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Home My WebLink About13-0397ti~ .fir L ~1^4 ~i ~ ~ ~'~3 ~ J~.~ 24 ~~ ~~,. f V ~~ Eri{~ar~,,~ PHEI.AN }iALLINAN, I_LP I3rian Yoder, Esq., Id. No.207412 1617 JFK E3oulevard, Suite 1400 One Penn Center Playa Philadelphia. PA 19103 215-563-7000 BANK OF AMF,RICA, N.A., SUCCESSOR BY MERGER "TO BAC HOME LOANS SERVICING. LP FKA COUNIRYWIUE HOME LOANS SERVICING, LP 7105 CORPORA"TI? DRIVE PIANO, "TX 75024 Plaintiff v. MICHELLE L. KAIL, DEBRA KAIL 848 LINDSI;Y ROAD CARLISLE, PA 17015-9223 Defendants f1TTORNl3Y FOR PLAIN"T1FF COURT OF COMMON PI,LAS CIVII. DIVISION 'T'ERM NO. ~ ~ .~~ ~ f V~~ Ct1MBERLAND COUN"fY CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE _,.,o ~;~,J afFu Pile W: 298440 ~.~ ~1t~ C~-# ~ ~c~~ ~ ~l ~~~s~~g NOTICF, 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 a.nd 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 "I'O YOUR LAWYER A'f ONCE. 1F YOU DO NO"f I fAVI~, A LAWYER, GO 'f0 OR TELEPHONE THE OFFICE SET FOR'TI I BELOW. 1~}IIS OFFICI; 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 LEUAL SERVICES T'O ELIGIBLE PERSONS AT A REDl1CED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY RF,I~ERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENilI CARLISLE, PA ] 7013 (717) 249-3166 (800)990-9108 File'i- ?~>8440 1. Plaintiff is BANK OF AMERICA, N.A., SUCCESSOR BY MERGER 'I'(:) BAC HOME LOANS SF,RVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING. 1,}' 7105 CORPORATE DRNE PLANO, TX i 5024 2. "fhe name(s) and last known address(es) of the Defendant(s) are: MICHELLI? L. KAIL DEBRA KAIL, 848 LINDSEY ROAD CARI,ISLF,, PA 17015-9223 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/02/2008 MICHELLE L. KAIL, and DF,BRA KAIL made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE EI.I?C"1'RONIC REGIS'T'RATION SYSTEMS, INC. AS A NOMINEE FOR SF,CURITY ATLAN"I'IC MORTGAGE CO. which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200825'212. By Assignment of Mortgage recorded 10/12/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201 128238."1'he mortgage and assignment(s), if any, are matters oI' 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 i C those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. fhe mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01 /2010 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 r~i~ a a~~saao by written notice sent to Mortgagor, the entire principal balance and all interest due 6 thereon are collectible forthwith. The following amounts are due on the mortgage as of 11/15/2012: Principal Balance $237,445.56 Interest $34,429.67 07/01/2010 through 11/30/2012 Late Charges $535.81 Property Inspections $15.00 Escrow Deficit $12,013.18 TOTAL X284,439.22 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. The action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. I'i~e u~ z~~s4ao WIIERI:FURI, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $284,439.22, 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 HALI,INAN, LLP i3y: Brian Yoder; F_sq., Id. No.2074I2 Attorney for Plaintiff r~i~ a_ zs>a~a~o LEGAL DESCRIPTION AI,I, "CHAT CFK"hAIN tract or parcel of land and premises lying, being and situate in South Middleton 'Cwp, County of Cumberland, and State of Pennsylvania being more particularly described as follows: BEING the same land and premises more particularly described in Deed Book N32, Page 856. BI:~INCJ premises No. 848 Lindsey Road. BITING Tax Parcel / BR"I' 10-0636-0076-0000000-40. BEING the same land and premises which became vested in Nicholas F. Kail, Jr., and Debra K. Kail, his wiic, by deed from Raymond E. Diehl and Genevieve A. Diehl, his wife. Donald f?. Diehl and Suzanne Diehl, his wife and Randy L. Diehl and Nancy Diehl, his wife, dated 3/16/1987, recorded 3/17/1987, in the Cumberland County Clerk/Register's Office in Decd Book N32, Page 856. PROPF.R'I'Y ADDRESS: 848 LINDSEY ROAD, CARLISLE, PA 17015-9223 PARCEL. # 40-10-0636-07 t=ile #: 298440 VERIFICATION ~l ~ ~ ~~ p~icol 0~~. U~LQ, ~, ,hereby states that h sh is _ Q„R,~., of BANK OF AMERICA, N.A., servicing agent for Plaintiff in this matter, that he she 's 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 hi er information 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. ~~ ` ,~C r Name: DATE: I ' 4 ' a-O ~J ~(~~uQ R.G1~q,Cv~~~J ~., Title: BANK OF AMERICA, N.A. File#: 298440 Name: KAIL File #: 298990 Pa. R. C. P. 205.5 BANK OF AMERICA, N.A., SUCCESSOR BY MF,RGER ~IY) BAC HOME LOANS SERVICING, LP FKn COON"IRYWII)E HOME LOANS SERVICING. LP Plaintiff(s) vs. MICHELLE 1.. KAII, DEBRA KAIL Defendant(s) FORM 1 Updated Ol/lll/2011 ~-a r..~ ~ IN THl? COURT OF COMMON PI~ `~ r- _ OF CUMBERLAND COi1NTY, PENNS~iANdA `~-'-~ ~ as : r~.._~ ~ r'. ~ _ .