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13-0496
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Case No. ~3 - yq(Q ~jtV 11~G^rv- Plaintiff vs. LAURA E. BENDER DONALD G. BENDER JR. Defendant(s) 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 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 file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to 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 (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. c7 .., -~' IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAIS'EE EPA: REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. rn ~ c._ =~ -~ ~ ri ~, r°: ~~ ~ ..,~ ~,, ~°~ tea Respectfully submitted: r~-:~ ~ ~{c~ ~-_ ..-- ,. ~ ~ ~ `+-; (Signature of unsel for Plaintiff) D' ~ rv ~'~`~''t .y_; •,.? ~ r,,~ .- . 1 /23/2013 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date __ Cumberland County Court of Common Fleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete•your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowl~gc: Borrower name{s}: Prpperty Address: City: Is the property for sale? Rcxltor Nerve: Borrower Occupied? Mailing Address (if different) City: Phone Numbers: Email: of people in household: Mailing Address; City: Phone Nutttbers: State:___._ _ Zip:. Yes [] No ^ Listing date: Price: $ Realtor Phone: Yes No ~] Honte: Cell: Offece: Qther: State: Zip: How long? State: Zip: Home: Office: Ctll; Other: Email; # of people in household: Haw long? First Mortgage Lender: _ Type of Loan: Loan Number: Second Mortgage Lender:, Type of Loan, _ ._ _._ _ __ Loan Number; Date Yau Closed Your I.roan: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for I3efault: Included Taxes ~ Iusurancc; Is the loan in Hattkruptcy7 Yes ^ No If yes, provide names, location of court, case number & attorney; Assets Amount Owed: Value: 1-Iame: $ Other Real Estate: $ $ _ Retirement Funds: $~ Investrn~ents: $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #l: Model: Amount awed: Value; Automobile #2: Model Amount owed: Value: _ Other transportation (automobiles, boats, m,,,,Qtorcvcles)• Model: Year: Amount owed; Value Manth[y Income Name of Employers: 1. 2. 3. Additional Income Description (not wages}: 1. monthly amount 2. monthly amount: Borrower Pay Days: Co-Borrower I'ay Days: Monthly Expenses: (Please only include expenses you are currently paying} l~IrN'SE AMOUNT EXPENSE AMOUNT Mo Food 2 M Utilities Car pa ens CondolNei .Fees Auto In~-rsnce Med. not covered Auto fuel/ its Other ro . moat Install. Loan Pa mart Cable TV Child Su rtlAlirn. S din Mate Da /er~ild Cart!'I'uit. Other Esc s Amount Available for Monthly Mortgage Payments Based on Incase & Expanses: Have you been working with a Housing Counseling Agency? Yes [~ No ^ If yes, please provide the following information: Counseling Agency: Cauciselor; Phone (office): I~ax• Year:. Year: Email; Have you made application for Homeowners Emergency Mortgage Assistance Program {HEMAPj assistance? Yes' ~] No if yes, please indicate the status of the application: Have you had any prior negotiations with your Leader or lender's loan servicing company to resolve your delinquency? Yes^ No^ if yes, please indicate the stales ofthose negotiations: Please provide the fallowing infornaation, if know, regarding your tender or lrnder`s loan servicing company: Lender's Contact (Namej: Phone: Servicing Company (Name): Genteel: Phone: T/We, ,authorize the above named to uselrefer this information to my IenderCservicer for the sale purpose of evaluating my financial situation for passible mortgage options. UWe understand that Uwe am/arc under no obligation to use the services provided by the above Rattled Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the follar~virsg information to lender and lender's counsd: Praof of income >past 2 bank statements ' -~ Proof of s>~y e~cgected income for the last ~5 days -Vj Copy of a current utility bill 'Y Letter explaining reason for delinggcnry and any suplrarting documentation (llardslllp letter} Listing, agreement (if property is currently on the market) KML LAW GROUP, P.C. SUTfE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866)413-2311 l3 - y4(o ~ ~~~ - ierr~ BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plaintiff vs. LAURA E. BENDER DONALD G. BENDER JR. Mortgagor(s) and Record Owner(s) 24 Gale Road Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE t~~ ~aE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION c-~ ~.