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HomeMy WebLinkAbout13-1514 KML LAW GROUP, P.C. _ SUITE. 5000 —BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET ` PHILADELPHIA, PA 19106 7 r' 1 (866) 413 -2311 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER j 1 . ' THE COURT OF COMMON PLEAS TO BAC HOME LOANS SERVICING LP, FKA ' COUNTRYQWIDE HOME LOANS SERVICING, LP OF Cumberland COUNTY 7105 Corporate Drive PTX B -209 CIVIL ACTION - LAW Plano, TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs• DAVID W. CROSBY NICOLE BUCKLEY CROSBY a /k/a NICOLE B. CROSBY No. J [[[ Mortgagor(s) and Record Owner(s) CM ACTION: MOR GAGE 5235 Wertzville Road Fo"nDSm Enola, PA 17025 Defendant(s) NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 'PHIS 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 COMMUNITY LEGAL SERVICES, INC. Law Center North Central 3638 North Broad Street Philadelphia, PA 19140 215- 227 -2400 or 215- 981 -3700 PHILADELPHIA BAR ASSOCIATION One Reading Center Philadelphia, PA 19104 215 -238 -6333 AVISO Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notifieacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la cone puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. C 0Lr LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O S1 NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. COMMUNITY LEGAL SERVICES, INC. Law Center North Central 3638 North Broad Street Philadelphia. PA 1.9140 215- 227 -2400 or 215- 981 -3700 PHILADELPHIA BAR ASSOCIATION One Reading Center Philadelphia, PA 19104 215- 238 -6333 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 215 -227- 2400 or 215 -981 -3700 or 215- 238 -6333. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.g_ov_ for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http: / /www.phfa.org /consumers /homeowners /real.a� 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http: / /www.pliiladelphiafed.orL'/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretention�kmllawgroup.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 1 I3704FC. Para information en espanol puede communicarse con Loretta al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYQWIDE HOME LOANS SERVICING, LP, 7105 Corporate Drive, PTX B -209 Plano. TX 75024. 2. The name(s) and address(es) of the Defendant(s) is /are DAVID W. CROSBY, 5235 Wertzville Road, Enola, PA 17025 and NICOLE BUCKLEY CROSBY a /k/a NICOLE B. CROSBY. 5235 Wertzville Road, Enola, PA 17025, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. >. On October 25, 2010 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS., INC., AS NOMINEE FOR VISION MORTGAGE CAPITAL, A DIVISION OF CONTINENTAL BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on November 02, 2010 as Instrument # 201031787. The mortgage has been assigned to: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYQWIDE HOME LOANS SERVICING, LP by assignment of Mortgage recorded on February 07, 2012 as Instrument # 201203707. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2011 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ............................... ............................... ....................$177,589.30 Interest from 09/01/2011 through 12/12/2012 at 4.5000% .................... $10,229.58 Per Diem at $21.83 EscrowAdvance .................................. ............................... ......................$3,452.54 TitleFees ................................................ ............................... .......................$200.00 Property Inspection Fees ............................................ ...................... $90.00_ $191,561.42 7. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance, the combined Act 6/91 notice, has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $191,561.42, together with interest at the rate of $21.83, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. B KML LAW GROU C. Michael McK er Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION hereby states that she is t 15 4,1 4 1 of Bank of America, N.A., successor by merger to BAC Home Loans Servicing L.P., Plaintiff in this matter, that he she 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 hiAer knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. R Date: Name: ric'ff'7i,�1,�,,� Title: 41 13704FC - DAVID W. CROSBY and NICOLE BUCKLEY CROSBY aWa NICOLE B. CROSBY 5235 Wertzville Road Enola, PA 17025 E�hifiitA ALL THAT CERTAIN lot of Found situate in Hampden Township, Cumberland Cau ty, Pennsylvania, bounded and descn'bed as follows: BEGINNING at a point in the center of the public road leading from Wertzville to Enola which point is a corner of Lot No. 3 on the hereinafter mentioned Plan of Lots; thence along said Lot No. 3 South I degree 30 minutes West 365.3 fat to a point (pin) m tine of land, now or forme dy of E.R. Long, thence along land of the latter, North 84 degrees West 100.4 feet to a point (pin) in the line of l and, now or forme dy of Dale W. waggoner; thence along land of said Waggoner, North 1 degree 30 minutes East 366 feet to a point in the center of the said public road leading from Wmtnn& to Enola; thecae along the center of said public road, North 85 degras 11 minutes East 100 feet to a point, the place of Being. BEING all of Lot No. 2 as designated on that certain Plan of Lots adopted by the said Harriet S. Randabaugh on March 3, 1955, said Pisa being esvbearerd of record in the Office of the Recorder of Deeds, m and for said Cumberland County, Pennsylvania in Plan Book No. 7, Page 20. HAVING thereon erected a dwelling known and numbered as 5235 Weetzviille Road. i (.B '`Exhibit has been redacted to remove all personally identifiable information or non-public information HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM Date: 12/06/2012 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT' COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1- 800 - 342 -2397. (Pe with impaired hearing can call (717 ) 780 -1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORI'ANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICATION 013TENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A, REDIMIR SU HIPOTECA. Date: 12/06/2012 HOMEOWNER'S NAME(S): NICOLE B. CROSBY and DAVID W. CROSBY PROPERTY ADDRESS: 5235 Wertzville Road, Enola, PA 17025 LOAN ACCT. NO.: 