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HomeMy WebLinkAbout13-0948a d_ ~. t~ _ t,~ d' i` ~ X13 fEE~ 2 I A~ 10~ 33 ~~ra~E~;LA~~O CDU~~~'~: F'E~d'~SvLVr~N1A PHELAN HALLINAN, LLP Allison F. Zuckerman, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff v. PAULA M. PRICE CODY O. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM C~ S ~~,-I NO. ~ ~- I~ CUMBERLAND COUNTY CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 298190 2~ a8~~ys Plaintiff is BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: PAULA M. PRICE CODY O. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 10/23/2008 PAULA M. PRICE and CODY O. PRICE made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE FOR COUNTRYWIDE BANK, FSB which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200836609. By Assignment of Mortgage recorded 10/24/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201129370.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(8); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified File #: 298190 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 O 1 /25/2013: Principal Balance $142,023.15 Interest $15,622.64 04/01 /2011 through O 1 /31 /2013 Late Charges $0.00 Property Inspections $15.00 Title Cost $250.00 Escrow Deficit $5,389.07 TOTAL $163,299.86 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. File #: 298190 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $163,299.86, 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. 19 File #: 298190 LEGAL DESCRIPTION ALL that certain tract or land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the public road leading from Mount Holly Springs to Barnitz (Township Road No. 475), said point being 134 feet, more or less, in a Westerly direction in said road from line of land now or formerly of Medusa Cement Company; thence continuing in said public road, North 47 degrees West 100 feet to a point; thence by land now or formerly of Kenneth W. Smith and June R. Smith, his wife, North 19 degrees 40 minutes East 200 feet to a stake; thence by land now or formerly of John E. Maurice, et al., South 47 degrees East l 00 feet to an iron pin; thence by land now or formerly of DD&M Corporation by a line parallel to the line of Medusa Cement Company and 133 feet in a perpendicular distance to Westward therefrom, South 19 degrees 40 minutes West 200 feet to the Place of BEGINNING. BEING improved with a dwelling house with attached garage. BEING the same premises which Donald R. Handshew and Bonnie L. Handshew, his wife, by Deed dated September 7, 1976, and recorded September 7, 1976, in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, in Book U26, Page 24, granted and conveyed unto Ronald Wagner Sheaffer and Rosealma B. Sheaffer, his wife. BEING THE SAME PREMISES which Ronald Wagner Sheaffer and Rosealma B. Sheaffer, his wife by their Deed dated OctoBer 17, 2008 and about to be recorded in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, granted and conveyed unto Cody O. Price and Paula M. Price, his wife, Mortgagors herein. PROPERTY ADDRESS: 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 PARCEL # 40-32-2334-002A File #: 298190 VERIFICATION ~,. r ~~ ~` ~~ 1~ ,hereby states that he is,~,crsT~nr~~(~~~ID~r~T of BANK OF AMERICA, N.A., Plaintiff in this matter, that he sh is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his~\! 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: j ~ File#: 298190 Name: PRICE ~~~ ~ ~ .A. Name• ~i~! t~~~ ~ n ~H t r1 _--, BANK OF AMERICA, N.A. File #: 298190 Pa.R.C..P. 205.5 Updated OI/01/2011 FORM 1 IN THE COURT OF COMMON PLEAS BANK OF AMERICA, N.A., AS SUCCESSOR OF CUMBERLAND COUNTY, PENNSYLVANIA BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME _ ~_~ `- LOANS SERVICING, LP `~ -' ~--~ w. , Plaintiff(s) -, ~ ~w "' ~ ~ "~ f";. ~ PAULA M. PRICE ~~ ~ ~~~ CODY O. PRICE I ~ ~ ~ 1 J ~ ~ ~ ~ ~~-,. Defendant(s) lJr Civil ~' G • • .,.., NOTICE OF RESIDENTIAL MORTGAGE FORECLOSi~RE 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 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 arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Date Respectfully submitted: llison F. Zuckerman, Esq., Id. No.309519 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas 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 counseling agency. Please provide the following information to the best of your knowledge: Borrower name(s): Properly Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender: Type of Loan: How long? Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: State: Zip: Yes ^ No ^ Listing date: Price: $ Realtor Phone: Yes ^ No ^ State: Zip: Home: Cell: How long? Home: Cell: Office: Other: Office: Other: State: Zip: Date You Closed Your Loan: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #I: Model: Year: Amount owed: Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles boats motorc cles)• Model: Year: Amount owed: Value Monthly Income Name of Employers: Year: 1 • Monthly Gross Monthly Net 2• Monthly Gross Monthly Net 3• Monthly Gross Monthly Net Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mort a e Food 2"d Mort a e Utilities Car Pa ment s Condo/Nei h. Fees Auto Insurance Med. not covered Auto fueUre airs Other ro a ment Install. Loan Pa ment Cable TV Child Su ort/Alim. S endin Mone Da /Child Care/Tuft. Other Ex enses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if 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. I/We understand that Uwe 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) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 File #: 298190 SHERIFF'S OFFICE OF CUMBERLAND COUNTY F ll..E0 „ . raj Ronny R Anderson c �- T y e ; Sherif �01� .r O �tD p��U1�ffipg�,d Jody S Smith # 2313 kR 26 AM ?3 Chief Deputy Richard W Stewart ' CUMBERLAND COUNTY Solicitor OFFICE OF THE SHERIFF P E N N S Y LVA N I A Bank of America, N.A. Successor by Merger to BAC Home Loans Servicing, Case Number vs. Paula M Price(et al.) 2013-948 SHERIFF'S RETURN OF SERVICE 03/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Paula M Price, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 602 West Pine St., S. Middleton Twp., Mt. Holly Springs, PA 17065. Residence appears to be vacant but mail is currently in the mailbox. 03/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Cody O Price, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 602 West Pine St., S. Middleton Twp., Mt. Holly Springs, PA 17065. Residence appears to be vacant but mail is currently in the mailbox. SHERIFF COST: $61.00 SO ANSWERS, + 2� March 25, 2013 ROW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft Inc. AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE PHS#298190 HOME LOANS SERVICING,LP DEFENDANT SERVICE TEAM/vla PAULA M.PRICE COURT NO.:13-948-CIVIL CODY O.PRICE SERVE CODY O.PRICE AT: TYPE OF ACTION 100 PINEWOOD RD XX Mortgage Foreclosure APT 129 XX Civil Action VIRGINIA BEACH,VA 23451-3968 SERVED = Served and made known to CODY O.PRICE,Defendant on the 1A day ofr 20 3,atp "*1 ` 6,o'c]ockJ�M.,at D o �10e-GVOV4 in the manner described below: rTj 1- l efendant personally served. N Adult family member with whom Defendant(s)reside(s). �y �p C Relationship is �•� �1 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). ZC� rr, Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. --i _Other: �d �prr Description: Age Height g Weight 19s" Race 1A) Sex I/�/� Other }{ 7 a competent adult,being duly sworn according to law, depose and state that I personally han_dea'a"_true and correct copy of the Foreclosure Complaint in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed ij�J7l before me this 16, d VASANTI MAJETHIA Of 20L� NOTARY PUBLIC REGISTRATION#357640 COMMONWEALTH OF VIRGINIA Notary: ByMY COMMISSION EXPIRES FEBRUARY 28, 201 ED On the day of ,20 o'clock_M.,I, ,a competent adult hereby state that Defendant OT FO ecause: _Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) No Answer on at at _Service Refused Other: Sworn to and subscribed before me this day of 20_. By: Notary: ATTORNEY FOR PLAINTIFF Chrisovalante P.Fliakos,Esq.,Id.No.94620 Lawrence T.Phelan,Esq.,Id.No.32227 Courtenay R.Dunn,Esq.,Id.No.206779 Francis S.Hallinan,Esq.,Id.No.62695 Allison F.Zuckerman.Esq.,Id.No.309519 Daniel G.Schmieg,Esq.,Id.No.62205 Melissa J.Cantwell,Esq.,Id.No.308912 Michele M.Bradford,Esq.,Id.No.69849 Mario J.Hanyon,Esq.,Id.No.203993 Judith T.Romano,Esq.,Id.No.58745 John M.Kolesnik,Esq.,Id.No.308877 Jenine R.Davey,Esq.,Id.No.87077 Matthew G.Brushwood,Esq.,Id.No.310592 Lauren R.Tabas,Esq.,Id.No.93337 Zachary J.Jones,Esq.,Id.No.310721 Jay B.Jones,Esq.,Id.No.86657 Justin F.Kobeski,Esq.,Id.No.200392 Andrew L.Spivack,Esq.,Id.No.84439 Adam Davis,Esq.,Id.No.203034 One Penn Center at Suburban Station 1617 John F.Kennedy Blvd., Suite 1400 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 Attorney for Plaintiff BANK OF AMERICA,N.A.,AS SUCCESSOR Court of Common Pleas BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME Civil Division LOANS SERVICING, LP Plaintiff CUMBERLAND County C-) �5 = `Y1 vs. No. 13-948-CIVIL ZZ r;cx� C_ PAULA M. PRICE CODY O. PRICE -� Ac's 'a Defendants C i MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan, LLP, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant, PAULA M. PRICE, by first class mail to PAULA M. PRICE at the mortgaged premises, 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065and at P.O. BOX 142, WALNUT BOTTOM, PA 17266; posting of the mortgaged premises, 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065; and publication pursuant to Pa. R.C.P. 430, and in support thereof avers the following: L ' Attempts to serve Defendant, PAULA M. PRICE,personally with the Complaint have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendant at the mortgaged premises, 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065. As indicated by the Return of Service, no service was made as said address is vacant. A true and correct copy of the Return of Service is attached hereto, made part hereof, and marked as Exhibit "A". 