~ _: 2 Liberty Avenue ~rn ~ - ~°i _"~ Carlisle, PA 17013 ~~ " ~ `r;~~, ~ ~ ~ ,.~ ra . :~ :Y, ~a LEGAL SERVICES INC ~' c-x © `..:~~ 8 Irvine Row ~, c rv _ ~=-' ~; Carlisle, PA 17013 ~.a '~` 717-243-9400 `~~ ~'' --~~. AVISO Le han demandado a usted en la Corte. Si usted quiere defenderse de ester demandas expuestas en las paginas siguientes, usted tiene veinte (20) digs de plazo al partir de la fecha de la demanda y la notificacion. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. Ademas, la torte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes Para usted. ll./ ~ 103. ~5 Po IAvT'>y C~` 7a8~43 12~`"a85 773 LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE 1NFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~kmllawcroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 117083FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, 7105 Corporate Drive, PTX B-209 Plano, TX 75024. 2. The name(s) and address(es) of the Defendant(s) is/are LAURA E. BENDER, 24 Gale Road, Camp Hill, PA 17011 and DONALD G. BENDER JR., 24 Gale Road, Camp Hill, PA 17011, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On May 21, 2009 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on June 10, 2009 as Instrument #200919475. The mortgage has been assigned to: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP by assignment of Mortgage recorded on April 02, 2012 as Instrument #201209307. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March O1, 2012 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$155,005.39 Interest from 02/01/2012 through 09/30/2012 at 5.5000% ......................$5,683.52 After 09/30/2012 interest on the principal balance will accrue monthly, on the first day of each month, in the amount of $710.44, calculated at 5.5000% Late Charges ................................................................................................$241.60 Escrow Advances ......................................................................................$1,550.43 Fee Due Advances .........................................................................................$15.00 $162,495.94 7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. Plaintiff is not seeking a judgment of personal liability (or an "in nersonam"judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $162,495.94, together with interest at the rate of $710.44, per month and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffl s Sale of the Property. By: ~c KML LAW GROUP, .C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 'Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 /Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff VERIFICATION hereby states that he/®e is ~~' ,~'~ Q ~~Q,,~~ of Bank of America, N.A., successor by merger to BAC Home Loans Servicing L.P., Plaintiff in this matter, that he/ he 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 knowledge, 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. Date. 1 { ~~ Name: Title:~'C~~ 1///+~ ~~ #117083FC -LAURA E. BENDER and DONALD G. BENDER JR. 24 Gale Road Camp Hill, PA 17011 ExFci6itA LEGAL DESCRIPTION ALL THAT CERTAIN lot of land situate in East Pennsboro Tovmship, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit BEGINNING at a point on the northern fine of Gale Road, which paint is at the dividing line between Late Nos, 35 and 36 on the Plan of bts hereinafter mertioned; thence North 12 degrees 10 minutes West and along the dividing line between tots Nos- 35 and 36 on the plan of bts hereinafter mentioned, a distance of 115 feet to a point at lands now or late of Dr. E S. Deubler, thence North 77 degrees 50 minutes East and along tine of lands now or fate of Dr_ E S: Deubler, a distance of 75 feet to a point at the dividing line between Lots Nos- 36 ark 37 on the phan of lots hereinafter mentioned; thence South 12 degrees 10 minutes East and along the dividing Nrte between Lots Nos_ 36 and 37 on the plan of fats hereinafter mentioned, a distance of 115 feet to a point on the