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HomeMy WebLinkAbout13-1089 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r Sheriff �* Jody S Smith -- Chief Deputy -a X Richard W Stewart ''i,: z t- N ' Solicitor OMCG=�r THE*,kER r t!] .� . r; C-> Bank of America, N.A. Successor by Merger to BAC Home Loans Servicing, -- vs. Case Number Courtney Yost(et al.) 2013-1089 SHERIFF'S RETURN OF SERVICE 03/08/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Courtney Yost, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 328 Walnut Street, Lemoyne Borough, Lemoyne, PA 17043. Per defendants ex-husband, defendant moved two years ago and no longer resides at this address. 03/08/2013 04:38 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit:Scott Cady at 328 Walnut Street, Lemoyne Borough, Lemoyne, PA 17043. RYT"99GETT, DEP4-4S( 03/12/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Courtney Yost, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/13/2013 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County,the within named Defendant Courtney Yost, not found. Jack Lotwick,Sheriff, Return of Service attached to and made part of the within record. Defendant no longer resides at 104 Blue Ridge Circle, Harrisburg, Pennsylvania. Defendant's new address is 21 W. Green Street, Shiremanstown,Pennsylvania 17011. 03/21/2013 08:05 PM-Deputy Tim Black, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Courtney Yost at 21 W.Green Street, Mechanicsburg Borough, Shiremanstown, PA 17011. .o""_ TI CK, DEPUTY SHERIFF COST: $99.46 SO ANSWERS, March 25,2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. ( tf itit Of the S1jcrrFfjt RjelleZ Ruhl Jack Dui nan ck Real Este Deputy Chief Dep ty Matthew L. Owens Solicitor Michael W. Rinehart Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania BANK OF AMERICA,N.A.AS SB/M TO BAC HOME LOANS SERVICING, LP, ET AL VS County of Dauphin COURTNEY M. YOST A/K/A COURTNEY YOST Sheriff s Return No. 2013-T-0771 OTHER COUNTY NO. 2013-1089 1, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for COURTNEY M. YOST A/K/A COURTNEY YOST the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, MARCH 13, 2013, DEFENDANT NO LONGER RESIDES AT ADDRESS: 104 BLUE RIDGE CIRCLE,HARRISBURG, PA 17110. NEW ADDRESS FOR DEFENDANT IS: 21 W. GREEN STREET, SHIREMANSTOWN, PA 17011. Sworn and subscribed to So Answers, before me this 14TH day of March, 2013 � i�, �J� Sheriff of C a. COMMONWEALTH OF PENNSYLVANIA B uty Sheriff NOTARIAL SEAL Deputy: W Karen M.Hoffman,Notary P:17,:2:0:14 ] p ty: CONWAY City of Harrisburg,Dauphin C Sheriff s Costs: $58 3/12/2013 M Commission Expires Au OF THE PROTI N i-ILE0-0. FIC:E 10 OTARY .2113Jt31' 26 Ph2: ! 9 CUMB"RLAND COUNTY PENNSYLVANIA PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 Attorney for Plaintiff 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 Plaintiff No. 2013-1089-Civil V. Cumberland County COURTNEY M. YOST A/K/A COURTNEY YOST 104 BLUE RIDGE CIRCLE HARRISBURG, PA 17110 SCOTT CADY 343 HERMAN AVENUE LEMOYNE,PA 17043-1940 Defendants MOTION TO LIFT CONCILIATION STAY Plaintiff, Bank of America, N.A., Successor (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: I. On February 27, 2012, Plaintiff filed a Complaint in Mortgage Foreclosure against Defendants for their failure to make. monthly payments of principal and interest upon their mortgage due January 1, 2012, and each month thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit A. 300120 2. On March 8, 2013, Plaintiff completed service on Defendant, Scott Cady, of the Complaint in Mortgage Foreclosure along with service of the Cumberland County Residential Mortgage Foreclosure Diversion Program Notice. A true and correct copy of the Affidavit of Service by Publication is attached hereto, made part hereof and marked as Exhibit B. 3. On March 21, 2013, Plaintiff completed service on Defendant, Courtney M. Yost, of the Complaint in Mortgage Foreclosure along with service of the Cumberland County Residential Mortgage Foreclosure Diversion Program Notice. A true and correct copy of the Affidavit of Service by Publication is attached-hereto, made part hereof and marked as Exhibit B. 4. 