„t' j,? ~.. ~J~ ~...i C7 -,- v ; ~~' n ~ c.s _..' ~ c7 ~;_ ~,, ~ _ C+ ~{ ( ~'~~~ Crvrl NOTICE OF RESIDF,NTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. Ifyou own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-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 a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. if you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty X60) 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 arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,, YOU MUST ACT Ql1ICKLY ANI) "TAKE THE STEPS REQ[JIRED BY "CRIB NOTICE. THIS PROGRAM IS FREE,. Respectfully submitted: Date Brian Yoder, Esq., Id. No.207412 Attorney for Plaintiff FOKM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket N BORROWER REQUEST FOR LIARDSHIP ASSISTANCE "fo complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the hest of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email _ State:___._ Zip: - _ Yes ^ No ^ Listing date: ~ _ ____Price: $ _ __ ___Realtor Phone: Yes ^ No ^ --------- State:----Z~p~ ---- _ Home: Office: Cel I: Other: N of people in household: How long? ___ Mailing Address: -~.._.., City: __ __ ________ _ State:_____Zip: _ __ _ Phone Numbers: Home: Officer Celt: Other: Email: # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: __ _ __ Date You Closed Your Loan: ___ _ Second Mortgage Lender: "type of Loan: ---------- ---------- L.oan Number: "Dotal Mortgage Payments Amount: $ Date of Last Payment: Included Faxes & Insurance: Primary Reason for Default: _ _ Is the loan in F3ankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets } lomr.' Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other: Automobile #I: Model: /mount Owed. $- --- $ - - -- $-- ~- -- Value:. $--- $-- Amount owed: _ Value: __ Automobile #2: Model: _ _ nmount owed: Value: -------- - - C~thei~ transp~rtation~utomobiles, boats, motorc Iles : Model: Year: f~nlOLlnt owed: Value __ Monthly Income Name of Employers ~ . Monthly Gross ~~ Monthly Gross_ 3~ __ __ Monthly Gross Additional Income Description (not wages): l . monthly amount: _ - 2. monthly amount: Year: Year: Monthly Net_ _ _Monthly Net _Monthly Net_ __ _ _ Iorrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying} FXPI NSF, --- __ - -- AMOUNT EXPENSE A M OUNT Mort a e _~~ ___ - ood _ _ _ _- -- 2"a Mortgage Utilities Car Payment(s) _ Condo/Nei~h. Fees Auto_Insurance - - _ _ - - Med. (not covered) - Auto fuel/repairs_ - ------- Other~rop_~ayment_ ----- Install. Loan Payment ' i Support//11im_ Day C hild CdrG/"Fuit. ----. Cable TV S~endin~ Money. _ --- Other Ex enses - __ - -- _ _ ___ Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Ycs ^ No ^ If yes. please provide the following information: Counseling .Agency: _ _ Counselor: Phone (Office): Fax: Email: Have ~rx~ made application for Homeowners Emergency Mortgage Assistance Program (HF,MAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Flave 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 known, regarding your lender and 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. 1/We understand that I/we am/are under no obligation to use the counseling 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: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) PHELAN HALLINAN, LLP D. Troy Sellars, Esq., Id. No. 210302 j: ritorney for Plaintiff 126 Locust Street , , ;ET P f' d fC � i Harrisburg, PA 17101 , ,s v t , 215-563-7000 x 1360 BANK OF AMERICA,N.A., SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, Civil Division LP 7105 CORPORATE DRIVE No. 13-397-CIVIL PLANO, TX 75024 Cumberland County Plaintiff v. MICHELLE L. KAIL DEBRA KAIL 848 LINDSEY ROAD CARLISLE,PA 17015-9223 Defendants MOTION TO LIFT CONCILIATION STAY Plaintiff, Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing, LP (hereinafter "Plaintiff'), by its attorney, D. Troy Sellars, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1. On January 24, 2013, Plaintiff filed a Complaint in Mortgage Foreclosure against Defendants for their failure to make monthly payments of principal and interest upon their mortgage due August 1, 2010, and each month thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit"A". 2. On January 31, 2013, Plaintiff completed service of the Complaint in Mortgage Foreclosure along with the Cumberland County Residential Mortgage Foreclosure Diversion Program Notice upon the Defendants. A true and correct copy of the Sheriff's Return of Service 792202 is attached hereto, made part hereof and marked as Exhibit`B". 3. Pursuant to the Cumberland County Administrative Order February 28, 2012, which created the Cumberland County Residential Mortgage Foreclosure Diversion Program, the Foreclosure action is stayed for sixty (60) days from the date of service. 4. Within 60 days after service of the complaint, the Defendants may opt into the program by filing a Request for Conciliation Conference with the Court. Upon the filing of the request, the Court will schedule a Conciliation Conference. The program provides that Defendants must contact MidPenn Legal Services within the first twenty (20) days of receipt of notice if not represented by counsel. 5. If more than sixty (60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendants have not opted to participate in the Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the Diversion Program. 