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,d UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ALAN M. MINATO, ESQUIRE - ID#75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. 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 ELANA B. FLEHINGER, ESQUIRE - ID#209197 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadines@udren.com Bank of America, N.A. C/O Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. SUTATIP GRUNDON 2001 CHESTNUT STREET CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County n-y31Lo civil NO. 10? COMPLAINT IN MORTGAGE FORECLOSURE C ; - "OX m -a rn a a C= ? F n c ?c z - N a , x° 0 ©m v= % •• A 4 -< .97' ;l -< YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in t] following pages, you must take action within twenty (20) days after this Complaint and Noti are served, by entering a written appearance personally or by attorney and filing in writing wi the Court your defenses or objections to the claims set forth against you. You are warned that you fail to do so the case may proceed without you and a judgment may be entered against y4 by the Court without further notice for any money claimed in the Complaint or for any oth claim or relief requested by the Plaintiff. You may lose money or property or other rigl important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOI 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 MA-1 BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAI MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEEQP OA k-? C K? - -7-7 S f 1 < A , 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) dial de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 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. Assignee: Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing, LP Date of Assignment: 10/03/2011 Recorded Date: 10/19/2011 Book/Instrument #: Instrument #201128919 Page: n/a 2. Upon information and belief Defendant(s) and/or their predecessor: Sutatip Grundon (hereinafter "Defendants"), are the owners of property located at 2001 Chestnut Street, Camp Hill, PA 17011, by virtue of Deed dated 08/11/2005 and recorded 09115/2005 in Official Records Book 270 at Page 4827 of the Public Records of Cumberland County, Pennsylvania (hereinafter the "Property"). 3. On 04/22/2008, Defendant(s) and/or their predecessor: SUTATIP GRUNDON promised to pay to the order of M&T Bank , the principal sum of $ 125,000.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 04122/2008, Defendant(s) and/or their predecessor: SUTATIP GRUNDON to secure the Note, mortgaged to Mortgage Electronic Regsitration Systems, Inc., as nominee for M&T Bank, the Property which is the subject of this action. The Mortgage was recorded on 05/0212008 in Official Records Book Instrument #200814487 at Page n/a . 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 12101/2011, 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 $119,686.51 Accumulated Interest (due from 11/01/2011 to 06/29/2012) $5,133.26 Accumulated Late Charges $79.00 Escrow Deficit/(Reserve) $1,420.47 Title Report $325.00 Attorney Fees $1,300.00 Property Inspection Fees $90.00 Grand Total $128,034.24 The above figures are calculated as of 06/29/12: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 6.50000 %. The per diem interest accruing on this debt is $21.2558 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 $39.50. 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 $128,034.24 plus ongoing interest, costs and attorneys fees and for sale of the premises. UDREN LAW OFFICES, P.C. BY: "-- --- Alan M. Minato, Esquire PA ID 75860 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 V. SUTATIP GRUNDON 2001 CHESTNUT STREET CAMP HILL, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County NO. VERIFICATION Dd ^e f tq . cu d e~7te hereby states that (5h/she is A IJycnt ViCc' P10;di6t of Bank of America, N.A., Plaintiff in this matter, that Pshe is 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 O her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 7 - S " ?O l ? 0!. hk? Name: 7"u &A e f N?, e 2 Title: A 5f,')-Mn1-- V/C c' Pms i ,d tm?' Company: Bank of America N.A. MJU #: 12050057 CASE #: 12050057-1 25-07-`12 12;11 FROM-Premier Abstracts 3005456163 SCHEDULE "A" I T-569 P0015/0030 1-492 ALL THAT CERTAIN PIECE OR PARCEL OF LAND situate in the Borough of Camp Hill, County of Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at point on the west side of Pennsylvania Avenue (80 feet wide) as shown on the hereinafter mentioned plan of lots at the dividing line between Lot Nos. 180 and 181, Section "D"; THENCE North 78° 52' West, 114.57 feet to Lot No. 183, Section "D"; T14ENCE along said Lot No. 183, Section "D", North 110 28' East, 135.07 feet to the southern line of Chestnut Street; THENCE South 85° East, along the southern line of Chestnut Street, 97.63 feet (erroneously written on plan of record as 103.49) feet to a point; THENCE along a curve to the right having a radius of 13 feet, an arc distance of 26.96 feet to a point on the western