7043 ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR VISION MORTGAGE CAPITAL, A DIVISION OF CONTINENTAL BANK CURRENT LENDER/SERVICER: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP / BANK OF AMERICA HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR M ORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DAT CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thin (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling_ agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your lender immediately of your intentions. .APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a. complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATIONAS SOON AS POSSIBLE. IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICA TION WITH PHFA WITHIN 30 DA YS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARIL Y PREVENTED FROM STARTING A FORECLOSURE A GAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARYSTAY OF FORECLOSURE." YO U HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS ALA TE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSUREACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFOREA SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED' BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) 3 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 5235 Wertzville Road, Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 10 /01 /2011 thru 12/06/2012 (10 mos. at $1,183.27 /month) $11,832.70 (5 mos. at $1,264.41 /month) $6,322.05 (b) Late charges: $0.00 (c) Other charges; Escrow, Inspec., NSF Checks: Property Inspection Fees — $90.00 (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $18,244.75 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (3 0) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE :LENDER WHICH IS $18,244.75 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check. certified check or money order made payable and sent to: BANK OF AMERICA PO Box 650070 Dallas, TX 75265 -0070 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. 4 OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: BANK OF AMERICA Address: PO Box 650070 Dallas, TX 75265 -0070 Phone Number: 800 - 669 -0102 Fax Number: 972 -526 -6235 Contact Person: General Collections Email Address: DG Customer Support(;bankofamerica.com EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who "Till assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: 5 TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. H FA Comprehensive Housing N N y VA' A �; 'Jt-,NNc : � ,xw A -IE `y Counseling Agencies Agencias de Consejo al Cliente para Vivienda Cumberland County *CCCS of Western PA - York 55 Clover Hill Road Dallastown PA 17313 888.511.2227 / 888.511.2227 www.cccspa.org Community Action Commission - Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 www.cactricounty.org Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing & Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle PA 17013 866.683.5907 / 717.249.0789 w ww.cchra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www. pa htm Pennsylvania Interfaith Community Programs, Inc. 40 E High S* Gettysburg PA 17325 717.334 1518 www.adamscha. NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated: 4/30/2012 9:03:04 AM Page 1 of 1 E.Xhibit C Recording Requested By: Bank of America Prepared By: Diana DeAvila 888 -603 -9011 450 E. Boundary St. Chapin, SC 29036 When recorded mail to: CoreLogic 450 E. Boundary St. Attn: Release Dept. Chapin, SC 29036 I � �� NIN IIi� III III III IIIN � nll DoclD# 13822364704310930 'Fax 1D: 10-14- 0840-006 Property Address: 5235 Wertzville Rd Enola, PA 17025 -1260 Property Location: Township of HAMPDEN PAO-AM 16892305 1/31/2012 This space for Recorders use MIN #: 1009555- 0000002184 -2 MFRS Phone #: 888 - 679 -6377 ASSIGNMENT OF MORTGAGE For Value Received, the undersigned holder of a Mortgage (herein "Assignor ") whose address is 1901 E Voorhees Street, Suite C, Danville, IL 61834 does hereby grant, sell, assign, transfer and convey unto BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP, FKA COUNTRYWIDE HOME LOANS SERVICING LP whose address is 400 NATIONAL WAY, SIMI VALLEY, CA 93065 all beneficial interest under that certain Mortgage described below together with the note(s) and obligations therein described and the money due and to become due thereon with interest and all rights accrued or to accrue under said Mortgage. Original Lender: VISION MORTGAGE CAPITAL, A DIVISION OF CONTINENTAL BANK Mortgagor(s): DAVID W CROSBY AND NICOLE B CROSBY, HUSBAND AND WIFE Date of Mortgage: 10/25/2010 Original Loan Amount: $180,000.00 Recorded in Cumberland County, PA on: 11/212010, book N /A, page N/A and instrument number 201031.787 This Mortgage has not been assigned unless otherwise stated below: IN WITIVESS WHEREOF, the undersigned has caused this Assignment of Mortgage to be executed on MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. B: Y al� lCe Al HOWS ASSI stan t State of California County of Ventura On FEB 41 2012 before me, Georges Rnedo Notary Public, personally appeared Alice Row who proved to me on the basis of satisfactory evidence to be the persory(s'f whose name(arts/pd"subscribed to the with instrument and acknowledged to me that X9she /tl>�xecuted the same in /her /thtsir authorized capacity (rand that byXsrher/0if5r signatureWon the instrument the person(W, or the entity , upon behalf of which the person(<acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. GEORGE A. PINLDO WITNESS my hand and official sea). ' COMM. #1 853836 NOTARY PUBLIC - CALIFORNIA ORNIA , A LOS ANGELES COUNTY •e Mw Comm. Exares June 14, 2013 Notary Public: George - Pinedo (Seal) My Commission Expires: f use 1 204 I hereby certify that the address of the within named assignee is: 400 NATIONAL WAY, 5I VALLEY, CA 93065 Signature DOCID4 13822364704310930 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 COUNTRYQWIDE HOME LOANS SERVICING, LP Case No. Plaintiff vs. �11�6 rr DAVID W. CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY - Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in 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 file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respect ll submitted: (Signature of Cou 1 for Plaintiff) 3/19/2013 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Dockct BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: NNIHN Borrower narne(s): Property Address: City: State:_ Zip: Is the property for sale? Yes ] No [ j Listing date: P ice $ Realtor Name: Realtor Phone: Borrower Occupied? Yes i I...o - -- Mailing Address (if different): City: State:. _Zip Phone Numbers: Homer Office: Cell: Other: of people in household: � How long? EXHI 'v Ming Address: City: State: Zip: Phone Number,: Home: Office: Cell. Other: Email; - ��- - -- of people in household: How long? First Mortgage Lender: Type of Doan: _ - Loan Number: Date You Closed Your Loan: Second Mortgage Lender: �- Type of Loan: 4 Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance; Date of Last Payment: — — P ry Reason for Default: Is the loan in Bankruptcy? Yes E] No if yes, provide names, location of Court, case number & attorney: Assets A ruoul31 Owed Value: i�ome Other Real Estate: $ -- Retirement Funds; $ — investments, $ � Checking: $ µ $ savings: Other: A utomobile 41: Model - _., _ Year: Amount owed: V alue: - - -- Automobile #2 Amount owed: Value: Other transPortation (automobiles boats motorcycles Model: Year. Amount owed: Value Monthly Income Narne of Employers: 3. L. Additional income Description (not wages): monthly amount: 2- monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) - �-� - --� 'EXPENSE AMOUNT EXPENSE AMOUN Mortgage Food �. M�g�C Utilities _- - - ---� Car Pa , cnH _- _Condo/Nei Fees Auto Insura Mod. not covered _ Auto fuel/repairs 4Cabl e r ro . a meet i Install. Loan Paymorit _ TV Child Su rt/Alim• ndin Meg Day /Child Care/Toit, r Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes No E I`' yes, please provide the following information: Counseling Agency: Counselor: Phone (Office)" Fax: �� Have you mace application for Homeowners Emergency Mortgage Assistance :Program (HEMAP) assistance? Yes ❑ N 0 7 if ves, 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 �] f yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your Iender or lender's loan servicing company: Lender's Contact (Name): Phone: _ - -- Servicing Company (game):_ Contact: Phone: Un'Ve, - , 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, VVVe understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Date �^ Co- Borrower Signature Date � Please forward this document along with the following information to lender and lender's counsel: 1 N Proof of income I Past 2 bank statements N' Proof of any expected income for the last 45 days 1r' Copy of a current utility bill 1 �1 Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson F!LED-OF ff lu,° Sheriff " THE PPOT'HC?' OT, '` L�I[1Nbc�"fi�b Jody S Smith Chief Deputy ZQl3 APR _2 . �'" Y Richard W Stewart - OU _; AND Y Solicitor OFFICE OF THE SHERIFF i irM IA Bank of America, N.A. as successor by merger to BAC Home Loans Case Number vs. David W Crosby(et al.) 2013-1514 SHERIFF'S RETURN OF SERVICE 03/25/2013 08:33 PM-Deputy Shawn Gutshall, being duly sworn according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be David Crosby-Husband ,who accepted as"Adult Person in Charge"for Nicole B Crosby at 5235 Wertzville Rd, Hampden Tow hip, Enola, PA 17025. TSHALL, DEPUTY 03/25/2013 08:33 PM-Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: David W Crosby at 5235 Wertzville Road, Hampden Township, Enola, PA 17025. STAM&JSWSHALL, DEPIL SHERIFF COST: $59.00 SO ANSWERS, 6z 2 r March 26, 2013 RON R ANDERSON, SHERIFF tc)CountySuite Sheriff,Teleosoft,Inc. • KML LAW GROUP, P.C. _ Suite 5000—BNY Mellon Independence Center ?n j!1 FEB ! 701 Market Street 8 ff j 1: 5 1} Philadelphia,PA 19106 CUMBERL AND � 215-627-1322 PENNSYLVANIA Attorney for Plaintiff BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP,FKA COUNTRYQWIDE 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 DAVID W.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY (Mortgagor(s)and Record Owner(s)) No. 13-1514 5235 Wertzville Road Enola,PA 17025 Defendant(s) PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P.2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of GREEN TREE SERVICING LLC for Voluntary Substitution under Pa.R.C.P. 2352 due to Assignment of Mortgage and attached Statement of Material Facts in Support of Voluntary Substitution,Verification,Certification of Service. The address for the new Plaintiff is 7360 S.Kyrene Road,Tempe,AZ 85283. )( i , By: / t. KML A' GROU', .C. Michael McKeever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Attorneys for Plaintiff atht awk, KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street - Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP,FKA IN THE COURT OF COMMON PLEAS COUNTRYQWIDE HOME LOANS SERVICING,LP 7105 Corporate Drive OF Cumberland COUNTY PTX B-209 Plano,TX 75024 CIVIL ACTION—LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE DAVID W.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY No. 13-1514 (Mortgagor(s)and Record Owner(s)) 5235 Wertzville Road Enola,PA 17025 Defendant(s) STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P.2352 GREEN TREE SERVICING LLC,by counsel,hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned Action of Mortgage Foreclosure relates to a property located at 5235 Wertzville Road Enola,PA 17025("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Instrument#201031787 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP,FKA COUNTRYQWIDE HOME LOANS SERVICING,LP. 4. GREEN TREE SERVICING LLC is the successor in interest to the Plaintiff by an assignment of mortgage recorded in land records of Cumberland County on July 8,2013 in Instrument Number 201322519 and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. Respectfully submitted By: KNELL G tU' Michael c Bever Pa.I► 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 -Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Attorneys for Plaintiff KML_LAW GROUP,P.C. SUITE 5000—BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 215-627-1322 ATTORNEY FOR PLAINTIFF BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING LP,FKA COUNTRYQWIDE HOME LOANS IN THE COURT OF COMMON PLEAS SERVICING,LP OF Cumberland COUNTY 7105 Corporate Drive PTX B-209 CIVIL ACTION-LAW Plano,TX 75024 Plaintiff ACTION OF MORTGAGE vs. FORECLOSURE DAVID W.CROSBY Term NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY No. 13-1514 (Mortgagor(s) and Record Owner(s)) 5235 Wertzville Road Enola,PA 17025 Defendant(s) CERTIFICATE OF SERVICE Barbara L. Hand, hereby certifies that she did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant,by first class mail, postage pre-paid, on 1-29-I t DAVID W. CROSBY 5235 Wertzville Road • Enola, PA 17025 NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY 5235 Wertzville Road Enola, PA 17025 Jo- IP KML Law Group,P.C. Barbara L.Hand,Legal Assistant bhand@lcmllawgroup.com 215-825-6320(Direct Phone). In the Court of Common Pleas of Cumberland County GREEN TREE SERVICING LLC =' 7360 S. Kyrene Road C-) .