Loading...
HomeMy WebLinkAbout13-1275 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson F,'_F-D-0Fl €` Sheriff O THE �'ROTHO'N") rAR,', Jody S Smith Chief Deputy 2913 MAR 26 AM 9*- ^4 Richard W Stewart CUMBERLAND COUNTY Solicitor OFFJCE OF ThESKRI ' PENNSYLVANIA Bank of America, N.A. Successor by Merger to BAC Home Loans Servicing, Case Number vs. Michael A. Russo{et al.} 2013-1275 SHERIFF'S RETURN OF SERVICE 03114/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Traci L. Russo, 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 769 Erford Road, East Pennsboro Township,Camp Hill, PA 17011. Per Michael Russo, defendant lives in Dauphin County, unsure of address. Per the Camp Hill Postmaster mail is still delivered to that address. 03/14/2013 11:38 AM-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: Michael A. Russo at 768 Erford Road, East Pennsboro Township, Camp Hill, PA 17011. TI B CK, DEPUTY SHERIFF COST: $64.00 SO ANSWERS, March 20, 2013 RONtrY R ANDERSON, SHERIFF (c)County8uRe Sheriff,Teleosoft Inc. r KNEEL Law Group, P.C. SUITE 5000-BNY INDEPENDENCE CENTER IN THE COURT OF COMMON PLEAS 701 MARKET STREET PHILADELPHIA,PA 19106-1532 OF Cumberland COUNTY (215)627-1322 ATTORNEY FOR PLAINTIFF CIVIL ACTION-LAW BANK OF AMERICA,N.A., SUCCESSOR BY ACTION OF MORTGAGE MERGER TO BAC HOME LOANS SERVICING LP FORECLOSURE FKA COUNTRYWIDE HOME LOANS SERVICING Term LP No. 13-1275 7105 Corporate Drive PTX B-209 Plano,TX 75024 Plaintiff rnco =,M F MICHAEL A. RUSSO TRACI L. RUS SO 769 Erford Road Camp Hill,PA 17011 acs C:) ca�', Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. w By: KML L R C. Michael cKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E.Kivitz Pa. ID 26769 Till P.Jenkins Pa. ID 306588 Joshua I. Goldman Pa. 205047 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Q .���1 �Si'd a G(-#13 b 9,71 I I�1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff t4'i l,.. a :rra,t+c4y , CI.: �l��. P�i0���iGP�� tt•,,� Jody S Smith x '� Chief Deputy ' 3 " -0 Pal 2- Richard W Stewart ¢ Solicitor OPPF C: FTH RI€w CU�'tBERLAW COUNT`S F'���SYL.VAt�tA Bank of America, N.A. Successor by Merger to BAC Home Loans Servicing, Case Number vs. Michael A. Russo(et al.) 2013-1275 SHERIFF'S RETURN OF SERVICE 05/09/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Traci L. Russo, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 05/13/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Traci L. Russo, 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 23 Heidi Terrace, East Pennsboro, Camp Hill, PA 17011. Current resident, Richard Zeigler, purchased this property in 1999 but believes that the defendant may have rented this property prior to him purchasing it. 05/24/2013 10:32 AM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and the Reinstated Complaint in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Traci L. Russo, personally, at 450 Harvard Court, Unit 101, Harrisburg, PA 17111. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $68.95 SO ANSWERS, May 29, 2013 RONNY R ANDERSON, SHERIFF (C)CountySuito.SShoriff,Tei2osoft,(ir, :. - Shelley Ruhl ; ;. Jack Duignan Chief Deputy Matthew L. Owens Michael W. Rinehart Solicitor 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. S/B/M TO BAC HOME LOANS SERVICING LP, ET AL VS County of Dauphin TRACI L. RUSSO Sheriff s Return No. 2013-T-1535 OTHER COUNTY NO. 2013-1275 And now: MAY 24, 2013 at 10:32:00 AM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon TRACI L. RUSSO by personally handing to TRACI L. RUSSO 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 450 HARVARD COURT, UNIT 101 HARRISBURG PA 17111 Sworn and subscribed to So Answers, before me this 28TH day of May, 2013 � � SheAff of Dauphin CouDly, Pa. By COMMONWEALTH OF PENNSYLVANIA De ty Sheriff NOTARIAL SEAL De uty: J STRAINING Karen M.Hoffman,Notary Public City of Harrisburg,Dauphin County Sheriffs Costs: $47.25 5/16/2013 My Commission Expires August 17,2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX B-209 Plano,TX 75024 Plaintiff vs. No. 13-1275 MICHAEL A.RUSSO TRACI L.RUSSO M C7 (Mortgagor(s)and Record Owner(s)) 769 Erford Road Camp Hill,PA 17011 r— C71 Defendant(s) > PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against MICHAEL A.RUSSO and TRACI L.RUSSO by default for want of an Answer. Assess damages as follows: $107,483.86 Debt Interest- 09/01/2009 to 08/09/2013 