line of Pennsylvania Avenue; THENCE along the western line of Pennsylvania Avenue, southwardly 129.97 feet to a point the place of beginning. BEING Lot Nos. 181 and 182, Section "D" in the Plan of College Park, recorded in Plan Book 4, Page 108, Cumberland County records. ' BankofAtnerica Home Loons PO Box 9048 Temecula, CA 92589-9048 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 111111111111111111111 7196 9006 9295 9617 5157 PRESORT First-Gass Mail U.S. Postage and Fees Paid WSO Iili.,III ..I-111-l"I.I+ 11111-rllllln?i?ll?lillrnl??.lnlli Sutatip Grundon 2001 Chestnut Street Camp Hill, PA 17011-5460 20120507-7 Exhibit A C3_1445 BLQPA1 14091 08724f2011 lapip efAmerica "llon Loans P.O. Box 942073 Simi Valley, CA 93094-1288 Sutatip Grundon 2001 Chestnut Street Camp Hill, PA 17011-5460 May 7, 2012 Send Payments to., P.O. Box 15222 Wilmington, DE 19686-5222 Certified Mail: 7196 9006 9295 9617 5157 Return Receipt Reauested Regular Mail Account No.: 184372872 Property Address: 2001 Chestnut Street Camp Hill, PA 17011-5460 Current Servicer: Bank of America, N.A. NOTICE OF INTENT TO FORECLOSE MORTGAGE Este as un aviso importante respecto a su derecho de ocupar su case. Favor de traducirlo de inmediato. (This is an important notice concerning your right to live in your home. Have it translated at once.) Our records indicate that you transferred all or a part of your interest in the above referenced property and/or allowed your mortgage loan to be assumed; however, you were not released from contractual liability for the loan. Therefore, you are still contractually responsible for repayment of this debt. We regret to advise you that this loan is in default, and we are prepared to initiate foreclosure proceedings. The following letter was sent to the current owner of the property: The MORTGAGE held by Fannie Mae (hereinafter we, us or ours) on your property located at 2001 Chestnut Street Cam Hill, PA 17011-5460 IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of.• Monthly Charaes: 12/01/2011 Account Number: 184372872-4 Sutatip Grundon 2001 Chestnut Street Camp Hill, PA 17011-5460 Late charges and other charges have also accrued to this date in the amount of $197.50 Late Charaes: 12/01/2011 $197.50 Other Charaes: Uncollected Late Charges: Uncollected Costs: Partial Payment Balance: $79.00 $75.00 ($0.00 ) TOTAL DUE: $8,207.36 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 $8,207.36. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $8,2 7.36, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made eith r by cash, cashier's check, certified check or money order, and made at Bank of America, N.A. at P.O. Box 15222, Wilmi ton, DE 19886-5222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payrr ants. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property, if the mortgage is fore sed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but y u cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually i curred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also Include our reasonable costs. If y u cure the default within the thirty (30) day period, you will not be required to pay attorneys fees. We may also sue you personalty for the unpaid principal balance and all other sums due under the mortgage. If you have! not cured This communication is from Bank of America, NA., the servicer of your home loan. Please write your account number on all checks and correspondence. We may charge you a fee (of up to 540.00) for any payment returned or rejected by your financial institution, subject to applicable law. C3_1445 BLQP 14001 06114/1011 Payment Instructions: • Make your check payable to Bank of America, N.A • Don't send cash • Please include coupon with your payment For all full month payment periods, interest is calculatedon a monthly basis. Accordingly, interest for all full months, including February, is calculated as 30/360 of annual interest, irrespective of the actual number of days in the month. For partial months, interest is calculated daily on the basis of a 365 day year. Balance Due for charges listed above: $8,207.36 as ct May 7, 2012. BLQPAI IIIIII I'll Ill'rllllli1Ill 111-11--F 11111 Ill', 11?1111111I11?I11nI Bank of America, N.A. PO BOX 15222 Wilmington, DE 19886-5222 1-888-872-6514 $7,855.86 AdksiOm?tl Prindpal Addt tine Escrow Check 7ota1 184372872400000820736000820736 1: 5869900 581: i8L, 3? 28? 211• ,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 orie hour before the Sheriffs foreclosure sale. You may do so by paying the total amo nt of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs nnected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date t?te t such a Sheriffs sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait 'You may find out at any time exactly what the required payment will be by calling us at the following number. 1-888-872-6514. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If yot} continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT LL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, yo are not entitled to this right to cure your default more than three times in any calendar year. Bank of America, N.A., the servicer of your home loan, is required by law to inform you that this communication is from a debt collector. This communication is from Bank of America, N.A., the servicer of your home loan. How we post your payme to: All accepted payments of principal and Interewill be applied to the longest outstanding instalment due, unless otherwise expressly prohibited or limited by law. If you submit an amount in addition to your scheduled monthly amount, we will apply tour payments as follows: (i) to outstanding monthly payments of principal and interest, (ii) escrow deficiencies, (iii) late charges and other amounts you ewe in connection with your loan and (lv) to reduce the outstanding principal balance of your loan. P ase specify if you want an additional amount applied future payments, rather than principal reduction. Postdated checks: Postdate checks will be processed on the date rece d unless a loan counselor agrees to honor the ate written on the check as a condition of a repayme plan. Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense Information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home ::::: :::•: ::::v. ...... .... n::: .{t. • w:: -.v ...... v x: C: •- .::. v.: ::•:::. .. x:.:v...:: ::.: ? ::..:.? i:•}•'J?t}::{: SqL: f• ?•J,}L v?{::1,• i :L•:LfL :.:{..} L{L :.{,.::$ :4?•.u :Y..viv.}• •.•.:£$ i3Y $$ '.}Yrri L+.. F« { £+:••y.•;.+}.t} ^ •: {:ti L ' r$T;:: ? $L}} .................. k ..{•:::.{+:::Rti?lr.:. .:11b--. }:.•.•:?}.:.^.:'•?.:t. . LY:: }-•.:v $y$+ }}}• L ON -' BE x : + '.G::i?:}ti:;?;i+L4 •.4i:{{} {2::L2{ry, .:: .. .:... C..:... ::. tt .:: vv:..2 y::s •:: n•:.+..::: •. w. ... .:.:....:::.. .....:•:: F}}}: :. ........ : . :.:. .......... <•}::+..:+:.:}:•}:•Y }}::{{?:.}}: •:..•:+ ..o •r::£;.`::3tL.......... r:i.+:'.. :.+ ... .a.. ::.:...... tt::: .: Y.v::: •: L:: :•. ?:: .:: •::: t:•::: w :::: v r+•:..: }}:: +::+ .:.: v:?• ..?.: :: :..kL :..:}?t::j•:...1.d:{}•:` }.',:•r:•}::}::+.::: . ?::'?t ?::i:[.« :. / 3 +f fi. • ? .. :. ` e H ....... ..::: ..::.: :.. t<{{.}} •:L< ,}.:{ :ry:.:: :/ A federal government program that allows you to repay the loan on newly agreed upon terms, which om Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or Modification extending the term of the loan. You may be eligible for this program if you meet the following Program requirements: (HAMP) 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-fa ily home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 fora unit property • You have experienced a hardship that has impacted your income. For example, a significa nt increase in your mortgage payment OR reduction in your income OR other hardship. • Your mortgage was obtained before Jan. 1, 2009. a 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 incom e. To calculate this, divide your first mortgage payment by your gross income (income before to es). Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the to n 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 ith Plan regular mortgage payments. This may include principal, interest, fees, and/or costs assessed t your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payment 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, pla cing 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 bri ng your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is pa due. Options to consider if you cannot or do not wish to stay in your home Home Designed to help borrowers who are eligible for the Home Affordable Modification Program (H %MP) Affordable but were unsuccessful in securing a permanent modification through the program. HAFA prow es the Foreclosure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a trans ction Alternatives in which you sell your property for less than the total amount owed on the loan (subject to agr ement Program by your servicer/lender/investor), resulting in the release of our lien on your home and avoids ce of (HAFA) foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily tran fer ownership of your property to us in order to avoid foreclosure. Short Sale/ Offered to borrowers who are not eligible for HAMP or other home retention alternatives. With a short Preforeclosure sale, you sell your property for less than the total amount owed on the loan (subject to agreem ent 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 we a 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 here to help you. Please call us today. 7196 9006 9295 19617 5157 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notificaci6n adjunta para obtener mats informaci6n Cuando (lame, tenga to informacidn de sus ingresos y gastos disponibles pare quo podamos discutir cual opcibn(es) pueden funcionar para usted. 