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. 5. Within 60 days after service of the complaint, the Defendant 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 Defendant must contact MidPenn Legal Services within the first twenty(20) days of receipt of notice if not represented by counsel. 6. If more than sixty (60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendant has 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. 7. Defendants failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty(60) days of service. 8. Since Defendants have opted not to participate in the Diversion Program, it is appropriate for the stay to be lifted. 300120 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: (v 5 BY: f&eg—:�6 ohtse . Schalk, Esquire ey for Plaintiff 300120 Exhibit A TI 2013 FEB 27 AM 10: �6 cUPE`N 1SYZ° COUNTY �A* A PHELAN HALLINAN,LLP Meredith Wooters,Esq.,Id.No.307207 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia,PA 19103 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 TERM q Plaintiff NO. �— 1 cvd V. CUMBERLAND COUNTY COURTNEY M.YOST A/K/A COURTNEY YOST 104 BLUE RIDGE CIRCLE HARRISBURG,PA 17110 SCOTT CADY 343 HERMAN AVENUE LEMOYNE,PA 17043-1940 Defendants CIVU,ACTION-LAW COMPLAINT IN MORTGAGE FORECLOSURE CQ File 4: 300120 / � � 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#: 300120 I 1. 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: COURTNEY M. YOST A/K/A COURTNEY YOST 104 BLUE RIDGE CIRCLE HARRISBURG,PA 17110 SCOTT CADY 343 HERMAN AVENUE LEMOYNE,PA 17043-1940 who is/are the mortgagor(s)and/or real owner(s)of the property hereinafter described. 3. On 03/11/2008 COURTNEY M. YOST and SCOTT CADY 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. 200807591. By Assignment of Mortgage recorded 03/05/2012 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201206451.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 01/01/2012 and each month thereafter are due and unpaid, and by the terms File#: 300120 k of said mortgage,upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor,the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 01/23/2013: Principal Balance $120,054.92 Interest $8,929.06 12/01/2011 through 01/31/2013 Late Charges $45.72 Property Inspections $15.00 Escrow Deficit $2,246.11 TOTAL $131,290.81 7. Plaintiff is not seeking a judgment of personal liability(or an in person am 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 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 N: 300120 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s)in the sum of $131,290.81,together with interest, costs,fees,and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLMAN,LLP By: Meredith Wooters,Esq., No.307207 Attorney for Plaintiff File#: 300120 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Borough of Lemoyne, County of Cumberland and State of Pennsylvania,more particularly bounded and described as follows,to wit: BEING Lot No. 22 in the Plan of Lots known as Revised Plan No. 2, Fort Washington, said Plan being recorded in the Office of the Recorder of Deeds in and for said County of Cumberland in Plan Book.1,Page 77, said Lot being bounded on the north by Walnut Street;on the east by Lot No. 23,on said Plan; on the south by a 20 foot alley,and on the west by Lot No. 21, on said Plan; containing 40 feet in front on Walnut Street and extending in depth an even wide 150 feet to said 20 foot alley. HAVING THEREON ERECTED a two.story brick and frame dwelling house,known as No. 328 Walnut Street,Lemoyne,Pennsylvania. PROPERTY ADDRESS: 328 WALNUT STREET,LEMOYNE,PA 17043-1659 PARCEL# 12-21-0265-127. File#1: 300120 y VERIFICATION hereby states that h sh is of BANK OF AMERICA,N.A., Plaintiff in this matter,that sh l 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"d>"'uormation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. ame: DATE:��X wlvz f�v Title: BANK OF AMERICA,N.A. File#: 300120 Name: YOST i File#: 300120 IN THE COURT OF C M P*S OF CUMBERL OMTY.,4 BANK OF AMERICA,N.A., AS SUCCESSOR