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.2311 By: KML LAW GROUP,P.C/J _Michael McKeever Pa.ID 9 —Jay E.Kivitz Pa.D)26769 Lisa Lee Pa.ID 78020 _Krishna Murtha Pa.11)61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 —Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.11)92382 Attorneys for Plaintd ski VIAta 1;6,410 rvo AND Now Vy— Judgment is entered in favor of BANK OF AMERICA,N.A.,SUCCPSSOR BY MERGER TO_BACROME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP and against MICHAEL A.RU NO and I:RACI L.RUSSO by default for want of an Answer and damages assessed in the sum of$107,483.86 as per the ab*cert Prothftt,apq�Of Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION-LAW BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX B-209 Plano,TX 75024 Plaintiff No. 13-1275 vs. MICHAEL A.RUSSO TRACI L.RUSSO (Mortgagors and Record Owner(s)) 769 Erford Road Camp Hill,PA 17011 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary By: 3 I 0 Deputy If you have any questions concerning the above,please contact: KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 116674FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: July 23,2013 TO: TRACI L.RUSSO 769 Erford Road Camp Hill,PA 17011 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME of Cumberland County LOANS SERVICING LP 7105 Corporate Drive CIVIL ACTION-LAW PTX.B-209 Plano,TX 75024 Plaintiff Action of VS. Mortgage Foreclosure MICHAEL A.RUSSO TRACI L RUSSO No. 13-1275 (Mortgagor(s)and Record Owner(s)) 769 Erford Road Camp Hill,PA 17011 Defendant(s) TO: TRACI L RUSSO 769 Erford Road Camp Dill,PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE. YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCIF PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECfIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLF..SS YOU ACT WITHIN TEN(10)DAYS FROM 111E DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT R.lG1frS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYFP, GO 1'0 OR TELEPHONE THE OFFICE SET FORTH BELOW. 11115 OFFICE CAN PROVIDE YOU WITH INFORMAITON ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO 11IRE A LAWYER,THIS OFFICE MAY BE ABLE:1'O PROVIDE YOU WITH INFORMATION ABOUT AGENCIES 1I1Af MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC. 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ED 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 �Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 31291.2 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 31.1835 215-627-1322 Attorneys for Plaintiff 116674FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DA:1'E OF THIS NOTICE: July 23,2013 TO: MICHAEL A.RUSSO 769 Erford Road Camp Hill,PA 17011 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas HOME, LOANS SERVICING LP FKA COUNTRYWIDE 110ME of Cumberland County LOANS SERVICING LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Plano,TX 75024 Plaintiff Action of vs. Mortgage Foreclosure MICHAEL A.RUSSO TRACI L RUSSO No. 13-1275 (Mortgagor(s)and Record Owner(s)) 769 Erford Road Camp Hill,PA 17011 Defen&int(v) TO: MICHAEL A.RUSSO 769 Erford Road Camp Hill,PA 17011 BRORTANT NOTICE YOU ARE IN DEFAUIXIIECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR By ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,AJUDGMENT MAY RE AGAINST YOU WITHOUT AHEARJNG AND YOU MAY LOSE YOUR PROPERTY OR OT1IFR IMPOWFANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT DAVE A LAWYER, GO To OR TELEPHONE THE OFFICE =FORTH BFLOW. THIS OFFICE CAN PROVIDE,YOU W111T INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNO'l.'AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOIN AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS ATAREDUCED FEE-OR NO FEE. CUMHERIAND COUNTY 13AR ASSOCIATION 2 LibeAy Avenue Carlisle,PA 17013 LEGAL SFRVJCF.S INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By; KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ED 78020 Kristina Murtha Pa.JD 61.858 David Fein Pa.ED 82628 Thomas Puleo Pa.Ul)27615 fill P Jenkins Pa.ID 306588 ��lyk`L.OflaAan Pa. ID 312912 Salvatore Filippcllo Pa.ED 313897 Michael J.Coskey Pa H)311835 215-627-1322 Attorneys for Plaintiff 116674FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT- OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF TIRS NOTICE: July 23,2013 TO; TRACI L RUSSO 450 Harvard CourtUnit 101 Harrisburg,PA 17111 