6. Defendants failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty(60) days of service. 7. Since Defendants have opted not to participate in the Diversion Program, it is appropriate for the stay to be lifted. WHEREFORE, Plaintiff respectfully requests that this matter be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program and the automatic stay be lifted. Respectfully submitted, PHELAN HAL AN, LLP Date: '7/( /y BY: , D. Troy Sars, Esquire Attorney for Plaintiff 792202 Exhibit 44A,, elr c t.4 Toe S4 PHELAN HALLINAN,LLP -< o - 5 Brian Yoder,Esq.,Id.No.207412 1617 JFK Boulevard,Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP COURT OF COMMON PLEAS FKA COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION 7105 CORPORATE DRIVE PLANO, TX 75024 TERM �j Plaintiff NO. I. '3q tII 1 v. CUMBERLAND COUNTY MICHELLE L.KAIL DEBRA KAIL 848 LINDSEY ROAD CARLISLE,PA 17015-9223 Defendants CIVIL ACTION-LAW COMPLAINT IN MORTGAGE FORECLOSURE 011 y1/�] WebefebY I the POW netign within to be a frt t end owed CC of the orintnai fitk.1 of record File/4: 298440 FORM 1 IN C:OlOR`i'C)F COMMON PLEAS litWl< OF AML'.RICA.'N.A., SUCCESSOR ifY OF CUMCILRI.AND) COUNTY, PENNSYLVANIA MERGER TO BAC IIOMI;LOANS SERVICING, . LP I'KA COUN'I'I(YWION IIOMI;LOANS SERVICING, LP I'laintiff(s) • vs. MICHELLE L. KATE DEBRA KAIL Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject:of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender_ if you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First, within twenty(20)days of your receipt of this notice,you must contact Midlenn 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 a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(tiP)days of the service upon you of the foreclosure complaint. it'you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a rein esentati ve of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward, If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. it is not necessary for you to contact Midl'enn Legal Service for the appointment of a legal representative. I lowever,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf, Tfyou 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 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 arguments with your lender before the mortgage foreclosure suit proceeds fbrwnrd. IF"YOU WISII '1'C)SAVE YOUR IIOME,YOU MUST ACT QUICKLY AND TAKE TIlE STEPS REQUIRED BY TilIS NOTICE. THIS PROGRAM IS TREE, Respectfully submitted. 4270 Dare Brian Yoder,Esq., Id. No.207412 Attorney for Plaintiff • FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Duto _� _ Cumberland County Court of Common Pleas I)oeket If BORIOWER REQUEST FOR IIAIWSIIIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best ofyour knowledge: Borrower name(s): Property Address: Ci|y: _____�__ Smm: Zip: ____ Is the property for sale? Yes | / l�u�] Listing date: _Price: $ Realtor Num*: }l � ea|(nr|/hnnm:________ Borrower Occupied? YeuFl No | l Mailing Address(if different): City: 0tate:____�ip� ____ Phone Numbers: Komo: O[Gco: � CoU: _ Other: Email: ______, // of people in household: How long? CO-BORROWER Mailing Addres : City: State:._• _Zip:____ Phone Numbers: Home: 0ffimw: _ _ Cell: Other: )f-u[people inhousehold: !low long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage |,eudcr: 'l'ype of Loan: Loan Number: |Fatal Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Payment: Pt i*xryRelo»^ bLUoDxu|i: . . Is the loan in Bankruptcy? Yes I. Non If yes, provide names, local or of court, case number& attorney; __ -�'- = - Assets &mot Io/ Owed: Value. Home: � $__� Other Real listote; Retirement Funds: $ . hnexbnet/m: $��_ Checking: Savings: � $___�_ Other: Aytomg6ile-#1;y4ode/:__ _ ___ You, Amount owed: Value: Automobile#2: Model: Year.. _____ Amount owed: Value: ___ Other transportation motorcycles): Model: Year: Amount owed: Value Monthly income Name of Employers: Monthly Gross Monthly Net Monthly Gross Monthly Net Monthly (},00s Monthly Net Additional Income Description(not wages): l. _ ______ �monthly amount: ____ 2. monthly amount: Borrower Pay Days CoBorrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) �-� � ----- � -------- -� ------ --�—'�— [ EXPENSE A��0DNT EXPENSE AMOUNT � Mortgage_ Food - ------ — �� 2" Mortgage Car ^ � Cond /Nv�h� Fuou --_ Auto I mno � KYcd, (not uovgr�0___ Auto fuel/repairs Other prop payment Install. I,oan Payment � Cable'IV _ -- _ Ch ild Support/A tin" Spending Day/Child | [x| _ ____ Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Kuvvyou6coo `vurkingwhhnI|oupingCmmuc|ing Agency? YxpEi No [71 l[yco, please provide the following information: Counseling,Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes El No IF yes, please indicate the status of those negotiations: Please provide the following information, if'known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company(Name); Contact: Phone; 1/We, , authorize the above named to use/refer this information to my lenderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. T/We understand that 1/we am/are under no obligation to use the counseling services provided by the above named Borrower signature I)at ' Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 hank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set -firth 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 I,AWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE; OFFICE SET FORTH BELOW. 