-A r, Tempe,AZ 85283 Plaintiff No. 13-1514'n t t vs. DAVID W.CROSBY ,t" NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY (Mortgagor(s)and Record Owner(s)) 5235 Wertzville Road Enola,PA 17025 "G. 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 DAVID W.CROSBY and NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY by default for want of an Answer. Assess damages as follows: $200,446.23 Debt Interest from 1/24/2014 to Date of Sale per diem at$21.83 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 th party against whom judgment is to be entered and to his attorney of record,if any,after the default oc urr d nd a least to days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P. 237.1 i By: t ` KML LAIK G ,PJY Michael McK r Pa.ID 561 _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 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff AND NOW T:t b , ( F I Judg nt is a in favor of GREEN TREE SERVICING LLC and against DAVID W.CROSBY and NICOLE B KLEY OSB a NICO CROSBY by default for want of an Answer and damages assessed in the sum of$20 6.23 p th ove certifi Prothonotary Rule of Civil Procedure No. 236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW GREEN TREE SERVICING LLC 7360 S. Kyrene Road Tempe,AZ 85283 Plaintiff No. 13-1514 VS. DAVID W.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY (Mortgagors and Record Owner(s)) 5235 Wertzville Road Enola,PA 17025 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 of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary &A0 By: � r 4,3tr Deputy��>� If you have any questions concerning the above,please contact: KML Law Group, P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 113704FC 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: November 15,2013 TO: DAVID W.CROSBY CROSBY,DAVID W. 5235 Wertzville Road Enola,PA 17025 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas IIOME LOANS SERVICING LP,FKA COUNTRYQWIDE IIOME of Cumberland County LOANS SERVICING,LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Plano,TX 75024 Plaintiff Action of vs- Mortgage Foreclosure DAVID W.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY No. 13-1514 (Mortgagor(s)and Record Owner(s)) 5235 Wertzville Road Enola,PA 17025 Defendant(s) TO: DAVID W.CROSBY 5235 Wcrtzvillc Road Enola,PA 17025 IMPORTANT N911CR YOU ARE IN DEFAULT 13L)CAUSF YOU HAVE FAMED TO ENTER A VM TEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TILL'COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNIaiSS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A IIIDGMENT MAY BE ENTERED AGABJSr YOU WITHOUT A HFARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TIES PAPER 10 YOUR fAWYF1R AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTE.BELOW. TIES 01TICE CAN PROVIDF,YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AIFORC)TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE-TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER I.EGAL SFR VICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE COMMUNI'fYLEGAL SERVICES,INC. Law Cerder North Central 3638 North Broad Street Philadelphia,PA 19140 215-227-2400 or 215-981-37(X) PHITADELPHIA BAR ASSOCIATION One Reading Center Philadelphia,PA 19104 215-238-6333 KML LAW CR ,,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.11)78020 Kristim Murtha Pa.ED 61858 David Fein Pa.ID 82628 '17howas Pulen Pa-ID 27615 Jill P.Jenkins Pa.10306M Alyk I.OBazian Pa.ID 312912 Salvatore Filippelin Pa-ID 313897 _Michael J.Coskey Pa ID 311835 215-627-1322 Aiturneys ror Plaintiff 113704FC 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: November 15,2013 TO: NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY CROSBY,NICOLE BUCKLEY a/k/a NICOLE B.CROSBY 5235 Wertzville Road Enola,PA 17025 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas HOME LOANS SERVICING LP,FKA COUNTRYQWIDE 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 DAVID W.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY No. 13-1514 (Mortgagor(s)and Record Owner(s)) 5235 Wertzville Road Enola,PA 17025 Defendant(s) T0: NICOLE BUCKLEY CROSBY a/Wa NICOLE B.CROSBY 5235 Wertzville Road E'nota,PA 17025 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO TIM CLAIMS SLI'I•DRT1I AGAINST YOU- UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DAJF OF'11.0 NOTICE,A JUDGMENT MAY BE F.NIF.RFJ)AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO"1'0 OR TL:LEPHONL THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT AIRING A IAWYJIL IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE.TO PROVIDE YOU W fn t INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COMMUNITY LEGAL SERVICES,INC. Law Center North Central 3638 NoitthBroad Street PUadelplda,PA 19140 215-227-2400 or 215-981-3700 PHILADELPHIA BAR ASSOCIATION One Reading Cenlcr Philadelphia,PA 19104 215-238-6333 By: KML LAW GROOk,P.C. _Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Krisfiaa Murtha Pa.11)61858 _David Fein Pa.ID 82628 Z o�aas Puled Pa.ID 27615 l P.Jenkins Pa.11)306588 yk L.Oflazian Pa.ID 312912 Salvatore Fitippello Pa.ID 313897 _Mirhael,I.Ceskey Pa In 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA GREEN TREE SERVICING LLC Plaintiff vs. DAVID W.CROSBY NO. 13-1514 NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): DAVID W. CROSBY, has a last known residence of 5235 Wertzville Road, Enola, PA 17025. The following information was used to search the DMDC (check all that apply): • 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 re ating to unswom falsification to autho ti s. 1 I Date l 2 I By: KML LAW G O .C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa.ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Jan-23-2014 11:46:59 AM SCRA 3.0 Status Repott Pursuant to Servicemembe s Civil Relief Act Last Name: CROSBY First Name: DAVID Middle Name: W. Active Duty Status As Of: Jan-23-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty.Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-.Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA - No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. iA 41a, fl- 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.htmi. 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 maybe 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: U64A356F40F9TB0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA GREEN TREE SERVICING LLC Plaintiff vs. DAVID W.CROSBY NO. 13-1514 NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appi/scra/scraHome.do) for the following individual(s): NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY, has a last known residence of 5235 Wertzville Road, Enola, PA 17025. The following information was used to search the DMDC(check all that apply): • 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 rel ting to unsworn falsification to authoriti s1. e ) Date By: KML LAW GROUPL C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 gill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Jan-23-2014 11:49:18 AM SCRA 3.0 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: CROSBY First Name: NICOLE Middle Name: B. Active Duty Status As Of: Jan-23-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component - NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Leif Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date " l Status Service Component NA NA - No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HislHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date'. Order Notification End Date Status Service Component' NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,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. y6iA k fit- jmhi_A��_ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mi1/faq/pis/PC09SLDR.htmi. 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: T6WD757FUOF9Y00 Department of Defense Manpower Data Center Results as of:Jan-23-2014 11:49:44 AM SCRA 3.0 Status Rtpo rt Pursuant to Smicemembers Civil Relief Act Last Name: CROSBY First Name: NICOLE Middle Name: BUCKLEY Active Duty Status As Of: Jan-23-2014 On Active Duty On Active Duty Status Date =Active Duty Start Date Active Duty End Date Status Service Component' NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component< NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HistHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,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. iA 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.htmi. 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: 66JDV5FFTOF9F50 KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff GREEN TREE SERVICING LLC 7360 S. Kyrene Road IN THE COURT OF COMMON PLEAS Tempe,AZ 85283 Plaintiff of Cumberland County vs. DAVID W.CROSBY CIVIL ACTION LAW NICOLE BUCKLEY CROSBY aWa NICOLE B.CROSBY (Mortgagor(s)and Record owner(s)) 5235 Wertzville Road ACTION OF MORTGAGE FORECLOSURE Enola,PA 17025 Defendant(s) No. 13-1514 ORDER FOR JUDGMENT Please enter Judgment in favor of GREEN TREE SERVICING LLC,and against DAV W.CROSBY and NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY for failure to e a nsw in the ove action within(20) days from the date of service of the Complaint,in the sum of$200,446.23. By: KML LAW G UP, .0 Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is GREEN TREE SERVICING LLC 7360 S. Kyrene Road Tempe,AZ 85283 and tha the name(s)and last known address(es) of the Defendant(s)is/are DAVID W.CROSBY,5235 Wertzville Roa Enola,PA 7025 a NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY,5235 Wertzville Road Enola, 70 5. By: KML R P Michael Keever Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I. Goldman Pa. 205047 Jill P.Jenkins Pa. ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $177,589.30 Interest from 09/01/2011 through $19,114.39 01/23/2014 Escrow Advance $3,452.54 Title Fees $200.00 Property Inspection Fees $90.00 $200,446 i By: KML LAW GRO ,P.C. Michael McKeever Pa.ID 5 129 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 :)�ill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff AND NOW,this day of 2014 damages are assessed as above. Pro Prothy 13-1514/113704FC i PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff GREEN TREE SERVICING LLC 7360 S. Kyrene Road Tempe,AZ 85283 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County DAVID W.CROSBY CIVIL ACTION-LAW NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 5235 Wertzville Road _ Enola,PA 17025 Defendant(s) No. 13-1514 5€=n r c) b ,� i_ f. PRAECIPE FOR WRIT OF EXECUTION-t c r TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $200,446.23 Interest from 1/24/2014 to Date of Sale per diem at $21.83 (Costs to be added) c By: KML LAW OUP,P. Michael McKeever Pa.ID 56129 �� JN n�� Jay E. Kivitz Pa.ID 26769 Sol,OO l�`.7 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 L t ti Thomas Puleo Pa.ID 27615 t� Joshua I.Goldman Pa. 205047 gill P.Jenkins Pa.ID 306588 Q.� Andrew F.Gornall Pa.ID 92382 1 tto s for Plaintiff 12 W 361 11 `�. Vv �;e,u, r KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 t 1 J 7i 215-627-1322 "'1 FEB � Attorney for Plaintiff + F GREEN TREE SERVICING LLC PEN.NS Y�V ,�A��d T,1 7360 S. Kyrene Road I L4)URT OF COMMON PLEAS Tempe, AZ 85283 Plaintiff of Cumberland County vs. DAVID W.CROSBY CIVIL ACTION-LAW NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY (Mortgagor(s) and Record Owner(s)) 5235 Wertzville Road ACTION OF MORTGAGE FORECLOSURE Enola,PA 17025 Defendant(s) No. 13-1514 AFFIDAVIT PURSUANT TO RULE 3129 GREEN TREE SERVICING LLC,Plaintiff in the above action,by counsel, 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: 5235 Wertzville Road Enola,PA 17025 1.Name and address of Owner(s)or Reputed Owner(s): DAVID W.CROSBY 5235 Wertzville Road Enola,PA 17025 NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY 5235 Wertzville Road Enola,PA 17025 2.Name and address of Defendant(s)in the judgment: DAVID W.CROSBY 5235 Wertzville Road Enola,PA 17025 NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY 5235 Wertzville Road Enola,PA 17025 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 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 5235 Wertzville Road Enola,PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statemen s herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to au orities. r DATED: s By: KML LAW P, . Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 ::40 1.L Goldman Pa.205047 ill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa. ID 92382 Attorneys for Plaintiff 13-1514 KML Law Group,P.C. Suite 5000-BNY Independence Center ' � =�s�.iyT( 701 Market Street 4 0/N FEQ Philadelphia,PA 19106 ' ; (215)627-1322 n Attorney for Plaintiff E tt L A I'D Co i a GREEN TREE SERVICING LLC 7360 S. Kyrene Road IN THE COURT OF COMMON PLEAS Tempe,AZ 85283 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW DAVID W.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY ACTION OF MORTGAGE Mortgagor(s)and Record Owner(s) FORECLOSURE 5235 Wertzville Road Enola,PA 17025 Docket No. 13-1514 Defendants 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: CROSBY,DAVID W. DAVID W. CROSBY 5235 Wertzville Road Enola,PA 17025 Your house at 5235 Wertzville Road,Enola,PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd Fl Courthouse to enforce the court judgment of$200,446.23 obtained by GREEN TREE SERVICING LLC 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: 1. The sale will be cancelled if you pay to GREEN TREE SERVICING LLC,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. 13-1514 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 Cumberland County at 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 Cumberland County at 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: http://www.philadelphiafed.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. LEGAL SERVICES INC 401 East Louther Street Carlisle,PA 17013 717-243-9400 13-1514 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: 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) 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 113704FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-1514 KML Law Group,P.C. _ i r i r Suite 5000-BNY Independence Center 701 Market Philadelphia,PA 19106 ' ?111: u u*3 �� (215)627-1322 �P�dU ������,,i Attorney for Plaintiff PE�Ejs r-s GREEN TREE SERVICING LLC 7360 S. Kyrene Road IN THE COURT OF COMMON PLEAS Tempe ,AZ 85283 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW DAVID W.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B.CROSBY ACTION OF MORTGAGE Mortgagor(s) and Record Owner(s) FORECLOSURE 5235 Wertzville Road Enola,PA 17025 Docket No. 13-1514 Defendants 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: CROSBY,NICOLE BUCKLEY a/k/a NICOLE B.CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY 5235 Wertzville Road Enola, PA 17025 Your house at 5235 Wertzville Road,Enola,PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday,June 04,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd Fl Courthouse to enforce the court judgment of$200,446.23 obtained by GREEN TREE SERVICING LLC 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: 1. The sale will be cancelled if you pay to GREEN TREE SERVICING LLC,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. 13-1514 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 Cumberland County at 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 Cumberland County at 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: http://www.philadelphiafed.oriz/foreclosur 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. LEGAL SERVICES INC 401 East Louther Street Carlisle,PA 17013 717-243-9400 13-1514 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: 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. og_v for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.or.g/consumers/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 113704FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KML Law Group,P.C. L: 4 Suite 5000—BNY Independence Center C i�J'�i;TA 701 Market Street FEB 18 Philadelphia,PA 19106a J 7 215-627-1322 DUMB ^ LAND COUNTY Attorney for Plaintiff PEN NS yj VA GREEN TREE SERVICING LLC 7360 S. Kyrene Road Tempe ,AZ 85283 IN THE COURT OF Plaintiff COMMON PLEAS vs. of Cumberland County DAVID W. CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY CIVIL ACTION-LAW Mortgagor(s) and Record Owner(s) 5235 Wertzville Road ACTION OF Enola,PA 17025 MORTGAGE FORECLOSURE Defendant(s) NO. 13-1514 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff,by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. r � i r By: KML LA P, Michael McKe er Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa. 205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-1514 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREEN TREE SERVICING LLC Plaintiff(s) From DAVID W.CROSBY,NICOLE BUCKLEY CROSBY A/K/A NICOLE B.CROSBY (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: $200,446.23 L.L.: $.50 Interest FROM 1/24/2014 TO DATE OF SALE PER DIEM AT$21.83 Atty's Comm: Due Prothy: $2.25 Atty Paid: $217.25 Other Costs: Plaintiff Paid: Date: 2/18/14 David D. Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name:JILL P.JENKINS,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No.306588 KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff 1 OTHO UTAr :4 NY 21 Aft IB, 02 CUMBERLAND PCU,,.,. PtNNS YLy4 PAR IN THE COURT OF COMMON PLEAS GREEN TREE SERVICING LLC 7360 S. Kyrene Road, Tempe , AZ 85283 Plaintiff vs. 113704FC CF: 03/22/2013 SD: 06/04/2014 $200,446.23 DAVID W. CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY Mortgagor(s) and Record Owner(s) 5235 Wertzville Road Enola, PA 17025 Defendant(s) of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 13-1514 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: Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by KML Law Group, P.C. (copy of 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 Defendarit(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. (copy of 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, eronica Cosme Legal Assistant IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING LLC; et seq. Plaintiff (Petitioner) V. DAVID W. CROSBY; et al. Defendant (Respondeat) CASE and/or DOCKET No.: 13-1514 Sheriff's Sale Date: 6/4/14 AFFIDAVIT OF SERVICE II Complaint (1Summous J1J Other: Notice of Sale I [IYTI-f (y�� Q, . 