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Un programa del gobierno federal qua le permite pager el pr6stamo bajo los nuevos tbrmino Modification acordados, qua pueden incluir la reducci6n de la tasa de inter6s, agregando la cantidad ade dada Program (RAMP) al final del pr6stamo, y / o extender el plazo del pr6stamo. Usted puede ser elegible pare est programa si cumple con los siguientes requisitos: La casa as su residencia principal y actualmente vive an ella. • La cantidad adeudada an la primers hipoteca debe ser igual o menos qua $729,750 d61 res 200 d6lares pare una propiedad de 2 unidades, $1,1 $934 na vivienda unifamiliar ra 29,250 , , u pa 403,400 para una propiedad de 4 unida iedad de 3 unidades o $1 are una ro s d6l es , p p are p Ha experimentado una dificultad qua he afectado sus ingresos. Por ejemplo, un aumen significativo an su pago hipotecario O reducci6n de sus ingresos U otras dificultades. • Obtuvo su hipoteca antes del 01 de enero 2009. • Su pago de la primers hipoteca (incluyendo principal, inter6s, impuestos, seguro y cuot de asociaci6n de propietarios, si se aplica) debe ser mss del 31 % de sus ingresos brutos a tuales. Para calcular esto, divida su pago hipotecario por sus ingresos brutos (ingresos antes d impuestos). Restablecimiento Si usted puede traer sus pagos del pr6stamo hipotecario al dia, se le aceptardn los fondos del Pr6stamo necesarios para que el pr6stamo este al dia hasta la fecha de la venta judicial. Plan de Pago Un acuerdo temporal qua permite el pago de la cantidad adeudada, cantidad del pago atra do junto con los pagos regulares de le hipoteca. Esto puede incluir principal, inter6s, honorario y/o costos aplicados a su pr6stamo. Acuerdo Un acuerdo por el cual nos comprometemos a no proceder con la ejecuci6n hipotecaria y/o Temporal de colecci6n de pagos por un periodo de tiempo, para permitirle que restablezca su habilidad d Tolerancia hacer los pagos requeridos. Modificaci6n de Pagar el pr6stamo bajo los nuevos t&rminos acordados, qua puede incluir la reducci6n de le y/o extender el plazo del la cantidad adeudada al final del pr6stamo d 6 tasa Pr6stamo , o s, agregan de inter (no por medio pr6stamo. de HAMP) Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos es n (solamente vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, este pro rama prestamos de to est6 diseflado para qua su pr6stamo este al dia mediante la creaci6n de una segunda hipot ca / FHA) gravamen sobre su propiedad por la cantidad adeudada. Opciones a considerar si no puede o no desea quedarse on su casa !: 5' ':3%}:3:•'}}}:?:C::::f 3:::}:'::}: 43 '$}. ? i.:: {:.:?y i ••.f.•::+i::: } 4"2":33::. :.L,k .2"v!i q %ry } ' {• I :::,v:: • , ; ::.:3}:•L3 .:... J.. ..:.:.:.', {}i ,x .x,:x. i v :,. .:.{. r }}h:.TiC• { T ::? I v{{:4ti ... Ti }:}L:.}:{•}:•Ti } .. :::. Yi. : ::.xi.4+• ... ,? r> n,.S:} r.} `4;:3:{?:i.. . v. .3 ....... .... ......: .. ....:.. . n.. v :...:.. n.T:•i}:t•}}::: ::::wnv.v: :} :-.•'ii::- }}:.{}3}'i::33:::: xf?: •C}::433:::. LLL- :? ..} ::}} • : - nv:•::.??:...:.:.:-::..::::.:;•}:x{--:::.v:::v:i:•:r•:,...:.vv: ?':: .. •.v:,...-:; •:::.:::::. •. :.:.. '.:{tY}}}}3ii:LL •'ri??3:::}:333::3::ivy ?^ ...........1: {{• : 32C }iv: ::: n ::::: }.:.J:,:•- ......v.:.... .... :. v::. , ::::. i.,}}: ::: n. x•:;;j -.::., ..:v::y}:L::-+.L:.•} :...?::.}}::}:3;::>F3?CL,.nv:: ..........{F•}:3 :3,}7#: :{{}:{:s}: {:{:..i:..>{ .:::..:.....:::::..r:.?t{:::: }:{{.........:....... ..#:: ... •: ''' . {. ,t. . }: . J ?/ si ' : : :R:>: }: :k: £ ? ::: '3 : ??<:4:: 4 ?' ? ? ' 3 ..... ... '. • .::: :.: :.:.:. $}.:4e: ::t:{ - ::: iii: Home ... {{ ..... . .: .. . {.: ..:,...,:: . . : . : c : : : : Diseflado para ayudar a los prestatarios qua son elegibles para el Programa de Home Afford ble Affordable Modification (HAMP), pero no tuvieron 6xito en obtener una modificaci6n permanente a trav6 del Foreclosure programa. HAFA ofrece la posibilidad de una vents corta y, si no tiene 6xito, una entrega de Alternatives escritura para evitar juicio hipotecario. Una yenta corta as una transacci6n en la qua usted nde su propiedad por menos de la cantidad adeudada en el pr6stamo (sujeto a previo acuerdo de su Program (HAFA) administrador / prestamista / inversionista), resultando an la liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una entrega de escritura para evitar juicio hipotecario es una transacci6n an la qua usted est6 de acuerdo de transferir voluntaria las escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. ente Venta Corta/ Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci6 de Venta antes de hogar. Con una venta corta, usted vende su propiedad por menos de la cantidad total adeud da an Ejecucibn el pr6stamo (sujeto a un acuerdo por su administrador / prestamista / inversionista), resultand en la Hipotecaria (no liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitando la ejecuci6n hipote ria. por medio de HAFA) Entrega de Se ofrece a los prestatarios que no son elegibles para HAMP u otras alternativas de retenci8 de Escritura Para hogar, y qua no pudieron vender la propiedad a trav6s de una yenta corta. Con una entrega e Evitar Juicio escritura para evitar juicio hipotecario, usted estS de acuerdo a transferir voluntariamente las Hipotecario escrituras de su propiedad a nosotros para evitar