'FIBS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TillS OFFICE MAY BE ABLE TO PROVIDE YOU Willi INFORMKIION ABOUT AGENCIES 'FITAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY KITORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVF,NUE CARLISLE, 17013 (717)249-3166 (800)990-9108 1. Plainti If is BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC I I.OME LOANS SERVICING, LP EKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s)arc: MICI LELLE L. KATE I)I:iI3RA KALE 848 LINDSEY ROAD CARLISLE,PA 17015-9223 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 07/02/2008 MICHELLE L. KAIL and DEBRA K.AIL made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC. AS A NOMINEE FOR SECURITY ATLANTIC MORTGAGE CO. which mortgage is recorded in the Office of the Recorder of Deeds of CUME3ERLAND County, in Mortgage Instrument No. 200825212, By Assignment of Mortgage recorded 10/12/2011 the mortgage was assigned to PLAIN.I'LFL which Assignment is recorded in Assignment of Mortgage Instrument No. 201 128238.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, �f The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/20I0 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 dale 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 11/15/2012: Principal Balance $237,445.56 Interest $34,429.67 07/0112010 through 11/30/2012 Late Charges $535.81 Property Inspections $15.00 Escrow Deficit $12,013.18 TOTAL $284,439.22 Plaintiff is not seeking a judgment of personal liability (or an in personain 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 I.aw, 8. The action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $284,439.22, 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, LLP By: 2.57 Brian Yoder,Esq.,Id. No.207412 Attorney for Plaintiff LEGAL DESCRIPTION ALL TIJAT CERTAIN tract or parcel of land and premises lying, being and situate in South Middleton Twp, County of Cumberland, and State of Pennsylvania being more particularly described as follows: BEING the same land and premises more particularly described in Deed Book N32, Page 856. BEING premises No. 848 Lindsey Road. BEING Tax Parcel /BRT 10-0636-0076-0000000-40. BEING the same kind and premises which became vested in Nicholas F. Kail, Jr., and Debra K. Kail, his wife, by deed from Raymond E. Diehl and Genevieve A. Diehl, his wife, Donald E, Diehl and Suzanne Diehl, his wife and Randy L. Diehl and Nancy Diehl, his wile, dated 3/16/1987, recorded 3/17/1987, in the Cumberland County Clerk/Register's Office in Deed Book N32, Page 856. PROPERTY ADDRESS: 848 LINDSEY ROAD, CARLISLE, PA 17015-9223 PARCEL# 40-10-0636-07 ,;, VERIFICATION hereby states that h D is Q,.st,,c;NAsfi of BANK OF AMERICA, N.A., servicing agent for Plaintiff in this matter, that he she s 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 Iii, her infnrrnation 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. Narne � DATE: I 4- cQ \(ice u.C2,2.c . kx. , Title: BANK OF AMERICA, N.A. File#: 298440 Name: KAIL Exhibit "B" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Sheriff ut Jody S Smith Chief Deputy , `?,* Richard W Stewart Solicitor OFFICE OF THS SHERIFF Bank of America,NA.Successor by Merger to BAC Home Loans Servicing, Clad Number Michelle L.Kali 2013-397 SHERIFF'S RETURN OF SERVICE 01/31/2013 04:1e PM-Deputy Shawn Gutshall,being duly sworn according to law,served the requested Notice of Residential Mortgage Forecisoure Diversion Program&Complaint In Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit Debra K.Kail at 848 Lindsey Road,South Middleton Township,Carlisle,PA 17013 0 7 HA'r ,DEPUTY 01/31/2013 04:19 PM-Deputy Shawn Gutshall,being duly sworn according to law,served the requested Notice of Residential Mortgage Forecisoure Diversion Program&Complaint In Mortgage Foreclosure by handing a true copy to a person representing themselves to be Debra Krell,Sister of defendant,who accepted as "Adult Person In Charge"for Michelle L Karl at 848 Lindsey Road,South Middleton Township,Carlisle, PA 17015-9223. , , .<1 �..