide Home Loans Servicing, LP
Date of Assignment: 10/03/2011
Recorded Date: 10/19/2011
Book/Instrument #: Instrument #201128917
Page: N/A
2. Upon information and belief Defendant(s) and/or their predecessor:
Robert M. Fuller, Jr.
(hereinafter "Defendants"), are the owners of property located at 2550 Lambs Gap
Road, Enola, PA 17025, by virtue of Deed dated 05/07/2010 and recorded 05/21/2010
in Official Records Book Instrument #201013164 at Page N/A of the Public Records of
Cumberland County, Pennsylvania (hereinafter the "Property").
3. On 06/08/2005, Defendant(s) and/or their predecessor:
ROBERT M. FULLER, JR. AND SHELLEY W. FULLER
promised to pay to the order of Countrywide Home Loans, Inc., the principal sum
of $180,000.00 payable with interest thereon provided in the Note.
4. By Mortgage dated 06/08/2005, Defendant(s) and/or their predecessor:
ROBERT M. FULLER, JR. AND SHELLEY W. FULLER
to secure the Note, mortgaged to Mortgage Electronic Registration Systems, Inc.,
as nominee for Countrywide Home Loans, Inc., the Property which is the subject
of this action. The Mortgage was recorded on 06/20/2005 in Official Records Book
1911 at Page 2252. 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 05/01/2011, 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 $164,212.71
Accumulated Interest (due from 04/01/2011 to
05'/22/2012) $10,770.82
Accumulated Late Charges $157.56
Escrow Deficit/(Reserve) $3,415.14
Tittle Report $325.00
Attorney Fees- Estimated $1,300.00
Property Inspections $90.00
Grand Total $180,271.23
The above figures are calculated as of 05/22/2012:
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 5.75000 %. The per diem interest accruing
on this debt is $25.7984 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 $52.52.
7. Breach letters have been sent to Defendant(s) in accordance with the requirements of
the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of
Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached
hereto as Exhibit "A"
WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the
sum of $1810,271.23 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDREN LAW OFFICES, P.C.
BY\,T • 'QUIRE
PA ID 310501
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Exhibit "A"
Legal Description
All that certain parcel of land situate in the Township of Hampden, Cumberland County,
State of Pennsylvania, bounded and described in accordance with a subdivision plan dated
September 10, 1973 and a survey dated March 1, 1974, both made by James A. Cieri,
Consulting Engineer, as follows:
Beginning at a point on the center line of Lambs Gap Road; thence along the lands now or
late of C Fry North Seven (07) degrees forty-five (45) minutes West, a distance of three
hundred forty-three and eight tenths (343.8) feet to a steel post; thence along lands now or late
of Pennsylvania State Game Lands (formerly H. McCormick) North eighty-five (85) degrees
fifteen (II'5) minutes East, a distance of four hundred twenty-two and four tenths (422.4) feet
to a steel' post; thence along lands now or late of D. Smith South zero (00) degrees thirty-five
(35) minutes West, a distance of five hundred fort-one and twenty-five one-hundredths
(541.25) feet to the center line of Lambs Gap Road; thence along the center line of Lambs
Gap Road North fifty-nine (59) degrees twenty-one (21) minutes West, a distance of thirty
and seventeen one-hundredths (30.17) feet to a point in the center line of Lambs Gap Road;
thence along Lambs Gap Road North sixty-nine (69) degrees four (04) minutes West, a
distance of ninety-nine and eighteen one-hundredths (99.18) feet to a point; thence along the
center ti 'e of Lambs Gap Road North seventy-two (72) degrees forty-three (43) minutes
West, a istance of one hundred seven and thirty-five one-hundredths (107.35) feet to a point;
thence al ng the same center line of Lambs Gap Road North sixty-seven (67) degrees fifty-
three (53) minutes West, a distance of one hundred fifty-eight and twenty one-hundredths
(158.20) !feet to the place of beginning.
Tax/Parcel ID: 10-11-3016-004
$K 19 1 1 PGZ269
Bankef America
PRESORT
PO ?8 U SS Postage and
Temecula, CA 92589-9048 Fees Paid
WSO
Send Payments to:
P.O. Box 15222
Wilmington, DE 1 9886-522 2
Send Correspondence to.,
PO Box 5170, MS SV314B
Simi Valley, CA 93065
LN
2251828571
20110705-7
Shelley W Fuller
2550 Lambs Gap Rd
Enola, PA 17025-1129
EXHIBIT A
SL OPA1 12870 12/2312010
Bankof America
FlOnte Loans
P.O. Box 660694
Dallas, TX 75266-0694
Send Payments to.
P.O. Box 15222
Wilmington, DE 19886-5222
July 1, 2011
Shelley W Fuller
2550 Lambs Gap Rd
Enola, PA 17025-1129
Account No.: 97035543
Property Address:
2550 Lambs Gap Rd
Enola, PA 17025-1129
Current Servicer:
BAC Home Loans Servicing, LP
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
LA NOTIFICACI6N EN 4DJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN
SU CASA. SI NO 11 COMPRENDE EL CONTENIDO DE ESTA NOTIFICAC16N OBTENGA UNA TRADLICCI6N
INMEDIATAMENTE LIL MIANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL
NUMERO MENCIONA ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA
PERDIDA DEL DERECH A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAMES): Shelley W Fuller
PROPERTY ADDRESS: 2950 Lambs Gap Rd
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
Enola. PA 17025-1129
97035543
I=7:C'LTF9 IF?ilf4rT1g42E7T3t1=1f'=i=T 3117 t_ u = `
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
M?PR FINANCIAL ASSISTANCE WHICH CAN SAVE Y HOME FROM FORECLOSURE N P
3E ELIGIQL
:FUTURE TGAGE PAYMENTS,
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 institution, subject to applicable law. 131-01PA1 12870 12123/2010
Payment Instructions: Account Number: 97035543-4
• Make your deck payable to BAC Shelley W Fuller Balance Due for charges listed above: $4,D70.74 as of July 1, 2011.
Home Loans Se dng, LP 2550 Lambs Gap Rd Please update rrmail information on the reverse side of this mupnn.
Pony send cash
Please induce coupon with your Enola, PA 17025-1129
gddirtonal
payment Pdnoipal
BLQPAt
For all full month payment periods, AdrA7iona1
interest is calculated On a monthly basis. I "'
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Accordingly, interest tor all full months, I I
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including February, ',Is calculated as BAC Home Loans Servicing, LP
301360 of annual irvlerh?est, irrespective of PO BOX 1 5222 G/eLI`
the actual number of lays in the month. Taal
For partial months, in rest is calculated Wilmington, DE 19886-5222
daily onthe basis of 365 day year. 1-800-669-6654
097035543400000407074000407074
1: 58 6 9 900 581: 9 70355 L. 3 11M
This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit
Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar
association may be able to help you find a lawyer.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983
• (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF CORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for
Thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY
CONSUMER CREDIT C NS 1 AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the
end of this notice, the le, der may NOT take action against you for Thirty (30) days after the date of this meeting. The names,
addresses and telephone inumbers of designated consumer credit counseling agencies for the county in which the property is located
are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of
your intentions.
APPLICATION FOR MORIGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see
following pages for specifi information about the nature of your default.) If you have tried and are unable to resolve this problem with
the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To
do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have
applications for the progrlam and they will assist you in submitting a complete application to the Pennsylvania Housing Finance
Agency. Your application'', MUST be filed or postmarked within Thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME
PERIODS SET FORTH 1 THIS LETTER, FORECLOSURE MAY PROCEED AGAINSTYOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility criterlal established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision
after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART
OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN A STATE OF DEFAULT DUE TO THE REASONS
MENTIONED IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE.
NATURE OF THE DEF&VIJ T - The MORTGAGE debt held by the above lender on your property located at:
2550 Lambs Gap Rd Enola, PA 17025-1129
IS SERIOUSLY IN DEFAULT because
YOU HAVE NOT MADE' MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now
past due:
Monthlv Charaes: 05/0112011
Late Charges: 05101/2011
Other Charaes: Uncollected Late Charges:
Uncollected Costs:
Partial Payment Balance:
TOTAL DUE:
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable)
$3,965.70
$105.04
$0.00
$0.00
($0.00)
$4,070.74
HOW TO CURE HE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE
TOTAL AMOUNT PAS DUE TO THE LENDER, WHICH IS $4,070.74 PLUS ANY MORTGAGE PAYMENTS AND LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payments must be made either by cashier's check. certified check or money order made payable and sent to:
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: 97035543
Shelley W Fuller 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.
BAG Home Loans Servicing, LP at P.O. Box 15222, Wilmington, DE 19886-5222.
You can cure any other default by takina the followina action within THIRTY (30) DAYS of the date of this letter. (Do not use if not
applicable)
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the
lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt
will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the
total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If
the lender refers your cane to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you
will still be required to pay, the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you Will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the
default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO
REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE
NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE.
OTHER LENDER REMEDIES - The lender may also sue you personalty for the unpaid principal balance and all other sums due
under the mortgage.
RIGHT TO CURE T - If you have not cured the default within the THIRTY (30) DAY
period and foreclosure p ceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one
hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due,
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as
specified in writing by the fender and by performing any other requirements under the mortgage. Curing your default in the manner
set forth in this notice Will restore your mortgage to the same position as if you had never defaulted
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgage
property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the
Sheriffs Sale will be sentlto you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THg LENDER:
Name of Lender: BAC Home Loans Servicing, LP
Address: P. O. Box 660694 Dallas, TX 75266-0694
Phone Number: 1-800-669-6654
Fax Number: 1-817-230-6811
Contact Person: MS TX2-977-01-13
Attention: Loan Counselor
We are currently developing a process to ensure secure email communications for your Home Retention inquiries. In the
interim, please contact us at the telephone number or address provided.
EFFECT OF SHERIFF'S 016LE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your
right to occupy it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTQAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt,
provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other
requirements of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM
ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE
DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT
INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER.
TO SEEK PROTECTION'UNDER THE FEDERAL BANKRUPTCY LAW.
Your loan is in default. Pursuant to your loan documents, BAC Home Loans Servicing, LP may, enter upon and conduct an inspection
of your property. The purposes of such an inspection are to (i) observe the physical condition of your property, (ii) verify that the
property is occupied andiior (iii) determine the identity of the occupant. If you do not cure the default prior to the inspection, other
actions to protect the mortgagee's interest in the property (including, but not limited to, winterization, securing the property, and
valuation services) may be taken. The costs of the above-described inspections and property preservation efforts will be
charged to your account as provided in your security instrument.
This communicaton is from Bank of America, N.A., the servicer of your home loan.
If you are unable to cure the default on or before July 31, 2011, BAG Home Loans Servicing, LP wants you to be aware of various
options that may be available to you through BAC Home Loans Servicing, LP to prevent a foreclosure sale of your property. For
example:
• Repayment Plan: It is possible that you may be eligible for some form of payment assistance through BAC Home Loans
Servicing, LP. Our basic plan requires that BAC Home Loans Servicing, LP receive, up front, at least % of the amount
necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular
monthly payment, over a defined period of time. Other repayment plans also are available.
• Loan Modification: Or, it is possible that the regular monthly payments can be lowered through a modification of the loan
by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure
alternative, however, is limited to certain loan types.
• Sale of Your Property: Or, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of
your home can be approved through BAG Home Loans Servicing, LP even If your home is worth less than what is owed
on it.
• Deed-in-Lieu: Or, if your property is free from other liens or encumbrances, and if the default is due to a serious financial
hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the
foreclosure stale.
If you are interested in discussing any of these foreclosure alternatives with BAC Home Loans Servicing, LP, you must contact us
immediately. If you request assistance, BAC Home Loans Servicing, LP will need to evaluate whetherthat assistancewill be extended
to you. In the meantime, AC Home Loans Servicing, LP will pursue all of its rights and remedies under the loan documents and as
permitted by law, unless it', agrees otherwise in writing. Failure to bring your loan current or to enter into a written agreement by July 31,
2011 as outlined above will result in the acceleration of your debt.
If your loan is currently being evaluated for a loan modification, forbearance or other loan assistance solution, this notice will not cancel
or delay that evaluation process. However, it is important that you promptly respond to all requests made in connection with your
evaluation for a loan assistance solution, including all requests for you to contact us and any documentation required. If you do not
comply with these requests in a timely manner, it may cause your loan to enter the foreclosure process as indicated in this notice. If
your loan is not eligible for a loan assistance program, please note this letter will continue to serve as notice of our right to initiate
foreclosure.