la ejecuci6n hipotecaria. (no por medio de HAFA) Estamos aqui para ayudarle. Por favor llamenos hoy. FOKMI I Tli THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,. FlaintsfF. J) .U.A ? G M(f % (.C, C ?A G? N . vs, rr• S? GL P v f i.???? ter- = _ . ?z} -Q31(D i N C Defendant(s) vil C(? x C•') NOTICE OF REST DENTIAL MORTGAGE FORECL HE DIVERSION PROGRAM Y,,u 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 a1awyer, you must take the f91tvwing ateps to be eligible for a conciliation conference. Firs, 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 ibe appointment date. During that meeting, you must provide the legal representative with all requested financial in-formation 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 beretb, the. legal representative will prepare and file a Request for COnciliatic Conference ;?;-ith the Court, which must be filed with the Court within sixty (60) days of the service upon you the foreclosure complaint. If you do so and a coneiliatiou conference is scheduled, you will have an opportur_ity 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 forevard. if you are represented by a Wwyer, you. and your lawyer must take the following steps to be eligible for a eonciliation.,ronfer . It is not necessary foryou to contact. Mi&enri Legal Service for the appointment of a legal representative. However, you trust 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 comple a financial worksheet in be format attached hereto, your lawyer will prepare and file a Request for Conciliati, Conference vti ith the Cowl, which trust be filed with the Court within sixty (60) days of the service upon you the foreclosure complaint. If you do so and a conciliation conference is scheduled, you till have an opportunizv 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, JF YOU WISH TO SAYE YOUR HOW, YOU MUST ACT QUICIaY AND TAKE THE STEPS REQ01RED BY THIS NOTICE. THIS PROGRAM IS FRIM, Respectful Iv subrnixed_.. -- - < ~? Datz (SibmMture of Counsel for Plaintiff] r irn 39 O? M. Minato, v Squire PA ID 75860 FORM 3 Plaintiff(s) Vs. Def ndant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated .2012 governing the Cumberlan, Count-v Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the o?•mr of the real property which is the subject of this mortgage foreclosure ac1don; 2. Defendant lives in the subject real property, which is defendant's primary residence; Defendant has been sen°ed with a "Notice or 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 con iIiation conference. The undersigned verities. 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 ti unsv orn falsification to authorities. Signature of Def=dant's Counsel/Appointed Legal Representative Signature of Defendant N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Date Date Signature of Defendant Date FORM 21 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Workskeet Date Cumberland County Court of Common Pleas Docket # Borrower name(s): Property Address: City: State; Zip: Is the property for sale? Yes ? No ? Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ? No ? Mailing Address (if different): City: State: Zip: Phone Nizubers: Home: Office: Cell: Other: Email: 4 of people in household: Mailing Address: City: Phone Numbers: Email: of people in household:. First MorTc=e Lender: _ Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for DefaWt: How long? State: Zip: Home: Office: Cell: Other: How- long,? Date You Closed Your Loan: Is the lown in Bankruptcy? Yes ? No ? BORROIV`ER REQUF-ST 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: If yes, provide names, location: of court; case number & artomey: t Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year, Amount owed- Value: Automobile 92: Model, Year: Amount owed.: Value: Other transportation (automobiles. boats. motorcycles):.Model: 'Sear: Amount owed: Value Monthiv Income Name of Employers: 1- L. Additional Income Desczepdon (not waves): L monthly amount: 2, monthly amount: Borrower Pay Days: Co-Borrower Fay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMC?U?>iT ! EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payment(s) Condo/Ke . Fees Auto hisuranee Med. (not covered) Auto fit.-]/repairs Other prop. a merit I lnstall. Loan Payment Cable TV Ch0d Su ord.Alim. S endi,n Money i Day/Child CarelTuit. i Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counselirtig Agency? I i Yes ? No ? If yes, please provide the follow.