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Home My WebLink About12-3450 -JJNS, YLVAN;1A ATTORNEY FOR PLAINTIFF PHELAN HALLINAN & SCHMIEG, LLP Jeremy J. Kgbeski, Esq., Id. No.94503 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 277759 BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff V. COURT OF COMMON PLEAS CIVIL DIVISION TERM 0tv i NO. 1 'a 3Y CUMBERLAND COUNTY JANET M. BRYANT-SCOTT TROY W, SCOTT, III 212 EDENDERRY WAY ENOLA, PA 17025-3414 THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA 1164 FEDERAL BUILDING, 228 WALNUT STREET HARRISBURG, PA 17101 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 277759 OLft?+ *IbS, 77S? 491 tk,+ n awar 9 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 277759 1. Plaintiff is BANK OF AMERICA, N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: JA'NET M. BRYANT-SCOTT TROY W. SCOTT, III 212 EDENDERRY WAY ENOLA, PA 17025-3414 THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA 1164 FEDERAL BUILDING, 228 WALNUT STREET HARRISBURG, PA 17101 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 06/29/2006 JA'NET M. BRYANT-SCOTT and TROY W. SCOTT, III made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR AMERICAN HOME MORTGAGE which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1958, Page 4872. By Assignment of Mortgage recorded 09/21/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201126175.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 277759 The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/01/2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6 The following amounts are due on the mortgage as of 02/24/2012: Principal Balance $251,397.35 Interest $9,018.67 02/01/2011 through 02/24/2012 Late Charges $123.50 Escrow Deficit $11,545.13 Subtotal $276,600.11 Suspense $5,095.99 Escrow Credit $1,226.06 TOTAL $270,278.06 7 8 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. File #: 277759 9. The United States of America is made a Defendant herein pursuant to 28 U.S.C. 2410, because of federal tax liens that have been filed with the Prothonotary of CUMBERLAND County in the Judgment Index Unit as follows: (a) United States vs. Troy W. Scott; Cumberland Docket No.2008-2593; filed 4/23/08; in the amount of $12,585.47 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $270,278.06, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & CHMIEG, LLP By: Jere J. obeski, Esq., Id. No.94503 Attornv f Plaintiff File #: 277759 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern dedicated right-of-way line of Edenberry Way at a dividing line of Lot No. 96 and Lot No. 97; thence by line of Lot No. 96 North 45 degrees 7 minutes 1 second East 100.00 feet to a point; thence by lands of Logans Run, Phase I, South 44 degrees 52 minutes 59 seconds East 80.00 feet to a point at the dividing line of Lot No. 97 and Lot No. 98; thence by line of Lot No. 98 South 45 degrees 7 minutes l second West 100.00 feet to a point on the eastern right-of-way line of Edenberry Way; thence by said right-of-way line of North 44 degrees 52 minutes 59 seconds West 80.00 feet to a point at the dividing line of Lot No. 96 and Lot No. 97, the place of BEGINNING. BEING Lot No. 97 on the Final Subdivision Plan for Logans Run, Phase IV, recorded in Plan Book 83, Page 27. SUBJECT to a 20 foot wide drainage easement as shown on the above mentioned Final Subdivision Plan. UNDER AND SUBJECT to restrictions as set forth in Misc. book 451, Page 687; Misc. Book 475, Page 657; and Misc. Book 651, Page 825. SUBJECT to building lines, rights-of-way, easements, mining and mineral rights, restrictions, reservations and exceptions as set forth on the recorded plan and as may appear in prior instruments of record. BEING THE SAME PREMISES which Jeffrey Hudak and Kelly J. Hudak by Deed dated March 18, 2004 and recorded October 27, 2004 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 265, Page 4677, granted and conveyed unto Kelly J. Hudak, Grantor herein. THE SAID Kelly J. Hudak a/k/a Kelly Jo Hudak, a/k/a Kelly Jo Knott is now known as