Time is of the essence. If you have any questions concerning this notice, please contact Loan Counseling Center immediately at
1-800-669-6654.
This communication is from Bank of America, N.A., the servicer of your home loan.
Attachment: Itemization of Charges and Fees
Monthly Charges:
Late Charges:
Other Charaes:
05/01/2011 - 07/31/2011
05/01/2011 - 06/30/2011
Uncollected Late Charges:
Partial Payment Balance:
(ED
$1,321.90
$52.52
$3,965.70
$105.04
$0.00
0.00
$4,070.74
TOTAL DUE:
M
This communication is from Bank of America, N.A., the servicer of your home loan.
2251838571
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
CUMBERLAND COUNTY
CCCS of Western PA
2000 Unglestown Road
Harrisburg, PA 17102
688.511.2227
888.511.2227
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
Community Action Commission of Captial PA Interfaith Community Programs Inc
Region 40 E High Street
1514 Derry Street Gettysburg, PA 17325
Harrisburg, PA 17104 717.334.1516
717.232.9757
This communication is from Bank of America, N.A., the servicer of your home loan.
Options are Available to Help You
Avoid Foreclosure
Call the number on the enclosed notice to learn more.
When you call, please have your income and expense information available
so we can discuss which option(s) could work for you.
Options to consider if your goal is to stay in your home
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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 ejxtending 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
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Home D esigned to help borrowers who are eligible for the Home Affordable Modification Program (HAMP)
Affordable bu t were unsuccessful in securing a permanent modification through the program. HAFA provides the
Foreclosure o tion 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) fo reclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer
ow nership 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 sane, 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.
We are hereto help you. Please call us today.
2251838571
Hay Opciones Disponibles Para Ayudarle a
Evitar la Ejecucion Hipotecaria
Llame al numero que aparece en la notificacidn adjunta para obtener mas
informacion
Cuando Ilame, tenga la informac16n de sus ingresos y gastos disponibles pare quo podamos
discutir cual opcibn(es) pueden funcionar pare usted.
Opciones a considerar si su objetivo es permanecer en su casa
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Home Affordable Un programa del gobierno federal que le permite pagar el prestamo bajo los nuevos terminos
Modification aicordados, que pueden incluir la reduccibn de la tasa de interes, agregando la cantidad adeudada
Program (HAMP) ail final del prestamo, y / o extender el plazo del prestamo. Usted puede ser elegible para este
programa si cumple con los siguientes requisitos:
. La casa es su residencia principal y actualmente vive an ella.
• La cantidad adeudada en la primera hipoteca debe ser igual o menos que $729,750 d6lares
pare una vivienda unifamiliar, $934,200 d6lares para una propiedad de 2 unidades, $1,129,250
d6lares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades
• Ha experimentado una dificultad que ha afectado sus ingresos. Por ejemplo, un aumento
significativo en su pago hipotecario O reduccibn de sus ingresos U otras dificultades.
• Obtuvo su hipoteca antes del 01 de enero 2009.
• Su pago de la primera hipoteca (incluyendo principal, interes, impuestos, seguro y cuotas de
asociaci6n de propietarios, si se aplica) debe ser mas 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 prestamo hipotecario al dia, se le aceptaren los fondos
del Prestamo necesarios para que el prestamo este al dia hasta la fecha de la vents judicial.
Plan de Pago Un acuerdo temporal que permite el pago de la cantidad adeudada, cantidad del pago atrasado
junto con los pagos regulares de la hipoteca. Esto puede incluir principal, interes, honorarios y/o
costos aplicados a su prestamo.
Acuerdo Un acuerdo por el cual nos comprometemos a no proceder con la 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.
Modificac16n de Pagar el prestamo bajo los nuevos terminos acordados, que puede incluir la reduccibn de la tasa
Pr6stamo de interes, agregando la cantidad adeudada al final del prestamo, y/o extender el plazo del
(no por medio prestamo.
de HAMP)
Reclamo Parcial Si usted tiene un prestamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos esten
(solamente vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, este programa
prestamos de la est6 diseriado para que su prestamo este al dia mediante la creaci6n de una segunda hipoteca /
FHA) gravamen sobre su propiedad por la cantidad adeudada.
OpOones a considerar si no puede o no desea quedarse en su casa
fff:'s
g X*
Home Dilseiiado para ayudar a los prestatarios que son elegibles para el Programa de Home Affordable
Affordable Modification (HAMP), pero no tuvieron exito en obtener una modificaci6n permanente a traves del
Foreclosure programa. HAFA ofrece la posibilidad de una yenta corta y, si no tiene exito, una entrega de
Alternatives escritura para evitarjuicio hipotecario. Una venta corta es una transacci6n an la que usted vende su
Program propiedad por menos de la cantidad adeudada en el prestamo (sujeto a previo acuerdo de su
(HAFA) administrador / prestamista / inversionista), resultando en la liberaci6n de nuestro derecho de
retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una entrega de escritura para evitar
juilclo hipotecario es una transacci6n en la que usted este de acuerdo de transferir voluntariamente
las iescrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria.
Venta Corta/ So ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci6n de
Venta antes de hdgar. Con una venta corta, usted vende su propiedad por menos de la cantidad total adeudada en
Ejecucion el',prestamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultando en la
Hipotecaria (no liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitando la ejecuci6n hipotecaria.
por medio de
HAFA)
Entrega de So 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 traves de una yenta corta. Con una entrega de
Evitar Juicio escritura para evitar juicio hipotecario, usted este de acuerdo a transferir voluntariamente las
Hipotecario escrituras de su propiedad a nosotros para evitar la ejecuci6n hipotecaria.
(no por medio
de HAFA)
>Nstamos aqui para ayudarle. Por favor llamenos hoy.
UDREN LA W OFFICES, A C.
WOODCREST CORPORATE CENTER
MARK J. UDREN,' ESQUIRE 111 WOODCREST ROAD
NJ MANAGING ATTORNEY SUITE 200
CHERRY HILL, NEW JERSEY 08003-3620
856. 669. 5400
TINA MARIE RICH FAX.• 856. 669. 5399
OFFICE ADMIA'ISTRAMR
FREDDIE MAC
PENNSYLVANIA
DESIGNATED COE E
April 4, 2012
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
ARTICLE # 7011 2970 0004 1348 8463
Robert M. Fuller, Jr.
2550 Lambs Gap Rd.
Enola, PA 17025
RE: Mortgage Loan dated June 8, 2005
NOTICE OF INTENTION TO FORECLOSE
Dear Mortgagor:
The Mortgage serviced/held by Bank of America, N.A. (hereinafter
we, us or ours) on your property located at 2S50 Lambs Gap Rd . ,
Enola, PA 17025 IS IN SERIOUS DEFAULT because you have not made the
monthly payments of $1,321.90 for the months of May 1, 2011 through
November 1, 2011 and $1,505.32 for the months of December 1, 2011
through April 1, 2012.
The last assessed late charge on this account was $52.52 at a late
charge rate of 5$ for each delinquent payment(s). As of today,
late charges have accrued to the total amount of $157.56. Other
charges including Property Inspection Fees have accrued at the
total amount of $75.00. The total amount now required to cure this
default, or in other words, get caught up in your payments, as of
the date of this letter is $17,012.46.
You may cure this default within THIRTY (30) DAYS of the date of
this letter, by paying to us the above amount of $17,012.46, plus
any additional monthly payments and late charges which may fall due
during this period. Such payment must be made either by cash,
cashier's check, certified check or money order, and made to
UDREN LAW OFFICES, P.C.
WOODCREST CORPORATE CENTER
.111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NEW JERSEY 08003-3620
If you do not cure the default within THIRTY (30) DAYS, we intend
to exercise the lender's right to accelerate the mortgage payments.
This means that whatever is owing on the original amount borrowed
will be considered due immediately and you may lose the chance to
pay off the original mortgage in monthly installments.
If full payment of the amount of default is not made within. THIRTY
(30) DAYS, the lender also intends to instruct our firm to start a
lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff or
other similar official to pay off the mortgage debt. If you cure
the default before we begin legal proceedings against you, you will
still have to pay the reasonable attorney's fees actually incurred,
up to $54.00. However, if legal proceedings are started against
you, you will have to pay the reasonable attorney's fees even if
they are over $50.00. Any attorney's fees will be added to
whatever you owe the lender, which may also include our reasonable
costs. If you cure the default within the THIRTY (30) DAY period
you will not be required to pay attorney's fees.
The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
If you have not cured the default within the THIRTY (30) DAY period
and foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time up to one hour
before the Sheriff's or other similar official foreclosure sale.
You may do so by paying the total amount of the unpaid monthly
payments ',plus any late or other charges then due, as well as the
reasonable attorney's fees and costs connected with the foreclosure
sale and perform any other requirements under the mortgage. It is
estimated that the earliest date that such a Sheriff's or other
similar official's sale could be held would be approximately six
months from the date of this letter. A notice of the date of the
Sheriff's or similar official sale will be sent to you before the
sale. of course, the amount needed to cure the default will
increase the longer you wait. You may find out at any time exactly
what the required payment will be by calling us at the following
number: (856) 669-5400. This payment must be cash, cashier's
check, certified check or money order and made payable to us at the
address stated above.
You should realize that a Sheriff's or other similar official sale
will end your ownership of the mortgaged property and your right to
remain in it. If you continue to live in the property after the
Sheriff's or other similar official sale, a lawsuit could be
started to evict you.
You shall have the right to assert in the foreclosure proceedings,
the non-existence of a default or any other defense that you may
have to acceleration or foreclosure.
You have additional. rights to help protect your interest in the
property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY
TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER
LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT
TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER
OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL
THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE
PAID PRIOR TO OR AT THE SALE, AND THAT THE OTHER REQUIREMENTS UNDER
THE MORTGAGE ARE SATISFIED. CONTACT US TO DETERMINE UNDER WHAT
CIRCUMSTANCES THIS RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE
THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
if you cure the default, the
position as if no default
entitled to this right to CL
in any calendar year.
mortgage will be restored to the same
had occurred. However, you are not
.re your default more than three times
UDREN LAW OFFICES, P.C.
CC* First Class Mail
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify
us in writing of a dispute within the 30 day period, we will obtain verification of the debt or
a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not
an admission of liability on your part. Also, upon your written request within the 30 day
period, we will provide you with the name and address of the original creditor if different from
the current creditor.
If you notify us in writing within the 30 day period as stated above, we will. cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
(856) 669-5400
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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
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND County
v.
SHELLE)(W. FULLER
2550 LArV BS GAP ROAD
ENOLA, PA 17025
NO.
ROBERT M. FULLER, JR.
2550 LANV BS GAP ROAD
ENOLA, PA 17025
Defendant(s)
VERIFICATION
hereby states that he/ he is
Bank of America, N.A., Plaintiff in this matter, that
he he 's 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 nowledge,
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: AXA 16-11
Name:lAn
Title: ;?\ 5 YQ? ?? j 1 CQ pY?e? C?.YI??i pp
Company: bon . c.1, I A
MJU #: 12030162 CASE #: 12030162-1
FORM 1
bcX0- Ck- (-W)xO4110 ,() .
Plaintiff(s)
,j
S, ,V lIV kA
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wv_& o-). ?N'4Lda et(s)
IN THE COURT OF COMMON PLEAS C?F, :
CUMBERLAND COUNTY, PENNSYLVA%4
Civil >
r.^.
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, You must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation
Conference with the Court. which must be filed with the Court within sixty, (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to he
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
It
Date _ t r of Counsel for Plaintiff]
MARRY B. REESE, ESQUIRE
PA ID 310501
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORR WER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different)
City:
Phone Numbers
State: Zip:
Yes ? No ? Listing date: Price: $_
Realtor Phone:_
Yes ? No ?
Home:
Cell:
State: Zip:
Office:
Other:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
Office:
Other:
How, long?
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second! Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: S
Date of Last Payment:
Primary Reason for Default:
How long?
State: Zip:
Home:
Cell:
Included Taxes & Insurance:
Is the loan in Bankruptcy? Yes ? No ?
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ _ $_
Retirement Funds: $ _ $
Investments: $ $
Checking: S
Savings: $ $_
Other: $ $
Automobile #1: Model:
Amount owed: Value:
Automobile #2: Model:
Amount owed: Value:
Other transportation (automobiles. boats, motorcycles): Model:
Year: Amount owed: Value
Month Income
Name of Employers:
1.