BANK OF AMU-RICA,N.A.,SUCCESSOR BY MERGER TO BAC In the Court of Common Pleas HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME of Cumberland County LOANS SERVICING LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Piano,TX 75024 Plaintiff Action of vs. Mortgage Foreclosure MICHAEL A.RUSSO TRACI L RUSSO -No. 13-1275 (Mortgagor(s)and Record Owner(s)) 769 Erford Road Camp Hill,PA 17011 Defendant(s) TO: TRACT L RUSSO 450 Harvard CourtUnit 101 Harrisburg,PA 17111 YWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILFJ-) TO ENTER A WRITTEN APPEARANCE PERSONALLY OR By ATTORNEY AND FILE IN WRITING WITH THECOUKI'YOUR DEFENSES OR OBJECTIONS To THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU At;I'WFITITNTEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY RE BN-VERhL)AGAINST You wrmou'r A HEARING AND YOU MAY LOSE YOUR PROPERTY OR 0'17IER 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 BERING A LAWYER. IF YOU CANNA l'AFFORD TO HIRE A I.AWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WIll I INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RFIIUCI-,D FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Cadiste,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 Fay_ KMW--4R P.C.OUP,L LAW JR Michael McKeever Pa.ID 56129 Lisa Lee Pa.IUD 78020 Kristina Murtha Pa.ID 61855 David Fein Pa,ID 82628 Thomas Puleo Pa. ID 27615 Jill P.Jenkins Pa.ID 306588 =Alyk L.011azian Pa.113 312912 Salvatore Filippello Pa.ED 313997 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE IN THE COURT OF COMMON PLEAS HOME LOANS SERVICING LP 7105 Corporate Drive OF CUMBERLAND COUNTY PTX B-209 Plano,TX 75024 Plaintiff CIVIL ACTION LAW vs. MICHAEL A.RUSSO ACTION OF MORTGAGE FORECLOSURE TRACI L.RUSSO (Mortgagor(s)and Record owner(s)) 769 Erford Road No. 13-1275 Camp Hill,PA 17011 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of BAND OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP,and against MICHAEL A.RUSSO and TRACI L.RUSSO for failure to file an Answer in the above action within(20)days from the date of service of the Complaint,in the sum of$107,483.86. p KML LAW GROUP,//,. _Michael McKeever Palo 56129 _Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 iKristina Murtha Pa,ID 61858 _David Fein Pa.ID 82628 _Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Andrew F.Gorrnall Pa.ID 92382 Attorneys for Plain jiff I hereby certify that the above names are correct and that the precise resicTeAce address of the judgment creditor is BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP 7105 Corporate Drive PTX B-209 Plano,TX 75024 and that the name(s)and last known address(es)of the Defendant(s)is/are MICHAEL A.RUSSO,769 Erford Road Camp Hill,PA 17011 and TRACI L.RUSSO,450 Harvard Court,Unit 101 Harrisburg,PA 171 11; By: KML LAW GROUP,P _Michael McKeever Pa. 6129 _Jay E.Kivitz Pa.1D 26769 _Lisa Lee Pa,ID 78020 Kristina Murtha Pa.ID 61858 _David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 iJill P.Jenkins Pa:ID 306588 Andrew F.Gomall Pa.ID 92382 �. SaI't ''[t iiflzel 10 ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $79,595.13 Interest from 09/01/2009 through $20,363.00 08/09/2013 Late Charges $22.40 Escrow Advances $5,872.85 Court Costs ($164.00) Title Fees $463.00 Property Inspections Fees $330.00 Credits ($8.02) Filing Fees $9.50 Attorney Fees/Trustee Fee $1,000.00 $107,483.86 By: KML LAW GRO ,P.C. Michael McKeever a. ID 56129 Jay E.Kivitz Pa. ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Attorneys for P aiRtiff x S�.!✓atr,nL 1 3 l389rJ AND NOW,this , day of 2013 damages are asse ed as skye. Pro Prothy 13-1275/116674FC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA. BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HONE LOANS SERVICING LP FKA COUNTRYWIDE HONE LOANS SERVICING LP C-- Plaintiff VS. NO.13-1275 cn -<� ---I MICHAEL A.RUSSO TRACIL.RUSSO 35 C-) :z =CD CD C" Defendant(s) C- —T -rl VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIC -iV RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(https://www.dmde.osd.mil/appi/scra/scraHome.do) for the following individual(s): TRACI L. RUSSO, has a last known residence of 450 Harvard Court,Unit 101,Harrisburg,PA 17111. The following information was used to search the DMDC(check all that apply): X Last Name • First Name • Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. Date_1 �13 By: KMf LAW GROUP,PA( Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristin Murtha Pa. ID 61858 David Fein Pa. 11) 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa.ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa.ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Aug-0g•201311:22:21 SCRA 3.0 Status Report Pursuant to Servicerab Civil I e Act me Last Name: RUSSO First Name: TRACI Middle Name: L. Active Duty Status As Of: Aug-09-2093 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 individuate active duty status based on the Active Duty Status Date k 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 inhere the individual left active duty status within 367 days preceding the Active Duty Status Date x The Member or His/Her Unit Was Notified of a Future Catwp 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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Obl A- 4"4— Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 2250 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. in the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL•hftp://www.defenselink.mil/faq/pis/PC09SLDR.htm]. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USG§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Nary Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 0439EOBlUO04730 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP C= Plaintiff vs. NO. 13-1275 W ` MICHAEL A.RUSSO (S TRACI L.RUSSO ca c:)ty; Defendant(s) —< r� VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (hitps://www.dmdc.osd.mil/appi/scra/scraHome.do) for the following individual(s): MICHAEL A. RUSSO, has a last known residence of 769 Erford Road, Camp Hill,PA 17011. The following information was used to search the DMDC(check all that apply): X Last Name • First Name • Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. Date ell 1 By: KML LAW GROUP, Michael McKeever A.. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 / Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Aug-o9-20,33,:20:06 SCRA 3.0 fit Statu Reps Pursuant to; ervicemembl Civil Relief blot Last Name: RUSSO First Name: MICHAEL Middle Name: A. Active Duty Status As Of: Aug-09-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Adtve Duty End Date Status Service Component NA NA .• No NA This response reflects the individuate active duty status based on the Active Duty Status Date } Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA '" ". No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Dale The Member or His/Her Unit Was Notified of a Future Cali-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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. if you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: T4G7E081 B004D70 PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSU wo )--- —, P.R.C.P 3180-3183 KML Law Group,P.C. n CD Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP IN THE COURT OF COMMON PLEAS 7105 Corporate Drive PTX B-209 of Cumberland County Plano,TX 75024 Plaintiff CIVIL ACTION—LAW VS. ACTION OF MORTGAGE FORECLOSURE MICHAEL A.RUSSO TRACIL.RUSSO Mortgagor(s)and Record Owner(s) No. 13-1275 769 Erford Road Camp Hill,PA 17011 Defendant(s) PRAECI[PE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $107,483.86 Interest from 8/10/2013 to Date of Sale per them at $14.17 (Costs to be added) 117 rrldoasl By: -7 to KML LAW GROUP,P Michael McKeever Pa 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 acl f Attorneys for Plaintiff 3 0 1 I SDU, -- �/ ' No. 13-1275 IN THE COURT OF COMMON PLEAS BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE ROME LOANS SERVICING LP vs. MICHAEL A.RUSSO and TRACIL.RUSSO (Mortgagor(s)and Record Owner(s)) 769 Erford Road Camp Hill,PA 17011 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure KML Law Group,P.C. Attorney for Plaintiff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township,Cumberland County, Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point on the easterly line of Erford Road (East),which point is 333.59 feet North of the northeasterly corner of Erford Road (East) and Dulles Drive (East),and at dividing line between Lot Nos. 17 and 17X, Block"I",on the hereinafter mentioned Plan of Lots;thence along easterly line of Erford Road (East), in an arc having a radius of 300 feet in a northerly direction to the left, 34.61 feet to a point at dividing line between Lot Nos. 16 and 17X, Block"I", on said Plan;thence along said dividing line North 72 degrees 31 minutes 36 seconds East, 146.68 feet to a point;thence South 26 degrees 00 minutes East,53.27 feet to a point at dividing line between Lot Nos. 17 and 17X, Block"I",on said Plan; thence along said dividing line,South 79 degrees 08 minutes 12 seconds West, 157.63 feet to a point, the place of BEGINNING. BEING Lot No. 17X, Block"I", in Plan No.7, Ridley Park,which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 15, Page 56. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY EAST PENNSBORO TOWNSHIP BEING PREMISES: 769 Erford Road Camp Hill PA 17011 SOLD as the property of MICHAEL A. RUSSO and TRACI L. RUSSO TAX PARCEL#09-17-1044-009 BEING the same premises which TRACI L. RUSSO by deed dated 2/14/2008 and recorded 3/14/2008 in Cumberland County in Deed Book Instrument#200807800 granted and conveyed unto MICHAEL A. RUSSO. KMI.Law Group,P.C. Suite 5000—BNY Independence Center H-I_ ; 701 Market Street Philadelphia,PA 19106-1532 13 215-627-1322 ' ! t Attorney for Plaintiff L;11"OERLAND BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO 'i"t ,L V q 1 A BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE IN THE COURT OF COMMON PLEAS HOME LOANS SERVICING LP 7105 Corporate Drive of Cumberland County PTX B-209 Plano,TX 75024 Plaintiff CIVII,ACTION-LAW VS. MICHAEL A.RUSSO ACTION OF MORTGAGE FORECLOSURE TRACI L.RUSSO (Mortgagor(s)and Record Owner(s)) 769 Erford Road Camp Hill,PA 17011 No. 13-1275 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP,Plaintiff in the above action,by counsel,KUL Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 769 Erford Road Camp Hill,PA 17011 I.Name and address of Owner(s)or Reputed Owner(s): MICHAEL A.RUSSO 769 Erford Road Camp Hill,PA 17011 TRACI L.RUSSO 450 Harvard Court,Unit 101 Harrisburg,PA 17111 2.Name and address of Defendant(s)in the judgment: MICHAEL A.RUSSO 769 Erford Road Camp Hill,PA 17011 TRACI L.RUSSO 450 Harvard Court,Unit 101 Harrisburg,PA 17111 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 EAST PENNSBORO TOWNSHIP 98 S Enola Drive Enola,PA 17025 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS '769 Erford Road Camp Hill,PA 17011 1 verify that the statements made in this affidavit are true and correct to the best of my information and belief I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.Section 4904 relating to unworn falsification to authorities. DATED: By: KML LAW GROUP, Michael McKeever Pa 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff 1k. VOJ-0 r4L Ft 13-1275 KML Law Group,P.C. tt Lt.- Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 ?L"3 AUG 2 Attorney for Plaintiff UMBERLAND flrjfw•pl t"L N S Y L VA N! BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING IN THE COURT OF COMMON PLEAS LP FKA COUNTRYWIDE HOME LOANS SERVICING LP of Cumberland County 7105 Corporate Drive PTX B-209 Plano,TX 75024 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE VS. FORECLOSURE MICHAEL A.RUSSO TRACIL.RUSSO Mortgagor(s)and Record Owner(s) Docket No. 13-1275 769 Erford Road Camp Hill,PA 17011 Defendant(si THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUSSO,MICHAEL A. MICHAEL A. RUSSO 769 Erford Road Camp Hill,PA 17011 Your house at 769 Erford Road,Camp Hill,PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$107,483.86 obtained by BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. 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: 13-1275 1. The sale will be cancelled if you pay to BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. 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 below 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 NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: htq2://www.philadelpbiafed.org/foreclosure/ 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 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 s 13-1275 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.pb a.or /cg onsumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 116674FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-1275 KML Law Group,P.C. ;. Suite 5000-BNY Independence Center +..,f_ i ;0 1'1_1 0 701 Market Street � � Philadelphia,PA 19106 ? n (215)627-1322 Fi `r L Attorney for Plaintiff U 1'1 F3 EFi + mot; �o BANK OF AMERICA,N.A., SUCCESSOR BY �YA FJ4A MERGER TO BAC HOME LOANS SERVICING IN THE COURT OF COMMON PLEAS LP FKA COUNTRYWIDE HOME LOANS SERVICING LP of Cumberland County 7105 Corporate Drive PTX B-209 Plano,TX 75024 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE vs. FORECLOSURE MICHAEL A. RUSSO TRACI L.RUSSO Mortgagor(s)and Record Owner(s) Docket No. 13-1275 769 Erford Road Camp Hill,PA 17011 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RUSSO,TRACI L. TRACT L. RUSSO 450 Harvard Court,Unit 101 Harrisburg,PA 17111 Your house at 769 Erford Road,Camp Hill,PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$107,483.86 obtained by BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP against you. 