BY PENNSTx lAg =-71 MERGER TO BAC HOME LOANS SERVICING, LP F/K/A Nr`' -Orr,COUNTRYWIDE HOME LOANS SERVICING, LP -cD C5 Plaintiff(s) �© =--n _Z vs. DC: .. °m COURTNEY M. YOST A/K/A COURTNEY YOST om SCOTT CADY Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have an attorney,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 not charge to you.Once you have been appointed a legal representative,you must promptly meet with the legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint.If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in attempt to work out a 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 the 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 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 our reasonable arrangements 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: a 4y Date Signature of Counsel for Plaintiff I 1 � Exhibit B 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �•' �`' 4. of�nrn6rryrAb C7- Jody S Smith -o" y Chief Deputy ' '• � �^ rr" Richard W Stewart Solicitor OFFICE OF THE OWPI ! C} G 1 Bank of America, N.A. Successor by Merger to SAC Home Loans Servicing, Case Nuntser Courtney vs. Yost(et al.) 2013-1089 SHERIFF'S RETURN OF SERVICE 03/08/2013 Ronny R Anderson, Sheriff,being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Courtney Yost, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 328 Walnut Street, Lemoyne Borough,Lemoyne, PA 17043.Per defendants ex-husband, defendant moved two years ago and no longer resides at this address. 03/08/2013 04:38 PM-Deputy Ryan Burgett,being duly sworn according to law,served the requested Complaint in Mortgage Foreclosure by"personally'handing a true copy to a person representing themselves to be the Defendant,to wit:Scott Cady at 328 Walnut Street,Lemoyne Borough,Lemoyne,PA 17043, R t 03/12/2013 Sheriff Ronny R Anderson,being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Courtney Yost, but was unable to locate the Defendant in the Sheriff's bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin,Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/13/2013 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County,the within named Defendant Courtney Yost,not found.Jack Lotwick,Sheriff,Return of Service attached to and made part of the within record.Defendant no longer resides at 104 Blue Ridge Circle,Harrisburg, Pennsylvania. Defendant's new address Is 21 W.Green Street,Shiremanstown,Pennsylvania 17011, 03/21/2013 08:05 PM-Deputy Tim Black,being duly sworn according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Courtney Yost at 21 W.Green Street,Mechanicsburg Borough,Shiremanstown,PA 17011. TI LACK, DEPUTY i SHERIFF COST:$99.46 SO ANSWERS, March 25,2013 RON R ANDERSON,SHERIFF y 1 (c)CounlySWe SherM,Te)eowfl.Inc. PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 Attorney for Plaintiff BANK OF AMERICA, N.A., AS SUCCESSOR BY Court of Common Pleas MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS Civil Division SERVICING, LP 7105 CORPORATE DRIVE Term PLANO, TX 75024 No. 2013-1089-Civil Plaintiff V. Cumberland County COURTNEY M. YOST A/K/A COURTNEY YOST 104 BLUE RIDGE CIRCLE HARRISBURG,PA 17110 SCOTT CADY 343 HERMAN AVENUE LEMOYNE, PA 17043-1940 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: COURTNEY M. YOST SCOTT CADY 21 W. GREEN STREET 343 HERMAN AVENUE SHIREMANSTOWN, PA 17011 LEMOYNE, PA 17043 Date: ?fit By: e AaL— J s ph V. Schalk, Esquire A rney for Plaintiff 300120 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 Term Plaintiff No. 2013-1089-Civil V. Cumberland County COURTNEY M. YOST A/K/A COURTNEY YOST 104 BLUE RIDGE CIRCLE <- HARRISBURG, PA 17110 MCV SCOTT CADY 2 343 HERMAN AVENUE -<>> LEMOYNE, PA 17043-1940 a c4 Defendants ORDER AND NOW, this -Z day of 9,,.. , 2013, upon consideration of Plaintiff's Motion to Lift Conciliation Stay in the above captioned matter, it is hereby ORDERED and DECREED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. n �` BY THE COURT: r' �^ - 5 ''C,at tq'L J t k, A/ A I L 300120 cc : Courtney M. Yost and Scott Cady Joseph P. Schalk, Esq., Id.No. 91656 Attorney for Plaintiff PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 COURTNEY M. YOST 21 W. GREEN STREET SHIREMANSTOWN, PA 17011 SCOTT CADY 343 HERMAN AVENUE LEMOYNE, PA 17043 300120 PHELAN HALLINAN, LLP Attorney for Plaintiff Emily M. Phelan, Esq., Id. No.315250 1617 JFK Boulevard, Suite 1400 _I: r� r' 111UPTU TAR One Penn Center Plaza Philadelphia, PA 19103 2C I i FEB -4 APB II: 50 emily.phelan@phelanhallinan.com 215-563-7000 CUMBERLAND COUNTY PENNSYLVANIA 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. 