Additional Income Description (not wages):
1. monthly amount:
? monthly. amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortva e Food
2" Mont acre Utilities
Car Payment(s) Condo/Nei h. Fees
Auto Insurance Med. (not covered)
4 Auto fiuel/repairs Other prop. payment
Install. Loan Payment Cable Tv'
1 Child S' ort/Alim. Spending Money
Da y/Chlild Care/Tuit. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes[-] No ?
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:_
Year:
Year:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company
to resolve your delinquency?
Yes ? No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Servicing Company (Name):
Contact: Phone:
Phone:
I/We. , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I,/We
understand that I/we ami'are under no obligation to use the services provided by the above
named
Borrower Signature
Date
Co-Borrower Signature Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
i
Past 2 bank statements
'Proof of any expected income for the last 45 days
V Copy of a current utility bill
t
N Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
y Listing agreement (if property is currently on the market)
3
FORM 3
t1 k O? Ny%(((n N` A • : IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
Plaintiff(s)
vs,
5?,1i? 11?e r .
Defendant(s) CIVIL
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated . 2012 governing the Cumberland
Countv Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
?. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
Signature of Defendant's Counsel/Appointed
Legal Representative
Signature of Defendant
Signature of Defendant
Date
Date
Date
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID#45362 _
Con
D 9 F
LORRAI INE GAZZARA DOYLE ESQUIRE - ID#34576
ALAN M . MINATO, ESQUIRE - ID#75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675
SALVA TORE CAROLLO, ESQUIRE - ID#311050
PAIGE M. BELLING, ESQUIRE - ID#309091
HARRY B. REESE, ESQUIRE - ID#310501
AMY G LASS, ESQUIRE - ID#308367
KASSIA FIALKOFF, ESQUIRE - ID#310530
ELIZAB ETH L. WASSALL, ESQUIRE - ID#77788
AGNES MOMBRUN, ESQUIRE - ID#309356
WOODC REST CORPORATE CENTER
111 W6 0DCREST ROAD, SUITE 200
CHERR Y HILL, NJ 08003-3620
856-66%- 5400 leadin2sna.udren.com
Bank of America, N.A. COURT OF COMMON PLEAS
16001 North Dallas Parkway, Addison, TX 75006 CIVIL DIVISION
Plaintiff CUMBERLAND County
V.
SHELLEY W. FULLER
2550 LAMBS GAP ROAD
ENOLA, PA 17025
NO
ROBERT M. FULLER, JR.
2550 LAMBS GAP ROAD
ENOLA, PA 17025
Defendant(s)
TO THE PROTHONOTARY:
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.
UDREN LAW OFFICES, P.C.
BY
ARRY B. REESE, ESQUIRE
PA ID 310501
SHERIFF'S OFFICE OF CUMBERLAND
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Bank of America, NA
vs.
Shelley W. Fuller (et al.)
?r of C11111b,",
COUNTY?-
?. co ?
Case Number
2012-3416
SHERIFF'S RETURN OF SERVICE
06/14/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Shelley W. Fuller, but was unable to locate her in his
bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential
Mortgage Foreclosure Diversion Program as not found as to the defendant Shelley W. Fuller. Request for
service at 2550 Lambs Gap Road, Enola, Pennsylvania 17025 the Defendant was not found. Robert
Fuller advised Deputies Shelly W. Fuller is thought to be residing in Lebanon County, Pennsylvania.
06/14/2012 08:25 AM - Jason Vioral, Sergeant, Deputy Sheriff, who being duly sworn according to law, states that on
June 14, 2012 at 0825 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:
Robert Martin Fuller, Jr., by making known unto himself personally, at The Cumberland County Sheriffs
Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents
and at the same time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $94.00
June 14, 2012
JASO IORA , DEPUTY
SO A ERS,
RON R ANDERSON, SHERIFF
»ou- jai r. She -f T i. soft. L,;:
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Bank of America, NA
vs.
Shelley W. Fuller (et al.)
h
.._ ,
OU;CE OF THE S"ERIFF
2111 Z 0 C T 16 AM 9: C 4
PE-NNSYL'VANIA
Case Number
2012-3416
SHERIFF'S RETURN OF SERVICE
09/20/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Shelley W. Fuller, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Lancaster County, Pennsylvania to serve the within
Complaint In Mortgage Foreclosure according to law.
09/26/2012 02:12 PM - Lancaster County Return: And now September 26, 2012 at 1412 hours I, Mark Reese, Sheriff
of Lancaster County, Pennsylvania, do hereby certify and return that I served a true copy of the within
Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Shelley W. Fuller by
making known unto herself personally, at 785 Eastside Drive, Landisville, Pennsylvania 17538 its
contents and at the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $37.00
October 09, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
ic) CountySuite Sheriff, Teleosoft. Inc.
SHERIFF'S OFFICE
jIq
50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA, 17608-3480 - (717) 299-8200
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT of RETURN
%
1. PLAINTIFF/S/ 2. COURT DOCKET NUMBER
Bank of America, NA 12-3416-CIVIL
3. DEFENDANT/S/ 4. TYPE OF DOCUMENT TO BE SERVED
Shelley W. Fuller Complaint in Mortgage Foreclosure
SERVE 5. NAME OF INDIVIDUAL COMPANY CORPORATION ETC. TO BE SERVED
Shelley W. Fuller
3
'I 6. ADDRESS (Street or RFD, Apartment No., City, Boro, Tw ., State and ZIP Code) 00
AT 1785 EASTSIDE DRIVE, LANDISVILLE, PA 17538-1516 n
it
Now, 20,1 SHERIFF OF LANCASTER COUNTY, PA., do hereby deputize the Sheriff of N
County to execute the writ and make return thereof according to law. This deputation being Made at the M
request and risk of the plaintiff Sheriff of Lancaster County
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
From Cumberland County
'LEASE ATTEMPT SERVICE AT LEAST 3 TIMES
,
NOTE ONLY APPLICABLE ON rr OF EXECUTION: N9. WAIVER OF WATCHMAN - Any deputy shMff levying upon or attaching any property under within writ may leave same without a watchman, in custody of
whomever is found in possession, aftler notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriffs
sale thereof.
9. SIGNATURE OF ATTORNEY OR OTHER ORIGINATOR Print Name 10. TELEPHONE NUMBER 11. DATE
Udren Law Office -11856-669-5400 Aug 23, 2012
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW:(This area must be completed if notice is to be mailed)
Udren Law Office Woodcrest Corporate Center 111 Woodcrest Road, Cherry Hill, NJ 08003
13.1 acknowledge receipt of the writ NAME of authorized LCSO Deputy or Clerk 14. Date Received 15. Expiration/Hearing Date
or complaint as indicated above Yvette Turco 717 723-4519 0912411 2 10119112
16.1 Hereby CERTIFY and RETURN that I have personally served, I have legal evidence a service as shown in "Remarks", have executed as
shown in "Remarks", the writ or complaint scr bed on the individual, company, corporation, etc., at the address shown above or on the individual,
18. Name
not
to
19. f- No Service See Remarks Below
20. Address of where served (Complete only it different than shown above)(Street or RFD, Apartment No., City, 21. Date of Service 22. Time AM /
Boro, TWP, State and ZIP Code) EST/ S.
23. Attempts Date Miles Dep. Int Date Miles Dep. int Date Miles Dep. Int Date Miles Dep. Int Date Miles Dep. Int
24. Advance Costs 25. Service Costs 26. Notary Costs 27. Mileage/Postage/N.F 28. Total Costs 29. COST DUE OR REFUND
I1041Z $150 $36.50 Oar) t0S'73
R
30. RemarKs:
CL
S.T.A.. i I S 2 -`?
o(a ?- 12--
31. AFFIRMED and subscribed to before me this SO ANSWER.
v1 Z
34. day of 20 32. Si e ofd[ ep. 5h?iff - 33.Da1'q
37• 35. Signature of Sheriff 36. IMW
Prothohotary/Deputy/Norary Public `'t
MY COMMISSION EXPIRES MARK S. E, SHERIFF OF LANCASTER COUNTY PA
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400 n N rt
pleadings ,,udren.com -v3 ° z
COURT OF COMMON PLEAS rn o 3G rn r-..:
Bank of America N.A. CIVIL DIVISION Zr�
' Cumberland County y,
Plaintiff <3> -" °
r =-n
V. MORTGAGE FORECLOSURE v° Z i
SHELLEY W.FULLER,ROBERT M.FULLER,JR., z c o cin
Defendant(s) T,►z _ 2,
NO. 12-3416-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), SHELLEY W.FULLER,ROBERT M.FULLER,JR.,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".
The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in
active military service because Plaintiff cannot provide date(s)of birth and/or Social Security number(s) for said
Defendant(s)to enable a search.
This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Dated: April 10,2013
Attorney for Plaintiff
SALVATORE CAROL.LO, ESQUIRE
PA ID 311050
MJU#: 12030162 CASE#: 12030162-1
Department of Defense Manpower Data Center Results as of:Apr-10-201307:58:26
SCRA 3.0
40 ftmuwt s7iiMs Rapwt
to SIerviceme fibers Civil Relief Act
Last Name: FULLER, JR.
First Name: ROBERT
Middle Name: M
Active Duty Status As Of: Apr-10-2013
A�eDufgiJ�ts.�e Eva-�uQ1�M,0ati f ' ';.
,..
NA NA NA
This response rsfled•dAi ♦r+diiAivais'active dilly et�lw based on 144° iflils ,Status Date
Yas`ttis
naUvartwgr&4ttltls .�9r 8raius ,+ 8a[fNmsmsaggaatN
ti
NA NA
r
This response reflects wd ft**WMdual left acditii1''- WIIrYsSDB'#days pre=drg the:As31veR1uly status Date
8larttlaie'.' ''1�tNi)a1e { s
NA ;>_ # NA
This response reflects wM",the unh has Nl,,L j tD report for active duty
Upon searching the data banks of the Department of Defense Manpower t9�tweed 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 Servioemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http://www.defenselink.miVfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
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 for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 12D791 D8W03AJE0
Department of Defense Manpower Data Center Results as of:Apr-10-2013 08:00:00
SCRA 3.0
lbSato Repint
Pmt to Services Civil Relief Act
Last Name: FULLER
First Name: SHELLEY
Middle Name: W
Active Duty Status As Of: Apr-10-2013
� �ftAdwri'OWjrreelroale�ates.
Actlm.73rgyr[QMM °8�.w.
NA NA t.'S1AiD.;: NA
This response refit ":Is,ec&*duty MUM based on th; :Status Date
AdhreOWy$W"lltls , k4V;a MONO 81tIYrs 9arrise€�Soepaaaat
NA '.IA #ki NA ..
This response re8ecb wMMU kdivitlual left aclhs dtYy iffdeys WOOK+p M Jiic6m uty status Date
Ordeffilesicallm f!w)rferaber ar�r- rtrrt#w
S3rtDals t7ntGrble7rllimAt�sia sisal. 8arwimsUesepeaent ,
NA NA
This response rellects whelMr tl»'ipS9lridui drJlialter unit rus tD repot for acdve duty
Upon searching the data banks of the Department of Defense Manpower-tr;based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
rj
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 Servicamembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mii"URL:http://www.defenselink.miVfaq/pis/PCOgSLDR.htmi. if you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
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 histher 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. Ali Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAH Commissioned 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 far all the Unifomred 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.Perms 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 repot for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: S21931 F8UO3AJ50
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
Bank of America,N.A. COURT OF COMMON PLEAS
16001 North Dallas Parkway CIVIL DIVISION
Addison,TX 75006 Cumberland County
Plaintiff
V. MORTGAGE FORECLOSURE
SHELLEY W. FULLER
785 EASTSIDE DRIVE r -n
LANDISVILLE,PA 17538-1516 NO. 12-3416-CIVIL .,o: w =-n
r
n r^r-
-orn
ROBERT M. FULLER,JR. ter- o=
2550 LAMBS GAP ROAD
ENOLA, PA 17025 < z• o-n
Defendant(s) $ or'
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), SHELLEY W.FULLER;
ROBERT M.FULLER,JR.; 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 $164,212.71
Interest Per Complaint $10,770.82
Additional Interest 05/23/2012 04/05/2013 $8,203.89
Late Charges Per Complaint $157.56
Additional Late Charges 05/23/2012 04/05/2013 $525.20
Escrow Per Complaint $3,415.14
Title Report $325.00
Attorney Fees-Estimated $1,300.00
Property Inspections $90.00
Grand Total $189,000.32
I hereby certify that(1)the addresses of the Plaintiff and Defendant are as shown above, and(2)that notice has been
given in accordance with Rule 237.1, a copy of which is attached hereto.