Kelly J. Teapole. PROPERTY ADDRESS: 212 EDENDERRY WAY, ENOLA, PA 17025-3414 PARCEL # 09-14-0836-302 File #: 277759 VERIFICATION 0& hereby states that he/ he s lC f?2 f, BANK OF AMERICA, N.A. Plaintiff in this matter, that he/epA authorized to make 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 g I formation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1 Z File #: 277759 Name: BRYANT-SCOTT Name kftv_?L, 14 (rJ Title: q ? V 1C40-, Qee ?: 'dao BANK OF AMERICA, N.A. File #: 277759 31 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff VS. JANET M. BRYANT-SCOTT, TROY W. SCOTT, III, and THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA, Defendants IN THE COURT OF CdMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 12-3450 CIVIL ORDER AND NOW, this 6 ` day of June, 2012, proceedings herein are stayed pending compliance with our Administrative Order dated February 28, 2012, and, specifically, pending service of the Notice of Residential Mortgage Foreclosure Diversion Program and the Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet set forth in Form 1 and Form 2, as amended, attached to said Administrative Order. BY THE COURT, A? Kevin A'Iless, P. J. i? Jeremy J. Kobeski, Esquire For the Plaintiff Janet M. Bryant-Scott Troy W. Scott, III 212 Edenderry Way Enola, PA 170225-3414 r -,C ?a C 1 c_ -V t s United States of America c/o the United States Attorney for the Middle District of Pennsylvania 1164 Federal Building 228 Walnut Street Harrisburg, PA 17101 Am Cop-, es '-ed lolb/ a PU--- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE _.F' ? "-- ?.IFF rr, Y-, Bank of America, NA vs. Case Number Janet M Bryant-Scott (et al.) 2012-3450 SHERIFF'S RETURN OF SERVICE 06/11/2012 05:49 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2012 at 1749 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: Janet M. Bryant-Scott, by making known unto Troy Scott III, Husband of Defendant at 212 Edenderry Way, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. c--7 RYA BURGETT, 06/11/2012 05:49 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2012 at 1749 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: Troy W. Scott, III, by making known unto himself personally, at 212 Edenderry Way, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. RYAN BURGETT, SHERIFF COST: $74.00 June 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c.` Coun'ySiAe Snerff. Te eoso't. Lac. AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS PHS # 277759 SERVICING, LP DEFENDANT SERVICE TEAM/ clo JANET M. BRYANT-SCOTT COURT NO.: 12-3450 CIVIL TROY W. SCOTT, III THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA SERVE THE UNITED STATES OF AMERICA C/O THE UNITED TYPE OF ACTION STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA AT: XX Mortgage Foreclosure MAIN JUSTICE BUILDING XX Civil Action 950 PENNSYLVANIA AVENUE, N.W. WASHINGTON, DC 20530 ' ~ ~.. ~> ~.)a,~~yy- ~ ~' i-11i,l~~.7- ~U ~ 2 ~UU 14 F4~ ~U~ I f`-'~~1~~R ~:td0 Ct~UNTY ~ENIi~YLVAMi,A SERVED Served and made known to THE 1'HE MIDDLE ISTRICT F PA ,Defendant the'! day of ~5~, 20 ~ at ,`~O_, o'clock . M., at , in the ma ner described below: Defendant ersonally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). A ent or pers n in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Descrip/t/ion: Age ~ Height S' ~ _ r7Veig1It7Q Race ~ Sei)~ Other I, ~!( ~ ~JYG(Ct a competent adult, being duly sworn according to law, depose and state that I personally handed a true nd correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this ~ day of ~, 2oLa try: B l "~ ~ ~.( VCf C ~ crlti V NOT SERVED of ~ at __ o'clock _. M., Defendant NOT FOUND because: _ Vac t _ Does Not E~ ' _ Moved _ Does Not Reside (Not Vacant) No nswer on _ at __, ai Sei 'icc Retu a ~ ~~~ ~ 11 /~ r Sworn to and subsCd-ibect'~••C'" ~'`7',y~'.