r>athem I"tee ~ Gale Road; and thence South 77 degrees 50 minutes West and along the northem fine of Gale Road, a distance of 75 feet to a point, the Place of BEGINNING. BEING Lot No. 36 on the Ptan of Lots known as Revised Plan of a Portion of Country Club Park, which plan is recorded in Plan Book 11, Page 27, Cumberland County records. BEING THE SAME premises which Dennis I. Ritz, Individually and as Executor of the Last Will and Testament of Alma M. Reitz, late, by deed dated on the 28~' day of July, 2008, and rsconded on the 5~' day of August, 2008, in the Office of the Recorder of Deeds in and for Cumberland Cour>ty, Pennsylvania, in Instrument ID 200826697, granted and cenveyed unto Donald G. Bender, Jr_ and Laura E. Bender, husband and wife, Grantors herein. ALTA Commitrneni Sr3iedule A (aonisiuedJ E~Fiidit ~ *Exhibit has been redacted to remove all personally identifiable information or non public information BatlkofAmerlca ''~' ItOne Bells P O. Box 942073 Sirrr Valley CA 93094-9288 Laura E Bender 24 Gale Road Camp HiA, PA 17011-2619 NOTICE OF INTENT TO FORECLOSE MORTGAGE Este es un aviso importante respecto a su derecho de ocuper 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 rat 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 defaul4 and we are prepared to initiate foreclosure proceedings. The folbwing letter was sent to the current owner of the property: The MORTGAGE held by Ginnie Mae (hereinafter we, us or ours) on your property located at 24 Gale Road Camp Hili, PA IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of.- Monthly Charges: 03/01/2012 Send Payments to: P.O.Box 15222 Wdmirgfon, DE 19BB6-5222 May 1, 2012 Certfied Maii: 7196 9006 9295 9505 8130 Return Receipt Requested Regular Mail Account No.: ~99 Property Address: 24 Gale Road Camp Hill, PA Current Servicer: Bank of America, N.A. $3,624.D3 Late charges and other charges have also accrued to this date in the amount of $96.64 Late Charges: 0 3/0 112 0 1 2 $96.64 Other Charges: Uncollected Late Charges: Uncollected Costs: Partial Payment Balance: TOTAL DUE: $241.60 $0.00 ($0.001 b3,962.27 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 $3,962.27. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $3,962.27, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made eRher by cash, cashier's check, certfied check or money order, and made at Bank of America, N.A. at P.O. Box 15222, Wilmington, DE 19886.5222. ff you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. ff 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 faeclose yol~ mortgaged property. ff the mortgage is foreclosed your mortgaged property wiq be sold by the Shedff to pay olf the mortgage debt. it we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actualty incurred, up to $50.00. However, i( legal proceedings are started against you, you will have to pay the reasonable attorney's fees even it they an: over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty (30) day per-ocl, you will not be required to pay attorneys fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. K you have not cured This communication is from Bank of America, NA., the servicxr of your home lawn. Haase write your acmul nrnber m at checks and canespmderce. Vye ma/ Burge you a lee (d up m SID.0019or erry payrtaxY retrned or rejected by you lnsicid irelldion, subject to applicable law. C3 1M5 B oPn2 twat oemabn 1n°"`dD"" Account Number:~~ Mare you daxk peyade ro sere or Laura E Bender Balance Due for charges fisted above: 43,96227 as of May 1,2012. arrlira.NA 24 Gale Road flsasaupmlesmaiiinbnralamm~eretarsesidedmisbbupan. omt send can • Fleece irrciarde coupon with your C HNI, PA arT~l rileaNwu~ l ~~ PRrripa BLOPn2 Fa ant fd nnritlr payrrep periods. Addlioral in i ~ I II I,,, ll,ll....I '~ llt 'II~I~I~~'llll ~~ll.