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Home My WebLink About13-1496 PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 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 Plaintiff NO. �� Ll 0(, v. STEVEN L. WYRICK AWA STEVE WYRICK CUMBERLAND COUNTY VALERIE WYRICK 2819 SHIPPENSBURG ROAD BIGLERVILLE, PA 17307 -9001 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File t_ 298976 �/I' 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 Filc #'' 298976 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: STEVEN L. WYRICK A/K/A STEVE WYRICK VALERIE WYRICK 2819 SHIPPENSBURG ROAD BIGLERVILLE, PA 17307 -9001 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/14/2008 STEVEN L. WYRICK and VALERIE WYRICK made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR COUNTRYWIDE HOME LOANS, INC. which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200812701. By Assignment of Mortgage recorded 07/11/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201119205.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 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 01/01/2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified File 4 298976 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 02/08/2013: Principal Balance $173,080.94 Interest $25,313.11 12/01/2010 through 02/28/2013 Late Charges $0.00 Property Inspections $15.00 Title Costs $250.00 Escrow Deficit $6,445.52 TOTAL $205,104.57 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 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 a 298976 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $205,104.57, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: — C;�ak 2 Jon an Lobb, Esq., Id. No.312174 Attorney for Plaintiff File #t 298976 LEGAL DESCRIPTION ALL THAT CERTAIN tract of mountain land situate on the Big Flat in the Township of Southampton. County of Cumberland, and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the new Baltimore Road at a common corner with land now owned by the Commonwealth of Pennsylvania; thence along the State Land, North 51 1/2 degrees East 500 feet to an iron pin; thence along land now or formerly of Pearl I. Robinson, by a line parallel with the new Baltimore Road, 85 feet to an iron pin; thence by same, South 51 1/2 degrees West, 500 feet to a point in the center of the said new Baltimore Road; thence in a southeastwardly direction along the center of the new Baltimore Road, 85 feet to the Place of BEGINNING. CONTAINING one acre, more or less. BEING the same premises which PEARL L ROBINSON, single woman, by Deed dated March 20, 1992 and recorded in Cumberland County, Pennsylvania Deed Book'O' Volume 35, Page 569. granted and conveyed unto GLEN KENT FRY, Grantor herein. PROPERTY ADDRESS: 2819 SHIPPENSBURG ROAD, BIGLERVILLE, PA 17307 -9001 PARCEL # 39 -16- 0224 -002A Pile P 298976 VERIFICATION ke ) , hereby states that hetshe is % t' of BANK OF AMERICA, N.A., Plaintiff in this matter, that he /si is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his he` information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: DATE: r Title: BANK OF AMERICA, N.A. File #: ?98976 Name: WYRICK File t: 298976 FORM 1 IN THE O F BANK OF AMERICA, N.A., AS SUCCESSOR BY OF CUM ERLA COUNTY, PE Y VANIA MERGER TO BAC HOME LOANS SERVICING, LP FK/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff(s) vs. STEVEN L. WYRICK A /K /A STEVE WYRICK - VALERIE WYRICK — Defendant(s) ��hCivil NOTICE OF RESIDENTIAL MORTGAGE FORECLO' S IE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date nathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Date Financial Worksheet Cumberland County Court of common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: EMU INKI Borrower name(s): Property Address: City: — State: Zip Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ _ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ -- Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cel I: Other: Email # of people in household: How long? Elm Mailing Address: City: State: _Zip: Phone Numbers: p' -- Home: Office: Email: Cell: Other: -- # of people in household: How long? First Mortgage Lender: Type of Loan: — Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: _ Loan Number: "Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Other Real Estate: $ $ Retirement Funds: $ $ Investments: Checking: $ - - - -- $ Savings: $— $ Other: $ Automobile fl: Model: Amount owed: Year: Value: Automobile #2: Model: Amount owed: Year: _ Value: Other trans ortation automobiles boats motorcycles): Model: Year: - Amount owed: Value )Monthly Income Name of Employers: I . - -- Monthly Gross _Month) Net 2 - -- -- Monthly Gross Monthly onthly Net 3 -- Monthly Gross -- -- Additional Income Description (not wages): Monthly Net I _monthly amount: monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses• (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mort a e 2 °d Mort a e Food - -- Car Pa ment(s) Utilities Condo/Nei h. Fees Auto Insurance Med. (not covered) -- Auto fuel /re airs Other prop. payment -- Install. Loan Pa merit Cable TV Child Su ort/Alim. Da / Child Care / Tuft. S ending Mone - -- Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): — Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ Ifyes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: ME == — — — — 0 I /We, authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /We understand that I /we am /are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: L Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OF THE Jody S Smith Chief Deputy ( �r: ct N13 PR 29 �� . Richard W Stewart t CUMBERLAND CGWI Solicitor OF 510E OF TkE 6�EPJF� PENNSYLVANIA Bank of America, N.A. Case Number vs. Steven L Wyrick(et al.) 2013-1496 SHERIFF'S RETURN OF SERVICE 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Steven L Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Steven L Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Valerie Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Valerie Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 04/02/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Valerie Wyrick, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure as"Not Found" at 2819 Shippensburg Road, Southampton, Biglerville, PA 17307. Deputies were informed by defendant's ex-husband defendant moved to Fayetteville three years ago he was unsure of her address or phone number. 04102/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Valerie Wyrick, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. No such number exists. 04/02/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Steven L Wyrick, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. No such number exists. 04/02/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Steven L Wyrick, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. Defendant is reported to live in Biglerville, PA, Adams County. 04/02/2013 09:30 AM -The requested Notice of Residential Mortgage Foreclosure Diversion Program & Complaint in Mortgage Foreclosure served by the Sheriff of Franklin County upon Valerie Wyrick, personally, at The Franklin County Sheriffs Office at 157 Lincoln Way East, Chambersburg, PA 17201. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. �c7 CountySuite Sheriff,Toleosoft,Inc. 04/02/2013 07:38 PM - Deputy Shawn Gutshall, 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: Steven L Wyrick at 2819 Shippensburg Road, Southampton, Biglerville, PA 17307. 9&�e SH A GUTSH , EPUTY SHERIFF COST: $118.00 SO ANSWERS, April 25, 2013 RbNIV R ANDERSON, SHERIFF (c)CountySuito ShoriK,Toleosott,Inc. SHERIFF' S RETURN - NOT FOUND CASE NO: 2013-00082 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK ANGEL L LAVIENA Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit : WYRICK VALERIE ` but was unable to locate Her in his bailiwick. He therefore returns the COMP MORT FORE , NOT FOUND as to the within named DEFENDANT WYRICK VALERIE 14781 CUMBERLAND HIGHWAY NEWBURG, PA 17240 NO SUCH NUMBERED ADDRESS Sheriff ' s Costs : So answer Docketing . 00 Service . 00 Affidavit . 00 ANGEL L A ENA Surcharge . 00 DANE M ANTHONY, Sheriff . 00 . 