13-1089-CIVIL COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY 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 COURTNEY M. YOST A/K/A COURTNEY YOST and SCOTT CADY, 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 $131,290.81 TOTAL $131,290.81 I hereby certify that (1) the Defendants' last known addresses are 21 WEST GREEN STREET, SHIREMANSTOWN, PA 17011 and 328 WALNUT STREET, LEMOYNE, PA 17043-1659, and (2) that notice has been given in accordance .th Rule Pa.R.C.P 237.1. Date v3 / Emily M. Phelan, Es Id. No.315250 Y q � Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: jq )`f PFf#793882 PROT NOTARY al,,A IRA Gc., 1389)0 793882 -RN* SOU2S b� MYialIed 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 emily.phelan@phelanhallinan.com 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. 13-1089-CIVIL COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY 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 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 COURTNEY M. YOST A/K/A COURTNEY YOST is over 18 years of age and last known addresses are 21 WEST GREEN STREET, SHIREMANSTOWN, PA 17011 and 328 WALNUT STREET, LEMOYNE, PA 17043-1659. (c) that defendant SCOTT CADY is over 18 years of age and resides at 328 WALNUT STREET, LEMOYNE, PA 17043-1659. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date V3P 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 793882 Department of Defense Manpower Data Center Results as of:Feb-03-201402:58:43 AM SCRA 3.0 "r +a ., stagy Report ‘ � Pursuant to Sevice aiem Civil Relief Act Last Name: YOST First Name: COURTNEY Middle Name: M Active Duty Status As Of: Feb-03-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active only End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date IS Active Duty End Date.' Status Service Component NA NA No NA This response reflects where the individual left active duty'.status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty',on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. YA : � i ' � ey Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Department of Defense Manpower Data Center Results as of:Feb-03-201402:58:35 AM SCRA 3.0 ,,, i. Status Report Pursuant to Servicementbers Civil Relief Act Last Name: CADY First Name: SCOTT Middle Name: Active Duty Status As Of: Feb-03-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA, :No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status.Date Active Duty.Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duly status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Noted of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date ':Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. it Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 BANK OF AMERICA, N.A., AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, CIVIL DIVISION LP F/K/A COUNTRYWIDE I TOME LOANS SERVICING,LP NO. 13-1089-CIVIL Plaintiff v. CUMBERLAND COUNTY COURTNEY M.YOST A/KJA COURTNEY YOST SCOTT CADY Defendant(s) TO: COURTNEY M.YOST A/K/A COURTNEY YOST 21 WEST GREEN STREET SHIREMANSTOVv'N, " 1701 I DATE OF NOTICE: 6 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT' THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY 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,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PH 4 7938g2 • BANK OF AMERICA,N.A., AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, CIVIL DIVISION LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP NO. 13-1089-CIVIL Plaintiff v. CUMBERLAND COUNTY COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY Defendant(s) TO: COURTNEY M. YOST A/K/A COURTNEY YOST 328 WALNUT STREET LEMOYNE,PA 17043-1659 DATE OF NOTICE: (A077-(l f THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGI ITS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A .LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY 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 HalIinan,LLP 1617 JFK Boulevard,Suite 3400 One Penn Center Plaza Philadelphia,PA 19103 PH if 79388 BANK OF AMERICA,N.A.,AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, CIVIL DIVISION LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP NO. 13-1089-CIVIL Plaintiff v. CUMBERLAND COUNTY COURTNEY M.YOST A/K/A COURTNEY YOST SCOTT CADY Defendant(s) TO: SCOTT CADY 328 WALNUT STREET LEMOYNE,PA 17043-1659 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WI'T'H 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,LLP 1617 JFK Boulevard,Suite MOO One Penn Center Plaza Philadelphia,PA 19103 PH#793882 (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. 13-1089-CIVIL COURTNEY M. YOST A/K/A COURTNEY YOST • SCOTT CADY Notice is given that a Judgment in the above captioned matter has been entered Q against you on 1141 1 A By: L' •, If you have any questions concerning this matter please contact: Phelan Hallinan, 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.** 793882 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC : COURT OF COMMON PLEAS HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP : CIVIL DIVISION Plaintiff : NO.: 13-1089-CIVIL V. COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due CUMBERLAND COUNTY $131,290.81 Interest from 02/05/2014 to Date of Sale $2,589.60 ($21.58 per diem) TOTAL $133,880.41 Note: Please attach description of property. PH # 793882 a-AL1 99 ce-at 1, 5D`' g. dl n Hallinan, LLP h E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff su„ Et_kiRci) EV-6 -435s1 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. COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Filed: P n Hallinan, LLP o h E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff Address where papers may be served: COURTNEY M. YOST A/K/A COURTNEY YOST 21 WEST GREEN STREET SHIREMANSTOWN, PA 17011 SCOTT CADY 328 WALNUT STREET LEMOYNE, PA 17043-1659 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Borough of Lemoyne, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEING Lot No. 22 in the Plan of lots known as Revised Plan No. 2, Fort Washington, said Plan being recorded in the Office of the Recorder of Deeds in and for said County of Cumberland in Plan Book 1, Page 77, said lot being bounded on the North by Walnut Street; on the East by Lot No. 23 on said Plan; on the South by a twenty (20) foot alley, and on the West by Lot No. 21 on said Plan; containing forty (40) feet in front on Walnut Street and extending in depth an even width one hundred fifty (150) feet to said twenty (20) foot alley. HAVING thereon erected a two story brick and frame dwelling house, known as No. 328 Walnut Street, Lemoyne, Pennsylvania. UNDER AND SUBJECT to all rights, restrictions, easements and rights-of-way of prior record. TITLE TO SAID PREMISES IS VESTED IN Courtney M. Yost and Scott Cady, by Deed from Nedra Gill Schubert, Executrix of the Estate of George Marlin Gill, deceased, dated 03/11/2008, recorded 03/13/2008 in Instrument Number 200807590. PREMISES BEING: 328 WALNUT STREET, LEMOYNE, PA 17043-1659 PARCEL NO. 12-21-0265-127 PHELAN HALLINAN, LLP Joseph E. DeBarberie, Esq., Id. No 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 joseph.debarberie@phelanhallinan. 215-563-7000 FILEU-OVF .31Y2tHE PROTHONOTAR; 2014 MAR -6 Ati la: 56 comCUMBERL AND COUNT'( 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. COURTNEY M. YOST A/KJA COURTNEY YOST SCOTT CADY Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 13-1089-CIVIL : 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: Pan Hallinan, LLP E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff J BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F /Ir /A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff v. COURTNEY M. YOST A /K/A COURTNEY YOST SCOTT CADY Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 13- 1089 -CIVIL 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 328 WALNUT STREET, LEMOYNE, PA 17043 -1659. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY 2. Name and address of Defendant(s) in the judgment: Name COURTNEY M. YOST A /K/A COURTNEY YOST SCOTT CADY 21 WEST GREEN STREET SHIREMANSTOWN, PA 17011 328 WALNUT STREET LEMOYNE, PA 17043 -1659 Address (if address cannot be reasonably ascertained, please so indicate) 21 WEST GREEN STREET SHIREMANSTOWN, PA 17011 328 WALNUT STREET LEMOYNE, PA 17043 -1659 —�a 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. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. PH # 793882 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 COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY UNIT, ESTATE RECOVERY PROGRAM COURTNEY M. YOST C/0 JAIME D. BLACK, ESQUIRE DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE INTERNAL REVENUE SERVICE ADVISORY U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 328 WALNUT STREET LEMOYNE, PA 17043-1659 6TH FLOOR, STRAWBERRY SQ. DEPT 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 303 WALNUT STREET, FLOOR 5 HARRISBURG, PA 17101-1825 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 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: L‘f PH # 793882 By: P an 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 BAOHOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP VS. COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY : COURT OF COMMON PLEAS : CIVIL DIVISION Plaintiff : NO.: 13-1089-CIVIL Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: COURTNEY M. YOST A/K/A COURTNEY YOST 21 WEST GREEN STREET SHIREMANSTOWN, PA 17011 C) SCOTT CADY 328 WALNUT STREET c._(<).,- LEMOYNE, PA 17043-1659 C=. r n - **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 328 WALNUT STREET, LEMOYNE, PA 17043-1659 is scheduled to be sold at the Sheriffs 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 $131,290.81 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 Sheriffs Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 13-1089-CIVIL BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY owner(s) of property situate in the BOROUGH OF LEMOYNE, CUMBERLAND County, Pennsylvania, being 328 WALNUT STREET, LEMOYNE, PA 17043-1659 Parcel No. 12-21-0265-127. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $131;290.81 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Borough of Lemoyne, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEING Lot No. 22 in the Plan of lots known as Revised Plan No. 2, Fort Washington, said Plan being recorded in the Office of the Recorder of Deeds in and for said County of Cumberland in Plan Book 1, Page 77, said lot being bounded on the North by Walnut Street; on the East by Lot No. 23 on said Plan; on the South by a twenty (20) foot alley, and on the West by Lot No. 21 on said Plan; containing forty (40) feet in front on Walnut Street and extending in depth an even width one hundred fifty (150) feet to said twenty (20) foot alley. HAVING thereon erected a two story brick and frame dwelling house, known as No. 328 Walnut Street, Lemoyne, Pennsylvania. UNDER AND SUBJECT to all rights, restrictions, easements and rights-of-way of prior record. TITLE TO SAID PREMISES IS VESTED IN Courtney M. Yost and Scott Cady, by Deed from Nedra Gill Schubert, Executrix of the Estate of George Marlin Gill, deceased, dated 03/11/2008, recorded 03/13/2008 in Instrument Number 200807590. PREMISES BEING: 328 WALNUT STREET, LEMOYNE, PA 17043-1659 PARCEL NO. 12-21-0265-127 WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13 -1089 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 FIK/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From COURTNEY M. YOST A/K/A COURTNEY YOST, SCOTT CADY (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: $131,290.81 L.L.: $.50 Interest FROM 2/5/2014 TO DATE OF SALE ($21.58 PER DIEM) - $2,589.60 Atty's Comm: Atty Paid: $248.21 Plaintiff Paid: Date: 3/6/14 (Sealy -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: David D. Buell, Prothonota Deputy 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 # 793882 HOME LOANS SERVICING, LP DEFENDANT COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY SERVICE TEAM/ lxh COURT NO.: 13 -1089 -CIVIL SERVE COURTNEY M. YOST A/K/A COURTNEY YOST AT: TYPE OF ACTION 21 WEST GREEN STREET XX Notice of Sheriff's Sale SHIREMANSTOWN, PA 17011 SALE DATE: June 4, 2014 * *DIVORCED.. One cannot accept service for the other ** SERVED Served and made known to COURTNEY M. YOST A/K/A COURTNEY YOST, Defendant on the 24.4'' day of MA2c(J , 20 141, at 8, l 0, o'clock _p M., at 21 w• GRZEN I}-t(ZEAtk i-ST NO, PA, in the manner described below: ^,Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is MotliZAt. _ 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 57)1 Height 5'5" Weight L40 Race W Sex F Other 1, Ronald MOLT a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 31a 4414 NAME: PRINTED NAME: Ronald Moll TITLE: Process Server 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 _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 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 # 793882 HOME LOANS SERVICING, LP DEFENDANT COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY SERVE SCOTT CADY AT: 328 WALNUT STREET LEMOYNE, PA 17043-1659 **DIVORCED- One cannot accept service for the other** SERVED SERVICE TEAM/ lxh COURT NO.: 13 -1089 -CIVIL TYPE OF ACTION XX Notice of Sheriff's Sale SALE DATE: June 4, 2014 cD ' Served and made known to SCOTT CADY, Defendant on the Q day of il-' L , 20 (4 , at rn 5ti35 , o'clock,. M., at 3Y8 WM-N'/T (5T,Lf/kbyuE , P4 , in the manner described below: ?" �� V Defendant personally served. cin r Adult family member with whom Defendant(s) reside(s). -C T Relationship is e7 Adult in charge of Defendant's residence who refused to give name or relationship. 3> n _ 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. 3' an officer of said Defendant's company. c:r .J CFI %JD Other: Description: Age SO c Height 6 Weight 170 Race 1/ti Sex /u Other I R011ald Mali a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to theenalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 4(ij(1 NAME: PRINTED NAME: Roilal d Moll TITLE: Proccss Server NOT SERVED On the day of,20 , at o'clock . M., I, , a competent adult hereby state that Defendant NOT FOUND ecause: _ Vacant Does Not Exist_ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 rwiu',� AJC E; (h" ° #,orCia ney for Plaintiff CU? L EF L /f. D COU NT PENNSYLVANIA 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. COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS . CIVIL DIVISION No.: 13 -1089 -CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". Date: 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 # 793882 Name and Address Of Sender Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center. Plaza Philadelphia, PA 19103 ZK/SCS • 06/04/2014 SALE u111, o v O N ESio Line Article Number Name of Addressee, Street, and Post Office Address Postage p n 1 **** TENANT/OCCUPANT 328 WALNUT STREET LEMOYNE,PA 17043.1659 $0.47 w� ¢ 7 is co a �_ 2 **** COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ. DEPT 280601 HARRISBURG, PA 17128 $0.47013 =t CL —hi z 3 **** COURTNEY M. YOST C/O JAIME D. BLACK, ESQUIRE 303 WALNUT STREET, FLOOR 5 HARRISBURG, PA 17101-1825 $0.47 litre;. -0 ,y 7$ • •f« 4 **** DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY UNIT, ESTATE RECOVERY PROGRAM P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 $0A7 .I,� t^ . it , 5 **** DOMESTIC RELATIONS OF CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, PA 17013 • $0.47 0 .,� ,),/ N 3 a '‘�' 6 **** COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O.. BOX 2675 HARRISBURG, PA 17105 $0.47 7 **** INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 $0.47 8 **** 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 • .1. v. to ••• r 't • - ti OST'(CIJMISERtAND)-..-.. - ge of $3.76 Total Nur» per of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster. Per (Name of Receiving Employee) The full decisration of value is requited on all domestic and international registered mail. The maximum indemnity payable for the reconstruction .ofnonnegotiable .doatttema under Express Mail document reconstruction insurance is S50,000 per piece subject to a limit of SS00.000 per occurrence. The maximum indemnity payable on Express Mail merchandise is $500. The maximum indemnity payable is 323.000 (or registered mail. sent with optional insurance. See Domestic Mail Manual R900 S913.and S921 for limitations of coverage.. Form 3877 Facsimile Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 7 LEO<IFFiC: at (F THE PRGiHCH3Ft' Y 4�lfln(Ffrt.. I I L + OFFICE OF THE $IE FF 20114 AUG 18 PM12: 15 CUMBERLAND COUNTY PENNSYLVANIA Bank of America, N.A. vs. Courtney Yost a/k/a Courtney Yost (et al.) Case Number 2013-1089 SHERIFF'S RETURN OF SERVICE 03/28/2014 06:49 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 328 Walnut Street, Lemoyne - Borough, Lemoyne, PA 17043, Cumberland County. 03/31/2014 06:08 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Courtney Yost a/k/a Courtney Yost at 14 Clemson Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County. 03/31/2014 07:31 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Scott Cady at 328 Walnut Street, Lemoyne Borough, Lemoyne, PA 17043, 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: $904.25 SO ANSWERS, July 28, 2014 RONNY R ANDERSON, SHERIFF (c) Counly.A1 e Sheriff. Teleosof. Inc. Lx.oe pi. ad. a• „in. 4-4 9 od 3 of97 2 CNJ On March 3, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA, Known and numbered as, 328 Walnut Street, Lemoyne as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: March 3, 2014 By: Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-1089 Civil Term Bank of America, N.A. is vs. Courtney Yost a/k/a Courtney Yost, Scott Cady Atty.: Joseph Schalk By virtue of a Writ of Execu- tion No. 13 -1089 -CIVIL, BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP f/k/a COUNTRY- WIDE HOME LOANS SERVICING, LP v. COURTNEY M. YOST a/k/a COURTNEY YOST, SCOTT CADY owner(s) of property situate in the BOROUGH OF LEMOYNE, CUMBER- LAND County, Pennsylvania, being 328 WALNUT STREET, LEMOYNE, PA 17043-1659. Parcel No. 12-21-0265-127. Improvements thereon: RESIDEN- TIAL DWELLING. Judgment Amount: $131,290.81. 123 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. isa Marie Coyne, editor SWORN TO AND SUBSCRIBED before me this day of May. 2014 Notary ""' ' rALTH OF PENNSYLVANIA NJ,TARIAL SEAL 9EBORAH A COLLINS Notary Public CARLISLE BORO.. CUMBERLAND CNTY My Commission Expires Apr 28. 2018 The Patriot -News Co. 2120 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he patriotNews 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 Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2013-1089 Civil Term Bank of America, N.A.' Vs . Courtney Yost a/k/a Courtney Yost Scott Cady Atty: Joseph Schalk By virtue of a Writ of Execution No. 13 -1089 -CIVIL BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. COURTNEY M. YOST A/K/A COURTNEY YOST SCOTT CADY owner(s) of property situate in the BOROUGH OF LEMOYNE, CUMBERLAND County, Pennsylvania, being 328 WALNUT STREET, LEMOYNE, PA 17043-1659 Parcel No. 12-21-0265-127. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $13129&81 -- Sworn This ad ran on the date(s) shown below: 04/13/14 04/20/14 04127/14 ( nd subscribed before me thi . 02 day of May, 2014 A.D. A. i tary Public CQMMONNItIt. t r. ur rtNNSYLVANIA Notarial Seal l-o:ly Lynn 141? -fel, ".otary Pubic Vashtciton Twc., Dauphin County My C,<n,r:ss:on E °res Dec. 12, 2016 MEMRFR oar 1110.0 '•""' ^r..,r,„,,n„ nc Nr7TARIFS 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 6th day of March, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 1089, at the suit of Bank of America N A against Courtney M Yost aka Courtney & Scott Cady is duly recorded as Instrument Number 201413854. IN TESTIMONY WHEREOF, 7 Il have hereunto set my hand and seal of said office this f day of A.D.0/y ecorder of Deeds ds, Cumberland County, Carlisle, PA' My Comm' Expires the First Monday of Jan. 2018