~~llll..ll„I,II Esaow A~, ~ iri+esl kx m fW mpihs. I I i II I l indudng Febnery, is caromed as 30!380 d errata Nered, iraspedire d Bank Of America, N.A. PO BOX 15222 the soul prober d dwys in de morMr. For pa+al ewriw, i,Erea fie dcamred Wilmington, DE 19888-b222 y~ deiymrre besisde365 day year. 1-BOO~fi69-01D2 022692299500000396227000396227 ~: 58 6 9 900 581:2 269 2 29911• BailkofAmerica '~' IfoHe liotells PA. Box 942073 Simi Valley, CA 93094-12BB Sentl Payments to: P.O. Box 15222 WAmirsgtar, I)E' 198B6~T22 May 1, 2012 Donald Bender 24 Gale Road Camp Hill, PA 17011-2619 Certfied Mail: 7196 9006 9295 9505 8147 Retum Receipt Requested Regular Mail Account No.:-99 Property Address: 24 Gale Road Camp Hill, PA Current Servicer: Bank of America, N.A. NOTICE OF INTENT TO FORECLOSE MORTGAGE Este es un aviso importante respedo a su derecho de ocupar su case. Favor de traduciMo 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 repaymerrt of this debt We regret to advise you that this loan is in default and we are prepared to initiate foreclosure proceedings. The folbwing letter was sent to the current owner of the property: The MORTGAGE hek! by Ginnie Mae (hereinafter we, us or ours) on your property located at 24 Gale Road Camp Hill, PA IS IN SERIOUS DEFAULT because you have not made the monthly payments for the months of.- Monthly bar e : 03/01/2012 $3,624.03 Late charges and other charges have also accrued to this date in the amount of $96.64 Late Charges: 03/01/2012 $96.64 Other Charges: Uncollected Late Charges: $241.60 Uncollected Costs: $0.00 Partial Payment Balance: ($0.001 TOTAL DUE: 53,862.27 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 $3,962.27. You may curs this default wtth~l THIRTY (30J DAYS of the date of this letter, by paying to us the above amount of $3,962.27, plus any additional rrwntfrly payments and late charge which mayfall due during this period. Such payment must be made either by cash, cashiers check, certified check or money order, and made at Bank of America, N.A. at P.O. Box 15222, Wilmington, DE 198865222. If you do not cure the default within THIRTY (~) DAYS, we intend to exercise our tight to accelerate the mortgage payments. This means that whatever is awing on the original amount borrowed will be considered due immediately and you may k3se the chance to pay atf the original mortgage in monthly installments. K 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 foreGose }roar mortgaged property. K the mortgage is fotedosed your mortgaged property wiR be sold by the Sheriff to pay olf the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. H you cure the defauK within the thirty (30) day period, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. K you have not cured Ths carmuricalion's tran Bank of Amedp, N.A., the servicer of yar horde loan. Poaese write ywr acmul rssitber on of ~s Brad ccmespmderr~. YYe may dtarge yvu s lee (ol up la S~O.CO)for any paymerl mtxned a rejected by your f naridel irwatlioq s~igerf to applicable law. c7_ias eLar>nz tort os¢saon p°y'""d 1ndnctloiR` Account Number. 99.5 • Mahe you AieW payable [o Banc of Donald Bender Balatce Due for dlargeS fisted above: $3,96227 a5 d May 1,2012. Arrimiaf. rLA 24 Gale Road ~asaui>~-maa nwrmalan on ns rsse,sesiaamisoswat. • oaty sam rasn • Neese irrclide coupon wiM your C Hil, PA arnP MtlRiawl ~ peyrterx BLOPA2 Pnaspa Fa d tut mach pemers panda, ~~, inlereal is c>flgyaledpnammlNy basis. I III I I,I '~ ~' ~ ~ ~~'~ ~~" ' ' ~~ ~ "' ~~~ I, I 1 I I ~ ~' ~' ~' ' Eaaow nanrdnlly, irlael brdtul rrsxiUrs. I ll I 1 I I II I I I I I I I I I indu3q Febnery, is rdl¢Aaled ac Bank Of America, N.A. 301380 d aesW yierd, ireepmiive d PO BOX 15222 ry,sy, the edud rember d days in the math raw Fa parcel marlw, irpreieemlculaled Wilmington, DE 198[36-5222 ddy m re bads d a 385 day year. 1-800$89-0102 022692299500000396227000396227 1:58 6 9 900 581:2 269 2 299[1• the detautt within the thirty (30J day period and foreclosure proceedings have begun, you still have the right to cure the default and pretrertt the sale at any time uP to one hour before the Sherrtl s foreclosure sate. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorneys fees and costs connected with the foreclosure sate [and perform any other requirements under the mortgage]. h is estimated that the earliest date that such a Sheriffs sale could be held would be approximately soc (8) months from the date of this Notice. A notice of the date of the Shelift sale will be sent to you before the sale. Of course, the amount needed to cure the detautt will increase the longer you wait. You may find out at any time exactly what the required payment wiq be by calling us at the folbwing number. 