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: ` 13-1275 1. The sale will be cancelled if you pay to BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. 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 below 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 NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 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 the Sheriff of 717-240-6390. 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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hitp://www,philadelphiafed.orejforeclosurel 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 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-1275 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for I-lel p for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orp-/consumers/homeow,ners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss , Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroui).com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 116674FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 2013-1275 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.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP Plaintiff(s) From MICHAEL A.RUSSO,TRACI L.RUSSO (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: $107,483.86 L.L.: $.50 Interest FROM 8/1.0/2013 TO DATE OF SALE PER DIEM AT$14.17 Atty's Comm: Due Prothy: $2.25 Atty Paid: $293.45 Other Costs: Plaintiff Paid: Date: August 27,2013 David D.Buell,Prothonotary (Seal) y: ¢j Deputy REQUESTING PARTY: Name:SALVATORE FILIPPELLO,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone:21.5-627-1322 Supreme Court ID No. 313897 KML LAW GROUP,P.C. 116674FC Suite 5000 CF: 03/08/2013 BNY Mellon Independence Center ;'` SD: 12/04/2013 701 Market Street i 4+ i s 'g `�1 6 $107,483.86 Philadelphia,PA 19106-1532 jWf ! i y 215-627-1322 Attorney for Plaintiff 4 rl E' r{T.J� BANK OF AMERICA,N.A., SUCCESSORAYjt Y( n NIA IN THE COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS of Cumberland County SERVICING LP 7105 Corporate Drive CIVIL ACTION—LAW PTX B-209 Plano, TX 75024 ACTION OF MORTGAGE FORECLOSURE Plaintiff VS. Term No. 13-1275 MICHAEL A. RUSSO TRACI L. RUSSO Mortgagor(s)and Record Owner(s) 769 Erford Road Camp Hill,PA 17011 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c) (2) Veronica Cosme, an employee of KML Law Group,P.C.,counsel of Plaintiff,hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) Personal Service by the Sheriffs Office/competent adult(copy of return attached). ( ) Certified mail by KML Law Group, P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group, P.C.to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult(copy of return attached). ( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached). ( ) Certified Mail&ordinary mail by KML Law Group,P.C. (original receipt(s)for Certified Mail attached). ( ) Published in accordance with court order(copy of publication attached). Pursuant to the Affidavit under Rule 3129(copy attached), service on all lienholders(if any)has been made by ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Respectfully submitted, Veronica Cosine Legal Assistant m (0 Lo 0 12 0 m +U 111 N r Lo 0 m t l ttr k d o o < O G d E i-I V Q 71 V 7 IL (D cil �t U) z �� x x E2 EL o n�o (D m°°=v- � d u)�c 9; LL U O xN �Y �m d OQ a m Z C= +a+ znE CL r o Wco U D a C m G `- W 2 C O .C. N O g ° D I = Z �O _ Z o� 4) < 3 a. m CM CL W cg vi?