UDREN L FFICES,P.C.
B
ttorney for Plaintiff
,IALVATORE CAROLLO, ESQUIRE
DAMAGES ARE REBY ASSESSED AS INDICATED
DATE: q11f7_1.
PROP n
MJU#: 12030162 CASE#: 12030162-1 �'��•SO ""'7
�2�a8 s q43
i„1:. Mn. 43..1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE: CHAPTER 13
Mary Elizabeth Fuller
aka Mary E Fuller CASE NO. 5:12-bk-01557-RNO
fka Mary Elizabeth Jones
fka Mary E Jones,
Debtor(s)
FCI Lender Services, Inc. as Servicer for
New American Funding Group,
Movant,
vs.
Mary Elizabeth Fuller aka Mary E Filler fka
Mary Elizabeth Jones fka Mary E Jones,
Debtor(s)/Respondent(s),
and
Charles J. DeHart, III,
Trustee/Respondent.
ORDER GRANTING MOTION FOR RELIEF FROM AUTOMATIC STAY
Upon consideration of the motion of FCI Lender Services,Inc.as Servicer for New American
Funding Group for Relief from the Automatic Stay, it is hereby
ORDERED AND DECREED THAT: The Automatic Stay of all proceedings, as provided
under I I U.S.C. § 362, is modified with respect to premises:
255 North Pennsylvania Avenue
Wilkes Barre,PA 18702
as to allow the Movant to foreclose on its Mortgage and allow the purchaser of said premises at
Sheriffs Sale (or purchaser's assignee) to take any legal action for enforcement of its right to
possession of said premises; and it is further
ORDERED THAT: The relief granted by this Order shall survive the conversion of this
bankruptcy case to a case under any other Chapter of the Bankruptcy Code.
Dated: September 26, 2012
By the Court,
Robert N.Opel,R,Bankruptcy Judge
Case 5:12-bk-01557-RNO Doc 27 Filed 09/26/12 Entered 09/27/12 07:44`3" Desc
Main Document Page 1 of 1
Notice Recipients
District/Off:0314-5 User:DBuffmgt Date Created:9/27/2012
Case:5:12—bk-01557—RNO Form ID:pdftl 10 Total:4
Recipients of Notice of Electronic Filing:
tr Charles J.DeHart,III(Trustee) dehartstaff @pamdl3uwtee.com
aty Jason Paul Provinzano MyLawyer @JPPLaw.com
aty Paige Marie Bellino ppronovost @udren.com
TOTAL:3
Recipients submitted to the BNC(Bankruptcy Noticing Center):
db Mary Elizabeth Fuller 255 N.Pennsylvania Avenue Wilkes—Barre,PA 18702
TOTAL: 1
Case 5:12-bk-01557-RNO Doc 27-1 Filed 09/26/12 Entered 09/27/1207:44:37 Desc
PDF -All Chatty: Notice Recipients Page 1 of 1
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 , w«.
SALVATORE CAROLLO,ESQUIRE -ID#311050 - Y ::
PAIGE M.BELLINO,ESQUIRE -ID#309091 -<> r
HARRY B.REESE,ESQUIRE- ID#310501 c nr=
AMY GLASS,ESQUIRE -ID#308367
KASSIA FIALKOFF,ESQUIRE -ID#310530 '
ELIZABETH L.WASSALL,ESQUIRE -ID#77788 r -=
-ID#309356 AGNES MOMBRUN ESQUIRE U
:WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003.3620
856-669-5400 pleadings @udren,com
Bank of America,N.A. COURT OF COMMON PLEAS
C/O Bank of America, N.A.,as successor by merger G CIVIL DIVISION
to BAC Home Loans Servicing,LP CUMBERLAND County
16001 North Dallas Parkway
Addison,TX 75006 �H
Plaintiff NO. `a V.
SHELLEY W.FULLER
2550 LAMBS GAP ROAD
ENOLA,PA 17025
ROBERT M.FULLER,JR.
2550 LAMBS GAP ROAD
ENOLA,PA 17025
Defendant(s) I
COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth, against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
--�. '7,r,-4.A 1 1 n 7 ..I
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 �'
�Ca CJ r�•.
SALVATORE CAROLLO,ESQUIRE-ID#311050 � �.
PAIGE M. BELLINO,ESQUIRE-ID#309091
HARRY B.REESE,ESQUIRE-ID#310501
AMY GLASS,ESQUIRE-ID#308367
KASSIA FIALKOFF,ESQUIRE-ID#310530
ELIZABETH L.WASSALL,ESQUIRE -ID#77788
AGNES MOMBRUN,ESQUIRE-ID#309356
W OODCREST.CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620.__
Bank of America,N.A. COURT OF COMMON PLEAS
16001 North Dallas Parkway,Addison,TX 75006 i CIVIL DIVISION
Plaintiff CUMBERLAND County
V.
SHELLEY W.FULLER
2550 LAMBS GAP ROAD NO.
ENOLA,PA 17025
i
ROBERT M.FULLER,JR.
2550 LAMBS GAP ROAD
ENOLA,PA 17025
Defendants)
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
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 Fia.lkoff, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall,
Esquire; Agnes Mombrun, Esquire; on behalf of the Plaintiff, in the above-captioned
matter.
UDREN LAW OFFICES,P.C.
BY A AA2�--
kARMYS. REESE, ESQUIRE
PA ID 310501
tjq
SHERIFFS OFFICE
50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA, 17608-3480 -(717)299-8200
SHERIFF SERVICE PLEASEMA St1 E FORK ftINTS
PROCESS RECEIPT,and AFFIDAVIT of RETURN
1. PLAINTIFF/S/ 2. COURT DOCKET NUMBER
,Bank of America,NA 112-3416-CIVIL
3. DEFENDANT/S/ 4. TYPE OF DOCUMENT TO BE SERVED
!Shelleyw.Fuller IComplalnt in Mortgage Foreclosure
SERVE 5. NAME OF iNDMDUAL COMPANY,CORPORATION,ETC,TO BE SERVED
no* r-
!Shelley W.Fuller
6. ADDRESS(Street or RFD,Apartment No„City,Boro,Twp„State and ZIP Code)
AT
)785 EASTSIDE DRIVE,LANDISVILLE,PA 17538-1516
7-IN -4;FRMCF-- I DEPUTIZE i OTHER G
Now, 20 .1 SHERIFF OF LANCASTER COUNTY,PA.,do hereby deputize the Sherrff of
County to execute the writ and make return thereof according to law. This deputation being made at the
request and risk of the plaintiff Sheriff of Lancaster County
8.SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIS-TJ-N;EXPEOMNG SERVICE:
; From Cumberland County
!PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES
!
NOTE ONLY APPUCUU ON WNT OF E MCUTKK-OLa.WANER OF WATCHMAN-Any deputy shedM kvylo4 upon or atu d"any property underwltk n writ may kave same witltart a watchman,in custody of
whomever It found in postession.afetr not6"person of anyoratutixnen4wRhout Nab*ty on the part of such deputyorthe shedM to any WAhWff herein foranyimdearuction or rernm at of any such property before sherif s
sal @thereof.
9.SIGNATURE OF ATTORNEY OR OTHER ORIGINATOR print Name 10.TELEPHONE NUMBER 11.DATE
Wren Law Office 1856-669-5400 jAug 23,2012
12.SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW.-(This area must be completed if notice is to be mailed)
IUdren Law Office Woodcrest Corporate Center 111 Woodcrest Road,Cherry Hill,N.!08003
::ifi _ ° •,,4 .J
13.1 acknowledge receipt of the writ NAME of authorized LCSO Deputy or Clerk 14.Date Received 1 S.Expiration/Hearing Date
or complaint as indicated above Yvette Turco 717 723-4519 +09124112 1011912
r 16,1 Hereli7y CER11P an3 RETURN that 1 have personally served, have legal evf have executed as
shownin-"Remarks";the writ or complaint scribed-ornhe-individual;company,corporation,etc;atthe-addrest shown•above-or on the individual;--..........
~~-
camoan
17. e rern a u am na to c a in ua om an ,corporation,etc.,named above.
18.Name and title of individual Served(if not shown above)(Relationship to Defendant)
19, i= No Service See Remarks Below
20. Address of where served(Complete only it different than shown above)(Street of.RFD,Apartment No., City, 21.Date of Service 22,Time AM/
Boro,TWP,State and ZIP Code)
23.Attempts Date Miles Dep.Int Date Miles Dep.Int Date Miles Dep,Int Date Miles Dep.int Date Miles Dep.int
24.Advance Costs 25.Service Costs 26. Notary Costs 27.Mileage/Postage/N.F 2B.Total Costs 29.COST DUE OR REFUND
R#t. -72: $1501 $36.50
30.Remarks:
S.T.A.:
31.AFFIRMED and subscribed to before me this SO ANSWER. .
34,day of 20
32 SlgDaUqe of p-_S 33.Daie
37. 35.Signature of Sheriff 36.le
Prothonomry/Deputy/Norary Public i
MY COMMISSION EXPIRES MARK S.PESE, SHERIFF OF LANCASTER COUNTY PA
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
ya.��►itr at�+a6c���G
Jody S Smith
Chief Deputy"
Richard W Stewart
Solicitor OFFICE OF THE SKSRirr-
Bank of America, NA
VS. Case Number
Shelley W. Fuller(et al.) 2012"3416
SHERIFF'S RETURN OF SERVICE
06/14/2012 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Shelley W. Fuller, but was unable to locate her in his
bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential
Mortgage Foreclosure Diversion Program as not found as to the defendant Shelley W. Fuller. Request for
service at 2550 Lambs Gap Road, Enola, Pennsylvania 17025 the Defendant was not found. Robert
Fuller advised Deputies Shelly W. Fuller is thought to be residing'In Lebanon County,Pennsylvania.
06/14/2012 08:25 AM-Jason Vioral, Sergeant, Deputy Sheriff,who being duly sworn according to law, states that on
June 14, 2012 at 0825 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:
Robert Martin Fuller, Jr.,by making known unto himself,personally, at The Cumberland County Sheriffs
Office, 1 Courthouse Square,Room 303,Carlisle, Cumberland County, Pennsylvania 17013 its contents
and at the same time handing to him personally the said true and correct copy of the same.
JASO IORA , DEPUTY
SHERIFF COST: $94.00 SO A RS,
June 14, 2012 RbNZI R ANDERSON, SHERIFF
iM Comt4WG Shwff.reiaosoN Inc.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400 _
Bank of America,N.A. �i COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
Cumberland County
V.
ROBERT M.FULLER,JR.,SHELLEY
W. FULLER MORTGAGE FORECLOSURE
Defendant(s) j NO. 12-3416-CIVIL
TO: ROBERT M.FULLER,JR.
2550 LAMBS GAP ROAD
ENOLA,PA 17025
Date of Notice: November 28, 2012
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND LOSE YOUR PROPERTY YOUR LAWYER AT
OR OTHER IMPORTANT RIGHTS-YOU SHOULD TAKE THIS PAPER
ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800) 990-9108
i
G
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO
DE UN TERMINO DE DIEZ(10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA,
DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS
DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO
IMMEDIATAMENTE Sl USTED NO TIENE ABOGAD DINERO E OF C1NAI NTT
PARA TAL SERVICIO,VAYA EN PERSONA O LLAM POR TELEFONO CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
UDREN LAW OFFICES, PC.
BY: _..._
Attorney for Plaintiff
KASSIA FIALKOFF, ESQUIRE
PA ID 310530
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill,New Jersey 08003-3620
MJU#: 12030162 CASE#: 12030162-1
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,N3 08003-3620
856-669-5400 ---
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
ROBERT M. FULLER,JR., SHELLEY
W.FULLER MORTGAGE FORECLOSURE
Defendant(s) NO. 12-3416-CIVIL
TO: SHELLEY W.FULLER
785 EASTSIDE DRIVE
LANDISVILLE,PA 17538-1516
Date of Notice: November 28,2012
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU
ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY
OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION
REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO
DE UN TERMINO DE DIEZ(10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN
NECESIDAD DE COMPARA.RECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA,
DICTAR SENTENCIA EN SU CONTRA,USTED PUEDE PERDER BIENES Y OTROS
DERECHOS, WORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO
IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,O SI NO TIENE DINERO SUFICIENTE
PARA TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA, CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASSISTENCIA LEGAL.