298190 t 2. Attempts to serve Defendant, PAULA M. PRICE,personally with the Complaint have been unsuccessful. The Plaintiff's Process Server attempted to serve the Defendant at the, 100 PINEWOOD RD, APT 129,VIRGINIA BEACH, VA 23451. As indicated by the Affidavit of Service, no service was made as the Defendant does not reside at said address. A true.and correct copy of the Affidavit of Service is attached hereto, made part hereof;and marked as Exhibit "B". 3. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. A true and correct copy of an affidavit of due diligence setting.forth the specific inquiries as to the Defendant's whereabouts and the results thereof is, attached hereto, made part hereof, and marked as Exhibit"C". 4. In accordance with CUMBERLAND County Local Rule 208.2(d),Plaintiff sent a copy of its Proposed Motion for Special Service and Order to the Defendant on May 28, 2013 and requested Defendant's concurrence. Plaintiff did not receive any written response from the . Defendant. A true and correct copy of Plaintiffs May 28, 2013 letter and postmarked certificate of mailing pursuant to Local Rule 208.2(d) attached hereto, made part hereof, and marked Exhibit "D". 5. Plaintiff has reviewed its internal records and has not been contacted by the Defendant to bring loan current. 6. Plaintiff submits that it has made a good faith effort to locate the Defendant but has been unable to do so. 298190 WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint -by first class mail; posting; and by publication. Respectfully submitted, PHELAN HALLINAN, LLP Date: J By: Phelan Hallinan, LLP Meredith Wooters,Esq., Id. No.307207 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 298190 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 , One Penn Center Plaza Philadelphia;PA 19103 215-563-7000 Attorney for Plaintiff BANK OF AMERICA,N.A.,AS SUCCESSOR Court of Common Pleas BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME Civil Division LOANS SERVICING, LP Plaintiff CUMBERLAND County vs. PAULA M. PRICE No. 13-948-CIVIL CODY O. PRICE Defendants MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT I. FACTUAL BACKGROUND Attempts to serve Defendant, PAULA M. PRICE, with the Complaint have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendant at the mortgaged premises, 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065. The Plaintiff's Process Server attempted to serve the Defendantat 100 PINEWOOD RD,APT 129, VIRGINIA BEACH, VA 23451. As indicated by the Return of Service and Affidavit of Service, no service was made. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by the affidavit of due diligence setting forth the specific inquiries as to the Defendant's whereabouts and the results thereof. Further, Plaintiff's counsel has reviewed its internal records and has not been contacted by the Defendant to bring loan current. Consequently, Plaintiff submits that it has made a good faith effort to locate the Defendant but has been unable to do so. II. LEGAL AUTHORITY Pennsylvania Rule of Civil Procedure 430(a) specifically states: . If service cannot be made under the applicable rule,the plaintiff may move the court for a special order directing the method of service. The motion shall be 298190 accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Pa.R.C.P. 430(a)(2009). In particular: An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and employers of the defendant, and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. Id. at 430(a)n. Similarly,the Pennsylvania Superior Court has gone on to explain that, "While by no means exhaustive, this Note-is at least indicative of the types of procedures contemplated by the legislature when enacting Rule 430." Deer Park Lumber, Inc. v. Moor, 384 Pa. Super. 625, 633, 559 A.2d 941, 946 (1989), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Only after such proof has been offered is the Court authorized to direct another method of substitute service. See id. In the instant case, as indicated by the Return of Service and Affidavit of Service, the Sheriff and the Plaintiff's Process Server have been unable to serve the Complaint. Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by .the affidavit of due diligence. Therefore, Plaintiff respectfully requests an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail,posting, and publication. III. CONCLUSION As indicated by the Return of Service and Affidavit of Service,the Sheriff and the Plaintiff's Process Server have been unable to serve the Complaint upon the Defendant. Plaintiff has made a 298190 good faith effort to discover the whereabouts of the Defendant as evidenced by its affidavit of due diligence. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, posting, and publication. Respectfully submitted, PHELAN HALLINAN, LLP Date: By: 26&IROW NW Meredith Wooters, Esq.,Id.No.307207 Attorney for Plaintiff 298190 Exhibit "A" ,. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sherfff tse6tly��a Jody S Smith Chief Depmy -Richard W Stewart Sowor I Bank of America,NA Successor by Merger to SAC Home Loans Servicing, Case Number + VS. 2013-948 Paula M Price(et al.) i SHERIFF'S RETURN OF SERVICE ` 03/25/2013 Ronny R Anderson,Sheriff,being duly sworn according to law,states he made diligent search and inquiry a for the within named Defendant to wit Paula M Price,but was unable to locate the Defendant in his i bailiwick.The Sheriff therefore returns the within.requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint In Mortgage Foreclosure as"Not Found"at 602 West Pine St.,S. i Middleton Twp.,Mt.Holly Springs,PA 17065.Residence appears to be vacant but mail is currently in the i mailbox. 03/252013 Ronny R Anderson,Sheriff,being duly sworn according to law,states he made diligent search and Inquiry i for the within named Defendant to wit Cody O Price,but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint In Mortgage Foreclosure as"Not Found"at 602 West Pine St.,S. Middleton Twp.,Mt.Holly Springs,PA 17065.Residence appears to be vacant but mail is currently in the mailbox. SHERIFF COST:$61.00 SO ANSWERS, March 25,2013 RON R ANDERSON,SHERIFF • I I (q Ca rj Wtu SMrW.Totem&Irk I Exhibit "B" AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE PHS#298190 HOME LOANS SERVICING,LP DEFENDANT SERVICE TEAM/vla PAULA M.PRICE COURT NO,:13.948-CIVIL CODY O.PRICE SERVE,PAULA M.PRICE A'1: TYPE OF ACTION 100 PINEWOOD RD XX Mortgage Foreclosure APT 129 XX Civil Action VIRGINIA BEACH,VA 23451-3968 SERVED Served and made known to_PAULA_ M.PRICE,Defendant on the_day of .. .,20 at ,o'clock­M.,at in the manner described below: Defendant personally 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 Height Weight Race Sex Other L. .a competent adult,being duly sworn according to law,depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of . ,2Q—. Notary: By: P40T SE-RVED On the 5 day of A t 20 t�,J 'clock I ter a competent adult hereby state.that Defendant NOT FO'1 TNU because: ' — Vacant —Does Not Exist _ Moved �Does Not Reside(Not Vacant) _No Answer on at at pp ' _Service Refused Other: Sworn to and subscribed �q i Il tn� 13 b a�►) �/� l 7 b before e this day If J y. � A"t Ina It B �/ ' e ' Notary: ATTORNEY FOR PLAINTIFF Chrisovalante P.Fliakos,Esq.,Id.No.94620 Lawrence T.Phelan,Esq.,Id.No.32227 Courtenay R.Dunn,Esq.,Id.No.206779 Francis S.liallinan,Esq.,id.No.62695 Allison F.Zuckerman,Esq.,Id.No.309519 Daniel G.Schmieg,Esq.,Id.No.62205 Melissa J.Cantwell,Esq.,Id.No.308912 Michele M.Bradford,Esq.,Id.No.69849 Mario J.Hanyon,Esq.,Id.No.203993 Judith T.Romano,Esq.,Id.No.58745 John M.Kolesnik,Esq.,Id.No.308877 Jenine R.Davey,Esq.,Id.No.87077 Matthew G.Brushwood,Esq.,Id.No.310592 Lauren R.Tabas,Esq.,Id.No.93337 Zachary J.Jones,Esq.,Id.No.310721 Jay B,Jones,Esq.,Id.No.86657 Justin F.Kobeski,Esq„Id.No.200392 Andrew L.Spivack,Esq.,Id.No.84439 Adam Davis,Esq.,Id.No.203034 One Penn Center at Suburban Station 1617 John F.Kennedy Blvd., Suite 1400 VASANTI MAJ£THIA NOTARY PUBLIC REGISTRATION#357640 COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES FEBRUARY 28; 2017 fl7g Exhibit "C" AFFIDAVIT OF GOOD FATI'H INVESTIGATION File Number: 298190 Attorney Firm: Phelan Hallinan LLP Subject: Paula M. Price &Cody O.Price Property Address: 602 West Pine Street,Mount Holly Springs,PA 17065 I.CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Paula M. Price-xxx-xx-4845 Cody O.Price-not available B. EMPLOYMENT SEARCH Paula M.Price &Cody O.Price-A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Paula M. Price&.Cody O. Price reside(s) at: 602 West Pine Street,Mount Holly Springs,PA 17065. II.INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases,which indicated that Paula M. Price&Cody O.Price reside at:602 West Pine Street,Mount Holly Springs,PA 17065. On 04-23-13 our office made a telephone call to the subjects' phone number (717)4:86- 5738 and received tlhe following information:not in service. 111. INQUIRY OF NEIGHBORS On 04-23-1.3 our office made a phone call in an attempt to contact Cory E. 1--lawbaker (717)486-8347, 600 West Pine Street, Mount Holly Springs,PA 17065: not in service On 04-23-13 our office made several-phone calls in an attempt to contact Fred.A.St<,alil (717)486-3548,609 West Pine Street,Mount Holly Springs,PA 17065: answering machine On 04-23-13 our office made several phone calls in an attempt to contact Paul.E.Lebo (717)323-0446, 603 West Pine Street,Mount Holly Springs, PA 17065:no answer IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 04-23-13 we reviewed.the National Address database and found the following information: Paula M. Price&Cody O.Price-602 West Pine Street,Mount Holly Springs,PA 17065. B. ADDI'I"IONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors,the following is a possible mailing address:no addresses on file. V. OTHER INQUIRIES A. DEATH RECORDS As of 04-23-13 Vital Records and all public databases have no death record on file for Paula M. Price &Cody O.Price. VI. ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Paula M.Price-not available Cody O. Price-not available B. A.K.A. Paula M.Sharp *Our accessible databases have been checked and cross-referenced for the above named individual(s). *Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge,information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S.Sec.4904 relating to unsworn falsification to authorities. The above information is obtained from available public records and we are only liable for the cost of the affidavit. Exhibit "D" Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 Jason Seidman, Ext 1394 Representing Lenders in Service Department Pennsylvania May 28,2013 PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS,PA 17065-1116 RE: BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. PAULA M. PRICE and CODY O. PRICE Premises Address: 602 WEST PINE STREET,MOUNT HOLLY SPRINGS,PA 17065- 1116 CUMBERLAND County,No. 13-948-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9),I am seeking concurrence with the requested relief that is, service of the complaint by first class mail and posting of the irioftgagcd premises. Please respond to me within one week, by ^ P 1113;- Should you have any further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. Very truly yours, Meredith Wooters,Esq.,Id. No.307207 Attorney for Plaintiff 298190 Name and Phelan Hallinan, LLP Address y 1617 JFK Boulevard,Suite 1400 N Of Sender One Penn Center Plaza o S O N Philadelphia,PA 19103 VLA Line Article Number Name of Addressee,Street,and Post Office Address Postage W M N 1**** PAULA M.PRICE $0.46 Z D } 602 WEST PINE STREET w MOUNT HOLLY SPRINGS,PA 17065 , rn 2 **** PAULA M. PRICE $0.46 P.O. BOX 142 M ccno WALNUT BOTTOM,PA 17266 o o ! 3 **** CODY O.PRICE $0.46 NOO 602 WEST PINE STREET . MOUNT HOLLY SPRINGS,PA 17065 4 **** CODY O.PRICE $0.46 100 PINEWOOD RD APT 129 VIRGINIA BEACH,VA 23451 RE: PAULA M.PRICE CUMBERLAND TEAM 4 PHS#298190/1021 Page I of 1 / -$''84 1,3! � ' Total Number of Total Number of Pieces Postmaster,Per(Name of The full declaration of value is required on all domestic and international registered mail. The max Pieces Listed by Sender Received at Post Office Receiving Employee) for the reconstruction of nonnegotiable documents under Express Mail document reconstruction in ' piece subject to a limit of$500,000 per occurrence. The maximum indemnity payable o'n Express, The maximum indemnity payable is$25,000 for registered mail,sent with optional insurance:-See'".,:_.._..._....__._ 8900 S913 and 5921 for limitations of coverage. Form 3877 Facsimile 2981.90 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 Attorney for Plaintiff BANK OF AMERICA,N.A., AS SUCCESSOR Court of Common Pleas BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME Civil Division LOANS SERVICING, LP Plaintiff CUMBERLAND County vs. No. 13-948-CIVIL PAULA M. PRICE CODY O. PRICE Defendants CERTIFICATION OF SERVICE The undersigned hereby certifies that a copy of the Motion for Service Pursuant to Special Order of Court, Memorandum of Law, Proposed Order and attached exhibits have been sent to the individual as indicated below by first class mail, postage prepaid, on the date listed below. PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 PAULA M. PRICE PO BOX 142 WALNUT BOTTOM, PA 17266 PAULA M. PRICE 100 PINEWOOD RD, APT 129 VIRGINIA BEACH, VA 23451-3968 CODY O. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 _ CODY O. PRICE 100 PINEWOOD RD, APT 129 VIRGINIA BEACH, VA 23451-3968 298190 . t The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Respectfully submitted, PHELAN HALLINAN, LLP Date: By: Meredith Wooters, Esq., Id. o.307207 Attorney for Plaintiff 298190 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA BANK OF AMERICA,N.A.,AS SUCCESSOR Court of Common Pleas BY MERGER TO BAC HOME LOANS SERVICING, LP F/KJA COUNTRYWIDE HOME Civil Division LOANS SERVICING, LP Plaintiff CUMBERLAND County C-) t-.:) --r,vs. No. 13-948-CIVIL !C:E> M rn PAULA M. PRICE CODY O. PRICE c:>-r, Defendants =C) C) ORDER AND NOW,this day of �� 2013,-upon consideration of Plaintiffs motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED, that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and of the Notice of Sheriffs Sale as authorized by PaRCP. 3129.2 (c)(1)(i)(C)*, on the above captioned Defendant,PAULA M. PRICE,by: 1. Posting of the premises: 602 WEST PINE STREET,MOUNT HOLLY SPRINGS,PA 17065 by the Sheriff or a non-party competent adult; and 2. First class mail to PAULA M. PRICE at the mortgaged premises located at 602 WEST PINE STREET,MOUNT HOLLY SPRINGS,PA 17065and at P.O. BOX 142, WALNUT BOTTOM,PA 17266. Service by mail is complete upon the date of mailing. 3. Publication in accordance with PaR.C.P. 430 PHS#29819ONLA It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. BY THE COURT: Mffirst *Prior to fulfilling the requirements of service of Notice of Sale as set forth in this Order, attempt service as set forth in Pa.RCP. 3129.2(c)(1)(i) .(A) or (B). In the event this attempted service is not successful,Plaintiff may proceed with service of the Notice of Sale in conformity with this Order. Cc:PAULA M. PRICE 602 WEST PINE STREET, MOUNT HOLLY SPRINGS,PA 17065 PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 0� PHS#298190/VLA !*ILROT- F FI CE r T H E HOPiOT A PHELAN HALLINAN,LLP AUG Adam H.Davis,Esq.,Id.No.203034 -5 AN jo., j2 1617 JFK Boulevard,Suite 1400 S�{ LQ One Penn Center Plaza PElys YL V COUNTY Philadelphia,PA 19103 ( }/ANNA Adani.Davis@PhelanHallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR COURT OF COMMON PLEAS BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE CIVIL DIVISION HOME LOANS SERVICING, LP Plaintiff CUMBERLAND COUNTY vs. PAULA M.PRICE No. 13-948-CIVIL CODY O.PRICE Defendants PRAECIPE,TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN,LLP By: Adam H.Davis,Esq.,Id. No.203034 Attorney for Plaintiff /bsp,Svc Dept. File#791952 C3 =m Phelan Hallinan,LLP John Michael Kolesnik,Esq.,Id.No.308877 ATTORNEYS FOR PLAINTIFF cn' -C> John.Kolesnik @phelanhallinan.com r°7-1 1617 JFK Boulevard, Suite 1400 � = " One Penn Center Plaza C:� ' Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, COURT OF COMMON PLEAS LP Plaintiff CIVIL DIVISION VS. CUMBERLAND COUNTY PAULA M.PRICE No. 13-948 CODY O.PRICE Defendant(s) AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail to the following persons, PAULA M. PRICE at 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 and PO BOX 142, WALNUT BOTTOM, PA 17266 on August 16, 2013, in accordance with the Order of Court dated July 18, 2013. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Phelan Hallinan,LLP DATE: G 2 By: 2 Jo Michael Kolesnik,Esq.,Id.No.308877 orney for Plaintiff Phelan Hallinan,LLP PH#791952 r �P AFFIDAVIT OF SERVICE - CUMBERLAND SDK PLEASE POST BY:09/04/2013 PLAINTIFF COUNTY: CUMBERLAND ' BANK OF AMERICA, N.A., AS SUCCESSOR BY � M- =M TO BAC HOME LOANS SERVICING, LP COURT NO. 13-948 z;;o -0 F/K/A COUNTRYWIDE HOME LOANS �r– w MC:J SERVICING, LP DEFENDANT a tom? PAULA M. PRICE TYPE OF ACTI( cs� XX Mortgage Foreclosure 7C SERVE AT: Eviction 602 WEST PINE STREET,MOUNT HOLLY XX Civil Action SPRINGS,PA 17065-1116 Complaint on Promissory Note ***PLEASE POST THE PROPERTY*** ***IN ACCORDANCE WITH THE***** ***ATTACHED COURT ORDER****** Served Post@4 and made known P ULA M.PRICE,Defendant on the 2'4!> day of NVJS� 20 13 at 3 d o'clock, .M.,at 602 WEST PINE STREET,MOUNT HOLLY SPRINGS,PA 17065-1116,in the manner described below: Defendant persona ly served. Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name/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 office of said defendant company. Other:� MEW Description: Age Height Weight Race Sex Other I, I�P6 ftteVV ,a competent adult,being duly sworn according to law,depose and state that I personally posted a true and correct copy of the Complaint in Mortgage Foreclosure issued in the captioned case on the date and 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. DATE: ��3 NAME: Z"" PRINTED NAME: JAPGQWCr h E TITLE: q�� serzktv- NOTSERVED On the_day of 20_,at_o'clock_.M.,Defendant NOT FOUND because: _Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) No Answer on at at Service Refused Other: PH#791952 Phelan Hallinan,LLP ATTORNEYS FOR PLAINTIFF Adam H.Davis,Esq.,Id. No.203034 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, COURT OF COMMON PLEAS LP Plaintiff CIVIL DIVISION VS. CUMBERLAND COUNTY PAULA M.PRICE No. 13-948 CODY O.PRICE Defendant(s) � `'' M CO cn - f'7 AFFIDAVIT OF SERVICE BY r> C PUBLICATION IN ACCORDANCE WITH COURT ORDER D� C)-n �C1 Dc c- � I hereby certify that service of the Civil Action Complaint in Mortgage Foreclosure was ma kn(ywn > to Paula M.Price in accordance with the Court Order dated July 18,2013 as indicated below: By publication as provided by Pa.R.C.P.Rule 430(b)(1)in The Sentinel on August 16,2013 and the Cumberland Law Journal on August 23,2013.Proofs of the said publications are attached hereto. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Phelan Hallinan,LLP DATE: Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff PH#791952 BSD 1 - PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Tackie Cox,Director of Sales of The Sentinel,of the County and State aforesaid,being duly sworn,deposes and says that THE SENTINEL,a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th, 1881,:since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): August 16,2013 COPY OF NOTICE OF PUBLICATION teen o NOIRE I IN THE COURT OF f.PENNSYLVANIA I Affiant further deposes that he/she is not i BANK OF AMERICA,NA.,AS S MON PLEAS I interested in the subject matter of the BY MERGER TR BAC HOME LOA SERVICING,T FIK/A COUNTRIri aforesaid notice or advertisement,and that LOANS SERVICING,Plaintiff I t. f rOUNTY all allegations in the foregoing statement as VS. to time,place and character of publication PAULA M.PRICE + are true. CODY O.PRICE } Defendants To PAULA M.PRICE AS SUCCESSOR BY You are hereby noted that on F LOANS SERVICING,LP,filed a MERGER TO BAC HOME LO the Court of Common Pleas of 1 Mortgage Foreclosure ComPI F eks to foreclose on the mortgage' CUMBERLAND'County Penn pRINGS,PA'17065-1116 Sworn to and subscribed before me this secured on your property whereupon your property wou' 1� You are hereby notified to plead lays from the date of this IL r►1 clam 1 (� O publication' a Judgment will i (• 1 l 1 I C I If you wish to defend,You must eqd file your defenses or objections 1 y �ed without you and a judgment in writing with the court.You intiff.You ma lose mone or may be entered against you vP Y y property or other rights impodi HAVE A LAWYER,GO TO OR NO 11C YOU SHOULD TAKE THIS NO,YOU WITH INFORMATION TELEPHONE THE OFFICE. ABOUT HIRING A LAWYER IPROVIDE YOU WITH IF YOU CANNOT AFFORD TofROVID PERSONS AT A INFORMATION'ABOOT AGELIGIBLE I REDUCED FEE OR,NO FE My commission expires: I i COMMONWEALTH OF PENNSYLVANIA Notarial sea► Bethany M,Holby,Notary public Carlisle eo%Cumberland County My Commis�on Expires 26,2015 MEMBER PENNSYLVANIAOCIATrON OF NOTARIES PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz August 23, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. sa Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 23 day of August, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 r CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN the court.You are warned that if you MORTGAGE FORECLOSURE fail to do so the case may proceed without you and a judgment maybe In the Court of Common Pleas of entered against you without further Cumberland County,Pennsylvania notice for the relief requested by the Civil Action—Law plaintiff. You may lose money or property or other rights important No. 13-948 to you. YOU SHOULD TAKE THIS NO- BANK OF AMERICA,N.A.AS TICE TO YOUR LAWYER AT ONCE. SUCCESSOR BY MERGER TO IF YOU DO NOT HAVE A LAWYER, BAC HOME LOANS SERVICING, GO TO OR TELEPHONE THE OFFICE LP f/k/a COUNTRYWIDE HOME SET FORTH BELOW. THIS OFFICE LOANS SERVICING,LP, CAN PROVIDE YOU WITH INFORMA- Plaintiff TION ABOUT HIRING A LAWYER. vs. IF YOU CANNOT AFFORD TO PAULA M. PRICE,CODY O. PRICE, HIRE A LAWYER,THIS OFFICE MAY Defendants BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES NOTICE THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- To PAULA M. PRICE DUCED FEE OR NO FEE. You are hereby notified that on CUMBERLAND COUNTY February 21, 2013, Plaintiff, BANK ATTORNEY REFERRAL OF AMERICA,N.A.AS SUCCESSOR CUMBERLAND COUNTY BY MERGER TO BAC HOME LOANS BAR ASSOCIATION SERVICING, LP f/k/a COUNTRY- 32 South Bedford Street WIDE HOME LOANS SERVICING, Carlisle,PA 17013 LP, filed a Mortgage Foreclosure (717)249-3166 Complaint endorsed with a Notice (800) 990-9108 to Defend, against you in the Court Aug. 23 of Common Pleas of CUMBERLAND County, Pennsylvania, docketed to No. 13-948. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 602 WEST PINE STREET,MOUNT HOLLY SPRINGS, PA 17065-1116 where- upon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with 9 -OFF IC t" F HIE -PA-IIIONC . NT/ 26 PH PHELAN HALLINAN, LLP 3: Joseph P. Schalk, Esq., Id. No. 91656 CU1BERLAD co wiiiMtorney for Plaintiff 126 Locust Street PENNSYLVANIA Harrisburg, PA 17101 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Court of Common Pleas F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Civil Division 7105 CORPORATE DRIVE PLANO, TX 75024 No. 13-948-CIVIL Cumberland County Plaintiff V. PAULA M. PRICE CODY 0. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 Defendants MOTION TO LIFT CONCILIATION STAY Plaintiff, Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP (hereinafter"Plaintiff'), by its attorney, Joseph P. Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1. On February 21, 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 May 1, 2011, 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 August 20, 2013, Plaintiff completed service of the Complaint in Mortgage Foreclosure along with the Cumberland County Residential Mortgage Foreclosure Diversion 791952 Program Notice upon the Defendants. True and correct copies of the Affidavit's of Service are 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 and have filed Answers to Plaintiff's Complaint, 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 HALLINAN, LLP Date: (I 0)13 BY: "AI ose9h Schalk, Esquire Atte,ney for Plaintiff 791952 • • Exhibit "A" 4.60 .4 rqi w I%) 70) 471 PHELAN HALLINAN,LLP ;7,1 4Z) Allison F.Zuckerman,Esq.,Id.No.309519 1617/PK Boulevard,Suite 1400 ATTORNEY FOR PLANdF One Penn Caner Plaza Philadelphia,PA 19103 215463-7000 BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP COURT OF COMMON PLEAS F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP CIVIL DIVISION 7105 CORPORATE DRIVE PLANO,TX 75024 TERM ev it Plaintiff NO. -6\4 V. CUMBERLAND COUNTY PAULA M PRICE CODY 0.PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS,PA 17065-1116 Defendants CIVIL ACTION-LAW COMPLAINT IN moRTGAGE FORECLOSURE We hew, Mtorn 00) twin. certif.a& tioi kr, ups —4r;4.1.Una Riaate R 4*of art othr (4: Me nal flied of . File/4. 298.190 „ NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff You may lose money or property or other rights important to you YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER., THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORM:ATI-ON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO 'ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. C11114BERIAND COUNTY ATTORNEY REFERRAL ClJMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-316( (800)990-9108 2w190 ^ . . l. Plaintiff is BANK OF AMERICA,NA., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP [/K/A COI TNTRY\VlDB HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. Deukune(s) and last known address(es)of the Defendant(s) are: PAULA M. PRICE CODY 0. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS,PA )7065-]ll0 whoinlare the mortgagor(s) and/or real owner(s) of the property hereinafter described, 3. On 10/23/2008 PAULA M. PRICE and CODY O. PRICE made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE FOR COUNTRYWIDE BANK, FSB which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200836609. By Assignment of Mortgage recorded 10/24/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201129370.The mortgage and assigtunent(s), if any, are matters of public record and are incorporated herein by reference in accordance wit6Pa.{l,C.P. 10.19(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings ii those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2011 and each month thereafter are due and unpaid, and by the ternis of said mortgage, upon thilure of Mortgagor to make such payments aftcr a date specified g 294190 by written notice sent to Mortgagor, Uecudrc principal balance and all interest due thereon are collectible forthwith. 6. The :following amounts are due on the mortgage uonf0l/Z5/20lJ: Principal Balance $142/23.15 Interest $15,622.64 U4/0l/Z0ll through 0l/3l/20l] Late Charges $0.00 Property Inspections $15.00 Title Cost $250.00 Escrow Deficit 15,389J7 TOTAL $163,299,86 7. Plaintiff is not.seeking a judgment of personal liability (or an iuperyonunl 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. 8. Notice of Intention to Foreclose as set forth in Act 6ofl974' Notice ufHomeowner's Fimergency Mortgage Assistance Program pursuant to Act 91 oflA8J, 00 amended iu 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) xotbar/6 thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. Ihis action does not come under Act 91 of 1983 because the mortgage is FHA-insured. puo*� 2o190 • WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s)in the sum of V63,299,86,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. PI .AN.i 1.Apri Mt-17L1 Al n F. .-unt L'sq.,Id.No3095I9 norhey•for ain't I cr Nti.L.)3 LEGAL DESCRIPTION ALL that certain tract or land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at a point in the public road leading from Mount Holly Springs to Barnitz(Township Road. No.475),said point being 134 feet, more or less, in a Westerly direction in said road from line of land now or formerly of Medusa Cement Company; thence continuing in said public road,North 47 degrees West 100 feet to a point; thence by land now or formerly of Kenneth W. Smith and June R. Smith,his wife,North 19 degrees 40 minutes East 200 feet to a stake; thence by land now or formerly()flan E. Maurice, et al., South 47 degrees East 100 feet to an iron pin;thence by land now or formerly of DD&M Corporation by a line parallel to the line of Medusa Cement Company and 133 feet in a perpendicular distance to Westward therefrom, South 19 degrees 40 minutes West 200 feet to the Place of BEGINNING. BEING improved with a dwelling house with attached garage. BEING the same premises which Donald R. Handshew and Bonnie L. Handshew, his wife, by Deed dated September 7, 1976, and recorded September 7, 1976, in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, in Book LI26, Page 24,granted and conveyed unto Ronald Wagner Sheaffer and Rosealma B. SheatTer, his wife. BEING THE SAME PREMISES which Ronald Wagner Sheaffer and Roseaima B. Sheaffer,his wife by their Deed dated OetoBer 17, 2008 and about to be recorded in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, granted and conveyed unto Cody 0. Price and Paula M. Price, his wile, Mortgagors herein, PROPERTY ADDRESS: 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 PARCEL # 40-32-2334-002A 298190 VERIFICATION (1.7:1'101 hereby states that he i ' of BANK OF — AMERICA, N.A., Plaintiff in this matter,that he(Sli)is authorized to make this Verification,and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true " and correct to the best of hi4(fiep information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unswom falsification to authorities. Namq = DATE: e = , ( 14 _ BANK OF AMERICA,NA, File#: 298190 Name: PRICE ) • upaatea Win/4W I FORM I IN THE COURT OF COMMON PLEAS BANK OF AMERICA,N.A.,AS SUCCESSOR OF CUMBERLAND COUNTY,PENNSYLVANIA BY MERGER TO BAC HOME LOANS SERVICING,LP F/KiA COUNTRYWIDE HOME LOANS SERVICING,LP Plaintiffts) vs. PAULA M. PRICE CODY a PRICE 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 lbreelosure 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 roust 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 insist be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward, If you are represented by a lawyer,you and your lawyer must take the following steps to he eligible for a conciliation conference. It is not necessary for you to contact MidPerm I,egal 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 vitt 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 forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 2 7, t`---/ / Date "Allison F. /iittl'(Titian,Esq., Id. No.309519 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQLTEST FOR HARDSHIP 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 of your knowledge; I isi OME14/PRIM kit)" ANTI( AN Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes 111 No I Listing date: Price: $ Realtor Name- Realtor Phone: Borrower Occupied? Yes rjj No n Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: _ #of people in household: How long? CO-BORROWER Mailing Address: V. City: State: Zip: Phone Numbers: Home: Office: „ Cell: Other: Email: #of people in household: How long? FINA N('IAI, IiNFC)RMATION First Mortgage Lender: Type of Loan: _ , I oan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes& Insurance:„ Date of Last Payment: Primary Rea,son Jr Default: ' Is the loan in l3ankruptcy? Yes I No [11 If yes,provide names, location of court,case number& attorney: Assets Ainovot()we}: Value: Home: $ $__________. Other Real Estate: S___________ Retirement Funds: $ $_________ Investments: $ Checking: Savings: $_________ Other: $ _______ ���*|� _____ _ Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: , Other nawortudon automobiles boats motorc dcs : Mkdel. Year: Amount Value Monthly Income Name of Employers: ].