- -, c r•LL,DEPUTY SHERIFF COST:$50,00 SO ANSWERS, x.off:a February 06,2013 RONtgR ANDERSON,SHERIFF (c)Co%r SJtu Snots.TNwwit Inn PHELAN HALLINAN, LLP D. Troy Sellars, Esq., Id. No. 210302 Attorney for Plaintiff 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 1360 BANK OF AMERICA, N.A., SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, Civil Division LP 7105 CORPORATE DRIVE No. 13-397-CIVIL PLANO, TX 75024 Cumberland County Plaintiff v. MICHELLE L. KAIL DEBRA KAIL 848 LINDSEY ROAD CARLISLE, PA 17015-9223 Defendants CERTIFICATION OF SERVICE I, D. Troy Sellars, Esquire, certify that I caused true and correct copies of Plaintiff's Motion to Lift Conciliation Stay and proposed Order to be sent sent via first class mail to the person listed below on the date indicated: MICHELLE L. KAIL DEBRA KAIL 848 LINDSEY ROAD CARLISLE, PA 17015-9223 Date: 7/ 1y By: e , ). D. Troy Sellars, Esquire Attorney for Plaintiff 792202 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff v. MICHELLE L. KAIL DEBRA KAIL 848 LINDSEY ROAD CARLISLE, PA 17015-9223 Defendants Court of Common Pleas Civil Division No. 13 -397 -CIVIL Cumberland County m N r. >() Lf rn-- 173 N C) CD ORDER AND NOW, this 2"� day of M , 2014, upon consideration of Plaintiff's Motion to Lift Conciliation Stay in the above captioned matter, it is hereby ORDERED and DECREED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. CC: 792202 ichelle L. Kail ebra Kail . Troy Sellars, Esq., Id. No. 210302 Attorney for Plaintiff 0-c2c'es PHELAN HALLINAN, LLP D. Troy Sellars, Esq., Id. No. 210302 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 1360 MICHELLE L. KAIL DEBRA KAIL 848 LINDSEY ROAD CARLISLE, PA 17015-9223 792202 4 t PHELAN HALLINAN, LLP Michael. Dingerdissen, Esq., Id. No.317 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Michael.Dingerdissen@phelanhallinan.com 215-563-7000 'II t\Ll-iivi) COUNTY !NSYLVA NIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP vs. MICHELLE L. KAIL DEBRA KAIL Attorney for Plaintiff CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 13-397 CIVIL 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 MICHELLE L. KAIL and DEBRA KAIL, 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 $284,439.22 TOTAL $284,439.22 I hereby certify that (1) the Defendants' last known address is 848 LINDSEY ROAD, CARLISLE, PA 17015-9223, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. / Date /'O! ichael Dingerdissen, Esq., Id. No.317124 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: WIN 79220 J 9 a1 gsa Rik. 36 7)o4 pia hie /N/4 PHELAN HALLINAN, LLP Michael Dingerdissen, Esq., Id. No.317124 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Michael .Dingerdi ssen @phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP vs. MICHELLE L. KAIL DEBRA KAIL Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 13-397 CIVIL 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) MICHELLE L. KAIL and DEBRA KAIL 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, as amended. (b) that defendant MICHELLE L. KAIL is over 18 years of age and resides at 848 LINDSEY ROAD, CARLISLE, PA 17015-9223. (c) that defendant DEBRA KAIL is over 18 years of age and resides at 848 LINDSEY ROAD, CARLISLE, PA 17015-9223. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date40A if" PHfelan Hallinan, LLP Michael Dingerdissen, Esq., Id. No.317124 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 792202 Department of Defense Manpower Data Center Results as of : Jun -10-2014 12:16:11 AM SCRA 3.0 Status .ort Pursuant to Sery ceme bers Civil, Relief Act Last Name: KAIL First Name: DEBRA Middle Name: Active Duty Status As Of: Jun -10-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals' active duty, status based on the Active Duty Status Date Left Active Duty Within 367 Das 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 Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Results as of : Jun -10-2014 12:16:00 AM SCRA 3.0 Status Report Pursuant to Servieemenibers Civil. Relief Act Last Name: KAIL First Name: MICHELLE Middle Name: L Active Duty Status As Of: Jun -10-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA " No - NA This response reflects the individuals"active duty, status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA - NA - No I NA This response reflects where the individual lett 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 Date Status Service Component NA NA . No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based -on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ra_ 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 FKA COUNTRYWIDE : COURT OF COMMON PLEAS HOME LOANS SERVICING, LP vs. MICHELLE L. KAIL DEBRA KAIL against you on : CIVIL DIVISION : No. 13-397 CIVIL Notice is given that a Judgment in the above captioned matter has been entered Q)1 11\ iq By: If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Michael Dingerdissen, Esq., Id. No.317124 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. * * 792202 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP MICHELLE L. KALI, DEBRA KAIL TO: Plaintiff Defendant(s) MICHELLE L. KAIL 848 LINDSEY ROAD CARLISLE, PA 17015-9223 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DIVISION NO. 13-397 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT 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 AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT 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 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By;. PH # 792202 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Michael Dingerdissen, Esq., Id, No.317124 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP v. MICHELLE L. KAIL DEBRA