SERVICIO DE REFERENCIA LEGAL
Cumberland County Bar Association
2 Liberty Avenue
Carlisle,PA 17013
(800)990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT.ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
UDREN LAW OFFICES,PC.
BY:
Attorney for Plaintiff
KASSIA FIALKOFF, ESQUIRE
PA ID 310530
Woodcrest Corporate Center
111 Wooderest Road, Suite 200
Cherry Hill,New Jersey 08003-3620
MJU#: 12030162 CASE#: 12030162-1,
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
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County €.�
Shelley W. Fuller MORTGAGE FORECLOSURE Mm
Robert M. Fuller,Jr.
�„r- C)
x,
Defendant(s) NO. 12-3416-CIVIL c
T.>:c-�
�, Q
PRAECIPE TO ISSUE WRIT OF EXECUTION
'`
L " .
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount due $.1894000.32,
Interest From 4/6/2013 $ 3,921.35 w
to Date of Sale September 4,2013 '
Ongoing Per Diem of$25.7984
to actual date of sale including if sale is w C)
held at a later date
(Costs to be added) $ ' t' )r=
ter°
P-1)
UDREN LAW OFFICES, P.C.
B A
n ntif
Jordan David, Esquire
OMJU#: 12030162 CASE#: 12030162-1
av� 011,
q Lt . 0& CA6
u �
�7. 0o << „
socc.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-3416 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 SHELLEY W. FULLER,ROBERT M.FULLER,JR.
(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: $189,000.32 L.L.:$.50
Interest FROM 4/6/2013 TO DATE OF SALE SEPTEMBER 4,2013 ONGOING PER DIEM OF
$25.7984 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE-
$3,921.35
Atty's Comm: Due Prothy: $2.25
Atty Paid: $291.50 Other Costs:
Plaintiff Paid:
Date: 5/23/13
David D. Buell, Prothonota
'(Seal)
_ Deputy
.REQUESTING PARTY:
Namc:JORDAN DAVID,ESQUIRE
Address:UDREN LAW OFFICES,P.C.
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
Attorney for: PLAINTIFF
Telephone: 856-669-5400
Supreme Court ID No.311968
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCRES.T CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200 x
CHERRY HILL,NJ 08003-3620
856-669-5400
leadin s udren.com
Bank of America,N.A. COURT OF COMMON PLEAS-
co
rn
Plaintiff CIVIL DIVISION fir
V. Cumberland County ;
Shelley W.Fuller MORTGAGE FORECLOSURE ,C-,
Robert M. Fuller,Jr. °�
Defendant(s) N0. 12-3416-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
II Premises is not subject to the provisions of Act 91
as this is an FHA insured mortgage
This statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
UDREN LAW OFFICES, P.C.
B
Attorne for Plaintiff
Jordan David, Esquire
,,,rUDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
III WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
P1 adin2s(a-)udren.com C)
Bank of America,N.A. COURT OF COMMON PLEAS C=
Plaintiff CIVIL DIVISION rT1
V. Cumberland County
Shelley W. Fullers na �*
C
Robert M. Fuller,Jr. MORTGAGE FORECLOSURE CA)
Defendant(s) :top C3-1�
NO. 12-3416-CIVIL C=
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:
2550 Lambs Gap Road,Enola,PA 17025
1.Name and address of Owner(s) or reputed Owner(s):
Shelley W. Fuller
785 Eastside Drive
Landisville, PA 17538-1516
Robert M. Fuller,Jr.
2550 Lambs Gap Road
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
Shelley W.Fuller
785 Eastside Drive
Landisville, PA 17538-1516
Robert M. Fuller,Jr.
2550 Lambs Gap Road
Enola,PA 17025
3.Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Jr Lien Holders -None
4. Name and address of the last recorded holder of every mortgage of record:
Bank of America,N.A.
16001 North Dallas Parkway
Addison,TX 75006
Sr Mortgage Holders-None
Jr Mortgage Holders -None
.r
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
2550 Lambs Gap Road
Enola,PA 17025
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 OFFICES, P.C.-
BY.
Attorne for Pl ff
aiin i
MJU#: 12030162 CASE#: 12030162-1 Jordan David, Esquire
fi
1
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
Ill WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
pleadings&udren.coin .-
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
V. Cumberland County
c:7 C:)
ROBERT M.FULLER,JR., SHELLEY W. MORTGAGE FORECLOSURE c-) G)
FULLER ? _4
Defendant(s) ^
NO. 12-3416-CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Robert M. Fuller,Jr.
2550 Lambs Gap Road
Enola,PA 17025
Your house (real estate) at 2550 Lambs Gap Road,Enola, PA 17025 is scheduled to be sold at
the Sheriffs Sale on Septenber 4, 2013 at 10:00am at the Cumberland County Courthouse,
Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment
of$189,000.32, 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.)
1
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
Bank of America,N.A. COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff Cumberland County Cz
n Co
V. r arm
SHELLEY W. FULLER; NO. 12-3416-CIVIL '
ROBERT M. FULLER JR.; et al
Defendant(s) � CD
..>C q
PRAECIPE TO FILE PROOF OF SERVICE � c �7
-< co
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter.
Dater ��� �
UDREN LAW OFFICES,P.C.
BY:
Atto y for/—lainti HARRY QUIRE
s
Bank of`Atncrica,NA,et.al.,Plaintiff Service of Process by
Plaintiffs) Service—__
VS• '�., APS International, Ltd.
Shelley W.Fuller,et.al.,Defendant(s) _ 1-800-328-7171
APS International Plaza
7800 Clenroy Road
Minneapolis,MN 55439-3122
APS File#: 124378-0001
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
{ UDREN LAW OFFICES I --Robert M.Fuller,Jr.
Ms.Henni Crommartv. Court Case No.Cumberland Co 12-3416-Civil
1 t l Woodcrest Rd.,Ste.200
iCherry Hill,NJ 08003-3620
Customer File: N12030162-1 – —
State of: tb.��/C°/�Ql�. )ss. - -- - - - _- - - - - - -- - -- - - - - - - - - - - - -
County of-
Name of Server: � ���o.Pf«, undersigned,being duly sworn, deposes and says
that at all times mentioned herein, s/he was of legal age and was not a party to this action;
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriffs Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Robert M.Fuller,Jr.
and after due and diligent efforts,was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Dates/Time/Address Attempted: 3004 S.Xeric Court,Denver,CO 80231
Reason for Non-Service: —�1��(��
Datesfrime/Address Attempted:
Reason for Non-Service:
Dates(rime/Address Attempted:
Reason for Non-Service:
Based upon the above stated facts,Affiant believes the defendant is avoiding service.
Signature of Server: Undersigned declares under penalty of perjury Subscribed and sworn to before me this
that the foregoing i .true and correct. y of — .20 J
Signature of Server Notary Public (Commission Expires)
APS International, Ltd.
SHER
4Q:'NpTAR Y
PUBO
���OF.
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION c-) c__
CUMBERLAND County -
v m
V.
Shelley W. Fuller; F - 1� :
Robert M. Fuller,Jr. NO. 12-3416-CIVIL -cb o gc1'
Defendant(s) <a
> —
a
3,C yp C7
MOTION FOR SPECIAL SERVICE PURSUANT
TO SPECIAL ORDER OF COURT
Plaintiff, by its counsel, moves this Honorable Court for an Order directing service of the
Notice of Sale upon Defendant(s):
ROBERT M. FULLER,JR.,
by regular mail and certified mail, and by posting the mortgaged premises and in support thereof
avers the following:
1. Process was unable to be served at the then last known address of said Defendant(s) as
follows:
ROBERT M. FULLER,JR.
2550 LAMBS GAP ROAD
ENOLA, PA 17025
A copy of the Return of Service is attached hereto as Exhibit"A".
2. Process was unable to be served at the then last known address of said Defendant(s) as
follows:
ROBERT M. FULLER, JR.
3004 S. XERIC COURT
DENVER, CO 80231
A copy of the Return of Service is attached hereto as Exhibit `B".
•
3. Pursuant to Pa.R.C.P. 430, Plaintiff made a Good Faith Investigation, the report
thereof being attached hereto as Exhibit"C".
4. Said investigation was unable to determine an alternate address for said Defendant(s).
5. Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or
information. A copy of the Postal Search results is attached hereto as Exhibit"D".
6. The last known address of Defendant(s) is as set forth in the attached Exhibits.
WHEREFORE, Plaintiff prays and respectfully requests that this Honorable Court enter
an Order pursuant to Pa.R.C.P. 430 directing service of the Notice of Sale upon said in paragraph
1, by regular mail and certified mail, and by posting the mortgaged premises.
UDREN LAW OFFICES, P.C.
BY:
Atto s vPlain i f
HARRY B. REESE, QUIRE
PA ID 310501
SHERIFF'S OFFICE OF CUMBERLAND COUNTY \)-,
Ronny R Anderson
Sheriff 4a Ate of)CttmGry
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor critFiceoFTK SK RIFF
Bank of America, N.A. Case Number
vs.
Shelley W. Fuller(et al.) 2012-3416
SHERIFF'S RETURN OF SERVICE
05/30/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant,to wit: Shelly W. Fuller, but was unable to locate the Defendant in
his bailiwick. He therefore deputized the Sheriff of Lancaster County to serve the within Real Estate Writ,
Notice and Description, in the above titled action,according to law.
06/25/2013 08:35 PM-Deputy Noah Cline, 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 2550 Lambs Gap Road, Hampden Township,Enola, PA
17025, Cumberland County.
07/12/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Lancaster County upon Shelley W. Fuller, personally,at 785 Eastside Drive, Landisville, PA 17538. So
Answers: Melissa Heim, Deputy Sheriff.
07/16/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant,to wit: Robert Martin Fuller,Jr., but was unable to locate the
Defendant in his bailiwick.He therefore returns the within Real Estate Writ, Notice and Description, in the
above titled action, as"Not Found"at 2550 Lambs Gap Road, Enola, PA 17025, property vacant, mail is
still delivered there per post office.
SHERIFF COST:$1,009.57 SO ANSWERS,
July 16, 2013 RONR ANDERSON, SHERIFF
FXHIBITA
(c)ceuntysuite Sheaf,Telsoson,Inc.
Bank of America,NA,et.al..Plaintiff(s) Service of Process by
vs. APS International, Ltd.
Shelley W. Fuller,et.al.,Defendsnt(s) � 1-800-328-717I
OSESSIZZI APS International Plaza
r 7800 Glcnroy Road
_�' Minneapolis,MN 55439-3122
APS File#; 124378-0001
AFFIDAVIT OF DUE AND DILIGENT ATTEMPT
Service of Process on:
UU12EN LAW OFFICES --Robert M.Fuller.Jr.
Ms.Nonni Crommarty Court Case No.Cumberland Co 12-3416-Civil
1 1 1 Woodcrest Rd..Ste.200
Cherry Hill.NJ 0 80 03-3 62 0
j Customer File: N12030162-1 J
State of: C.407/el - - - - • -
�f �/ C�
County of: A ,/1/ /f. )
Name of Server: r' � j %��� ,undersigned, being duly sworn,deposes and says
that at all times mentioned herein,s/he was of legal age and was not a party to this action:
Documents Served: the undersigned attempted to serve the documents described as:
Notice of Sheriffs Sale of Real Property
Service of Process on: The undersigned attempted to serve the documents on
Robert M.Fuller,Jr.
and after due and diligent efforts.was unable to effect service.
Attempts: The following is a list of the attempts made to effect service:
Datesfrale/Address Attempted:
3004 S.Xeric Court,Denver,CO 80231 �� /5°� U//3f"..
Reason for Non-Service:
DatesrTimc/Address Attempted:
Reason for Non-Service:
Dams/rime/Address Attempted: - •
Reason for\•on-Service:
Based upon the above stated facts,Affiant believes the defendant is avoiding service.
Signature of Server. "Undersigned declares under penalty of perjury Subscribed and sworn to before me this
that the foregoin i true and correct. ` 0:y of 20
Signature of Server - Notary Publ• % (Commission Expires)
APS International,Ltd. ,°`�t•`'.H �, ' ,'' / ��� ��
aol'AR y %.
\ PUBIAG‘o)::
EXHIBIT B
Commonwealth County of Cumberland Court of Common Pleas
Of Pennsylvania Civil Division
Plaintiffs)
Bank of America, NA
vs
Defendant(s)
Robert M. Fuller,Jr.