``:-:° before me this day " ~'' " of - ~0 By: Notary: •,_ rar J 1 AT~'O$NRY~~'FOR PLAINTIFF '~ `' =.t Lh~ta'<eiiceT. Phe]an, Esq., Id. No. 32227 "' Fr` 1~CSs'4S~~I-)allinan, Esq., Id. No. 62695 ' ~~'~~~;~~. Schmieg, Esq., Id. No. 62205 Iv4icFiele M. ]Bradford, Esq., Id. No. 69849 Judith T. Romanq Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. ?06779 Allison F. Wells, Esq.. Id. No. 309519 Melissa J. Cantwell, Esy., Id. No. 308912 Mario J. Hanyon, Esq., Td. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick. Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Matthew G. Brushwood, Esq.. Id. No. 310592 Dana B. Ostrovsky, Esq., Id. No. 8392] Zachary J. Tones, Esq.. Id. No. 31072 I One Penn Center at Suburban Station g OF P r F 2813 JUL 10 c r' PHELAN HALLINAN, LLP Of 117: Attorney for Plaintiff Jonathan Lobb, Esq., Id. No.312174 CUtIBERL 1617 JFK Boulevard, Suite 1400 PENN YL0 COUNT Y One Penn Center Plaza L�' N/A Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA,N.A.SUCCESSOR BY CUMBERLAND COUNTY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS COURT OF COMMON PLEAS SERVICING,LP CIVIL DIVISION VS. No.12-3450 CIVIL JANET M.BRYANT-SCOTT TROY W.SCOTT,III THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JANET M.BRYANT- SCOTT, TROY W. SCOTT,III, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $270,278.06 TOTAL $270,278.06 I hereby certify that(1) the Defendants' last known address is 212 EDENDERRY WAY, ENOLA, PA 17025-3414, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date Aathan ob b, Esq., Id. No.312174 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. e DATE: 7 1v/42 PH a 277759 PROTHONOTARY Ck- 13 a5y� V e� �Y ,u c PHELAN HALLINAN,LLP Attorney for Plaintiff Jonathan Lobb,Esq.,Id.No.31.2174 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA,N.A.SUCCESSOR BY CUMBERLAND COUNTY MERGER TO BAC HOME LOANS SERVICING, COURT OF COMMON PLEAS LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP CIVIL DIVISION VS. No.12-3450 CIVIL JANET M.BRYANT-SCOTT TROY W.SCOTT,III THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above- captioned matter,and that on information and belief,he/she has knowledge of the following facts,to wit: (a) that the defendant(s)JA'NET M.BRYANT-SCOTT is/are not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940,as amended. (b) that defendant JA'NET M.BRYANT-SCOTT is over 18 years of age and resides at 212 EDENDERRY WAY,ENOLA,PA 17025-3414. (C) that the Plaintiff is without sufficient information to determine whether defendant(s)TROY W.SCOTT,III is/are not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940,as amended. (D) that defendant TROY W. SCOTT,III is over 18 years of age and resides at 212 EDENDERRY WAY,ENOLA,PA 1.7025-3414. This statement is made subject to the penalties of 18 Pa.C.S.Section 4904 relating to unsworn falsification to authorities. Date P an Hallinan,LLP Jonathan Lobb,Esq.,Id.No.312174 Attorney for Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza,Philadelphia,PA 191.03 215-563-7000 277759 Department of Defense Manpower Data Center Results as of:Jul-09-2013 12:57:53 SCRA 3.0 ' �-3 f.\ Status,wort Pursuant to Smicemem ors.Civil Relief Act Last Name: BRYANT-SCOTT First Name: JANET Middle Name: M Active Duty Status As Of:'Jul-09-2013 On Active Duty On Active Duty Status Date Active Duty Start Date T Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Dale Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 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 (Rule of Civil Procedure No. 236) -Revised BANK OF AMERICA,N.A. SUCCESSOR CUMBERLAND COUNTY BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE COURT OF COMMON PLEAS HOME LOANS SERVICING, LP VS. CIVIL DIVISION JANET M. BRYANT-SCOTT No. 12-3450 CIVIL TROY W. SCOTT,III THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Notice is given that a Judgment in the above captioned matter has been entered against you on toll? By: If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Jonathan Lobb, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 277759 BANK OF AMERICA,N.A. SUCCESSOR BY COUWI'OF COMMON PLEAS MERGER TO RAC HOME LOANS SERVICING, CIVIL DIVISION I.P F/K/A COUNTRYWIDE HOME.f...OANS SERVICING,LP NO. 12-3450 CIVIL Plaintiff V, CUMBERLAND COUNTY JANTET