-ing information: Counseling Agency: Counselor: Phone (Offlce): Fax:- 2 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 ALAN M. MINATO, ESQUIRE - ID#75860 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 PAIGE M. BELLING, ESQUIRE - ID#309091 HARRY B. REESE, ESQUIRE - ID#310501 KASSIA FIALKOFF, ESQUIRE - ID#310530 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 AGNES MOMBRUN, ESQUIRE - ID#309356 ELANA B. FLEHINGER, ESQUIRE - ID#209197 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadinssu,udren.com =ILED-OF ICE OF THE FROTH OTAR?Y 2012JUL 12 A 9:44 C Bank of America, N.A. COURT OF COMMON PLEAS 16001 North Dallas Parkway, Addison, TX CIVIL DIVISION 75006 CUMBERLAND County Plaintiff SUTATIP GRUNDON 2001 CHESTNUT STREET CAMP HILL, PA 17011 Defendant(s) TO THE PROTHONOTARY: NO. )d -u31b &Vi 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; Kassia Fialkoff, Esquire; Salvatore Carollo, Esquire; Elizabeth L. Wassall, Esquire; Agnes Mombrun, Esquire; Elana B. Flehinger, Esquire; on behalf of the Plaintiff, in the above- captioned matter. UDREN LAW OFFICES, P.C. BY: - TY Alan M. Minato, Esquire PA ID 75860 SHERIFF'S OFFICE OF CUMBERLA14D COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Coop et CRWbrty, Cs. Of r CE OF E 64ERIFX FILEfl T Of THE PRON 2012 JUL 30 AM 9: 0 j cure gA Bank of America, NA VS. (case Numb Sutatip Grundon 2012-4316 SHERIFF'S RETURN OF SERVICE 07/18/2012 08:35 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to taw, states that on July 18, 2012 at 2035 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: Sutati Grundon, by making known unto Praduang Manning, Mother of Defendant at 2001 Chestnut Street, Camp Hill, Ccrrnberland County, Pennsylvania 17011 its contents and at the same time handing to her person iii the said true and correct copy of the same. r SHERIFF COST: $43.00 July 23, 2012 (c) CountySuite Sheriff, Teleosoft. Inc. SO ANSWERS, t 2 RON R ANDERSON, UDREN LAW' OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsC~udren.com __ Bank of America, N.A. Plaintiff ATTORNEY FOR. PLAINTIFF ~, .. ... .~ . _ ~r=, ~ n =,1';jr~ COURT OF COMMON PLEAS CIVIL DNISION Cumberland County ti. MORTGAGE FORECLOSURE SUTATIP GRUNDON, Defendant(s) NO. 12-4316-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), SUTATIP GRUNDON, who/each of whom is over 18 years of age isiare not in active military service as defined in the Servicemembers' Civii Re~hef Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth andior Social Security numbers} for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.~S. X4904 relating to unsworu falsification to authorities. ~ ` Dated: October 16, 2012 ~~ r ~ ~~ % /` ~~ / I~l, Attorne} or Iainti f ~ ~ ;~at~E M. SELLING, ESI~UIFtE PA ID 309091 MJU#: 12050057 CASE#: 12050057-1 Department of Defense Manpower Data Center ~L63.~~a.~ elC°~l C3:rt ~~ l'~arsutirtt i~a ~~r~~ic~rn~;bwr'~ (:'~~•~ai l~t~li~z`.~.a; f;~ ~~r Last Name: GRUNDON First Name: SUTATIP Middle Name: Active Duty Status As Of: Oct-16-2012 GesuRs as of :Oct-16-2012 09:5230 SCRA 23 On Active Dury On Active Duty Status Date Active Dutv Start Date Active Duty End Date Status Serv+ce Component PdA NA .-_. __-.- ~~ --------- No ~~ NA This response reflects the. individuals' active duty status basetl on the Active Dury Status Date ___ Left Active Duty Within 367 Days of Active Duty Status Date Active Dutv Start Date Active Duty End Date Status Service Component t`IA it NA _._ _ No r1A 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 W as Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date i Order Notification E=nd Date S[atus Service Component N A NA ~, ------- No ~ NA This response reflects whether the individual or hislher unit has received early notification to report for active tluty Upon searching the data banks of the Department of Defense P~ianpower 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). ?his status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ~• Mary M. Snavely-Dixon. Director Department of Defense -Manpower Data Center 4800 Mark Center Grive. Suite 04E25 Arlington. VA 22356 r 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 stronoly supports the enforcement of the Servicemernbers Civil Relief Act (50 USC App. § 501 et seq. as amendedt (SCRA1 {formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual references above, or any family member, frienc, or representative asserts in any manner that the individual was on active duty for the active duty status date, or cs 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:/rwww.defenselink.mil/faglpis/PC09SLDR.html. If you have evidence the person was on active duty fo• the active duty status date and you fail tc obtain this additional Service verification, punitive provisions of the SCRA may he invoked against you. See 50 L!SC 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 witnin 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification tc 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 cal' 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 py Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mooiiizanon position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARsI and Coast Guard Reserve program Admmistrator lRPAst. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S public Health Serv ce or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps 1. 