1-800-6fi9-0102. This payment must be in cash, cashiers check, cert'rfied check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end yourownership of the mortgaged property and your right to remain init. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the properly. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three tlmes 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. THs tromnuriraton is from BaNc d America, N.A, fie servicer of your hone loan. E-mail uea: ProtitNng your a-mai adtlr~ below wiA slow us to send you irfomiation on your accent Arxour Nurtlhe 89 Donald Bandar E-mal adAess: Xow wa post your papnara: All accepted paymerds of pdrrdpal and irrlarest rii 6e appled m the longest outstandng instalmerd due, unless otherwise e><preasy prohibhed or inioad M law. M you st>bmit an amount n ad3tion to your sdreduled monWy amount, we wi apply your paymeMe as folorrs: (i) to outstanding momMy payments of pmapal one iMaest Il) escrow defrierwyas, (i) rota dlarges and other amourds you true b eotrreo9m with ytrr loan and (h1 to reduce the olda~rldig prinapal bakrrce Or your loan. Pleaee spedTy if you warn an additlorial amoum appiad to future payments, rather than pdndpal redrelon. PoaMahd elrerJCe: Pcetdated rhedcs wll ba proceaeed an the data recehed urlass a ban cnraisebr agrees to fnrgr the data wriden on the check as a condiGOn or a repaymem plan. Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option{s) could work for you. Options to consider if your goal is to stay in your home .. ....:.:t~,%; .. : t ... .. ~ : . :.,ar;::;' ~;:: ~::::..~ :~ .*.(2~~x .• C . ~.i:~Ft ..: ' Y .:. ' `CSi j~~ :.t>i ~. 3 Home A federal government program that allows you to repay the loan on newly agreed upon terms, which Affordable may include lowering the interest rate, placing past due amounts at the end of the loan, and/or Modification extending the term of the loan. You may be eligible for this program if you meet the following Program requirements: (RAMP) • The home is your primary residence and you currently live in it. • The amount you owe on the first mortgage is equal to or less than $729,750 for asingle-family home, $934,200 fora 2 unit property, $1,129,250 fora 3 unit property or $1,403,400 fora 4 unit property • You have experienced a hardship that has impacted your income. For example, a significant increase in your mortgage payment OR reduction in your income OR other hardship. • Your mortgage was obtained before Jan. 1, 2009. • Your payment on your first mortgage (including principal, interest, taxes, insurance and homeowners association dues, if applicable) is more than 31 % of your current gross income. To calculate this, divide your first mortgage payment by your gross income (income before taxes). Laan If you can bring your loan payments up to date, we will accept the funds needed to bring the loan up Rsinstatemerrt to date until the day of your foreclosure sale. Repayment A temporary agreement which allows forthe repayment of the unpaid, past due amount along with Plan regular mortgage payments. This may incude principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and/or collection of payments for a Forbearence period of time, to allow you to re-establish your ability to make the required payments. Agreemerrt Loan Repay the loan on newly agreed upon terms, which may include lowering the interest rate, placing Modification amounts past due at the end of the loan, and/or extending the term of the loan. {non•HAMP) Partial Claim If you have a Federal Housing Administration (FHA) loan and your payments are past due but you {FHA loans are now able to make your regular monthly mortgage payment, this program is designed to bring your Only) loan up to date by creating a second mortgage/lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home .,~,;,;. : ., ' ._ ..... ....... ........ :. .: \. q :: } .. ..... .:.v:::.: v ::: .v:.~~ is ~:: M .. '' "~Y: .. : ... .~~:~ti.... e:::~/.L':.:=n.......:.. Y. ~:.4. v: fiJ .. ................ .:u :$. ..... r.mmi.