00 PHELAN HALLINAN AND SCHMIEG 04/17/2013 Sworn and subscribed to before me � C/ COMMONWEALTH OF PENNSYLVANIA this day of NOTARIAL SERI. RICHARD D. McCARTY, Notary Public °2 �� A. D. Chambersbtq Som, Franklin County Icy Commission Ex elms Jan.A, 20166 Notary/ _ SHERIFF' S RETURN - NOT FOUND CASE NO: 2013-00082 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK ANGEL L LAVIENA Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit : WYRICK STEVEN but was unable to locate Him in his bailiwick. He therefore returns the COMP MORT FORE , NOT FOUND as to the within named DEFENDANT WYRICK STEVEN 14781 CUMBERLAND HIGHWAY NEWBURG, PA 17240 NO SUCH NUMBER; DEF SUPPOSEDLY LIVES IN BIGLERVILLE PA ADAMS COUNTY ,47T,,=mPte) 11- 2-13 Sheriff ' s Costs : So answers : Docketing . 00 Service . 00 Affidavit . 00 ANGEL L LAVIENA Surcharge . 00 DANE M ANTHONY, Sheriff . 00 . 00 PHELAN HALLINAN LLP 04/17/2013 Sworn and subscribed to before me COMMONWEALTH OF PENNSYLVANIA this day of RICHARD D. McCARTYNotary Public Chambersbtq Boro., Frankiin County �/ A.D. My Commisslon Expires Jan.29,2415 1 4A�� Notary,/-. , SHERIFF' S RETURN - NOT FOUND 1 CASE NO: 2013-00082 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK DANE M ANTHONY Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit : WYRICK STEVEN but was unable to locate Him in his bailiwick. He therefore returns the COMP MORT FORE , NOT FOUND as to the within named DEFENDANT WYRICK STEVEN 5997 FAIRWAY DRIVE WEST FAYETTEVILLE, PA 17222 DEF SUPPOSEDLY LIVES IN BIGLERVILLE PA ADAMS COUNTY Angi"pMb 1.7--13 Sheriff ' s Costs : So answers : Docketing . 00 Service . 00 Affidavit . 00 _ Surcharge . 00 DANE M HONY, Sheriff . 00 . 00 PHELAN HALLINAN LLP 04/17/2013 Sworn and subscribed to before me this r V-6��day of , COMMONWEALTH OF PENNSYLVANIA ° t,5 A.D. RICHARD D. McC RTY, Notary Public a Ctiambersburg 8oro., Franklin County My Commission iras Jan. 29, 2015 Notary f SHERIFF' S RETURN - REGULAR CASE NO: 2013-00082 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK MICHAEL LEVEILLE Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMP MORT FORE was served upon WYRICK VALERIE the DEFENDANT at 0930 : 00 Hour, on the 4th day of April 2013 at FRANKLIN COUNTY SHERIFF' S OFFI CHAMBERSBURG, PA 17201 by handing to VALERIE WYRICK a true and attested copy of COMP MORT FORE together with and at the same time directing Her attention to the contents thereof . All r-4f9wA-y fi4yer(1-Y 44-E, !9a l7ZZz hTrem pMt) V--Z-2e13 Sheriff ' s Costs : So Answers : Docketing . 00 Service . 00 MICHAEL LEVEIL E Affidavit . 00 Surcharge . 00 By . 00 Deputy Sheriff . 00 04/17/2013 PHELAN HALLINAN LLP Sworn and Subscribed to before me this day of COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL, AA&- RICHARD D. MCCARTY, Notary Public o A.D. Chambershn Boro., Franklin Gnuhty < Commission its Is�7, � 2015 Notary,/-, , SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson tL _,4;(• Sheriff HE Jody S Smith rrt Chief Deputy '. � � 3 IW 28 Fri Richard W Stewart .� �U�4E3E.Rt�►�NI� L',G�Jii�''f Solicitor OF�IC Frt kSf<P1FP ;�E��dSYLV�P I *Amended* Bank of America, N.A. Case Number vs. Steven L Wyrick(et al.) 2013-1496 SHERIFF'S RETURN OF SERVICE 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Steven L Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Steven L Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Valerie Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/26/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Valerie Wyrick, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 04/02/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Valerie Wyrick, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program & Complaint in Mortgage Foreclosure as"Not Found"at 2819 Shippensburg Road, Southampton, Biglerville, PA 17307. Deputies were informed by defendant's ex-husband defendant moved to Fayetteville three years ago he was unsure of her address or phone number. 04/02/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Valerie Wyrick, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. No such number exists. 04/02/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Steven L Wyrick, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. No such number exists. 