- c q'S S E mm a�rn U ` o = a m ❑❑❑❑ 0 m .o 0 Z w m ( n W I r- � c Q a � CA CD O S E M tL Qm CA ~ U O Co `��' Q M O S 2 � o Q N c= Z _7 r Zln Od m ° `Q W o W a— ` m ? E o 6 Oou� N f-} MW Q O m 3 W 0, ca t- a ca F- OOOCLO CLMm = uJCD a O o U wo C J E — 7 ID U Q �o a a ),� Z N 0 p1 �'� O CV O W ),-o (n U) Wd a. YOwn.Cj °a LL �,j ¢U C:) c) °'° € ti Q �mnWQD� Za' LL coD U_ co z O p 2 r CV M L6 CO Cx7 t IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO ;CASE and/or DOCKET No.: 13-1275 BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE ROME LOANS SERVICING LP;et seq. Sheriffs Sale Date: 12/4/2013 Plaintiff(Petitioner) ; V. ' i MICHAEL A.RUSSO;et al. Defendant(Respondent) AFFIDAVIT OF SERVICE PA Complaint ❑Summons IR Other:NOTICE OF SALE I,RYAN MARI{S,certify that I am eighteen years of age or older and that 1 am not a party to the action nor an employee nor relative of a party,and that 1 served MICHAEL A.RUSSO the above process on the 5 day of September,2013,at 3:35 o'clock,PM,at 769 Erford Road Camp I lilt,PA 17011 ,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: f By handing a copy to the Defendant(s) Description:Approximate Age 56-60 Height 5'8 Weight 195 Race WI11TF Sex MALE Hair BLACK Military Status: ZNo ❑Yes Branch: i. i i Commonwealth/State of SS: County of _-mr ix f ) Before me,the undersigned notary pub'c, us day,personally,appeared fwr o azl to me known,who being duly sworn according to law depya h ollowing: r� I hereby swear or affirm 91 tth f f et forth in the foregoing Affidavit of Service are true and correct. Subscribed and sworn to before me (Si nature o Affiant) this &.day of -top t 120 I3 Nile Number:11667 C Case ID#:3749650 Notary Public COMMONW OF PENNSYLVANIA Notarlal Seal Eric M.Atflerbach,Notary Public Washington Twp.,Barks County My Commission Explres Nov.18,2013 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO ;CASF,and/or DOCKET No.: 13-1275 BAC HOME.LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP;et seq. ;Sheriff's Sale Date: 12/4/2013 Plaintiff(Petitioner) V. ; MICHAEL A.RUSSO;et al. Defendant(Respondent) AFFIDAVIT OF SERVICE C I .lComplaint 0 Summons n Other:NOTICE OF SALE I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee not relative of a party,and that I served TRACI L.RUSSO the above process on the 10 day of September,2013,at 4:25 o'clock,PM,at 450 Harvard Ct Unit 101 Harrisburg,PA 171 It, County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: [/] By handing a copy to the Dcfcndant(s) Description:Approximate Age 46-50 Height 5'5 Weight 170 Race WHITE Sex FEMALE Hair BLACK Military Status: 9 No El Yes Branch: Commonwealth/State of p^ } SS: County of $e y f ) Before me,the undersigned notary publi Ws day,personally,appeared Ryww M K f to me known,who being duly sworn according to I ,de o.,V f611owing: I hereby swear or affrrn that a f/ t�set forth in the foregoing Affidavit of Service are true and correct. Subscribed and sworn igna rcofAffiant) this 41 d of ♦ __,20 IF FileNumber:1166 4FC Case ID 0:3749650 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Eric M,AMerbach,Notary Public Washington TWp.,Berks County My Commission Expires Nov,18,2013 KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff BANK OF AMERICA,N.A., SUCCESSOR BY IN THE COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS of Cumberland County SERVICING LP 7105 Corporate Drive PTX B-209 CIVIL ACTION-LAW Plano,TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE VS. Term MICHAEL A.RUSSO No. 13-1275 TRACI L.RUSSO Mortgagor(s)and Record Owner(s) 769 Erford Road Camp Hill,PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP FKA COUNTRYWIDE HOME LOANS SERVICING LP, Plaintiff in the above action, by and through an authorized employee of its attorneys,KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 769 Erford Road Camp Hill, PA 17011 1.Name and address of Owner(s)or Reputed Owner(s): MICHAEL A. RUSSO 769 Erford Road Camp Hill,PA 17011 TRACI L. RUSSO 450 Harvard Court,Unit 101 Harrisburg, PA 17111 2.Name and address of Defendant(s)in the judgment: MICHAEL A. RUSSO 769 Erford Road Camp Hill, PA 17011 TRACI L. RUSSO 450 Harvard Court,Unit 101 Harrisburg, PA 17111 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE- Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 EAST PENNSBORO TOWNSHIP 98 S Enola Drive Enola,PA 17025 4.Naive and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. TENANTS/OCCUPANTS 769 Erford Road Camp Hill, PA 17011 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. Section 4904 relating to unsworn falsification to authorities. DATED: November 12, 2013 KML Law Group, P.C. BY: Veronica Cosme Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny Sheriff Anderson heriff & v at Cu lithe Jody S Smith Mit FEB ! �, ar Chief Deputy J_ CU,I` 3LRL/ ii COUNTY Richard W Stewart Solicitor ,F1-- CE v-:=Ricc PENNSYLVANIA Bank of America, N.A. Case Number vs. 2013-1275 Michael A. Russo (et al.) SHERIFF'S RETURN OF SERVICE 10/02/2013 02:38 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 769 Erford Road, East Pennsboro-Township, Camp Hill, PA 17011, Cumberland County. 