'J42�l'r� certify that 1 am eighteen years of age or older and that 1 am of a party to the action nor an employee nor relatiyye ofIparty, and that I Attempted to serve NICOLE BUCKLEY CROSBY A/K/A NICOLE B. CROSBY the above process on the f day of M 0-1e.e{ , 20 I `tom at "% ,(� o'clock, M -M, et 5020 WOOLRIDGE ROAD MOSELEY, VA 23120 Manner of Service: By handing a copy to: Q An officer, partner, trustee, or registered agent of the Defendant organization who is not a plaintiff in the action* The manager, clerk, or other person for the time being in charge of a regular place of business or activity of the Defendant organization who is not a plaintiff in the action * ( An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action * By handing a copy to the Defendant(s) By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found • By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which he/she resides • By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s) agent or to the person for the time being in charge thereof * By posting a copy of the original process on the most public part of the property pursuant to an order of court * Nance: f V f Relationship/Title/Position: Ir Remarks: Description: Approximate Age Height Defendant was not served because: '" ' Moved Weight /7 5 Race (,J Sex Hair $Y7 nknown t' No Answer 13 Vacant Other: Service was attempted on the following dates/times: 1) Commonwealth/State of V (�--1( r'/I County o Andra 2) q24i 1 547o 3) SS: Before me, the undersigned notary public, this day, personally, appeared ) ((ID ('l l.( �_ 6 (¢Q Z j ' 1e me known, who being duly swam according to law, deposes the following: I hereby swea s set forth int regoing Affidavit of Scrvicceec true and correct. gnAO®BPIF �on\��f ignature of AfTiant) File Number:113704FC Case ID #:3923085 Subscr' ed and swo�rn""to before me s day of ,4y'/Zc L. , 20 Notary P •tic Commonwealt of Virginia Michael S. Beasley My Commission Expires 07/31/2015 .-.__ u-reenn.n 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 Citibank N.A. 701 East 60th Street N. Sioux Falls, SD 57117 Citibank N.A. c/o Brittany Jan Suttell, Esquire 1060 Andrew Drive, Suite 170 West Chester, PA 19380 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 5235 Wertzville Road Enola, PA 17025 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: May 19, 2014 KML Law Group, P.C. BY: Veronica Cosme Legal Assistant Name and Address of Sender IOLDBECK(If iUITE 5000 01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service: ❑Certified ❑Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street, City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RRA Fee 1. PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 TENANTS/OCCUPANTS 5235 Wertzville Road 2. Harrisburg, HA 1 /1Ub-26/5 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Enola, HA 1 /U25 .sP°P Si S•0:a. PITNEY5 _��V 01.38° `''�f :1447+ 02 1M i1�1 • 0004285957 MAR06 2014 ���i'c�• : MAILED FROM ZIP CODE 19106 3. Carlisle, PA 17013 4. Y ;, 5. . • 6. 7. 8. Total Number of/Pieces, ., Listed by Send ', �`-_.. � To al Number of Piecc Recived at Post OfY ei �] Postmaste , er (N e of receiving employee) See Privacy Act Statement on Reverse PS Form 3877, February%2002 (Page 1 of 2) Complete by Typewriter, Ink, or¢-dII Point Pen 113704FC Cumberland County Sale Date: 06/04/2014 DAVID W. CROSBY & NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY Name and Address of Sender 'ML LAW GROUP, P.C. QUITE 5000 '01 MARKET STREET 'HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑Certified ❑Recorded Delivery (International) ❑ COD ❑ Registered ❑ Delivery Confirmation ❑ Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here (If issued as a certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt Article Number Addressee (Name, Street City, State, & ZIP Code) Postage Fee Handling Charge Actual Value if Registered Insured Value Due Sender if COD DC Fee SC Fee SH Fee RD Fee RR Fee 1. Citibank N.A. 701 East 60th Street N. Sioux Falls, SD 57117 2. rJ. Citibank N.A. c/o Brittany Jan Suttell, Esquire 1060 Andrew Drive, Suite 170';;t West Chester, PA 19380 !„ `�.:. --y. r' ft s 't `•v. , ;n;•,! + 3.rt f �7 . m •VA. sd'1 ,cs .sem' :.---: 1/$.-z y '' t �tED ST ` o o J -f °o`.3 t:\ A , �a 7sTD� , y /)ai 0 6-> 9,3 IV do ��`� -13(10:4- 3p -� .: s....:.: _.�� 5. �<0 CP Bo OG 6 D ems\ s 6. 7. 8. Total Number of Pieces Listed by Sender Total Number of ieces Received at Po ffic Postmaster, Per ( of ceiving employee) See Privacy Act Statement on Reverse PS Form 3877, February 2002 (Page 1 of 2) ' C 113704FC Cumberland County Sale Date: 06/04/2014 ompiete by Typewriter, Ink, or Ball Point Pen DAVID W. CROSBY & NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff GREEN TREE SERVICING LLC 7360 S. Kyrene Road Tempe , AZ 85283 Plaintiff vs. DAVID W. CROSBY NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY Mortgagor(s) and Record Owner(s) 5235 Wertzville Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13-1514 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 GREEN TREE SERVICING LLC, 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: 5235 Wertzville Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): DAVID W. CROSBY 5235 Wertzville Road Enola, PA 17025 NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY 5235 Wertzville Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: DAVID W. CROSBY 5235 Wertzville Road Enola, PA 17025 NICOLE BUCKLEY CROSBY a/k/a NICOLE B. CROSBY 5235 Wertzville Road Enola, PA 17025 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA GREEN TREE SERVICING LLC; et seq. Plaintiff (Petitioner) V. DAVID W. CROSBY; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13-1514 Sheriffs Sale Date: 6/4/14 AFFIDAVIT OF SERVICE (]Complaint P1 Summons [l Other: Notice of Sale i 7yTopr-lt( Q. IS/412 T rJ certify that 1 am eighteen years of age or older and that I am of a party to the action nor an employee nor relat,iyye of oarty and that 1 Attempted to serve NICOLE BUCKLEY CROSBY AICA NICOLE B. CROSBY the above process on the 1 day of /L( f4'f�l! {a` 20 j at "'"/ :) o'clock, PrM, at 5020 WOOLRIDGE ROAD MOSELEY, VA 23120 Manner of Service: By handing a copy to: [ An officer, partner, trustee, or registered agent of the Defendant organization who is not