~_____________________��oudJ�G/uoo Monthly Net ~__ J. Monthly Gross Monthly Net __ 3. ________ Monthly Gross Monthly Net Additional Income Description (not wages): 7 /nonU/|yumoun� _____ ____ 2. monthly amount: __________ Borrower Pay Days: Co-Borrower Pay Days: __________ Monthly Expenses: (Please only include expenses you are currently paying) 8XP��S[ AMOUNT EXPENSE AMOUNT. --� ---------|------- -------------'--'-------' Bdo Food - - ' Car Payment(s) Condo/Neigh.Fees Auto Insurance Med, (not covered) Auto fitel/renairs Install. Loan Payment Cable Tv Child Supnort/Alim, Spending Money „„_____ Amount Available for h400t ly Mortgage Payments Based on Income&:. Expenses: liave you been working with a 1loijsing Counseling Agency? Yes No Fl If yes,please provide ilic ibllowing iob`cmm{im: Counseling Agency: Counselor: Phone(Office). Fax: have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP) assistance? Yes No Ej [ryes,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? Yesili No Ej 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(Niune):, Phone: Servicing Company(Name): Contact: Phone: AUTUORIZATION 1/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that liwe am/are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please tbrward 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) Exhibit “B” • AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LI'F/K/A COUNTRYWIDE PHS#298190 HOME LOANS SERVICING,LP DEFENDANT SERVICE TEAM/ PAULA M.PRICE COURT NO,; 13-948-CIVIL CODY 0,PRICE SERVE CODY 0,PRICE AT; TYPE OF'ACTION 100 PINEWOOD RD XX Mortgage Foreclosure APT 129 XX Civil Action VIRGINIA BEACH,VA 23451-3968 gRyp.) 5— ved and ine known to 1.-e[CtId;i111 day of ly r 70 /3,at M .at„IQ /..„2 el 12,4 ,in the Milliner described below: 1.2,'ifjfendant personally served, Adult family member with whom Defendant(s)residet,$). Relationship is Adult in charge of Defendaut'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. art officer of said Defendant's company, Other: s P 1, f/ Description: ',tie Height/t' "" Weight NS- Race 1°4) Sexill Other ITU6k0, . _ ,a competent adult, being duly sworn according to law, depose and state that I personally hamlet, a true and correct copy of the Foreclosure Complaint in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above, Sworn to and subscribed before me-this '1 - VASANTi MAJETH1A lt NOTARY PUBLIC REISTRATION a 367640 COM MO NYVE ALT H OF VIRGiblifs 1"MarY: 1V MY t.70MM1SSION ExPIFIES FEBRUARY 7t , 2 0 1'6r • On the day cif , .20 at o'clock M.,I a competent adult hereby state that DeloniCint NcEr`FOONliii;KTYniTJ.: Vacant Does Not Exist: Moved Does Not Reside(Not Vacant) No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary; ATTORNEY FOR PLAINTIFF Chrisovc,tana P.Iliakos,Esq.,Id.No.94620 Lawrence T.Phelaa,Esq.,17,No.32227 Couctenay R.Dunn,Esq„td,No.206779 Franck S.flallinan,Esq.,Id.No,62995 Allison F.Zuckerman,Esq.,Id.No.309519 Daniel CL SchniitT,Esq.,17.No,92205 Melissa 3,Cantwa, 17.No,308912 Michcle M.Bradford,Esq.,17,No.09849 Mario 1.Hanyon,Esq.,Id.No,203993 Judith T.Puiriuu,EMI,Id,No 55745 Mut M.Kolesnik,Esq.,Id.No.308877 Jenine R.Davey,Esq„Id.No.87077 tvIantww G.Brushwood,Esq.,Id.No 310592 laurel:R.Tabas,Esq.,17 No.9.3337 Zachary 1,Jones,Esq„Id.No.310721 Juy B. tones,Esq„Id,No 86657 Just in Fs.Kobeski,Esq.,id.No.200392 Andrew 1„Spivack,ltsq.,17,No.84439 Adam DmiN,Esq„Id.Ni),2113034 Our!.Penn Center at Suburban Station 1617 John F.Kmnedy Blvd., Suite 1400 (174' . . AFFIDAVIT OF SERVICE —CUMBERLAND SDK PLEASE POST BY 09A-412013 PLAINTIFF COUNTY: CUMBERLAND -i BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP COURT NO. 13-948 . F/K/A COUNTRYWIDE HOME LOANS SERVICING, 1..1' DEFENDANT PAULA M.PRICE TYPE OF ACTION XX Mortgage Foreclosure ' SERVE AT: Eviction 602 WEST PINE STREET, MOUNT HOLLY XX Civil Action SPRINGS,PA 17065-1116 .Complaint on Promissory Note , ***PLEASE POST THE PROPERTY*** ***IN ACCORDANCE WITH THE***** . ***ATTACHED COURT ORDER****** . . .. Served Pot44) it.jj thi•Ith: kiiiityli PM !1 ,A M.PRICE,Defendant on the 24day DI rocuYT ,20 te3 of, 62,1.,5 6 ..,,,ina. •M..at 602 WEST PINE STREET,MOUNT HOLLY SPRINGS,PA 17065-11 I 6,in the manner described below: Ikfentlani pvnionu ly saved. Adult family member with whom Defctulant(s)teside(s). Relationship is _..,.., . ...,_,_ Adult in charge of Defendant's rem,icon who refused HY give)1:m1e/relationship, Manager/Clerk of place of lodging in which Duthridands)reside(s). Agent or person in charge of Defendae!.;office or usual place of busines5, ofti,c a said defendant company, 0z-p-T, r?ww Description: Age_ Height Weight Race Sex Other, 1, iffIV•F . 94(e2;( ) ,a competent adult,being dilly sworn according to law,depose and state that I personally posted a true and correct copy of the Complaint in Mortgage Foreclosure issued in the captioned case tni the date and the address indicated above.I understand that this statement is made subject to the penalties of I t' Pa.C.S,Sec.4904 relating to unworn falsification to authorities. DATE:1. ,0. / NAME: PRINTED NAMP' /4-19eLt - ov(Eili0 - 'c ri'LE: efe461E-56, se,:•. '• '::. NoT sERvED On 1, -, dny 01 ,20 ,Ar o'docf;..,:,M.,f>fcndant Nat'mum)bccau : _VsC•e■fit 000 Sok EkiSi. MOVO(/ ,„,Ijoes Not Ret;icle(Not VitC:1ffi) _NO iti4'0('00 .S4:trVi,c RCIUM1 0a1W' PEI II 791952 i Phelan Ha Bimini,LLP John Michael Kolesnik,Esq.,Id.No.308877 ATTORNEYS FOR PLAINTIFF John.Kolesnik@phelanhallinan.corn 1617 IFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 21.5-563-7000 r-tLL GOPY PLEASE RETURN BANK OF AMERICA,NA„AS SUCCESSOR BY - MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, COURT OF COMMON PLEAS LP CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. No. 13-948 ca. V* - PAULA M.PRICE z. 4.04 m-rt CODY 0.PRICE "3-co 70. rn Defendant(s) sk I ' 7110 C) e") zc) AFFIDAVIT OF SERVICE OF COMPLAINT 13Y MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail to the following persons, PAULA M.PRICE a 602 WEST PINE STREET,MOUNT HOLLY SPRINGS,PA 17065-1116 and PO BOX 142, WALNUT BOTTOM, PA 17266 on August 16, 2013, in accordance with the Oder of Court dated July 18, 2013. The undersi ed understands that this tattrnerit 1'2 subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Phelan Hallinan,LLP DATE: By: de Jo chaeI Koiesnik,Esq fa.No.308877 orney for Plaintiff Phelan Hallinan,JJP PH#791952 • PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 Attorney for Plaintiff 126 Locust Street Harrisburg, PA 17101 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Court of Common Pleas F/KJA COUNTRYWIDE HOME LOANS SERVICING, LP Civil Division 7105 CORPORATE DRIVE PLANO, TX 75024 No. 13-948-CIVIL Cumberland County Plaintiff V. PAULA M. PRICE CODY 0. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 Defendants CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiff's Motion to Lift Conciliation Stay and proposed Order were sent via first class mail to the person listed below on the date indicated: PAULA M. PRICE CODY 0. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 CODY 0. PRICE 100 PINEWOOD RD APT 129 VIRGINIA BEACH, VA 23451-3968 tio , Date: /I/VI 3 BY:111 4... 4 P40.......dirdp Jt ell 131 chalk, Esquire Atto ey or Plaintiff 791952 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Court of Common Pleas F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Civil Division 7105 CORPORATE DRIVE PLANO, TX 75024 No. 13-948-CIVIL Cumberland County Plaintiff v. PAULA M. PRICE CODY O. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 t Defendants ,.,c- ORDER = c� AND NOW,this 3 day of -3)4.4.A..10-/ , 2013, upon considetatiFe 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. BY TH COURT: J. cc : Paula M. Price ody O. Price Joseph P. Schalk, Esq., Id. No. 91656 Attorney for Plaintiff, i1 791952 ‘---1j'y1 PHELAN HALLINAN, LLP ( ` s> �T 0�t,,) j Attorney for Plaintiff Emily M. Phelan, Esq., Id. No.315250 1617 JFK Boulevard, Suite 140020111 FEB 1 AH One Penn Center Plaza a�� rP�, B Philadelphia, PA 19103 , `)' t RLAND CQUp, 7-F" emily.phelan @phelanhallinan.com PEENS YLVANIA 215-563-7000 BANK OF AMERICA, N.A.,AS CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION VS. No. 13-948 PAULA M. PRICE CODY O. PRICE 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 PAULA M. PRICE and CODY O. PRICE, Defendants 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 $163,299.86 TOTAL $163,299.86 1 hereby certify that (1) the Defendants' last known addresses are 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116, PO BOX 142, WALNUT BOTTOM, PA 17266, and 100 PINEWOOD ROAD, APARTMENT 129, VIRGINIA BEACH, VA 23451- 3968, and (2) that notice has been given in accordance with PydT4 Pa.R.C.P 237.1. Date Emily M. Phelan, Esq., Id. No.315250 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PH#791952 PROTHONOTARY aH� 9���3Gaa� �-301012► �,�c�, mailed PHELAN HALLINAN, LLP Attorney for Plaintiff Emily M. Phelan,Esq., Id. No.315250 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 eniily.phelan@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC COURT OF COMMON PLEAS HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS CIVIL DIVISION SERVICING, LP No. 13-948 VS. PAULA M. PRICE CODY O. PRICE 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 defendants PAULA M. PRICE and CODY O. PRICE 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 PAULA M. PRICE is over 18 years of age and the last known addresses of the defendant are 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 and PO BOX 142, WALNUT BOTTOM, PA 17266. (c) that defendant CODY O. PRICE is over 18 years of age and the last known addresses of the defendant are 100 PINEWOOD ROAD, APARTMENT 129, VIRGINIA BEACH, VA 23451-3968 and 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date Phelan Hallinan, LLP Emily M. Phelan, Esq., Id. No.315250 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 791952 nmp3 0 M D rl r o m o o m Z _< it a y a C3 � u a m CD co Z Z Duo ads s' 0 Z 3 N ® C N CD CA CD C) p Oz A m N m 0 IO ',Zl CD CD w -' 3a m � v C) CD o' 3 Q 4 Co z z.�' a 2 - io m a. - n a a fl7 3 m ° 3 s CD m m o � o C) - Q c m y - -, a _ o D o ° 0 � m � 6 Z o Oy - w m D D S 2 2 2 � c Q z °3.0 n n m - o ° v ° m 3 G7 Z m m < 1 ^' ^' -O ° F j N m n CD N Z Z N � 3 3 o m a $ n y a m CO W O CD CD CD w m Q C C o = � °a n y o UDi cn p � N m M IA a m C CD o N a (D O C o _ m o - 3 o3i o CS" C7 (D m (D N [T $ o N N o O o 3 D o O T - O - a O � n ET n O y w y DDD m z' z 2 0 m P o al n o IL (Rule of Civil Procedure No. 236) - Revised BANK OF AMERICA, N.A., AS CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS SERVICING,LP CIVIL DIVISION VS. No. 13-948 PAULA M. PRICE CODY O. PRICE Notice its given that a Judgment in the above captioned matter has been entered against you on A) f ? , By: ...E If you have any questions concerning this matter please contact: Phelan Hallman, LLP Emily M. Phelan, Esq., Id. No.315250 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.'' 791952 RANK (}F' AMERICA, N.A., SUCCESSOR BY COURT OF C(),% v1()N PLEAS tiJFRC,4 R '1 O BAC 1IOIt1E LO 1NS SI RVI( IN(;, CIVIL,DIVISI{}'� 1,P L,'k'�h CtJU?�1TRY1h'ID1:I;IIC��'IE LOANS . SF RVIC'ING, LP NO, 13 94 C UP IBERLANID ( (W( N'l Y 1 AIJI_A N1, PRICE COD') Q. PRICE Defendant(s) To: PAULA M.PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, I A 1;7065-1116 DATE.QF NOTICE: THIS I�IIZM IS A DEBT " t`)1.1�I- -OR ATTEMPTING TO COI_.I,ECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COI LECT 'I 1E INDEBTEDNESS REFERRED TO HEREIN, ANY) ANY INFORMATION OBTAINED FROM YOU `VILL 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 SHOUI..,D TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF' YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE, SET.FORTH BELOW. TIIIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT MIRING A LAWYF;k. 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 BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 ARLISLE,PA 17013 t 17)219-316(1 By:_.. Emily M.Phelan,Esq.,Id.No.315250 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PH#791.952 13ANK OF AMERICA, N.A., AS Si CCI'SS()R RY COURT OI`(-()\4M(-)N Pl I AS Ml-;R(iER"1'O BAC: 1IO1L-1F.LOANg CIVII. i)IL ISION LP F/Kl:1 C'C)I,'NTRYL\%1D1;f IC)CIF;l;tJ,1:NS" :SERVICING, l:,P NO. 13-945 . " Plt13]Iltt ,. V. CI°I BI:`R ,AN-1 ( OUI�i'L Y P At_:.LA M. PRICE (,ODY O.PRICE ' Deiend<trii(s) TO: PAULA-M.PRICE PO BOX 142 WALNUT"BOTTOM,PA 17266 DATE or NOTICE: . THIS FIRM IS A DEBT COLLECTOR ATTEMPTING; TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU 1I\? AN AI"1`ENIPT TO C'OLLEC'T 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 ECT A DEBT, BUT ONLY AS 1NFORCENIENT OF L.LEN 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 FRONI 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 TIIIS PAPER. TO YOUR LAWYER A'I' (ONCE. IF YOU DO NOT " HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATIONT 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 BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By:__ Emily M,Phelan,Esq., Id. No.315250 Attorney for Plaintiff Phelan Hallinan,I..LP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PH#791952 BANK 01 AN'l FICA ' o.. S S1J( { i 5i{}R I3Y COi ART 01 {`01tIM0}N PLEAS �1ERCIEId 7`O IiAC: 110NI ;LCOANS 41J81,'J _ING, C:�IV '.L DIF I410N' LP 1 IK1 IIt)Ni1; 1"()A= SERVICING, i_"P NO 1S Pl<<;ntltf 4. CUM3I,RI,AND COUNTY PAULA Y1 PRIC1" CO,DY O.PRICK Dcendantis? - `I'O: CODY 0. PRICE 100 PINEWOOD ROAD APARTMENT 129 VIRGINIA BEACH,VA 2345.1-3965 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR AT7I.MP'I'ING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLI...E_•.C`l' 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, TIIIS CORRESPONDENCE, IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS F,NFORCBMENT 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 R OTHER AGAINST YOU WITHOUT A HEARING AND YOU MAY I.,OSE YOUR PROPERTY OR QrI HER IMPORTANT-RIGHTS. YOU SHOULD TAKE THIS PAPLR TO YOUR LAWYERIAT ON{_;1✓. II'. YOU.DO NOT HAVE A LAWYER. GCS TO OR 'n;I- P1 IONI E Tl IE 01 I I['I SET FORT)I BELOW; THIS OFFICE CAN PROVIDE YOU WI'I`lI NFORMA`I"ION AI30I.T'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 BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COUR'THOIJSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (7 17)2-1,11 l tf)6 By: _.._ Emily Phelan,Esq.,Id:No.315250 Attorney for Plaintiff Phelan hlallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PH#791952 13,,,1,NK OF ANIFA'7('A, N.,,\.. AS SUCCESSOIZ fly COUW1 OFCO,'VINION PI EAS R 'F0 l0t\41`11 1,0 NS SERVICING, ('1vii,DIVISION -. O ,HONIPLANS 1,11 f,/K/A ('OViJ1'M,,Y\VIT)1 SERVICING, I-P N -9148 C1 NMFRI.AND C01 JNTY CODY 0, 11RICE TO: CODY O.PRICE 602 WEST PINE STREET' MOUNT HOLLY SPRINGS.PA 17005-1116 DATE'.OF NOTICE: THIS FIRM IS A DEBT'COLLECTOR ATTENIPTIN.GTO COI-LECT A DEBT. THIS NOTICI IS SENT TO YOU IN AN ATTENIPTTO COLLECT THE INDEBTEDNESS SS 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 ATTEI'VIPT 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 COt'iRT 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 i OTHER AGAINST YOU WITHOUT A HEARING ANT) YOU MAY LOSE YOUR PROPERTY, OR IMPORTANT'RIGHTS. YOU SHOULD TAKE.. THIS PAPER TO YOUR LAWYER AT ONCE. IF YO[.1' DO NOT HAVE A LAWYER, GO TO.OR 'TELEPHONE THE OFFICE SET FORTH BELOW.' THIS (.)I,-I:,ICE 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 REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: —---------Enfl, 1.Phelan.Esq.,Id.No.315250 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PH#791952 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. PAULA M. PRICE CODY 0. PRICE Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 02/15/2014 to Date of Sale ($26.84 per diem) TOTAL Note: Please attach description of property. PH # 791952 ets, --DAL 04.0:1?5 DOCk " " .1C." tp• L. \S COURT OF COMMON PLEAS CIVIL DIVISION : NO.: 13-948 CUMBERLAND COUNTY $163,299.86 $2,952.40 $166,252.26 116an Hallinan, LLP r") Jbjeph E. DeBarberie, Esq., Id. No.31542:I Attorney for Plaintiff in T-I-1 Zr- cf) CL* rqry IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. PAULA M. PRICE CODY 0. PRICE Defendant(s) PRAECIPE FOR WRIT OF EXECUT ON (Mortgage Foreclosure) Filed: an Hallinan, LLP o"ph E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff Address where papers may be served: PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 P.O. BOX 142 WALNUT BOTTOM, PA 17266 CODY O. PRICE 100 PINEWOOD ROAD, APARTMENT 129 VIRGINIA BEACH, VA 23451-3968 LEGAL DESCRIPTION ALL that certain tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the public road leading from Mount Holly Springs to Barnitz (Township Road No. 475), said point being 134 feet, more or less, in a Westerly direction in said road from line of land now or formerly of Medusa Cement Company; thence continuing in said public road, North 47 degrees West 100 feet to a point; thence by land now or formerly of Kenneth W. Smith and June R. Smith, his wife, North 19 degrees 40 minutes East 200 feet to a stake; thence by land now or formerly of John E. Maurice, et al., South 47 degrees East 100 feet to an iron pin; thence by land now or formerly of DD&M Corporation by a line parallel to the line of Medusa Cement Company and 133 feet in a perpendicular distance to Westward therefrom, South 19 degrees 40 minutes West 200 feet to the Place of BEGINNING. BEING improved with a dwelling house with attached garage. SUBJECT to the Building and Use Conditions and Restrictions set forth in Cumberland County Deed Book D', Volume 24, Page 61. TITLE TO SAID PREMISES IS VESTED IN Cody 0. Price and Paula M. Price, his wife, by Deed from Ronald Wagner Sheaffer and Rosealma B. Sheaffer, his wife, dated 10/17/2008, recorded 11/07/2008 in Instrument Number 200836608. PREMISES BEING: 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 PARCEL NO. 40-32-2334-002A PHELAN HALLMAN, LLP Joseph E. DeBarberie, Esq., Id. No.315421 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 joseph.debarberie@phelanhallinan.com 215-563-7000 FiLED-G1-EtuE fliE PROTHONOTAR'l 2011i MP -1 AMU: 12 CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. PAULA M. PRICE CODY 0. PRICE Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 13-948 : CUMBERLAND COUNTY 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: 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: Ian Hallinan, LLP eph E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. PAULA M. PRICE CODY O. PRICE Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13 -948 CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A., AS SUCCESSOR BY. MERGER TO BAC HOME LOANS SERVICING, LP F/K/A 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 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065 -1116. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 P.O. BOX 142 WALNUT BOTTOM, PA 17266 CODY O. PRICE 100 PINEWOOD ROAD, APARTMENT VIRGINIA BEACH, VA 23451 -3968 2. Name and address of Defendant(s) in the judgment: Name PAULA M. PRICE Address (if address cannot be reasonably ascertained, please so indicate) 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 P.O. BOX 142 WALNUT BOTTOM, PA 17266 129, CODY O. PRICE 100 PINEWOOD ROAD, APARTMENT 129 VIRGINIA BEACH, VA 23451 -3968 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) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. PH # 791952 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) t SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY C/O SNELBAKER & BRENNEMAN PC ATTN: KEITH O. BRENNEMAN, ESQUIRE SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY 44 WEST MAIN STREET MECHANICSBURG, PA 17055 P.O. BOX 8 BOILING SPRINGS, PA 17007 -0008 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 DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 -1116 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 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: 1 J , i PH # 791952 By: P n Hallinan, LLP Jo h E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215 -563 -7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F /K/A COUNTRYWIDE HOME LOANS SERVICING, LP PAULA M. PRICE CODY O. PRICE vs. : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff : NO.: 13-948 Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 -1116 CODY O. PRICE 100 PINEWOOD ROAD, APARTMENT 129 VIRGINIA BEACH, VA 23451 -3968 PAULA M. PRICE r , - c-= Q PO BOX 142 ..-- c,.. " WALNUT BOTTOM, PA 17266 3� �� * *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 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065 -1116 is scheduled to be sold at the Sheriff's Sale on 06/04/2014 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $163,299.86 obtained by BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A 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 x1.230. 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 tile 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. 13-948 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP V. PAULA M. PRICE CODY 0. PRICE owner(s) of property situate in the TOWNSHIP OF SOUTH MIDDLETON, CUMBERLAND County, Pennsylvania, being 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 Parcel No. 40-32-2334-002A (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $163,299.86 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL that certain tract of land with the improvements thereon erected, situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point in the public road leading from Mount Holly Springs to Barnitz (Township Road No. 475), said point being 134 feet, more or less, in a Westerly direction in said road from line of land now or formerly of Medusa Cement Company; thence continuing in said public road, North 47 degrees West 100 feet to a point; thence by land now or formerly of Kenneth W. Smith and June R. Smith, his wife, North 19 degrees 40 minutes East 200 feet to a stake; thence by land now or formerly of John E. Maurice, et al., South 47 degrees East 100 feet to an iron pin; thence by land now or formerly of DD&M Corporation by a line parallel to the line of Medusa Cement Company and 133 feet in a perpendicular distance to Westward therefrom, South 19 degrees 40 minutes West 200 feet to the Place of BEGINNING. BEING improved with a dwelling house with attached garage. SUBJECT to the Building and Use Conditions and Restrictions set forth in Cumberland County Deed Book 'D', Volume 24, Page 61. TITLE TO SAID PREMISES IS VESTED IN Cody 0. Price and Paula M. Price, his wife, by Deed from Ronald Wagner Sheaffer and Rosealma B. Sheaffer, his wife, dated 10/17/2008, recorded 11/07/2008 in Instrument Number 200836608. PREMISES BEING: 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 PARCEL NO, 40-32-2334-002A WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13 -948 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F /K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From PAULA M. PRICE, CODY O. PRICE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he /she has been added as a garnishee and is enjoined as above stated. Amount Due: $163,299.86 L.L.: $.50 Interest FROM 2/15/2014 TO DATE OF SALE ($26.84 PER DIEM) - $2,952.40 Atty's Comm: Atty Paid: $221.50 Plaintiff Paid: Date: 3/7/14 (Seal) REQUESTING PARTY: Name: JOSEPH E. DEBARBERIE, ESQUIRE Address: PHELAN HALLINAN LLP 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215 -563 -7000 Supreme Court ID No. 315421 Due Prothy: $2.25 Other Costs: 2iztaie David D. B -11, Prothonota Deputy AFFIDAVIT OF SERVICE PLAINTIFF BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE P11 # 791952 HOME LOANS SERVICING, LP CUMBERLAND COUNTY DEFENDANT SERVICE TEAM/ lxh PAULA M. PRICE COURT NO.: 13-948 CODY 0. PRICE SERVE CODY 0. PRICE AT: 100 PINEWOOD ROAD APARTMENT 129 VIRGINIA BEACH, VA 23451-3968 TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: June 4, 2014 SERVED Served and made known to CODY 0. PRICE, Defendant on the 2S—day of IA AYLCE4-- , 20 at , o'clocica_M., at IlliTET4eYd INPT12- , in the manner described below: A. Defendant personally 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: D c' ion: Age 1 Height t Weight a ad Race VALSex 1 Other I'dtW2---, a competent adult, being duly sworn acc handed a true and correct copy of the Notice of Sheriff's S. - - case on the date and at the address indicated ab Sworn to and subscribed before me this ig–S day of IY1a-r , By: OLA-PrUtt Notary: ng to law, depose and state that I personally nner as set forth herein, issued in the captioned NOT SERVED . On the day of , 20 , at o'clock . M., I, , a competent adult hereby state that Defendant NOT FOUND because: Vacant _Does Not Exist No Answer on at Service Refused Other: Sworn to and subscribed before me this day of , 20 By: Notary: VASANT! MAJETHIA NOTARY PUBLIC REGISTRATION # 357640 COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES FEBRUARY 28, 2017 ___ Moved _ Does Not.Reside (Not Vacant) at ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 ED rn C.f.) '<C7) C) =C=, w cfl ril r CD '71 Priority: STANDARD Received: 3/19/2014 at 10:14 am Court Date: Filed: Service on Summons, Inc. Field Sheet #2014000778 11 A 11 SERVE: Home: CODY O. PRICE, 100 PINEWOOD RD, APT 129, VA BEACH, VA 23451 SPECIAL INSTRUCTIONS: .s - _J9 Attempts Server: Trevor W. Martz Date Time Comments 1.3/2( OS-3 Ai-r _Tie- Aro air *NC, 2. l21 /ej3/ ,'n— Me— Ne aAie 1 D Actual Service Info 3 /Z$--- / %& Type: P6X4fiVf4t- Served on: adi Address: Comments: Miles Hours Additional Addr: 1 2 3 Courier Out of Pocket Costs Age 3 L Sex Race w11,`k_ Height ( Weight goo Hair RiU rj Case Number: 13- 948 -CIVIL Cumberland Common Pleas Plaintiff Defendant BANK OF AMERICA, ■.A., ET AL PAULA M. PRICE, CODY O. PRICE Type of Writ: NOTICE OF SHERIFFS SALE Client: Firm: FULL SPECTRUMSERVICES Phone: (856) 813 -1460 Fax: (856) 813 -1462 Client Reference Number: PH # 791952 Copyright ©1992 -2011 Database Services, Inc. - Process Server's Toolbox V6.5k Glasses Y6) rr, C, , PHELAN HALLINAN, LLP "" ' �'yP J 9 Adam H. Davis, Esq., Id. No.203:03i RL fi f£; Q COUNF 1617 JFK Boulevard, Suite 1400 PENNSYLVANIA 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., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff, v. PAULA M. PRICE CODY O. PRICE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.: 13-948 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: T/6-/(`?` / Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 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. PH # 791952 Name and Address Of Sender Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 AZK/SCS - 06/0412014 SAL Line Article Number Name of Addressee, Street, and Post Office Address Postage iir p. 1 **** TENANT/OCCUPANT 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-111.6- $0A7 o I/ W 2 **** SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY ' P.O. BOX 8 BOILING SPRINGS, PA 17007-0008 Its N t $0.471 N r`�`ye ' ` ""' 3 **** SOUTH MII)DLETON TOWNSHIP MUNICIPAL AUTHORITY C/O SNELBAKER & BRENNEMAN PC ATTN: KEITH O. BRENNEMAN, ESQUIRE 44 WEST MAIN STREET MECHANICSBURG, PA 17055 2411 .4r% $0.47 ' -",.*! Nk=2c �z 3k 1C, . `.:.1?1-- . '1'.1P. �0.t ". •'� w 4 **** DOMESTIC RELATIONS OF CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, PA 17013 $0.47 h s 5 **** COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. BOX 2675 HARRISBURG, PA 17105 $b.47 to c.92- ' , o, • eft ¢ 6 **** INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 $0.47 `moi `rr j bd 7 44** 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 $0.47 l,x (el4 '':'.4, i,::..'d .,. "ie +'Ei'. .;. tt•.�t.i�E. ff, .,r.- ,. $3.29 Total Number of Pieces Listed by Sender Tota l Number of Pieces Received at Post Office Postmaster. Per (Name of Receiving Employee) The full declaration of value is required on all domestic and international registered mail. The maximum Indemnity payable for the constnwtion of nonnegotiable documents under Express Mail document reconw uction insurance is $50,000 per piece subject to a limit of $300,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is $25.000 for negistcmd mail, sent with optional insurance. Sec Domestic Mall Manual R900 9913 and S921 (or limitations of coverage. orm 3877 Facsimile • PHELAN HALLINAN, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 r. 1.14E PRO THOS v i f'TAY —0 -AN (:Jf CUMB BLAND PENNSYLVgNf raj Y BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME : LOANS SERVICING, LP vs. PAULA M. PRICE CODY O. PRICE Plaintiff Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 13-948 AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail, to PAULA M. PRICE on 3/31/2014 in accordance with the Order of Court dated 7/18/2013. The property was posted on 3/29/2014. Publication was advertised in The Sentinel on 4/3/2014 & in The Cumberland Law Journal on 4/11/2014. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. DATE: Phelan Hallinan, LLP By: Meredith Wooters, Esq., 7d. No.307207 Attorney for Plaintiff ,_. • 11 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR • BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff vs. PAULA M. PRICE CODY O. PRICE Defendants ORDER Court of Common Pleas Civil Division CUMBERLAND County .c, No. 13 -948 -CIVIL re2 o -c3 cam.- �: en G .pry z� r 77� p 7. AND NOW, this $ th day of J U. , 2013, upon consideration of Plaintiff's motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED, that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and of the Notice of Sheriff's Sale as authorized by Pa.RCP. 3129.2 (c)(1)(i)(C)*, on the above captioned Defendant, PAULA M. PRICE, by: L Posting of the premises: 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065 by the Sheriff or a non-party competent adult; and 2. First class mail to PAULA M. PRICE at the mortgaged premises located at 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065and at P.O. BOX 142, WALNUT BOTTOM, PA 17266. Service by mail is complete upon the date of mailing. 3. Publication in accordance with Pa.R.C.P. 430 PHS # 298190/VLA Attorney% en. Phase Riftrir It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. BY THE COURT: pm A NIA= sdA *Prior to fulfilling the requirements of service of Notice of Sale as set forth in this Order, Plaintiff must first attempt service as set forth in Pa.RCP. 3129.2(cx1)(1) (A) or (B). In the event this attempted service is not successful, Plaintiff may proceed with service of the Notice of Sale in conformity with this Order. Cc:PAULA M. PRICE 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065 PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 PHS # 298190/VLA Name and Address I of Sender L Article Number 44414 2 PHELAN HALLMAN, LLP ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103-1814 Name of Addressee. Swed, and Pest Office Address Postage PAULA M. PRICE 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 PAULA M. PRICE PO BOX 142 WALNUT BOTTOM, PA 17256 3 4 5 6 7 RE: PRICE PHS# 791952 CUMBERLAND Total Number of Total Number of Pieces Pieces Listed by Sender Received atPost Office Postmaster, Per (Name of Receiving En►Pl) LASlNOS-CER 111+ 1CATE OF MAILING - CODE 1020 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE PH # 791952 HOME LOANS SERVICING, LP DEFENDANT PAULA M. PRICE CODY O. PRICE SERVE PAULA M. PRICE AT: 602 WEST PINE STREET MOUNT HOLLY SPRINGS, PA 17065-1116 **PLEASE POST PROPERTY IF UNABLE TO OBTAIN SUCCESSFUL SERVICE**PLEASE POST PROPERTY ON YOUR LAST ATTEMPT** SERVICE TEAM/ lab COURT NO.: 13.948 TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: June 4, 2014 SERVED Served and made known to PAULA M: PRICE; Defendant on the a tif'day of 4A4 -P -e-44 , 20 14, at 1.1.: (5' , o'clock*. M., at 6O2 W ,p l &t< "+dT1R 7 , in the manner described below: _ Defendant personally served. Mot/Air 4f p,¢t 414 _ 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 °Meek of said Defendant's company. POS_Mt . V Other: - Description: Age Height Weight Race Sex Other I, Ronatti MOIL , a competent adult, hereby verify that I personally Hared 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. DATE: 3 NAME: PRINTED NA.ME:.Rona« Moll ?recess Scrvar TITLE: NOT SERVED On the dayof 20 , at o'clock _. M., I, ., a competent adult hereby state that Defendant NOT FOUND because: _ Vacant _ Does Not Exist _ Move _ Does Not Reside (Not Vacant) k No Answer on 3 61/ 14 at 9t ' 45 psi 3 Z ' 1 at i : 10 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 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Patrick Doane, Production Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says .that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): April 3, 2014. COPY OF NOTICE OF PUBLICATION NOTICE OF SHERIFF'S SALE IN THE COURT OF COMMON PLEAS OF CUMBERLAND OUNTY, PENNSYLVANIA NO. 13-948 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOM LOANS SERVICING, LP F/JC/A COUNTRYWIDE HOME LOANS SERVICING, LP • j V. (PAULA M. PRICE and CODY O. PRICE (NOTICE TO: PAULA M. PRICE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY !Being Premises: 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 Being in SOUTH MIDDLETON TOWNSHIP, County of CUMBERLAND, Commonwealth of Pennsylvania, 40-32-2334-002A Improvements consist of residential property. Sold as the property of PAULA M. PRICE and CODY O. PRICE E Yr h ur ouse (real estate) at 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 is scheduled to be sold at the Sheriffs Sale on 6/04/2014 at 10:00 AM, at the CUMBERLAND County Courthouse, 1 Courthouse Square, Room 303, Carlisle, PA 17013, to enforce the Court Judgment of $163,299.86 obtained by, BANK OF AMERICA, NA., AS 1 SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP against g the above premises. F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP (the mortgagee), EPHELAN HALLINAN, LLP Attorney for Plaintiff 1 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true_ Sworn to and subscribed before me this My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Bethany M. Hol �SeNotaryl Carlisle BoroCumberlandPublic MY Commission County MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND --1 9tq,P �s Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 11, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 11 day of April, 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE In the Court of Common Pleas of Cumberland County, Pennsylvania NO. 13-948 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING, LP v. PAULA M. PRICE and CODY O. PRICE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO: PAULA M. PRICE Being Premises: 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116. Being in SOUTH MIDDLETON TOWNSHIP, County of CUMBER- LAND, Commonwealth of Pennsyl- vania, 40-32-2334-002A. Improvements consist of residen- tial property. Sold as the property of PAULA M. PRICE and CODY O. PRICE. Your house (real estate) at 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 is sched- uled to be sold at the Sheriff's Sale on June 4, 2014 at 10:00 A.M. at the CUMBERLAND County Courthouse, 1 Courthouse Square, Room 303, Carlisle, PA 17013, to enforce the Court Judgment of $163,299.86 ob- tained by, BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING, LP (the mortgagee), against the above premises. PHELAN HALLINAN, LLP Attorneys for Plaintiff Apr. 11 12 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ED -OFF ICL ,a ytlt otCurbr,r,. { it. PROTHONO TA 2[)11 3111113 18 PH 12: f if CUMBERLAND COUNTY t fc :;,r= IPENNSYLVANIA Bank of America, N.A. vs. Case Number Paula M Price (et al.) 2013-948 SHERIFF'S RETURN OF SERVICE 03/17/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Paula M. Price, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 602 West Pine Street, Mount Holly Springs, PA 17065, property is vacant, please see previous attached Sheriffs Return, and P.O. Box 142, Walnut Bottom, PA 17266 is not an acceptable physical street address. cab 03/25/2014 06:38 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 602 West Pine Street, South Middleton - Township, Mt Holly Springs, PA 17065, Cumberland County. 06/04/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse 1 Courthouse Square Carlisle Pa, 17013 at 1000 am on June 4, 2014. He sold the same for the sum of $1.00 to Attorney Joseph Schalk, on behalf of, Bank of America, N.A., as Successor by Merger to BAC Home Loans Servicing, LP F/K/A Countrywide Home Loans Servicing, LP, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $865.17 SO ANSWERS, July 28, 2014 RONR ANDERSON, SHERIFF (c) Co,-ntySi, to Sheriff; . eleosoft. inc. Lig-00 ed. ed. et,. 9'392 °-11 3 of 7 a On March 17, 2014 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 602 West Pine Street, Mount Holly Springs, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 17, 2014 By: Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-948 Civil Term Bank of America, N.A. vs. Paula M. Price Cody O. Price Atty.: Joseph Schalk By virtue of a Writ of Execution No. 13-948, BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP f/k/a COUNTRYWIDE HOME LOANS SERVICING, LP v. PAULA M. PRICE CODY O. PRICE owner(s) of property situate in the TOWNSHIP OF SOUTH MIDDLETON, CUMBER- LAND County, Pennsylvania, being 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116. Parcel No. 40-32-2334-002A. Improvements thereon: RESIDEN- TIAL DWELLING. Judgment Amount: $163,299.86. 94 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. SWORN TO AND SUBSCRIBED before me this 2 da of Ma 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 The Patriot -News Co. 2020 Technology Pkwy • Suite 300 Mechanicsburg, PA 17050 Inquirieb - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriotNews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of.Dminhin in Miscellaneous Book "M", Volume 14, Page 317. 2013-948 Civil Term Bank of Anierica, N.A. Vs Paula M Price Cody 0 Price Atty: Joseph Schalk By virtue of a Writ of Execution No. 13-948 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FIK/A COUNTRYWIDE HOME LOANS SERVICING, LP PAULA M. PRICE CODY 0. PRICE owner(s) of property situate in the TOWNSHIP OF SOUTH, MIDDLETON, CUMBERLAND County, Pennsylvania, being 602 WEST PINE STREET, MOUNT HOLLY SPRINGS, PA 17065-1116 Parcel No. 40-32-2334-002A (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $163,299.86 This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 n o - d subscribed before t 02 d of May, 2014 A.D. .1� 1 tary Public COMMONWEALTH OF PENNSYLVANIA notarial Seal Hotly Lynn Warfel, Rotary Pubic v ash!ngton Twp., Dauphin County My Commission Exr^res Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bank of America N A is the grantee the same having been sold to said grantee on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 7th day of March, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 948, at the suit of Bank of America N A against Paula M Price & Cody 0 is duly recorded as Instrument Number 201413851. IN TESTIMONY WHEREOF, I have hereunto set my hand iek and seal of said office this /e day of /rf , A.D. 070/- /„v Recorder of Deeds Recorder of i eds, Cumberland County, Carlisle; PA My Commission Expires the First Monday of Jan. 2018