~m .r ... ..: ... n. .. ....... ... .............:.:~.: ii}.J% Home Designed io help borrowers who are eligible for the Home Affordable Modification Program (RAMP) Atfordable but were unsuccessful in securing a permanent modification through the program. HAFA provides the Forecbsure option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A short sale is a transaction Attematives in which you sell your property for less than the total amount owed on the loan (subject to agreement p~rem by your servicerAender/investor), resulting in the release of our lien on your home and avoidance of {HAFA) forecosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale! Offered to borrowers who are not eligible for RAMP or other home retention alternatives. With a short Preforecbsure sale, you sell your property for less than the total amount owed on the loan (subject to agreement by Sale your servicer/lenderfinvestor), resulting in the release of our lien on your home and avoidance of {non-HAFA) foreclosure. geed in Lfeu of Offered to borrowers not eligible for RAMP or other home retention alternatives, and who were not Foreclosure able to sell the property through a short sale. With a deed in lieu of foreclosure, you agree io (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 9505 8147 Hay Opciones Disponibles Para Ayudarle a Evitar la Ejecucion Hipotecaria Llame al ntimero que aparece en la notification adjunta para obtener mas information Cuando (lame, tango la informacidn de sus ingresos y gastos disponibles para que podamos discutir coal opcidn(es) pueden funcionar para usted. Opciones a considerar si su objetivo es permanecer en su casa ;; ~ ,~,.r,,,,~ <~<;.~ °r ,,.. .a ;.. ~° ;:;~~ .~~av, >,::: ~«:~,~~ .,....,.:F<~...~...... : :.>;. ~. .........x ... ...... ~; :4: ..#~::$y',..A`3 ....~`'.':' ii... f.....2?SisWN~',:3Y:j~..:.'.^..>:^...a.: 3.E.::%fkt$.<~. ..:..:{&~:QS<6;Y.:'f-<::::.....'`.::3:::/l.-:'Y:?'ti:::3i... Home Affordable Un programa del gobierno federal que le permite pager el prestamo bajo los nuevos terminos Modification acordados, que pueden incluir la reduccibn de la Casa de interes, agregando la cantidad adeudada Program (HAIIAP) al final del prestamo, y / o extender el plazo del prestamo. Usted puede ser elegible para este programa si rumple oon los siguientes requisitos: • La casa es su residencia principal y actualmenie viva en ella. • La cantidad adeudada en la primers hipoteca date ser igual o mends que $729,750 dblares para una vivienda unifamiliar, $934,200 dblares para una propiedad de 2 unidades, $1,129,250 dblares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades • Ha experimentado una dificultad que ha afedado sus ingresos. Por ejemplo, un aumento significativo en su pogo hipotegrio O reduccibn de sus ingresos U otras dificultades. • Obtuvo su hipoieca antes del 01 de enero 2009. • Su pogo de la primers hipoteca (incluyendo principal, interes, impuestos, seguro y cuotas de asociaci8n de propietarios, si se aplica) date ser mSs del 31% de sus ingresos brutos aduales. Para calcular esto, divide su pogo hipotecario por sus ingresos brutos (ingresos antes de impuestos). Restablecimiento Si usted puede iraer sus pagos del prestamo hipotecario al die, se le aceptaren los fondos del Prestamo necesarios para que el prbstamo este al die haste la fecha de Ia yenta judicial. Plan de Pago Un acuerdo temporal que permile el pogo de la cantidad adeudada, cantidad del pogo atrasado junto con los pagos regulares de la hipoteca. Esto puede incluir princpal, interes, honorarios y/o costos aplicados a su prbstamo. Acuerdo Un acuerdo por el coal nos comprometemos a no proceder con la ejecucibn hipotecaria y/o Temporal de coleccidn de pagos por un periodo de tiempo, para permitirle que reslablezca su habilidad de Tolerancia hater los pagos requeridos. Modifieacidn de Pager el prbstamo bajo los nuevos terminus acordados, que puede incluir la reduccibn de la lase Prl3stamo de interes, agregando la cantidad adeudada al final del prestamo, y!o extender el plazo del (no por medio prbstamo. de RAMP) Reclamo Partial Si usted liana un prestamo de la Administracibn Federal de Vivienda (FHA) y sus pagos estan (solamerrte vencidos, pero ahora puede hater sus pagos regulares mensuales de la hipoteca, este programa prestamos de la estS diseiiado para que su prbstamo este al die mediante la creacibn de una segunda hipoteca / FHA) gravamen sutra su propiedad por la cantidad adeudada. Opciones a considerar si no puede o no desea quedarse en su casa ' v ~. .: :. ~~ " .:.,~ ... v: :nom::}:{:~; .'