M.BRYANT SCOTT TROY W. SCOTT,III 'EHT--.'UNlrl'ED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR.THE MIDDLE DISTRICT OF PA Defendant(s) TO: JANET M.BRYANIT-SCOTT 212 EDENDERRY WAY ENOLA,PA 17025-3414 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR AT"I'liMPTING TO COLI-E("T A DEBT. THIS NOTICE IS SENT TO YOU IN ANAT TEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT ANT) SHOULD NOT BE CONSTRU'ED TO BE AN ATTEMPT TO COI.l.hCT A DEBT, :BUT ONLY AS ENFORCEMENT OF LUN AGAINST PROPERTY. IMPORTAN'l.'NOTICE YOU ARE IN DEFAULT BECAUSE YOU ILAVE FAR.A.H.) TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFFNTSES 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 IMPOR"TAN"T RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU;' DO NOT HAVE A LAIVYER, GO TO OR TELEPI-IONETHE OFFICE SET FOXFH 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' THAT MAY O.FFT---R LEGAL ST.--RVI0 S TO ELIGIBLE PERSONS ATA REDUCED FEE OR NO FEE. Office of the Prothonotary CU AVIBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUJNTY COURTHOUSE Carlisle,PA 17013 2 LIBISRTY AVENUE (717)240-6195 CARLISLE,PA 17013 (7 t7)249--31.66 By: �� t � �T� �� Meredith Wooters,Esq.,Id,No.307207 Attorney for Plaintiff Pliclan Hallinaii,LLP 1617 JFK Boulevard,Suite 1400 111 IS 2717759 a One.Penn Center Plaza Philadelphia, PA 19103 TIFIS 4 L777*5 9 BANK OF AMERICA,N.A. SUCCESSOR.BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, CIVIL DIVISION LP F/KJA COUNTRYWIDE HOTVIE LOANS SERVICING, Lp NO. 12-3450 CIVET., Plaintiff V. CUMBERLAND COUNTY JANET M,BRYANT-SCOTT TROY W. SCOTT,III THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendant(s) TO: TROY W.SCOTT,III 212 EDE-NDERRY WAY ENOLA,PA 17025-31414 DATE OF NOTICE- THIS FIRM IS A DEBT COLI,ECTOR COLLECT A DEBT. THIS N(TFICE IS SENT TO YOU IN AN ATTEANIPT 'ro COIJECT THE INDEBTEDNESS Rl'-.*,'FERR.F`,D TO HE'REIN, AND ANY INFORMATION OBTAINF.D FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONsTRUTTI) TO BE AN ATTEMPT TO COITECT A DEBT', BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALT-Y OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SEFFORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE EGRED� 'RJ'Y OR OTHER AGAINTSTY01. WITHOUT A HEARING AND YOU MAY LOSE YOUR F'ROPE, IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPIlRT0 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 INMORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE; TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMAX OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, Office of tile Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 1701.3 2 LIBERTY AVENUE {71 7)240-6195 CARLlSLF:,PA 17013 (717)249-3166 Bv� Meredith Wooters,Esq.,Id,No,3072107 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Bowevard,Suite 1400 PHS it 277759 O-o Penn Center Plaza Ph i]adelph ia,PA 19103 rr 2014 JAP.,28 � i 11: t; pE a 4SYLY COUNTY AN1A Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA, N.A. SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, Civil Division LP Plaintiff CUMBERLAND County V. No. 12-3450 CIVIL JANET M.BRYANT-SCOTT TROY W.SCOTT,III THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendant(s) PRAECIPE TO THE PROTHONOTARY: ❑ Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled, Discontinued and Ended. ® Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. Date: 1 PHELAN HALL AN,LLP &seph . lk,Es , Id. o.91656 ey for Plaintiff PH#771591 OL gq.Sold a crt�u 36O'91>,v Phelan Hallinan,LLP Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA, N.A. SUCCESSOR BY MERGER Court of Common Pleas TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP Civil Division Plaintiff CUMBERLAND County V. No. 12-3450 CIVIL JANET M.BRYANT-SCOTT TROY W.SCOTT,III THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA Defendant(s) CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: JANET M. BRYANT-SCOTT TROY W. SCOTT,III 212 EDENDERRY WAY ENOLA, PA 17025-3414 Date: 1 2 Iq PHELAN HALL N, LLP B Jose halk,Esq., Id.No-91656 t rney for Plaintiff