AFFIDAVIT OF DILIGENT SEARCH AND INQUIRY
I, Abigail Sessions, do hereby swear and affirm that I made the following diligent
search and inquiry on defendant, Robert M. Fuller,Jr.:
1. On July 19, 2013, I conducted a Skip Trace,the results of which indicated the
defendant's current residence is 3004 S.Xeric Court, Denver, CO, 80231.
2. On July 19, 2013, I conducted an Internet search for the Death Records of the
Defendant,the results of which indicated that the defendant is not deceased.
3. On July 19, 2013, I conducted an Internet search for the Voter Registration
Records of the Defendant,the results of which indicated that the defendant is a
registered voter at the address of 2550 Lambs Gap Road, Enola, PA, 17025.
4. On July 19, 2013, I conducted an Internet search for the Motor Vehicle Records
of the Defendant,with no results obtained from the search.
5. On July 19,2013, I conducted an Internet search of Facebook,Twitter,Yahoo!,
Google and Bing with whitepages.com indicating that the defendant is currently
residing in Denver, CO.
6. On July 19, 2013 at 7:25pm I placed a phone call to defendant's neighbor,Debbie
Vonderherd(303-695-8916),of 3001 S.Xeric Court, Denver, CO, 80231 to
inquire about defendant's last known address. There was no answer.
7. On July 19, 2013 at 7:26pm I placed a phone call to defendant's neighbor,C.O.
Bakken(303-755-1429), of 3000 S. Xeric Court, Denver, CO, 80231 to inquire
about defendant's last known address. There was no answer.
I SOLEMNLY swear and affirm that the foregoing statements are true and correct
to the best of my knowledge, information,and belief. I understand that false
statements herein are made subject to the penalties of 18 PA. C.S. Section 4904
relating to unsworn falsification to authorities. g A. A
07/21 /2013
Date A igail Sessions
Investigative Processor
De Novo Attorney Services, Inc.
P.O.Box 20215
Baltimore, MD 21284
Our Job Serial Number: NOV-2013004907
Ref: 12030162-1
EXHIBIT 0
Udren Law Offices, PC.
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO:POSTMASTER DATE: August 7,2013
Enola,PAT CASE No.: 12030162-1
Please furnish the new address or the name and street address(if a boxholder)for the following. Please take special
note that this request deals with a matter pending in Court and,therefore,any information available would be greatly
appreciated,even if any existing forwarding order has expired.
NAME:Robert M.Fuller,Jr.
LAST KNOWN ADDRESS:2550 Lambs Gap Road,Enola,PA 17025
NOTE: The name and last known address are required for change of address information. The name, if known,and post
office box address are required for boxholder information.
The following information is provided in accordance with 39CFR 265.6(d)(6)(ii). There is no fee for providing
boxholder information. The fee for providing change of address information is waived in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support Manual 352.44a and b.
1. Capacity of requester: Attorney at Law
2. Statute/regulation that empowers me to serve process(not required if requester is an attorney)
3. The names of known parties to the litigation:(FIS for Green Tree Servicing,LLC) vs.NAME:Robert M.Fuller.Jr.
4. The Court in which the case has been or will be heard: Cumberland County Pennsylvania
5. The docket or other identifying number if one has been issued: 12-3416
6. The capacity in which this individual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR
BOXHOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN
CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES
INCLUDING A FINE OF UP TO$10,000 OR IMPRISONMENT OR(2)7O AVOID PAYMENT OF THE FEE FOR CHANGE
OF ADDRESS INFORMATION OF NOT MORE THAN FIVE YEARS, OR BOTH. (TITLE 18 U.S.C.SECTION 1001)
I certify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,PC.
oodcrest Corporate Center
11 Woodcrest Road
' t berry *cr_. I: s3
BY: 11 d L►
_
osure
********************************************* t ***************************************
POST OFFICE USE ONLY
NEW ADDRESS/BOXHOLDER'S NAME AND STREET ADDRESS
_Not known at address given No such number AFFIX POSTMARK HERE
_Left no forwarding No change of address on file
_No such street GOOD AS ADDRESSED
ptil Ots,
vP "t�
1409 06
VSPS
EXHIBIT D
l
Udren Law Offices, PC. 91/-1--
Woodcrest Corporate Center 2/t itilditi
111 Woodcrest Road
Cherry Hill, New Jersey 08003
TO:POSTMASTER DATE: August 7,2913
Deaver CO 10231 CASE No.:12030162-1
Please tarnish the new address or the name and street address(if a boxholder)for the following. Please talus special
note that this request deals with a matter • . in Court and,thereture,any information available would be greedy
PA !-: order has expired.
N „'
-1 s ' ADD 1 f ii .'„ a '6.7 ir t c I y CO580231 ,
NOTE: The name and last known address are required for change of address iionaation. The some,if known,and past
office box address are required for boxholdar brformation.
The following information is provided in accordance with 39CFR 265.6( ri). There is no fee for providing
boxholder Win. The fee for•providing of address information is in accordance with 39CFR 265.6(d)(1)
and(2)and corresponding Administrative Support 352.44a and b.
1. Ctof
2. S gu that n�oa me to serve 1 s(not ifregae ter is ea attorney)
3. The names of known panes to sthe litigation:(FIS for Green Tree Servicing, vs.NAME:Robert 11L Fuller.Jr,
4. The Court in which the case has been or will beheard: a:,- ,...,::..• .,,.,∎I, i-,,.:till
5. The docket or other identify number if one has been bawl: 12-3416
6. The capacity in which this mdtvidual is to be served(defendant,witness): Defendant(s)
WARNING
THE SUB1f S570NOF FALSE INFOR1l!A270NT1OOBTAINAND USE CHANGE OF ADDRESS 1NFlOR1IL!TIONOR
BOXIYOLDER INFORMATION FOR ANY OTHER PURPOSE OTHER THAW THE SERVICE OF.LEGAL PROCESS IN
CONNECTION NTH-IACTUAL OR PROSPECTIVE LITIGATION COULD.RESULT IN ANAL PENALTYES
INCLUDING A FINE OF UP IV$10,000 OR IAaPR1,S'ONMENT OR(2)710 AVOW)RAIMENT OFTEE FEE FOR CHANGE
OF ADDRESS INFORAM7ONOF NOT MORE THAN FIVETEARS,OR BOTIL(TITLE 18 U.S.C.EECIT0NIOO1)
I oertify that the above information is true and that the address information is needed and will be used solely for
service of legal process in connection with actual or prospective litigation.
Udren Law Offices,PC.
Woodcrest . ... :to Cen
111 W.. �-^^''
(p4 ... 1 i. 08003
BY: ail ' I�461'OliLr.�,t ,
*********************MME************** **************Mi******F************* �� le ,
POST OFFICE r _l' ONLY e4N re) c, .
NEW ADDRESS/BOXHOLDER'S N I AND STREET ADDRESS p`` ' ”„' 1,
_Not]mown at address given __No each sinker AFFIX POSTMARK HERE I--, „ '`-''
___Left no forwarding No change of address on file a 1\,
No such street X GOOD AS ADDRESSED c er
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
CUMBERLAND County
v.
Shelley W. Fuller;
Robert M. Fuller,Jr NO. 12-3416-CIVIL
Defendant(s)
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
(a) If service cannot be made under the applicable rule the plaintiff may move
the court for a special order directing the method of service. The motion shall be
accompanied by an affidavit stating the nature and extent of the investigation
which has been made to determine the whereabouts of the defendant and the
reasons why service cannot be made.
NOTE: A sheriffs return of "not found" or the fact that a defendant has moved
without leaving a new forwarding address is insufficient evidence of concealment.
Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended
adoption mailed to last known address requires a "good faith effort" to discover
the correct address. Adoption of Walker, 468 Pa. 165, 360 A2d 603 (1976).
An illustration of a good faith effort to locate the defendant includes (1) inquiries
of postal authorities including inquiries pursuant to the Freedom of Information
Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and
employers of the defendant and (3) examinations of local telephone directories,
voter registration records, local tax records, and motor vehicle records.
As set forth in the Returns of Service marked Exhibits "A" and `B" the Sheriff and/or Process
Server has been unable to serve the following Defendant(s) at their last known addresses.
A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced
by the attached Affidavit of Good Faith Investigation marked Exhibit "C".
Plaintiff conducted a Postal Search Inquiry which did not reveal any new addresses or
information. A copy of the Postal Search results is attached hereto as Exhibit"D".
WHEREFORE, Plaintiff prays and respectfully requests service of the Notice of Sale
upon Defendant(s)by regular mail and certified mail, and by posting the mortgaged premises.
UDREN LAW OFFICES, P.C.
BY: MARRY S.REESE,ESQUIRE
• ' 310501
Attorneys for Pl.; tiff
•
VERIFICATION
The undersigned hereby states that he/she is the Attorney for
the Plaintiff in this action, that he/she is authorized to make
this Verification, and that the statements made in the foregoing
MOTION FOR SPECIAL SERVICE PURSUANT TO SPECIAL ORDER OF COURT are
true and correct to the best of his/her knowledge, information and
belief.
The undersigned understands that this statement herein is made
subject to the penalties of 18 Pa.C. S . Sec 4904 relating to unsworn
falsification to authorities .
Date: �- (7)
UDREN LAW OFFICES, P .C.
BY:
Att eys or Pl intiff
HARRY B. SE, ESQUIRE
PA: 310501
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
CUMBERLAND County
v.
Shelley W. Fuller;
Robert M. Fuller,Jr. NO. 12-3416-CIVIL
Defendant(s)
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served by U.S. mail on
each of the attached parties or their attorneys this 27TH day of September, 2013.
Udren Law Offices, P.C.
Attorney for Plaintiff
By:
ARRY B. REE ', ESQUIRE
PA ID 0501
SERVICE LIST
CUMBERLAND COUNTY, PENNSYLVANIA
CCP.No. Docket Number: 12-3416-CIVIL
NAME: ROBERT M. FULLER,JR.
MAILING ADDRESS: 3004 S. XERIC COURT
DENVER, CO 80231
a
• • •
IN THE ORDER OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Bank of America,N.A.
Plaintiff
v.
Shelley W. Fuller; NO. 12-3416-CIVIL
Robert M.Fuller,Jr.
Defendant(s)
ORDER
AND NOW, this 3/id day of , 2013,upon consideration of Plaintiffs Motion and
the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of
the Notice of Sale on Defendant(s), Robert M. Fuller,Jr., shall be complete when Plaintiff or
its counsel or agent has served true and correct copies of the Notice of Sale by posting the
mortgage premises at:
2550 LAMBS GAP ROAD
ENOLA,PA 17025
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
ROBERT M.FULLER,JR.
3004 S. XERIC COURT
DENVER, CO 80231
BY THE COURT:
J.
� x
rte__
Car y inAt cp
I PS-ESC--
910703
4.5
L
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
Bank of America,N.A. COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County , `
Plaintiff
o .-t1
v. NO. 12-3416-CIVIL
SHELLEY W. FULLER; ,
ROBERT M.FULLER,JR.; et al �--a -moo
Defendant(s)
PRAECIPE TO FILE PROOF OF SERVICE
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter.
Date: ( 0 1—q 'C3
UDREN LAW OFFICES,P.C.
BY:
A o ey for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PA ID 311050
IN THE ORDER OF COMMON PLEAS QF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Bank of America,N.A.
Plaintiff
v.
Shelley W.Fuller; NO. 12-3416-CIVIL
Robert M.Fuller,Jr.
Defendant(s)
tt ORDER
AND NOW,this -- y oft c pp t ,2013,upon consideration of Plaintiffs Motion and
the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of
the Notice of Sale on Defendant(s),Robert M.Fuller,Jr.,shall be complete.when Plaintiff or
its counsel or agent has served true and correct copies of the Notice of Sale by posting the
mortgage premises at:
2550 LAMBS GAP ROAD
ENOLA,PA 17025
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
ROBERT M.FULLER,JR.
3004 S.XERIC COURT
DENVER,CO 80231
BY THE COURT:
• 1 J.
ma; c
n'T c, -c Y!
vs r-- a�
CIAJ CT)
C 8,c;
r-
`-# CJ
• -
Bank of America,NA,et.al.,Plaintiff(s) Service of Process by
ys, ��t•"� APS International, Ltd.