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 lJniforrneC Services periods. Title 32 periods of .fictive Duty are not covered by SCRA. as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to ex*end 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 incusive 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. Tne Last Date on Active Duty entry is important because a number o~ 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 Serv ce members under the SCRA are protected WARNING: This certificate was provieed based on a last name, SSN/date of birth, and active dut)~ status date provided by the requester Providing erroneous information will cause an erroneous certificate to be provided. Certificate IC: CK21 M1 OC5Q y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i ����titr pt�aa�nGrr��i Jt Jody S Smith Chief Deputy n v l ]j Ali 1` Richard W Stewart Solicitors PE H 1� YLVi j J Nationstar Mortgage LLC Case Number vs. Sutatip Grundon 2012-4316 SHERIFF'S RETURN OF SERVICE 01/04/2013 07:55 PM -Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 2001 Chestnut Street, Camp Hill, PA 17011, Cumberland County. 01/07/2013 06:57 PM -Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Sutatip Grundon at 2001 Chestnut Street, Camp Hill Borough, Camp Hill, PA 17011, Cumberland County. 02/20/2013 As directed by Mark J Udren, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 04/03/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Room 303, Carlisle, PA on April 3, 2013 at 10:00 a.m.. He sold the same for the sum of$1.00 to Attorney Mark Udren, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,154.45 SO ANSWERS, May 17, 2013 RONFrY R ANDERSON, SHERIFF 0 p o?, sz, u �, _ 44 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 Sutatip Grundona ' Defendant(s) MORTGAGE FORECLOSURE X, NO. 12-4316-CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Bank of America,N.A., Plaintiff in the above action,by its undersigned attorney,upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at: 2001 Chestnut Street, Camp Hill,PA 17011 1.Name and address of Owner(s) or reputed Owner(s): Sutatip Grundon 2001 Chestnut Street Camp Hill,PA 17011 2.Name and address of Defendant(s) in the judgment: Sutatip Grundon 2001 Chestnut Street Camp Hill, PA 17011 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 Manufacturers and Traders Trust Company 1 Fountain Plaza,4th Floor Buffalo,NY 14203 ,. 3 . Members lit Federal Credit Union 5000 Louise Drive Mechanicsburg,PA 17055 5. Name and address of every other person who has any record lien on the property: Sr lien Holders-None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle,PA 17013 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle,PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg,PA 17128-1230 Tenants/Occupants 2001 Chestnut Street Camp Hill, PA 17011 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 unswom falsification to authorities. DATED: UDREN LAW OFFICES, P.C. BY: Attorney for Plaintiff Katherine E. Knowlton, Esq PA SD 311713 MJU#: 12050057 CASE#: 12050057-1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com Bank of America,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County SUTATIP GRUNDON MORTGAGE FORECLOSURE Defendant(s) NO. 12-4316-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Sutatip Grundon 2001 Chestnut Street Camp Hill, PA 17011 Your house(real estate) at 2001 Chestnut Street, Camp Hill, PA 17011 is scheduled to be sold at the Sheriffs Sale on March 6, 2013 at 10:00am at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle, PA 17013, to enforce the court judgment of$130,214.55, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ALL THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE BOROUGH OF CAMP HILL,COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA,MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS,TO WIT: BEGINNING AT POINT ON THE WEST SIDE OF PENNSYLVANIA AVENUE(80 FEET WIDE) AS SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS AT THE DIVIDING LINE BETWEEN LOTS NOS. 180 AN D181, SECTION "D'; THENCE NORTH 780 52' WEST, 114.57 FEET TO LOT NO. 183, SECTION"D"; THENCE ALONG SAID LOT NO. 183, SECTION"D",NORTH 11° 28' EAST, 135.07 FEET TO THE SOUTHERN LINE OF CHESTNUT STREET; THENCE SOUTH 85° EAST,ALONG THE SOUTHERN LINE OF CHESTNUT STREET, 97.63 FEET (ERRONEOUSLY WRITTEN ON PLAN OF RECORD AS 103.49)FEET TO A POINT; THENCE ALONG A CURVE TO THE RIGHT HAVING A RADIUS OF 15 FEET,AN ARC DISTANCE OF 26.96 FEET TO A POINT ON THE WESTERN LINE OF PENNSYLVANIA AVENUE; THENCE ALONG THE WESTERN LINE OF PENNSYLVANIA AVENUE, SOUTHWARDLY 129.97 FEET TO A POINT THE PLACE OF BEGINNING. BEING LOT NOS. 181 AND 182, SECTION"D" IN THE PLAN OF COLLEGE PARK, RECORDED IN PLAN BOOK 4, PAGE 108, CUMBERLAND COUNTY RECORDS. BEING KNOWN AS: 2001 CHESTNUT STREET, CAMP HILL, PA 17011 PROPERTY ID NO.: 01-22-0536-152 TITLE TO SAID PREMISES IS VESTED IN SUT.ATIP GRUNDON,A MARRIED WOMAN BY DEED FROM THOMAS R. GRUNDON AND SUTATIP GRUNDON, HUSBAND AND WIFE DATED 0811112005 RECORDED 09115/2005 IN DEED BOOK 270 PAGE 4827. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-4316 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 SUTATIP GRUNDON (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: $130,214.55 L.L.: .50 Interest FROM 10/5/2012 TO DATE OF SALE MARCH 6,2013 ONGOING PER DIEM OF$21.26 TO ACTUAL DATE OF SALE INCLUDING IF SALE IS HELD AT A LATER DATE-$3,252.13 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $194.25 Other Costs: Plaintiff Paid: Date: 10/19/12 David D. Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name: KATHERINE E. KNOWLTON, ESQUIRE Address: UDREN LAW OFFICES,P.C. 111 WOODCREST ROAD,SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for:PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 311713 TRUE COPY FROM RECORD In Testimony whereof,I here unto set my hand and the sea of said Court t Ca isle,Pa. This _-I-'day of_ ,20-/,/)- rothonotary t Ap G e On October 25, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Camp Hill Borough, Cumberland County, PA, Known and numbered as, 2001 Chestnut Street, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 25, 2012 By: Real Estate Coordinator h 13 'd E i'0 1107 CUMBERLAND LAW JOURNAL Writ No. 2012-4316 Civil Bank of America, NA VS. Sutatip Grundon Atty.: Mark J.Udren ALL THAT CERTAIN piece or par- cel of land situate in the Borough of Camp Hill, County of Cumberland and Commonwealth of Pennsylva- nia, more particularly bounded and described as follows,to wit: BEGINNING at point on the west side of Pennsylvania Avenue(80 feet wide) as shown on the hereinafter mentioned Plan of Lots at the divid- ing line between Lots Nos. 180 an dl81, Section"D";thence North 78° 52'West, 114.57 feet to Lot No. 183, Section "D"; thence along said Lot No. 183, Section "D", North 11" 28' East, 135.07 feet to the southern line of Chestnut Street;thence South 85° East, along the southern line of Chestnut Street, 97.63 feet(errone- ously written on plan of record as 103.49)feet to a point;thence along a curve to the right having a radius of.15 feet, an arc distance of 26.96 feet to a point on the western line of Pennsylvania Avenue; thence along the western line of Pennsylvania Av- enue, southwardly 129.97 feet to a point the place of BEGINNING. BEING Lot Nos. 181 and 182,Sec- tion"D"in the Plan of College Park, recorded in Plan Book 4, Page 108, Cumberland County Records. BEING KNOWN AS: 2001 Chest- nut Street, Camp Hill,PA 17011. PROPERTY ID NO.: 01-22-0536- 152. TITLE TO SAID PREMISES is vested in Sutatip Grundon, a mar- ried woman by Deed from Thomas R. Grundon and Sutatip Grundon, husband and wife dated 08/11/2005 recorded 09/15/2005 in Deed Book 270 Page 4827. 57 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1, and February 8, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. isa Marie Coyne, tditor SWORN TO AND SUBSCRIBED before me this da of Februaz 2013 d- Notary 760ROUGH,IAL SEAL A COLLINS y Public CA CUMBERLAND COUNTY My oExpires Apr 28,2014 i The Patriot-News Co. • 2020 Technology Pkwy �10 ews Suite 300 t4e Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds it `-_ chin in Miscellaneous Book"M", Volume 14, Page 317. 20124316 CMI Bank of America, Vs SuwdpGrandon This ad ran on the date(s)shown below: /qty; Mark J Vdren THAT CERTAIN PIECE OR _ 01/22113 CEL OF LAND SITUATE IN 01/29/13 THE BOROUGH OF CAMP HILL COUNTY, OF CUMBERLAND. 02/05/13 AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND . . . . . . . . . . . . . . . . . . . . . . . . . DESCRIBED AS FOLLOWS,TO W.I'P. BEGINNING AT POINT ON THE WEST SIDE OF PENNSYLVANIA AVENUE Sworn to and sub cribed before me this 14 day of February, 2013 A.D. FEET WIDE)AS SHOWN ON THE Nota u SECTION "D"; THENCE NORTH 78° 52' WEST 11457 FEET TO LOT NO. 183,SECTION"D";THENCE ALO NG SAID LOT.NO. 183, SECTION "D", NoRm 11°28'EAST,135.07 FEET TO COMMONWEALTH OF PENNSYLVANIA THE SOUTHERN LINE OF CHESTNUT Notarial Seal STREET, THENCE SOUTH 85° EAST Holly Lynn Warfel,Notary Public i ALONG THE SO .LINE OF CHESTNUT 63 FEET Washington Twp.,Dauphin county (ERRONEOU,L ON PLAN My Commission Expires Dec.12,2016 OF RECORD AS 103.49)FEET TO A MEMBER,PENNSYLVANIA ASSpCZATION OF NOTARIES POINT;THENCEALONG ACURVE TO THE RIGHT HAVING A RADIUS OF .15 FEET;AN ARC DISTANCE OF 26.9y FEET TO A POINT O THE WESTERN LINE OF PENNSYLVANIA AVENUE; THENCE ALQ, " THE WESTERN LINE OF AVENUE, SOUTHWARDLY 129. TO A POINT THE PLACE OF BEGINNING. BEING. LOT NOS.,181 'AND 182, SECTION "D" IN THE PLAN OF COLLEGE PARK, "RECORDED IN PLAN BOOK 4, PAGE 108, CUMBERLAND COUNTY RECORDS. BEING KNOWN A: 2001 CHESTNUT STREET-CAMP HII,I.,PA 17011 PROPERTY ID NO.:01-22-0536-152`_L TIT7 TO SAID PREMISESIS VESTED IN SUTATIP GRUNDON,A MARRIED WOMAN BY DEED FROM THOMAS R. GRUNDON AND SUTATIP GRUNDON, HUSBAND AND WIFE DATED 08/11/1005'RECORDED 09/15/2005 IN DEED BOOK 270 PAGE 4827. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 3rd day of Aril A.D., 2013, under and by virtue of a writ Execution issued on the 19th day of October, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 4316, at the suit of Bank of America,N.A. against Sutatip Grundon is duly recorded as Instrument Number 201318605. IN TESTIMONY WHEREOF, I have hereunto set my hand an seal of said office this day of ,A.D. C;2 4iss4lm rder of Deeds c canhr,Cadlste,w► a the Fort Monday of Jan.2014