KAIL TO: DEBRA KAIL 848 LINDSEY ROAD CARLISLE, PA 17015 - DATE OF NOTICE: Plaintiff Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 13-397 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT 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 AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT 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 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 792202 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Itat. 11igcrd s en, Esq., Id. No.317124 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME COURT OF COMMON PLEAS LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP CIVIL DIVISION PLAINTIFF : NO.: 13-397 CIVIL V. • MICHELLE L. KAIL : CUMBERLAND COUNTY DEBRA KAIL DEFENDANT(S) To the Prothonotary: Issue writ of execution in the above matter: _ Amount Due $284,439.22 triF -71; _ r OD 7 Interest from 06/12/2014 to Date of Sale $8,183.00 r-- ($46.76 —($46.76 per diem) x» c TOTAL $292,622.22 ti • Ph n Hallinan,LLP . Jonathan Lobb,Esq.,Id.No.312174 Attorney for Plaintiff ;1j3 PD 51/ 00 CI3F Note: Please attach description of property. 103.75 Ii PH#792202 !to.5b " .5o LL 611-1455c5i 308to57 2� Ct,Yit w a a c7 z U r-+ -ti a W c, u Z o inW O. .^ 0O O O x 3 �¢ _ �¢ � a w U " a Q ° ai N o � � .� Pa 4..j.. � � � � O Q 'JoU 12coU F. a W U' wa cs z gv o � 05 0 cf) a w � w ) az Ucr U Z � • v� w � E-I zW Oo M O — �: ci U '*d0 3 z O U x z w a bO Qqa u aQFi AW A O \ , , L g 4 � W w •W ' °d <pa Q . < 4, W o .G �a. U xQ ed. �a , 0-1 oOha xW w , vsg z xW \ = �" � a ( z8 o wA o a �aaUa w ti J:--{ .a;.. 1 HE P('3 T!'t't]'H'1",' PHELAN HALLINAN, LLP Attorneys for Plaintiff Jonathan Lobb, Esq., Id. No.312174 2 JUL =as , 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza �'UN8 R'LA,t D COON T Philadelphia, PA 19103 PENNSYLVANIA Jonathan.Lobb@phelanhallinan.com 215-563-7000 BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC : COURT OF COMMON PLEAS HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP : CIVIL DIVISION PLAINTIFF : NO.: 13-397 CIVIL V. MICHELLE L. KAIL : Cumberland County DEBRA KAIL DEFENDANT(S) CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: (X) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant ( ) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Ph an Hallinan,LLP Jonathan Lobb,Esq.,Id.No.312174 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER COURT OF COMMON PLEAS TO BAC HOME LOANS SERVICING, LP FKA • COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION PLAMTIFF • NO.: 13-397 CIVIL V. • MICHELLE L. KAIL • CUMBERLAND COUNTY DEBRA KAIL DEFENDANT(S) AFFIDAVIT PURSUANT TO RULE 3129.1 Bank of America,N.A.,Successor by Merger to BAC Home Loans Servicing,LP fka Countrywide Home Loans Servicing, LP,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 848 Lindsey Road,Carlisle,PA 17015-9223. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) r�1 MICHELLE L.KAIL 848 LINDSEY ROAD CARLISLE,PA 17015-9223 = - rr n ; 1-._. DEBRA KAIL 848 LINDSEY ROAD 3z3 CARLISLE,PA 17015-9223r--Y; (..x) r_D „ y a-- cam- -•C 2. Name and address of Defendant(s)in the judgment: - Name Address(if address cannot be reasonably ascertained,please so indicate) MICHELLE L.KAIL 848 LINDSEY ROAD CARLISLE,PA 17015-9223 DEBRA KAIL 848 LINDSEY ROAD CARLISLE,PA 17015-9223 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) KAY JEWELERS P.O.BOX 1799 AKRON,OH 44309 STERLING JEWELERS INC. P.O.BOX 1799 AKRON,OH 44309 PH#792202 STERLING JEWELERS INC.,ET AL 1400 KOPPERS BUILDING C/O WILLIAM T.MOLCZAN,ESQUIRE 436 SEVENTH AVENUE WELTMAN,WEINBERG &REIS CO.,L.P.A. PITTSBURGH,PA 15219 STERLING JEWELERS INC.,ET AL 325 CHESTNUT STREET C/O WILLIAM T.MOLCZAN,ESQUIRE SUITE 501 WELTMAN,WEINBERG&REIS CO.,L.P.A. PHILADELPHIA,PA 19106 PORTFOLIO RECOVERY ASSOCIATES, 140 CORPORATE BOULEVARD LLC NORFOLK,VA 23502 PORTFOLIO RECOVERY ASSOCIATES, 1835 MARKET STREET,SUITE 501 LLC PHILADELPHIA,PA 19103 PORTFOLIO RECOVERY ASSOCIATES, 1 INTERNATIONAL PLAZA,FLOOR 5 LLC PHILADELPHIA,PA 19113 C/O DANIEL J.SANTUCCI,ESQUIRE MIDLAND CREDIT MANAGEMENT 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) 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. Name Address(if address cannot be reasonably ascertained,please indicate) None. 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: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 848 LINDSEY ROAD CARLISLE,PA 17015-9223 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 PH#792202 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: -7 '((l I ly By: Ph n 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 19103 215-563-7000 PH#792202 BANK OF AMERICA, N.A.,SUCCESSOR BY MERGER TO : COURT OF COMMON PLEAS BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE . HOME IfOANS SERVICING,LP : CIVIL DIVISION • PLAINTIFF : NO.: 13-397 CIVIL VS. : Cumberland Count MICHELLE L. KAIL ricoFrl ' cr ' DEBRA KAIL ' DEFENDANT(S) a ci C.) - NOTICE OF SHERIFF'S SALE OF REAL PROPERTY c' TO: Michelle L. Kail - ti.r s Debra Kail 848 Lindsey Road Carlisle,PA 17015-9223 **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.