,Shelley W.Fuller,et.al„Defendant(s) ' "f �l. !,` I-800-328-?�71
ses IN TER tkubovLt APS international Plaza
•
7800 Glenroy Rd.
Minneapolis,MN 55439-3122
APS File 0: 125757-0001
AFFIDAVIT OF SERVICE -- Individual
Service of Process on:
UDREN LAW OFFICES --Robert M. Fuller,Jr.,by posting
Ms.Henni Crommarty Court Case No.Cumberland Co 12-3416-Civil
I I 1 Woodcrest Rd.,Ste.200
Cherry Hill.NJ 08003-3620
I i
State of: (l S 1`/C l p� )ss. - - - - - - -
County of:C xMF-) t( (1 .1nG ) , /
Name of Server: ,�0) /Vic(/-e11i l�Lr,y7(6r) ,undersigned, being duly sworn,deposes and says
that at the time yoff service, s/he c•s of legal age and was not a party to this action;
DatefTime of Service: that on the �'/ `day of 20 ,at Ouo'clock M
Place of Service: at 2550 Lambs Gap Road . in Enola,PA 17025
Documents Served: the undersigned served the documents described as:
Notice of sheriff's Sale of Real Property w/Order
Service of Process on: A true and correct copy of the aforesaid document(s)was served on:
Robert M.Fuller,Jr., by posting
Person Served,and
Method of Service: By personally delivering them into the ds of the person to be served.
NA, By delivering them into the hands of S4l n ' ,a person
of suitable age, who verified, or who upon questionini stated,that he/she resides with
Robert M. Fuller,Jr.,by posting at the place of service, and whose relationship to the person is:
Description of Person The person receiving documents is described as follows:
Receiving Documents: Sex : Skin Color Hair Color : Facial Hair.
Approx. Age ; Approx. Height - : Approx. Weight
To the best f my knowledge and belief, s.id person was not engaged in the US Military at
the - of see 'ce.
/• '.-r . •14erjury Subscri ed and sN`orn to before me this
Signature of Server: ers gn cla 1 at t e .� _• _r d . ct. ay of tilt tX • 70
/, ��
.t re of Server Notary Public ( � p
/ � �. missi •x rtes)
APS International, Ltd. COMMO WOM OF PENNSYLVANIA
Notarial Seal
Susan K.Guyer,Notary Public
Carlisle Boro,Cumberland County
My Commission Expires Sept 4,2015
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
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 cT.
Bank of America,N.A. COURT OF COMMON PLEAS
CIVIL DIVISION ,
V. Cumberland County c a
SHELLY W.FULLER MORTGAGE FORECLOSURE -
ROBERT M.FULLER,JR.
Defendant(s) NO 12-3416-CIVIL >c;:: • 'T'
�u
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff,by its/his/her Attorney hereby verifies that:
1. A copy of the Notice of Sheriffs Sale,a true and correct copy of which is attached hereto as
Exhibit"A",was sent to every recorded lienholder and every other interested party known as of the date
of the filing of the Praecipe for the Writ of Execution,on the date(s)appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date
appearing on the attached Return Receipt,which was signed for by Defendant(s) on the date specified on
the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit"B".
3. If a Return Receipt is not attached hereto,then service was by personal service on the date
specified on the attached Return of Service, attached hereto as Exhibit"B".
4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as
Exhibit"B".
All Notices were served within the time limits set forth by Pa Rule C.P. 3129.
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: l-()-2.4.1 3 UDREN LAW e FICES,P.C.
BY:
Attorneys for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PA ID 311050
MJU#: 12030162 CASE#: 12030162-1
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
I leadin's udren.com
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v Cumberland County
Shelley W. Fuller MORTGAGE FORECLOSURE
Robert M. Fuller,Jr.
Defendant(s) NO. 12-3416-CIVIL
AMENDED 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:
2550 Lambs Gap Road, Enola, PA 17025
1.Name and address of Owner(s) or reputed Owner(s):
Shelley W. Fuller
785 Eastside Drive
Landisville,PA 17538-1516
Robert M. Fuller,Jr.
2550 Lambs Gap Road
Enola, PA 17025
Robert M. Fuller,Jr.
3004 S.Xeric Court
Denver, CO 80231
2. Name and address of Defendant(s) in the judgment:
Shelley W. Fuller
785 Eastside Drive
Landisville, PA 17538-1516
Robert M. Fuller,Jr.
2550 Lambs Gap Road
Enola, PA 17025
Robert M. Fuller,Jr.
3004 S. Xeric Court
Denver, CO 80231
3. Name and address of every judgment,creditor whose judgment is a record lien on the real
property to be sold:
Jr Lien Holders -None
4. Name and address of the last recorded holder of every mortgage of record:
Bank of America,N.A.
16001 North Dallas Parkway
Addison, TX 75006
Sr Mortgage Holders -None
Jr Mortgage Holders - None
5.Name and address of every other person who has any record lien on the property:
Sr lien Holders -None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
Cumberland County Domestic Relations Section
13 North Hanover Street
Carlisle,PA 17013
Cumberland County Real Estate Tax Department
1 Courthouse Square
Carlisle, PA 17013
Commonwealth of PA, Department of Revenue
Bureau of Compliance
PO Box 281230
Harrisburg, PA 17128-1230
Tenants/Occupants
2550 Lambs Gap Road
Enola, PA 17025
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: [ 0, 221- z UDREN LA FFICES, P.C.
BY:
Attorney for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PA ID 311050
MJU#: 12030162 CASE#: 12030162-1
UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
an o merica, COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v. Cumberland County
SHELLEY W. FULLER MORTGAGE FORECLOSURE
ROBERT M. FULLER,JR.;
Defendant(s)
NO. 12-3416-CIVIL
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
OWNER(S): SHELLEY W.FULLER AND ROBERT M. FULLER,JR.;
PROPERTY: 2550 Lambs Gap Road,Enola,PA 17025
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale
on 09/04/2013 at 10:00 AM, at the Cumberland County Courthouse,Commissioners
Hearing Room,2nd Floor,Carlisle,PA 17013. Our records indicate that you may hold a
mortgage or judgment on the property,which will be extinguished by the sale. You may wish to
attend the sale to protect your interests.
The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30
days after sale. Distribution will be made in accordance with the schedule unless exceptions are
filed thereto within 10 days after the filing of the schedule.
MJU#: 12030162 CASE#: 12030162-1
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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 l s ' udren.com
Bank of America,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v. CUMBERLAND County
SHELLEY W. FULLER, MORTGAGE FORECLOSURE
ROBERT M. FULLER,JR.,
Defendant(s) NO. 12-3416-CIVIL
VERIFICATION OF SERVICE OF NOTICE OF SALE
BY CERTIFIED MAIL AND REGULAR MAIL
PURSUANT TO COURT ORDER
The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that
pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by
certified mail and regular first class mail as follows:
TO:
ROBERT M.FULLER,JR.
3004 S.XERIC COURT,DENVER, CO 80231
DATE MAILED: October 8,2013
I verify that the statements made herein are true and correct and I understand that false statements made
herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to
authorities.
Dated: •1-`1 ,2013
UDREN LAW FICES,P.C.
BY:
Att y for Plaintiff
MJU#: 12030162 CASE#: 12030162-1 SALVATORE CAROLLO, ESQUIRE
PA ID 311050
Etan
IN THE ORDER OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Bank of America,N.A.
Plaintiff
v.
Shelley W.Fuler NO. 12-3416-CIVIL
Robert M.Fuller,Jr.
Defendant(s)
�,,,�[ p ORDER
AND NOW,this )""aay of bw ,,2013,upon consideration of Plaintiffs Motion and
the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of
the Notice of Sale on Defendant(s),Robert M.Fuller,Jr.,shall be complete when Plaintiff or
its counsel or agent has served true and correct copies of the Notice of Sale by posting the
mortgage premises at:
2550 LAMBS GAP ROAD
ENOLA,PA 17025
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
ROBERT M.FULLER,JR.
3004 S.XERIC COURT
DENVER,CO 80231
BY THE COURT:
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UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD,SUITE 200
CHERRY HILL,NJ 08003-3620
856-669-5400
Bank of America,N.A. COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
Plaintiff
v. NO. 12-3416-CIVIL
SHELLEY W. FULLER;
ROBERT M.FULLER,JR.; et al
Defendant(s)
PRAECIPE TO FILE PROOF OF SERVICE
TO THE PROTHONOTARY:
Kindly file the attached Proofs of Service with regard to the captioned matter.
Date: I O°1-91
L 3
UDREN LAW OFFICES,P.C.
BY:
A o ey for Plaintiff
SALVATORE CAROLLO, ESQUIRE
PA ID 311050
tItt 1\\1°
•
IN THE ORDER OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Bank of America,N.A.
Plaintiff
v.
Shelley W.Fuller; NO. 12-3416-CIVIL
Robert M.Fuller,Jr.
Defendant(s)
y,�[ ORDER
AND NOW,this May of CJr ,Db ,t,,2013,upon consideration of Plaintiff's Motion and
the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of
the Notice of Sale on Defendant(s),Robert M.Fuller,Jr.,shall be complete.when Plaintiff or
its counsel or agent has served true and correct copies of the Notice of Sale by posting the
mortgage premises at:
2550 LAMBS GAP ROAD
ENOLA,PA 17025
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
ROBERT M.FULLER,JR.
3004 S.XERIC COURT
DENVER,CO 80231
BY THE COURT:
#diat,„04e.
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Service of Process by
Bank of.America.NA,.el.al..Piainliffts)
v � ` APS International, Ltd.
Shelley W.Fuller,et.at Defendantfa) . • a _ fit•
1-$0(028-7171
• APS ttt'rF UTtovt4 ;APS International Plaza
7800 Glenroy.Rd.
Minneapolis.MN 55439-3122
APS Fite#: 1237;7.00111
AFFIDAVIT OF SERVICE--Individual
• Service of Process on:
.UDREN LAW OFFICES --Robert M.Fuller,Jr.,by posting
Ms.Hanni Crommarll Court.Case No.Cumberland Co 12-3416-Civil
111 Woodcrest Rd.,Ste..200
Cherry Hill,NJ 08003=3620
� I
State of: {117 S ill e] 11 �— - - - _ - - - • - - - - - - —
)ss.
Cbunty^of: :.As a, : b. a
Name of Server: ii. II -C 1_ IL_ ,undersigned,being duly sworn,deposes and says
that at the timm-e off ervice.s/he of legal age and was not a party t/o this action:
Date/Time of Service: that on the Q tday of ,20 ,,at !' Oo'clock .M
Place of Service: at .2550 Lambs Gap Read • in Enola.PA 17025
Documents'Served: the undersigned served the documents described as:
Notice of sheriff's Sale of Real Properly w/Order
Service of Process on: A true.and correct copy of the aforesaid document(s)was served on:
Robert M.Fuller,Jr.,by posting
Person Ser•ed,.and
Method of Service: By personally delivering them into the ds of the person to be served.
! By delivering them into the hands of S4i I ,a person
of suitable age,who verified,or who upon questioning stated.that he/she resides with
Robert M.Fuller,Jr.,by posting
—
at the place of service,and whose relationship to the person is:
Description of Person The person receiving documents is described as follows:
Receiving Documents: Sex : Skin Color • Hair Color Facial Hair
Approx.Age ; Approx.Height Approx.Weight
t To the best •f my knowledge and belief.s id person was not engaged in the US Military at
th • of se► ce. /Signature of Server: .ersgni- i c a ' 't •r . , perjury Subscrt ed and s�^m to before me this
I e . e_• _ 1. , d • et. Q ay of l� ' l�J
/���
•
ji 410111r i re of Server Notary Public I r missi 'LJ'xpires)
APS International,Ltd. _- •" C0 EALTH OF PENNSYLVANIA
Notarial Seal
Susan K.Guyer,Notary Public
Carlisle Born,Cumberland County
My Commission byires Sept.4,2015
MEMBER PENNSYLVANIA ASSOCIATION OF NIWARIES
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff o� et mribety,iX �j s
Jody S Smith }: . '..—
Chief Deputy
Richard W Stewart
Solicitor OFFICE CiFME$!tERIFF
Bank of America, N.A.
vs. Case Number
Shelley W. Fuller(et at) • 2012-3416
SHERIFF'S RETURN OF SERVICE
05/30/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant,to wit: Shelly W. Fuller, but was unable to locate the Defendant in
his bailiwick. He therefore deputized the Sheriff of Lancaster County to serve the within Real Estate Writ,
Notice and Description, in the above titled action, according to law.