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Michael McKeever, on behalf of Secretary of Veterans Affairs, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $980.32 SO ANSWERS, January 24, 2014 RONNY R ANDERSON, SHERIFF We90 ,d,ad . 5ti &Clod- 4 *- 9"7i*e' g440. 30/( 74/ • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2013-1275 Civil Term TAX PARCEL#09-17-1044-009. BEING the same premises which BANK OF AMERICA,N.A. TRACI L. RUSSO by deed dated vs. 2/14/2008 and recorded 3/14/2008 in Cumberland County in Deed Book MICHAEL A.RUSSO, Instrument#200807800 granted and Traci L.Russo conveyed unto MICHAEL A.RUSSO. Atty.: Michael McKeever ALL THAT CERTAIN tract or par- cel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on th east- erly line of Erford Road(East),which point is 333.59 feet North of the northeasterly corner of Erford Road (East)and Dulles Drive(East),and at dividing line between Lot Nos. 17 and 17X, Block TIIIT on the hereinafter mentioned Plan of Lots;thence along easterly line of Erford Road(East),in an arc having a radius of 300 feet in a northerly direction to the left,34.61 feet to a point at dividing line between Lot Nos. 16 and 17X, Block "I", on said Plan;thence along said dividing line North 72 degrees 31 minutes 36 seconds East, 146.68 feet to a point; thence South 26 degrees 00 minutes East,53.27 feet to a point at dividing line between Lot Nos. 17 and 17X, Block"I",on said Plan;thence along said dividing line, South 79 degrees 08 minutes 12 seconds West, 157.63 feet to a point, the place of BEGIN- NING. BEING Lot No. 17X, Block "I in Plan No.7,Ridley Park,which plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania,in Plan Book 15,Page 56. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY EAST PENNS- BORO TOWNSHIP. BEING PREMISES: 769 Erford Road Camp Hill PA 17011. SOLD as the property of MICHAEL A.RUSSO and TRACI L.RUSSO. 101 The Patriot-News Co. 2020 Technology Pkwy patnot*Xews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is 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. 2013.1275 Civil Term ANK OF AMERICA,N . vs. This ad ran on the date(s)shown below: MICHAEL A.RUSSO 10/13/13 TracI L.Russo Any: Michael McKeever / 10/20/13 ALL THAT-CERTAIN tract or parcel of land situate in East Pennsboro Township, 10/27/13 Cumberland County, Pennsylvania, more ,\ particularly bounded and described as >/ follows,to wit: BEGINNING at a point on the easterly line V • • • • of Erford Road(East),which point is 33359 t feet North of the northeasterly corner of ,` Erford Road(East)and Dulles Drive(East), .l Sworn to and ubscribed before me is 11 day of November, 2013 A.D. and at dividing line between Lot Nos. 17 t ' and 17X, Block of Lots;the hereinafter ng b js,e, mentioned Plan of Lots; thence along o ( easterly line of Erford Road(East),in an arc having a radius of 300 feet in a northerly Vr " •ublic direction to the left,34.61 feet to a point at 1 dividing line between Lot Nos.16 and 17X, Block"I",on said Plan;thence along said dividing line North 72 degrees 31 minutes 36 seconds East,146.68 feet to a point;thence R' ��f 'F PENNSYLVANIA South 26 degrees 00 minutes East,53.27 feet =,a j to a point at dividi g�" n Lot Nos. Ol ` r';t3r1;,Public 17 and 17X,Block"I",on said Plan;thence �tphin Ccunty along said dividing line,South 79 degrees 08 !iCornrt�ission Expires Dec.12,2016 minutes 12 seconds West,157.63 feet to a MEMBER,PENNSYLVANIA ASSOCIATION OF VOTARIES • 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 Secretary of Veterans Affairs is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 27th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 1275. at the suit of Bank of America. NA against Michael A. Russo and Traci I,. Russo is duly recorded as Instrument Number 201403354. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /`1 day of Feb. , A.D. (D.-O/y Recorder of Deeds"Cumberland County,Carlisle,PA Recorder of Deeds My Commission Expires the First Monday of Jan.2018