04/02/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Steven L Wyrick, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. Defendant is reported to live in Biglerville, PA,Adams County. 04/02/2013 07:38 PM- Deputy Shawn Gutshall, 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: Steven L Wyrick at 2819 Shippensburg Road, Southampton, Biglerville, PA 17307. (c)countysuito Shoritf, elecsoft Inc. UTS AL EPUTY 04/04/2013 09:30 AM -The requested Notice of Residential Mortgage Foreclosure Diversion Program &Complaint in Mortgage Foreclosure served by the Sheriff of Franklin County upon Valerie Wyrick, personally, at The Franklin County Sheriffs Office at 157 Lincoln Way East, Chambersburg, PA 17201. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $118.00 SO ANSWERS, April 25, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuito Sheriff,Teleosoft,Inc. SHERIFF' S RETURN - NOT FOUND CASE NO: 2013-00082 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK ANGEL L LAVIENA Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: WYRICK VALERIE ' but was unable to locate Her in his bailiwick. He therefore returns the COMP MORT FORE , NOT FOUND as to the within named DEFENDANT WYRICK VALERIE 14781 CUMBERLAND HIGHWAY NEWBURG, PA 17240 NO SUCH NUMBERED ADDRESS Sheriff ' s Costs : So answer. : Docketing . 00 Service . 00 Affidavit . 00 ANGEL LILA ENA Surcharge . 00 DANE M ANTHONY, Sheriff . 00 . 00 PHELAN HALLINAN AND SCHMIEG 04/17/2013 Sworn and subscribed to before me j ce 4MON a'EALTH OF PENNSYLVANIA this E ��r�/ day of e NOTARIAL SEAL RICHARD D. McCART Nota�+Public A.D. Chembersburg Bam, Froriklin County My Commis�valo€t Explms Jars, 29, 2015 Notary SHERIFF' S RETURN - NOT FOUND CASE NO: 2013-00082 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK ANGEL 'L LAVIENA Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit : WYRICK STEVEN but was unable to locate Him in his bailiwick. He therefore returns the COMP MORT FORE , NOT FOUND as to the within named DEFENDANT WYRICK STEVEN 14781 CUMBERLAND HIGHWAY NEWBURG, PA 17240 NO SUCH NUMBER; DEF SUPPOSEDLY LIVES IN BIGLERVILLE PA ADAMS COUNTY Sheriff ' s Costs : So answers : Docketing . 00 Service . 00 Affidavit . 00 ANGEL L LAVIENA Surcharge . 00 DANE M ANTHONY, Sheriff . 00 . 00 PHELAN HALLINAN LLP 04/17/2013 Sworn and subscribed to before me COMMONWEALTH OF PENNSYLVANIA this i ��`�day of1441t-� NOTARIAL SEA!- n v RICHARD D. McCARTY, Notary Public Chambarsburg Boro., Frankoin County A.D. My Commimlon Expires,Jan. 29, 2015 Notary SHERIFF' S RETURN - NOT FOUND CASE NO: 2013-00082 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK DANE M ANTHONY Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit : WYRICK STEVEN but was unable to locate Him in his bailiwick. He therefore returns the COMP MORT FORE , NOT FOUND , as to the within named DEFENDANT , , WYRICK STEVEN 5997 FAIRWAY DRIVE WEST FAYETTEVILLE, PA 17222 DEF SUPPOSEDLY LIVES IN BIGLERVILLE PA ADAMS COUNTY Sheriff ' s Costs : So answers : bocketing . 00 ' Service . 00 Affidavit . 00 - Surcharge . 00 DANE M HONY, f8heriff . 00 . 00 PHELAN HALLINAN LLP 04/17/2013 Sworn and subscribed to before me this day of —v COMMONWEALTH OF PENNSYLVANIA D. NOTARIAL SEAL. RICHARD D. WCARTY, Notary Public Chamb®rsburg eoro., Frarklln Couhty My Commission Pros Jan, 29, 2015 Notary ;� - SHERIFF' S RETURN - REGULAR CASE NO: 2013-00082 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN BANK OF AMERICA NA VS STEVEN AND VALERIE WYRICK MICHAEL .LEVEILLE Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMP MORT FORE was served upon WYRICK VALERIE the DEFENDANT at 0930 : 00 Hour, on the 4th day of April 2013 at FRANKLIN COUNTY SHERIFF-' S OFFI CHAMBERSBURG, PA 17201 by handing to VALERIE WYRICK a true and. attested copy of COMP MORT FORE together with and at the same time .directing Her attention to the contents thereof . Sheriff ' s Costs : So Answers : Docketing . 00 Service . 00 MICHAEL LEVEIL E Affidavit . 00 Surcharge . 00 By . 00 Deputy Sheriff . 00 04/17/2013 PHELAN HALLINAN LLP Sworn and Subscribed to before me this / day of COHMONIhIEALTH OF PENfvSYL AN; NOT LRIAL SEAL RICHP.Ro O. F OCAR i Y, P Jot& . Public A.D. Chambersbwg I3oro., I=ra,,.cir, Oouh My Commission Epires !�;i: �? 2015 Notary,/, ,