a plaintiff in the action* The manager, clerk, or other person for the time being in charge of a regular place of business or activity of the Defendant organization who is not a plaintiff in the action * An agent authorized by the Defendant organization in writing to receive service of process for it who is not a plaintiff in the action * By handing a copy to the Defendant(s) By handing a copy at the residence of the Defendant(s) to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found * E By handing a copy at the residence of the Defendant(s) to the clerk or manager of the hotel, inn, apartment house or other place of lodging at which he/she resides * n By handing a copy at the office or usual place of business of the Defendant(s) to the Defendant's(s') agent or to the person for the time being in charge thereof* C] 13y posting a copy of the original process on the most public part of the property pursuant to an order of court *Nance: it VI to t' 1J l2q.v Relationshipfritle/Position: Ar Remarks: tt Description: Approximate Ages Heights Weight t7 5 Race (,t) Sex Hair Sr? ..- Defendant Defendant was not served because:' Moved EUnknown ONo Answer j Vacant El Other: Service was attempted on the following dates/times: 1) 1 q- 8•%oC Commonwealth/State of VI eon, ( TV/ 4 - County o .gra 2) qa—qf /012-5.57v1 ) SS: ) 3) Before me, the undersigned notary public, this day, personally, appeared l t HO (Nit( eS vs y¢ -e— T7y ' to me known, who being duly swom according to law, tleposes the following: ,'mer or No agoing Affidavit of Service are true and corneal. tiro (Signature of Affiant) File Number:l 13704FC Case ID #1:3923085 Subscribed and swo�rn""to before me day of ify'%Gt L , 20 411) Notary P •tic Commonwealt of Virginia Michael S. Beasley My Commission Expires 07/31/2015 .. /1 . A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff {,, (}tai 4,6A t5 Eii +'�almb,r' �',`' i fi Pi O 1 HO? 3 TAR) Jody S Smith ' Chief Deputy 2 PI JUL 21 AM S; 149 Richard W Stewart Solicitor CUMBERLAND CGUNTY ;,�� � � °' PENNSYLVANIA Green Tree Servicing, LLC Case Number vs. David W Crosby(et al.) 2013-1514 SHERIFF'S RETURN OF SERVICE 03/27/2014 03:00 PM - Deputy William Cline, 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 5235 Wertzville Road, Hampden Twp, Enola, PA 17025, Cumberland County. 06/04/2014 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Sqaure, Carlisle, PA 17013 on June 04, 2014 at 10:00 a.m. He sold the same for the sum of$35,000.000 to Attorney Jill P. Jenkins, on behalf of, Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $2,140.58 SO ANSWERS, July 16, 2014 RONR ANDERSON, SHERIFF / �Zt 4 973-6 S 3n g 7'/3 ti D D tV ,...__`,riff. e€eosoft arc On February 20, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, Known and numbered as 5235 Wertzville Road, c• Enola, as Exhibit "A" filed with this writ and by This Reference incorporated herein. CD css, LL'LLJDate: February 20, 2014 By: cs Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-1514 Civil SOLD as the property of David W. Crosby and Nicole Buckley Crosby Green Tree Servicing, LLC a/k/a Nicole B. Crosby, husband vs. and wife. David W. Crosby TAX PARCEL# 10-14-0840-006. Nicole B. Crosby BEING the same premises which Jeffrey E. Urey and Janice A. Urey, Atty.: Jill P.Jenkins husband and wife by deed dated ALL THAT CERTAIN lot of ground 8/17/06 and recorded 8/31/2006 situate in Hampden Township, in Cumberland County in Deed Book Cumberland County, Pennsylvania, Volume 276 at Page 2059 granted bounded and described as follows: and conveyed unto David W. Crosby BEGINNING at a point in the cen- and Nicole Buckley Crosby a/k/a ter of the public road leading from Nicole B. Crosby,husband and wife. Wertzville to Enola which point is a comer of Lot NO.3 on the hereinafter mentioned Plan of Lots;thence along said Lot NO.3 South 1 degree 30 minutes West 365.3 feet to a point (pin) in line of land,now or formerly of E.R.Long;thence along land of the latter, North 84 degrees West 100.4 feet to a point(pin)in the line of land, now or formerly of Dale W.Waggoner; thence along land of said Waggoner, North 1 degree 30 minutes East 366 feet to a point in the center of the said public road leading from Wertzville to Enola; thence along the center of said public road, North 85 degrees 11 minutes East 100 feet to a point, the place of Beginning. BEING all of Lot NO.2 as desig- nated on that certain Plan of Lots adopted by the said Harriet S.Rauda- baugh on March 3, 1955, said Plan being entered of record in the Office of the Recorder of Deeds,in and for said Cumberland County,Pennsylvania in Plan Book NO.7, Page 20. HAVING thereon erected a dwell- ing known and numbered as 5235 Wertzville Road. IMPROVEMENTS consist of a residential dwelling. MUNICPALITY Hampden Town- ship. BEING PREMISES: 5235 Wertz- ville Road Enola PA 17025. 45 • PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 2 day of May, 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO.,CUMBERLAND CNTY My Commission Expires Apr 28,2018 The Patriot-News Co. 2020 Technology Pkwy e atriotNews 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. --- - - t 2013-1514 ChM Term This ad ran on the date(s)shown below: Green Tree Servicing,LLC 04/13/14 VS . 04/20/14 Dav1 --- 04/27/14 E "",,,O, mi .Swao n to .nd subscribed before me� j •ay of May, 201, A.D. i by the said Harriet S. Raudabaugh on March 3, 195`5, said Plan being ,1,11,4kl , '_ • •! .. entered of record in the Office of the •IiC , Recorder of heeds, in and for said Cumberland County,Pennsylvania in t,,=1\1( ll� Plan Book NO.7,Page 20. +2 3 HAVING thereon erected a dwelling 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 Sheriffs Deed in which Federal National Mortgage Assoc. is the grantee the same having been sold to said grantee on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 18th day of February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 1514, at the suit of Green Tree Servicing LLC against David W. Crosby&Nicole Buckley Crosby a/k/a Nicole B. Crosby is duly recorded as Instrument Number 201415706. IN TESTIMONY WHEREOF, I have hereunto set my hand and -al of said office this a/ day of . , A.D. &Oft / 1 411,/ Recorder of Deeds Recorder 7 Deeds,Cumberland County,Carlisle,PA My Comm ssion Expires the First Monday of Jan.2018