%,x G:k: Y.•..:... i~;. Home Diseiiado para ayudar a los prestatarios que son elegibles para el Programs de Home Affordable Affordable Modification (RAMP), pero no tuvieron Lxito en obtener una mod~cacibn permanente a trav2s del Foreclosure programa. HAFA ofrece la posibilidad de una yenta coma y, si no liana exito, una entrega de AHarnatives escritura para evitarjuicio hipotecario. Una yenta corta es una transaccibn en la que usted vende su p~rem propiedad por mends de la cantidad adeudada en el prestamo (sujeio a previo acuerdo de su (HAFA} administrador / prestamista ! inversionisla), resultando en la liberacibn de nuestro derecho de retencibn sutra su propiedad y evitar la ejecucibn hipotecaria. Una entrega de escritura para evitar juicio hipotecario es una transaccibn en la que usted est~ de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecucibn hipotecaria. Verna Cortaf Se ofrece a los prestatarios que no son elegibles para RAMP u otras alternatives de retencibn de Verna antes de huger. Con una yenta corta, usted vende su propiedad por mends de la cantidad total adeudada en Ejecuci6n el prbstamo (sujeto a un acuerdo por su adminisVador / prestamista / inversionista), resultando en la Hipotecaria (no liberacibn de nuestro derecho de retencibn sutra su propiedad y evitando la ejecucibn hipotecaria. por medic de HAFA) Entrega de Se ofrece a los prestatarios que no son elegibles para RAMP u otras alternatives de retencibn de Esuitura Para huger, y que no pudieron vender la propiedad a troves de una yenta corta. Con una entrega de Evitar Juicio escritura para evitar juicio hipotecario, usted est~ de acuerdo a transferir voluntariamente las Hipolxicario escrituras de su propiedad a nosotros para evitar la ejecucibn hipotecaria. (no por medic de HAFA) Estamos aqui para ayudarle. Por favor llamenos hoy. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. LAURA E. BENDER DONALD G. BENDER JR. (Mortgagor(s) and Record Owner(s)) 24 Gale Road Camp Hill, PA 17011 Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against LAURA E. BENDER and DONALD G. BENDER JR. by default for want of an Answer. Assess damages as follows: Debt Monthly Interest - 02/01/2012 to 06/01/2014 Total (Assessment of Damages attached) $177,415.18 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 /1 � By: KML LAW GROTC. Michael McKeever a. D 56129 Jay E. Kivitz Pa. ID 2 769 Lisa Lee Pa. ID 78020 _Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 _Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 31389 Alyk L. Oflazian Pa. ID 312912 64.so*a -760Pg 79 Q # _ Nce 'Mcklea. �� . Attorneys for Plaintiff AND NOW)0kef [ ( , , Judgment is entered in favor of BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP and against LAURA E. B DER and DON 1 G. BENDER - by default for want of an Answer and damages assessed in the sum of $177,415.18 as er the a. e certi 1 .tion. Prothonot Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 LAURA E. BENDER DONALD G. BENDER JR. (Mortgagors and Record Owner(s)) 24 Gale Road Camp Hill, PA 17011 Plaintiff vs. Defendant(s) No. 13-496 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above -captioned matter has been entered against you. David D. Buell Prothonotary By: Deputy If you have any questions concerning the above, please contact: KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 117083 FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: LAURA E. BENDER BENDER, LAURA E. 24 Gale Road Camp Hill, PA 17011 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plaintiff vs. LAURA E. BENDER DONALD G. BENDER JR. (Mortgagor(s) and Record Owner(s)) 24 Gale Road Camp Hill, PA 17011 Defendant(s) DATE OF THIS NOTICE: May 21, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-496 TO: LAURA E. BENDER 24 Gale Road Camp Hill, PA 17011 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 (10) 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: .B1• KMLLAWU',P.C. Michae ! Keever Pa. ID 56129 Lisa Lee ' • . ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DONALD G. BENDER JR. BENDER, JR, DONALD G. 24 Gale Road Camp Ibll, PA 17011 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 Plaintiff vs. LAURA E. BENDER DONALD G. BENDER JR. (Mortgagor(s) and Record Owner(s)) 24 Gale Road Camp Hill, PA 17011 Defendant(s) TO: DONALD G. BENDER JR. 24 Gale Road Camp Hill, PA 17011 DATE OF THIS NOTICE: May 21, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-496 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 (10) 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: KML LAW G I UP, P.C. Michael Keever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Jennifer Lynn Frechie Pa ID 316160 215-627-1322 Attomeys for Plaintiff >ML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. LAURA E. BENDER DONALD G. BENDER JR. (Mortgagor(s) and Record owner(s)) 24 Gale Road Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 13-496 ORDER FOR JUDGMENT Please enter Judgment in favor of BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, and against LAURA E. BENDER and DONALD G. BENDER JR. for failure to file an Answer in the above action within (20) days from the date of service of the Complaint, in the sum of $177,415.18. By: KML LAW GRO,iJP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 _Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Andrew F. Gomall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 _Alyk L. Oflazian Pa. ID 312912 -614Y11 Attorneys For Plainti frehlic 3 k b lcao I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 and that the name(s) and last known address(es) of the Defendant(s) is/are LAURA E. BENDER, 24 Gale Road Camp Hill, PA 17011 and DONALD G. BENDER JR., 24 Gale Road Camp Hill, PA 17011; 0611t By: KML LAW GR 0 ', P.C. Michael McKeeve 'a. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff J ) ,C�� Irtattt Th,(,o ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Monthly Interest from 02/01/2012 through 06/01/2014 Late Charges Escrow Advances Fee Due Advances AND NOW, this f / day of 13-496/117083FC By: $155,005.39 $20,602.76 $241.60 $1,550.43 $15.00 $177,415.18 KML LA !1' OUP, P.C. Michael ver Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff J 'Y FretiikijLs1 koP , 2014 damages are assessed as above. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A', COUNTRYWIDE HOME LOANS SERVICING, LP s. Plaintiff vs. NO. 13-496 LAURA E. BENDER DONALD G. BENDER JR. -� Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): LAURA E. BENDER, has a last known residence of 24 Gale Road, Camp Hill, PA 17011. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to, unsworn falsification to authorities. Date By• KML LAW GR �'!!.' , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 ,,Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of : Jun -09-2014 07:01:12 AM SCRA 3.0 Status .Deport Pursuant to .Sere icernernbers Civil, Relief Act Last Name: BENDER First Name: LAURA Middle Name: E. Active Duty Status As Of: Jun -09-2014 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 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End 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 ftitsen1/4— The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a cat to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: LAL5K0B7S06EX80 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff vs. LAURA E. BENDER DONALD G. BENDER JR. Defendant(s) NO. 13-496 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): DONALD G. BENDER JR., has a last known residence of 24 Gale Road, Camp Hill, PA 17011. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date cid to By: KML LAW GROU .c. Michael McKee - , Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313 897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of : Jun -09-2014 07:03:22 AM SCRA 3.0 Status Report Pursuant to .Servicernembers Civil Relief Act Last Name: BENDER First Name: DONALD Middle Name: G. Active Duty Status As Of: Jun -09-2014 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 Da s of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End 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, NOM, 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 • The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty' responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: ZAWAL037006FT20