06/25/2013 08:35 PM- Deputy Noah Cline, 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 2550 Lambs Gap Road, Hampden Township, Enola, PA
17025, Cumberland County.
07/12/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Lancaster County upon Shelley W. Fuller, personally, at 785 Eastside Drive, Landisville, PA 17538. So
Answers: Melissa Heim, Deputy Sheriff.
07/16/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant,to wit: Robert Martin Fuller, Jr., but was unable to locate the
Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the
above titled action, as"Not Found"at 2550 Lambs Gap Road, Enola, PA 17025, property vacant, mail is
still delivered there per post office.
SHERIFF COST: $1,026.52 SO ANSWERS,
. July 16, 2013 RONKY ANDERSON, SHERIFF
EtIVIC\ 0�
(c)CountySuite Sheriff,Teleesoft,Inc.
t
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_
SHELLEY W. FULLER, MORTGAGE FORECLOSURE
M. FULLER,JR., ri`� n -
Defendant(s) NO. 12-3416-CIVIL
VERIFICATION OF SERVICE OF NOTICE OF SALE {`' '
BY CERTIFIED MAIL AND REGULAR MAIL Z
PURSUANT TO COURT ORDER v ---
The undersigned hereby verifies that he or she is counsel for Plaintiff in the above case and that
pursuant to the court order issued in this matter a true and correct copy of the Notice of Sale was sent by
certified mail and regular first class mail as follows:
TO:
ROBERT M. FULLER,JR.
3004 S.XERIC COURT, DENVER, CO 80231
DATE MAILED: October 8,2013
I verify that the statements made herein are true and correct and I understand that false statements made
herein are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Dated: Oc)r Z-`\ ,2013
UDREN LAW FICES, P.C.
BY:
Att y for Plaintiff
MJU#: 12030162 CASE#: 12030162-1 SALVATORE CAROLLO, ESQUIRE
PA ID 311050
•r
IN THE ORDER OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL TRIAL DIVISION
Bank of America,N.A.
Plaintiff
v.
Shelley W.Fuller; NO. 12-3416-CIVIL
Robert M.Fuller,Jr.
Defendant(s)
.�,,�[ �, r r ORDER
AND NOW,this -3"r kay of Oc:i „,2013,upon consideration of Plaintiffs Motion and
the Affidavit of Good Faith investigation attached hereto,it is hereby ORDERED that service of
the Notice of Sale on Defendant(s),Robert M.Fuller,Jr.,shall be complete when Plaintiff or
its counsel or agent has served true and correct copies of the Notice of Sale by posting the
mortgage premises at:
2550 LAMBS GAP ROAD
ENOLA,PA 17025
And by mailing by certified mail and regular mail to the last known address of Defendant(s) as
follows:
ROBERT M.FULLER,JR.
3004 S.XERIC COURT
DENVER,CO 80231
BY THE COURT:
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SA' ERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
�4tSS I,t�j�
Jody S Smith
Chief Deputy
Richard W Stewart
OFFIOEOFTHE ERVFF
Solicitor i 4iI `afa a�r1
Bank of America, N.A. Case Number
vs. 2012-3416
Shelley W. Fuller(et al.)
SHERIFF'S RETURN OF SERVICE
05/30/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant,to wit: Shelly W. Fuller, but was unable to locate the Defendant in
his bailiwick. He therefore deputized the Sheriff of Lancaster County to serve the within Real Estate Writ,
Notice and Description, in the above titled action, according to law.
06/25/2013 08:35 PM - Deputy Noah Cline, 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 2550 Lambs Gap Road, Hampden Township, Enola, PA
17025, Cumberland County.
07/12/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of Lancaster County upon Shelley W. Fuller, personally, at 785 Eastside Drive, Landisville, PA 17538. So
Answers: Melissa Heim, Deputy Sheriff.
07/16/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant, to wit: Robert Martin Fuller, Jr., but was unable to locate the
Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the
above titled action, as"Not Found"at 2550 Lambs Gap Road, Enola, PA 17025, property vacant, mail is
still delivered there per post office.
08/28/2013 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/6/2013
11/04/2013 As directed by Mark Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/4/2013
12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at
10:00 AM. He sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of Federal National
Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,338.08 SO ANSWERS,
January 10, 2014 RbNRY R ANDERSON, SHERIFF
y�-oa p)- Cam.
a as Pd CO.
. .s- u Pd,
Gf271 �YS 7-3
(cj �
CouniySwte,Sheliti,Teleosoft,Inc 3&e7���
On May 30, 2013 the Sheriff levied upon the
defendant's interest in the real property situated in
Hampden Township, Cumberland County, PA,
Known and numbered as, 2550 Lambs Gap Road,
Enola, Cumberland, as Exhibit "A" filed with this
writ and by this Reference incorporated herein.
r�
Date: May 30, 2013
By:
Real Estate Coordinator
LXII 30 CUMBERLAND LAW JOURNAL 07/26/13
2012-3416 Civil Term feet to a point;thence along the same
center line of Lambs Gap Road North
BANK OF AMERICA,N.A. sixty-seven (67) degrees fifty-three
vs. (53)minutes West,a distance of one
SHELLEY W. FULLER, hundred fifty-eight and twenty one-
Robert Martin Fuller,Jr. hundredths(158.20)feet to the place
of BEGINNING.
Atty.: Mark Udren BEING KNOWN AS: 2550 Lambs
ALL THAT CERTAIN parcel of land Gap Road,Enola,PA 17025.
situate in the Township of Hampden, PROPERTY ID NO.: 10-11-3016-
Cumberland County, State of Penn- 004.
sylvania,bounded and described in TITLE TO SAID PREMISES IS
accordance with a subdivision plan VESTED IN Robert M. Fuller,Jr. by
dated September 10, 1973 and a deed from Robert M. Fuller, Jr. and
survey dated March 1, 1974, both Shelley W.Fuller dated 05/07/2010
made by James A. Cieri, Consulting recorded 05/21/2010 in Deed Book
Engineer,as follows: Instrument#201013164.
BEGINNING at a point on the cen-
ter line of Lambs Gap Road; thence
along the lands now or late of C.Fry
North seven(07)degrees fortyfive(45)
minutes West, a distance of three
hundred forty-three and eight tenths
(343.8) feet to a steel post; thence
along lands now or late of Pennsyl-
vania State Game Lands (formerly
H.McCormick)North eighty-five(85)
degrees fifteen (15) minutes East,
a distance of four hundred twenty-
two and four tenths(422.4)feet to a
steel post; thence along lands now
or late of D. Smith South zero (00)
degrees thirty-five minutes West, a
distance of five hundred forty-one
and twenty-five one hundredths
(541.25) feet to the center line of
Lambs Gap Road; thence along the
center line of Lambs Gap Road North
fifty-nine (59) degrees twenty-one
(21) minutes, West, a distance of
thirty and seventeen one-hundredths
(30.17) feet to a point in the center
line of Lambs Gap Road,thence along
Lambs Gap Road North sixty-nine
(69) degrees four(04)minutes West,
a distance of ninetynine and eighteen
one-hundredth(99.18)feet to a point;
thence along the center line of Lambs
Gap Road North seventy-two(72)de-
grees forty-three(43)minutes West,
a distance of one hundred seven and
thirty-five one-hundredths (107.35)
53
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
July 26, August 2 and August 9, 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.
—")U� )L �,. --- -
L' a Marie Coyne, E itor
SWORN TO AND SUBSCRIBED before me this
9 da of Au ust 2013
Notary
71AR EAL'OLLINS blic CARLISL BERLAND COUNTY My s Apr 28.2014
The Patriot-News Co. •
1900 Patriot,Drive t4e r
ec'hanicsburg, PA 17050
Inquiries - 717-255-8213 NOW you know
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Michael J. Morrow, being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of
Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither he nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s)shown below:
07/28/13
r
08/04/13
08/11/13
t`
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Sworn to and bscribed a re P 23 ay of August, 2013 A.D.
is Uyi
COMMONWEALTH OF PENNISYLVANIA
Notarial Seal
Holly Lynn Warfel,Notary Public
Washington Twp.,Dauphin County
My Cornm,ission Expires Dec.12,2016
MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
2612.3116 CIMI arm
BANK OF AMERIOA,NA.
vs.
`tHELLEY W.FULLER
Rpbert Mwtln FuNsr,Jr.
Atty: Mark Udrsn
ALL THAT CERTAIN PARCEL OF
LAND SITUATE IN THE TOWNSHIP OF
HAMPDEN,
'CiRa BLAND COUNTY, STATE
OF PENNSYLVANIA, BOUNDED
AND DESCRIBED IN ACCORDANCE
WITH A SUBDIVISION PLAN DATED
SEPTEMBER 1%1973 AND A SURVEY
DATED MARCH 1,1974,BOTH MADE
BY AMFES A CIERI, CONSULTING
ENGINEER,AS FOLLOWS:
BEGINNING AT A POINT ON THE
CENTER LINE OF IAMBS GAP ROAD;
THENCE ALONG THE LANDS NOW
OR LATE OF C.FRY NORTH SEVEN
(07) DEGREES FORTY-FIVE (45)
MINUTES WEST; A .DISTANCE OF
THREE HUNDRED FORTY-THREE
AND EIGHT TENTHS(343.8)FEE7 TO A
STEEL.POST,
THENCE ALONG LANDS NOW OR
IATEOFPENNSYLVANIASTATEGAME
LANDS(FORMERLY H.MCCORMICK)
NORTH EIGHTY-FIVE(85) DEGREES
FIFTEEN (15) MINUTES EAST, A
DISTANCE OF FOUR HUNDRED
TWENTY TWO AND FOUR TENTHS
(422.4)FEET TO A STEEL POST'
ALONG LANDS NOW OR
LATE OF D.SMITH SOUTH ZERO(00)
DEGREES THIRTY-FIVE MINUTES
WEST,ADISIANCE OF FIV E HUNDRED
FORTY-ONE AND TWENTY-FIVE ONE
HUNDREDTHS(541:25)FEET TO THE
CENTER LINE OF LAMBS GAP ROAD;
THENCE ALONG THE CENTER LINE
OF LAMBS GAP:ROAD NORTH FIFTY-
NINE (59) DEGREES TWENTY-ONE
(21)_MINUTES, WEST, A DISTANCE;
OF T'HIRT'Y AND SEVENTEEN ONE-
HUNDREDTHS (30.17) FEET TO"A.
POINT IN`.' -. R LINE OF
i nUAS MP WAS
THENCE ALONG IAMBS.GAP ROAD ^a
NORTH UM-NINE (69)"DEGREES s
FOUR (04) MI&rM WEST; A
DISTANCE OF NINETI-NINE AND
EIGHTEEN ONE-HUNDREDTH(99.18)
FEET TO A POINT, '
THENCE. ALONG THE CENTER
LINE OF LAMBS GAP ROAD NORTH
SEVENTY-TWO (72) DEGREES
FDRI'YTIIREE (43) MINUTES WEST;
A DISTANCE OF ONE HUNDRED
SEVEN AND THIRTY-FIVE ONE-
HUNDREDTHS (10735) FEET TO A
POINT,
THENCE ALONG THE SAME CENTER
LINE OF IAMBS GAP ROAD NOM
SDMSEVEN (67) DEGREES FIFTY-
THREE (53) MINUTES WEST A
DISTANCE OF ONE •HUNDRED
FIFTY EIGHT AND TWENTY ONE-
HUNDREDTHS(158.20)FEET TO THE
PLACE OF BEGINNING.
BEING KNOWN AS:2550 IAMBS GAP
ROAD,ENOLA,PA 17025 -
PROPERTY ID NO.:10-11-3016-M ,
TITLE TO SAID PREMISES IS VESTED
IN ROBERT M.FULLER,JR.BY DEED
FROM ROBERT M.FULLER JR.AND
SHELLEY W.FULLER DATED 05107(1010
RECORDED 05/11010 IN DEED BOOK
INSTRUMENT*2DI013164.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the
Sheriff s Deed in which Federal National Mortgage Association is the grantee the same having been
sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution
issued on the 23rd day of May, A.D., 2013, out of the Court of Common Pleas of said County as of Civil
Term, 2012 Number 3416, at the suit of Bank of America,NA against Shelley W. Fuller and Robert M.
Fuller Jr. is duly recorded as Instrument Number 201401148.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 1 day of
J0 n , A.D. a 01 Ll
W- d , 'r� DeWfi/
Recorder of eeds
Recorder of Deeds.Cumberland County,CarNsle,PA
My commission Expires the First Monday of Jan.2018