** Your house(real estate) at 848 Lindsey Road,Carlisle,PA 17015-9223 is scheduled to be sold at the Sheriff's Sale on 12/03/2014 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$284,439.22 obtained by BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP(the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty(30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 the filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 13-397 CIVIL BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP V. MICHELLE L. KAIL DEBRA KAIL owner(s) of property situate in SOUTH MIDDLETON TOWNSHIP, CUMBERLAND County, Pennsylvania, being 848 Lindsey Road, Carlisle,PA 17015-9223 Parcel No. 40-10-0636-076 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $284,439.22 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises lying,being and situate in South Middleton Twp, County of Cumberland,and State of Pennsylvania being more particularly described as follows: BEING the same land and premises more particularly described in Deed Book N32,Page 856. TITLE TO SAID PREMISES VESTED IN Vested by Warranty Deed,dated 7/2/2008,given by Debra Kail to Debra Kail and Michelle L. Kail,Mother and Daughter and recorded 7/24/2008 at Instrument# 200825211 PREMISES BEING: 848 Lindsey Road,Carlisle,PA 17015-9223 PARCEL NO.40-10-0636-076 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA o f ,,( ��\i DAVID D. BUELL,PROTHONOTARY �1 _.,.�'n One Courthouse Square • Suite100 • Carlisle, PA • 17013 ve (717)240-6195 375o www.cepa.net BANK OF AMERICA,N.A.,Successor by Merger to BAC HOME LOANS SERVICING, LP f/Wa COUNTRYWIDE HOME LOANS SERVICING, LP Vs. NO 13-397 Civil Term CIVIL ACTION—LAW MICHELLE L. KAIL DEBRA KAIL WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $284,439.22 L.L.: $.50 Interest from 6/12/14 to Date of Sale @($46.76 per diem) -- $8,183.00 Atty's Comm: Due Prothy: $2.25 Atty Paid: $198.75 Other Costs: DatePaid: : 7/18/ 4 iL2444....Tô Ti?LLC_L?é.L._., David D. Buell,Prothonotary (Seal) B i i„ ife.//. Deputy REQUESTING PARTY: Name: JONATHAN LOBB, ESQUIRE Address: PHELAN HALLINAN, LLP ONE PENN CENTER AT SUBURBAN STATION 1617 JFK BLVD,STE 1400 PHILADELPHIA,PA 19103-9897 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No.312174 r' AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME PH # 792202 LOANS SERVICING, LP DEFENDANT MICHELLE L. KAIL DEBRA KAIL SERVE MICHELLE L. KAIL AT: 848 LINDSEY ROAD CARLISLE, PA 17015-9223 SERVICE TEAM/ Ixh COURT NO.: 13-397 CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: December 3, 2014 SERVED Served and made known to MICHELLE L. KAIL, Defendant on the day of SYPTIO 6 20 6=94, o'clock p, M., at g-4. c_i i).5ey RD, ertp-tstki Pk, in the manner described below: /Defendant p&sonally 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). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age 30 Height 3r.? q Weight 4)1f2 Race IA/ Sex h Other Ronald Moll , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. c=i c) 47— DATE: q NAME: Ronald Moll PRINTED NAME: Process Server TITLE: NOT SERVED On the day of , 20 , at o'clock . M., I, , a competent adult hereby state threndant NOT FOUND because: Vacant Does Not Exist Moved Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 s / AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME PH # 792202 LOANS SERVICING, LP DEFENDANT MICHELLE L. KAIL DEBRA KAIL SERVE DEBRA KAIL AT: 848 LINDSEY ROAD CARLISLE, PA 17015-9223 SERVICE TEAM/ lxh COURT NO.: 13-397 CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: December 3, 2014 SERVED Served and made known to DEBRA KAIL, Defendant on thC3Pday of Ye -4/91 ailic 20 14 , , o'clock 4.M., at sfg pp, C4i2.LL, t4, in the manner described below: Defendant personally served. 'Adult family membe - with whom Defendant(s) reside(s). Relationship is 6411ie.... 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). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age 3()Height c,)" Weight Race W Sex Other Ronald Moll , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 1 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: NAME: Ronald Mo 1 PRINTED NAME: Process Server TITLE: NOT SERVED On the day of , 20_, at o'clock . M., I, state that Defendant NOT FOUND because: Vacant Does Not Exist Moved Does Not Reside (Not Vacant) , a competent adult hereby ___ No Answer on at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. at BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034C. 1617 JFK Boulevard, Suite 1400 +' One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY CUMBERLAND COUNTY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS COURT OF COMMON PLEAS SERVICING, LP Plaintiff, CIVIL DIVISION v. MICHELLE L. KAIL DEBRA KAIL Defendant(s) No.: 13-397 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". Date: / b/ (Y0 IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PH # 792202 Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff v. Michelle L. Kail Debra Kail Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13-397 CIVIL CUMBERLAND COUNTY AMENDED Ali'HDAVIT PURSUANT TO RULE 3129.1 Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing, LP, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 848 Lindsey Road, Carlisle, PA 17015-9223. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) Michelle L. Kail Debra Kail 2. Name and address of Defendant(s) in the judgment: Name Michelle L. Kail Debra Kail 848 Lindsey Road, Carlisle, PA 17015-9223 848 Lindsey Road, Carlisle, PA 17015-9223 Address (if address cannot be reasonably ascertained, please so indicate) 848 Lindsey Road Carlisle, PA 17015-9223 848 Lindsey Road Carlisle, PA 17015-9223 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) Kay Jewelers Sterling Jewelers Inc. Sterling Jewelers Inc., Et Al Molczan, Esquire Weltman, CO., L.P.A. Sterling Jewelers Inc., Et Al Molczan, Esquire Weltman, CO., L.P.A. PH # 792202 C/O William T. Weinberg & Reis C/O William T. Weinberg & Reis P.O. Box 1799 Akron, OH 44309 P.O. Box 1799 Akron, OH 44309 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 325 Chestnut Street Suite 501 Philadelphia, PA 19106 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice U.S. Attorney for The Middle District of PA Federal Building 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: wwir By: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 PH # 792202 Name and Phelan Hallinan, LIP Address .0 1617 JFK Boulevard, Suite 1400 Of Sender One Penn Center Plaza Philadelphia, PA 19103 AZK/KAZ -12/03/2014 SALE Line Article Number Name of Addressee, Street, end Post Office Address Asset Acceptance, LLC. 28405 Van Dyke Warren, MI 48093 Postage $0.47 2 Asset Acceptance, LLC. C/O Michael B. Volk, Esq. 6 KACEY CT STE 203 MECHANICSBURG, PA 17055.9237 $0.47 3 Sr*** Bureau of Compliance Department 280948 Harrisburg, PA 17128-0948 4 **0* Capital One Bank (USA) 4851 Cox Road Glen Allen, VA 23060 5 *0** Capital One Bank C/O Michael F. Ratchford, Esq. EDWIN A ABRAHAMSEN & ASSOC 120 N KEYSER AVE SCRANTON, PA 18504-9701 $0.47 50.47 $0.47 ***r. Portfolio Recovery Association, LLC. C/O Mark Richard Garvey, Esq. 120 Corporate Boulevard Norfolk, VA 23502 $0.47 RE: MICHELLE L. KAIL (CUMBERLAND) PH # 792202/1026 Page I of I 45 Day $2.82 Taal Number of Picots listed by Sado Total Humber of Pieces Received a Pon Omec Ponmaon, NT (Name of Receiving Employee) The full declaration of value is required on all domestic and international reginered marl, The maximum indemniry payable for the reoam union of nomugotiable documents under Express Mail document reconstruction insurance is $50,000 per piece subject to a limn of $100,000 per occurrence. The maximum indemnity payable an Express Mall merchmulise Is $500. The maximum mdcmoity payable is $25,000 for registered mail, sem with optional insurance. See Domestic Wil Manual .8900 5913 and 5.921forlimitations of eosenge.. Form 3877 Facsimile PH II 792202 Name and Address Of Sender Line 2 Article Number Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 AZKJHLW - 12/03/2014 SALE Name of Addressee, Street, and Post Office Address COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 3 U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 171084754 $0.47 RE: MICHELLE L. KAIL (CUMBERLAND). .,° PH # 792202/1021Page 2 of 2 Writ Team $5.64 Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Employed) Thc full declaration of value Is required on all domestic and international registered moil, The wain for the raconstruction of nonnegotiable documents under Express Mail document reconstruction insui p eee Eub)ect to a limit of $5110,000 per occurrence. The maximum Indemnity payable on figures; Mi The maximum indemnity payable is S23.000 for registered aril, sent with optional insurance. See l) 8900 5913 and 5921 for limitations of coverage. Form 3877 Facsimile t Name and Address Of Sender Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Line Article Number Name of Addressee, Street, and Post Office Address Postage , 8 f, P "'� -` ?� � u �• .. ""' '' �� N Y .+•i 1 **** TENANT/OCCUPANT 848 LINDSEY ROAD CARLISLE, PA 17015-9223 0:47 .; PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff v. MICHELLE L. KAIL DEBRA KAIL Defendant(s) Attorney for Plaintiff : CIVIL DIVISION : No.: 13-397 CIVIL NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for 12/03/2014 at 10:00 AM in the above -captioned matter has been continued duuntil 02/04/2015 at 10:00 AM. / Date: ! Z//! /C PH # 792202 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER • TO BAC HOME LOANS SERVICING, LP FKA : CIVIL DIVISION COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff : No.: 13-397 CIVIL v. MICHELLE L. KAIL DEBRA KAIL Defendant(s) CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Notice of the Date of Continued Sheriffs Sale and Certificate of Filing were served by regular mail on the person(s) on the date listed below: MICHELLE L. KAIL 848 LINDSEY ROAD CARLISLE,, PA17015-9223 !/ Date: Z (777i,r PH # 792202 DEBRA KAIL 848 LINDSEY ROAD CARLISLE, PA 17015-9223 Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff