The URL can be used to link to this page

Home My WebLink About13-1800 Supreme Co> of Pennsylvania Co pleas ,�. t G . ■� { {4ks Y CQIIIIiy I g The information collected on this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as required Ly law or rules o court. Commencement of Action: . ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from another Jurisdiction ❑ Declaration of Takin Lead Plaintiff Name: Lead Def ndant's Naam�e: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER DANEL,E L. WA'I'SON TO BAC HOME LOANS SERVICING, LP FKA JAMES M. WATSON COUNTRYWIDE HOME LOANS SERVICING LP Are money Damages requested ?: ❑ Yes ® No Dollar Amount Requested within arbitration limits (Check one) X_ outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented ro Se Liti ant Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIALW CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other mass tort) ❑ Employment dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑ Employment Dispute: Other ❑ Other: MASS TORT ❑ Other ❑ Asbestos ❑ Tobacco ❑ Toxic Tort -DES REAL PROPERTY ❑ Toxic Tort -Implant MISCELLANEOUS • Toxic Waste ❑ Ejectment ❑ Common Law /Statutory • Other ❑ Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LA GROUP, P.C. S UITE 5000 - BNV MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413 -2311 W W W.KMLI.AWGROUP.COM BANK OF AMERICA, N.A., SUCCESSOR BY MERGER IN THE COURT OF COMMON PLEAS TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE 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. DANELLE L. WATSON JAMES M. WATSON No. Mortgagor(s) and Record Owner(s) i'B. AMON: MORTMW 1296 Asper Drive FOUCIDSM Boiling Springs, PA 17007 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. �.� t*a ct� CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013` o � o LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CA 717 - 243 -9400 AVISO Le ban 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 notificacion. 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 corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. /�'� LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOG ADO CO SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O L E ?�. CLL4 0U'2 �� 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 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: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hqp://www.phfa.org/consumers/homeowners/real.Mx 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.nhiladelphiafed.org /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 homeretentionkkmllaw rgroup.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 114145FC. Para informacion 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 COUNTRYWIDE 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 DANELLE L. WATSON, 1296 Asper Drive, Boiling Springs, PA 17007 and JAMES M. WATSON, 1296 Asper Drive, Boiling Springs, PA 17007, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On April 07, 2009 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS A NOMINEE FOR ALLIED HOME MORTGAGE CAPITAL CORPORATION, A CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on May 07, 2009 as Instrument #200914932. The mortgage has been assigned to: BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP by assignment of Mortgage recorded on May 20, 2011 as Instrument# 201114553. 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 July 01, 2010 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: PrincipalBalance ............................... ............................... ....................$233,837.11 Interest from 06/01/2010 through 03/31/2013 at 5. 0000 % ....................$33,126.89 After 03/31/2013 interest on the principal balance will accrue monthly, on the first day of each month, in the amount of $974.32, calculated at 5.0000% EscrowAdvances ................................. ............................... ............ ..........$9.397.16 $276,361.16 7. Plaintiff is not seeking a judgment of personal liability (or an " nersonam 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. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and the principal balance exceeds the state mandated amounts under Pa. Act 6 of 1974 and, as such, the Plaintiff is not required to send Notice under Act No. 6 of 1974. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $276,361.16, together with interest at the rate of $974.32, per month 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. By: KML LAW GRO . Michael McKe r Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristin 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. Gomall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 XSalvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION Y hereb states that of Bank of America, N.A., successor by merger to BAC Home Loans Servicing L.P., Plaintiff in this matter, that he sh s 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 hi er 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 unswom falsification to authorities. Date: */'P'% x ame:r� -� i17% Title: �iSi�l 1 c°�il`�� #114145FC - DANELLE L. WATSON and JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 ExhibitA ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Monroe in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows; BEING Lot No 63 on the Plan of Lots of Section C of White Rock Acres, recorded in the Ofice of the Recorder of Deeds of Cumberland County on November 10, 1970, in Plan Book 22, page 15, and more fully described as follows, to wit: BEGINNING at a point on the Western line of Asper Drive (50 feet wide) at the line dividing Lot Nos. 62 and 63 as shown on said Plan; thence by the Western line of Asper Drive the following Three courses and distances: 1) South 60 degrees 26 minutes East, 122.0 feet: 2) by a curve to the right having a radius of 125 feet, the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East: 3) South 22 degrees 16 minutes the right having a radius of 125 feet, the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East; 3) South 22 degrees 16 minutes West, 28.56 feet: thence by the Northern line of Lot No. 64 as shown on said Plan. North 74 degrees 08 minutes West, 342.18 feet to a point; thence by the Southern line of Lot No. 62 as shown on said Plan, North 50 degrees 20 minutes East, 233.66 to the Place of BEGINNING. CONTAINING 1.06 acres. HAVING THEREON ERECTED an aluminum 2 story type dwelling known as 1296 Asper Drive. Parcel #22 -33 -0043 -011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA _ COUNTRYWIDE HOME LOANS SERVICING, Case No. / J goo / vf/ LP Plaintiff vs. DANELLE L. WATSON JAMES M. WATSON 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. Respectfully submi d: Vw "20 &7777�__ (Signature Cou Plaintiff) A 3 Date Cumberland County Residential Mortgage Foreclosure Diversions Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete-your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: Cit State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: S Realtor Name: Realtor Phone: Borrower Occupied? Yes No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office; Email-, Cell: Other: # of people in household: How long? Mailing Address; City: State: Zip: Phone Numbers: Home: Office: ce: Cell: Other: Email: # ofpeople in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your loan: Second Mortgage Lender: Type of Loan: Loan Number Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default Is the loan in Bankruptcy? Yes ❑ Na ❑ If yes, provide names, location of court, case number & attorney. Assets Amount Owed slue; Home: $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ - Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Y Amount owed: Value: AAtQMobile #2 : Model: Y ear: Amount owed: Value: Other trKW2%tati0n fautomobiles boats mg clew• Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): I . - Monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: MM athly Enenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT mortgaw Food 2W Mortgage Utilities Car Payinant Condo/Nei . Fees Auto Insurance Ma not coy Auto fueYmpairs Other prop. payment Install Loan Pa Mont Cable TV Child S rt/Alim. Spending More Da /Child Care/Tuit. Ex Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No M If yes, pleasc provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email:. Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes [I No[] If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes F] No If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: Itwe, 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. VWe understand that I/we 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 Wowing information to lender and lender's counsel: Yrr Proof of income _ll( Past 2 bank statements YY, Proof of any expected income for the last 45 days Y Copy of a current utility bill 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 R Anderson I FILED-O'FTICE Sheriff OF THE PR0TH0N0-U,\PC'( Jody S Smith M-3 APR 29 AM 10' 33 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor OFFICE OF THE IMMFF PENNSYLVANIA Bank of America, N.A. Case Number vs. 2013-1800 Danelle Watson(et al.) SHERIFF'S RETURN OF SERVICE 04/09/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Danelle Watson, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program'and Complaint in Mortgage Foreclosure as"Not Found"at 1296 Asper Drive, Monroe Township, Boiling Springs, PA 17007. Residence appears vacant. Per the Boiling Springs Postmaster the defendant has moved and left a forwarding address of:602 Glenwood Drive, Ephrata, PA 17522. 04/09/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: James M.Watson, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1296 Asper Drive, Monroe Township, Boiling Springs, PA 17007. Residence appears vacant. Per the Boiling Springs Postmaster the defendant has moved and left a forwarding address of: 602 Glenwood Drive, Ephrata, PA 17522. SHERIFF COST: $51.00 SO ANSWERS, April 17,2013 RONISW R ANDERSON, SHERIFF (0)CountySufte Sheriff,Teleosoft,Inc. KML Law Group, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET IN THE COURT OF COMMON PLEAS PHILADELPHIA,PA 19106-1532 OF Cumberland COUNTY (215)627-1322 ATTORNEY FOR PLAINTIFF CIVIL ACTION-LAW BANK OF AMERICA,N.A., SUCCESSOR BY ACTION OF MORTGAGE MERGER TO BAC HOME LOANS SERVICING,LP FORECLOSURE FKA COUNTRYWIDE HOME LOANS SERVICING,LP Term No. 13-1800-Civil 7105 Corporate Drive PTX B-209 Plano,TX 75024 Plaintiff • C: vs. C � DANELLE L WATSON � JAMES M WATSON 1296 Asper Drive NC Boiling Springs,PA 17007 r-� Defendant(s) t.? PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: a=, z KML LAW G UP,P.C. Michael McK ver Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E.Kivitz Pa. ID 26769 J' 1 P. Jenkins Pa. ID 306588 oshua I. Goldman Pa. 205047 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff OL ��.�5 AL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff ;1t mk ,,pe;fit, 0 - `4 ,.. i� t d%, i f}I...`- I#�t) Jody S Smith Chief Deputy 20113 JUI-1 —7i P-1 10: 0 1 Richard W Stewart ?- CU BERLA140 COUNI If Solicitor Or'F ICF P THE SI-EfZI r k tNNSYLVANIA Bank of America, N.A. Case Number vs. Danelle Watson (et al.) 2013-1800 SHERIFF'S RETURN OF SERVICE 05/23/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Danelle Watson, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Lancaster, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 05/23/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: James M. Watson, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Lancaster, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 05/30/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Lancaster County upon Danelle Watson,who accepted for James M. Watson, at 1 Denver Road, Denver, PA . Mark S. Reese, Sheriff, Return of Service attached to and made part of the within record. 05/30/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Lancaster County upon Danelle Watson, personally, at 1 Denver Road, Denver, PA. Mark S. Reese, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.00 SO ANSWERS, 2 June 04, 2013 RON �. R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. SHERIFF'S OFFICE OF LANCASTER COUNTY Mark S. Reese .. _. Brad Harris �EIJERIi� 6 Sheriff , * ' Solicitor Marc Lancaster Charles Hamilton Chief Deputy Lieutenant BANK OF AMERICA NA vs. Case Number DANELLE WATSON (et al.) 2013-1800 SHERIFF'S RETURN OF SERVICE 05/30/2013 11:05 AM - SERVED THE COMPLAINT IN MORTGAGE FORECLOSURE(CIMF) BY HANDING A COPY TO DANELLE WATSON,WHO ACCEPTED AS"ADULT PERSON IN CHARGE" FOR JAMES M WATSON AT 1 DENVER ROAD, DENVER, PA 17517. SO ANSWERS: DEPUTY JEFF LEAMAN, DEPUTY SHERIFF OF LANCASTER COUNTY, PA. JEFF LEAMAN, DEPUTY 05130/2013 11:05 AM- SERVED THE COMPLAINT IN MORTGAGE FORECLOSURE(CIMF) BY PERSONAL SERVICE UPON DANELLE WATSON AT 1 DENVER ROAD, DENVER, PA 17517. SO ANSWERS: DEPUTY JEFF LEAMAN, DEPUTY SHERIFF OF LANCASTER COUNTY, PA. JEFF LEAMAN, DEPUTY SHERIFF COST. $88.88 SO ANSWERS, May 31, 2013 MARK S. REESE, SHERIFF COSTS DATE CATEGORY MEMO CHK# DEBIT CREDIT 05/24/2013 Advance Fee Advance Fee 737174 $0.00 $150.00 05124/2013 Receiving,Docketing&Return $9.00 $0.00 05/24/2013 Service $9.00 $0.00 05/24/2013 Affidavit $2.50 $0.00 05/24/2013 Deputy Time 2X $20.00 $0.00 05/24/2013 Copies 2X $12.00 $0.00 0 5/2 412 01 3 Service(Additional Defendant) $6.00 $0.00 05/24/2013 Affidavit-Additional Fees $1.00 $0.00 05/28/2013 Service Mileage $14.69 $0.00 05/30/2013 Service Mileage $14.69 $0.00 05/31/2013 Refund $61.12 $0.00 $150.00 $150.00 BALANCE: $0.00 = plaintiff Attorney:KML LAIN GROUP, Suite 5000-BNY Independence Center, 709 Market Street, Philadelphia, PA 99106-153, (cj Ceunty8uite Sheriff,Telecsaft,Inc. SHERIFF'S OFFICE 50 NORTH DUKE STREET, P.O. BOX 03480, LANCASTER, PENNSYLVANIA, 17608-3480 - 717 299-7200 SHERIFF SERVICE PLEASE MAKE SURE FORM PRINTS"? PROCESS RECEIPT,and AFFIDAVIT of RETURN r LEGIBLY = ,, 1. PLAINTIFF/$/ 2 COURT DOCKET NUMBER BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS 13-1800-Civil 3 DE ENDANT/S/ 4 DANELLE L WATSON Complaint in Mortgage Foreclosure 5. NAME OF INDIVIDUAL,COMPANY,CORPORATION,ETC,TO BE SERVED SERVE DANELLE L WATSON _ 6. ADDRESS Street or RFD,apartment No-,City,Boro,Tw .,State and ZIP Code AT 602 Glenwood Drive Ephrata,PA 17522 7. INDICATE UNUSUAL SERVICE: DEPUTIZE OTHER Now, 20 =,1 SHERIFF OF LANCASTER COUNTY,PA.,do hereby deputize the sheriff of County to execute the writ and make return there of according to law. This deputation being made at the request and risk of the plaintiff Sheriff Lancaster County =TRU ER INFO NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: B.WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman,in custody of whomever=possession,possession,after notifying person of levy or attachment,without liability on the part of such deputy or the sheriff to any plaintiff herein for any toss, destruction or removal of an such ro ert before sheriffs sale thereof. 9,SIGNATURE OF ATTORNEY OR OTHER ORIGINATOR Print Name 10. TELEPHONE 11. DATE Michael T.McKeever 215-627-1322 111 12.SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW:(This area must be completed If notice is to be mailed) ItiML LAW GROUP,P..C,Suite 5000,701 Market Street,BNY Mellon Independence Center,Philadelphia,PA 19106 ":177777 BELOW.FOR USE.OF SHERIFF ONLY—DO NOT WRITE BELOW THIS LINE "?' 13.1 acknowledge receipt of the writ Name of authorized LCSO Deputy or Clerk 14.Date Received 15.Expiration/Hearing Date 6t complaint as indicated above. 16.1 Hereby certify that I ❑have personally served ❑have legal evidence of service as shown in"Remarks" ❑have executed as shown in the"Remarks,the writ or compliant described on the individual,company,corporation,etc.,at the address shown above or on the individual, company,corporation etc at the address inserted below by handing a TRUE and ATTESTED COPY thereof 17.❑hereby certify and return a NOT FOUND because I am unable to locate the individual,company,corporation,etc., named above. 18.Name and title of individual Served(if not shown above)(Relationship to Defendant) 19 0 No Service See Remarks Below 20.Address of where served(Complete only it different than shown above)(Street or RFD,Apartment 21. 22.Time AM/PM No.,City,Boro,TWP,State and ZIP Code) Date E.S.T/E.D.S.T of Servic e 21 Date Miles Dep Date Miles Dep Int Dat Miles Dep Date Miles Dep Date Miles Dep Attempts Int a In Int Int 24.Advance Costs 25.Service Costs 26.Notary Costs 27.Mileage/Postage/N.F 28.Total Costs 29,COST DUE OR REFUND 30.Remarks S.T.A: 31.AFFIRMED and subscribed to before me this SO ANSWER. 34.day of 20 37 32.Signature of Dep.Sheriff 33.Date Prothonotary/Deputy/Norary Public 35.Signature of Sheriff 36.Date MY COMMISSION EXPIRES Terry A.Bergman SHERIFF OF LANCASTER COUNTY PA 5 SHERIFF'S OFFICE 50 NORTH DUKE STREET, P.O. BOX 03480, LANCASTER, PENNSYLVANIA, 17608-3480 - 717 299-7200 SHERIFF SERVICE PLEASE -AK Slt1RE FOORM PRINTS PROCESS RECEIPT, and AFFIDAVIT of RETURN G BL 1. PLAINTIFF/S/ 2, CO URT DOCKET NUMBER BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS 13-1800-Civil 3. DEFENDANT/S/ TYPE JAMES M WATSON Complaint in Mortgage Foreclosure 5. NAME OF INDIVIDUAL,COMPANY,CORPORATION,ETC,TO BE SERVED SERVE JAMES M WATSON _ 6. ADDRESS Street or RFD,apartment No.,City,Boro,Tw .,State and ZIP Code AT 602 Glenwood Drive Ephrata,PA 17522 7. INDICATE UNUSUAL SERVICE: I DEPUTIZE I OTHER Now, 20 =, 1 SHERIFF OF LANCASTER COUNTY,PA.,do hereby deputize the sheriff of County to execute the writ and make return there of according to law. This deputation being made at the request and risk of the plaintiff Sheriff Lancaster County 8-SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT IST IN FxPF:nITI1,11-CCD111r'C, NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: B.WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman,in custody of whomever found in possession,after notifying person of levy or attachment,without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriffs sale thereof. 9. SIGNATURE OF ATTORNEY OR OTHER ORIGINATOR Print Name 10. TELEPHONE 11. DATE Michael T.McKeever 215-627-1322 12.SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW:(This area must be completed if notice is to be mailed) KML LAW GROUP,P.C.,Suite 5000,701 Market Street,BNY Mellon Independence Center,Philadelphia,PA 19106 SP�ATC ETO,-,W-� O:R,lU3E O SHERIFF,�ONL - O OT WRIT BEL�O THIS LINE 13. 1 acknowledge receipt of the writ Name of authorized LCSO Deputy or Clerk 14.Date Received 15. Expiration/Hearing Date Ur complaint as indicated above. 16. 1 Hereby certify that I ❑have personally served ❑have legal evidence of service as shown in"Remarks" ❑have executed as shown in the`Remarks,the writ or compliant described on the individual,company,corporation,etc.,at the address shown above or on the individual, company,corporation,etc.,at the address inserted below by handing a TRUE and ATTESTED COPY thereof 17.❑hereby certify and return a NOT FOUND because I am unable to locate the individual,company,corporation,etc.,named above. 18. Name and title of individual Served(if not shown above)(Relationship to Defendant) 19❑No Service See Remarks Below 20.Address of where served(Complete only it different than shown above)(Street or RFD,Apartment 21. 22.Time AM/PM No.,City,Boro,TWP,State and ZIP Code) Date E.S.T/E.D.S.T of Servic e 23. Date Miles Dep Date Miles I Dep Int Dat Miles Dep Date Miles Dep Date Miles Dep Attempts Int a Int Int Int 24.Advance Costs 25. Service Costs 26. Notary Costs 27.Mileage/Postage/N.F 28.Total Costs 29.COST DUE OR REFUND 30.Remarks S.T.A: 31.AFFIRMED and subscribed to before me this SO ANSWER. 34.day of 20 37. 32.Signature of Dep.Sheriff 33.Date Prothonotary/Deputy/Norary Public 35. Signature of Sheriff I 36.Date MY COMMISSION EXPIRES Terry A.Bergman SHERIFF OF LANCASTER COUNTY I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP 7105 Corporate Drive PTX B-209 Plano,TX 75024 Plaintiff 17 vs. No. 13-1800-Civil`' cv': r, DANELLE L.WATSON JAMES M.WATSON c �, (M ort a or(s)and Record Owner(s)) �rte-- _._ ,�, 1296 Asper Drive u --�ac..� Boiling Springs,PA 17007 - --n Defendant(s) '- �j 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 DANELLE L.WATSON and JAMES M.WATSON by default for want of an Answer. Assess damages as follows: $280,258.44 Debt Monthly Interest- 06/01/2010 to 07/31/2013 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was ma'led or delive ed to the party against whom judgment is to be entered and to his attorney of record,if any,after the default o ed nd least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.27.1 By: KML LAW _Michael McK ver Pa.ID 56129 _Jay E. e Pa. Pa.80 26769 � 1� _Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 C-" M f Thomas Puleo Pa.ID 27615 „ I�A LI SLi Jill P.Jenkins Pa.ID 306588 1 t{p( _Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff U�i ce AND NOW OwA o Ob/3 ,Judgment is entered in favor of BANK OF AMERICA,N.A., SUCCEV60R BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP and against DANELLE L.W4 SON and JAMES M. WATSON by. default for want of an Answer and damages assessed in the sum of$280,258.44 as pe the ab cert' n. Prot ota Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION-LAW BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP 7105 Corporate Drive PTX B-209 Plano,TX 75024 Plaintiff No. 13-1800-Civil vs. DANELLE L. WATSON JAMES M. WATSON (Mortgagors and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary By: Deputy If you have any questions concerning the above,please contact: KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 114145FC 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 TMS NOTICE: July 29,2013 TO: DAN ELLE L.WATSON 1296 Asper Drive Boiling Springs,PA 17007 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME of Cumberland County LOANS SERVICING,LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Plano,TX 75024 Plaints Action of vs. Mortgage Foreclosure DANELL E L.WATSON JAMES M.WATSON No. 13-1800-Civil (Mortgagor(s)and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(s) TO: DANELLE L.WATSON 1296 Asper Drive Boiling Springs,PA 17007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FOR'171 AGAINS').' YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A IWARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPOIUAN r RIGIFFS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SE-l'IjOR'1'11 BELOW. TI-HS 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 AGENCIHS TIIA.T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 i LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: XML LA GROUP,P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Pu[eo Pa. ID 27615 Jill P.Jenkins Pa.ID 306588 A[yk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 114145FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF TIRS NOTICE: July 29,2013 TO: DANELLE L WATSON I Denver Road Denver,PA 17517 Tn the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME of Cumberland County LOANS SERVICING,LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Piano,TX 75024 plaintiff Action of VS. Mortgage Foreclosure DANELLE L.WATSON JAMES M.WATSON No. 13-1800-Civil (Mortgagor(s)and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(v) TO: DANELLE L.WATSON I Deaver Road Deriver,PA 17517 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU I IAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT ABEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE, SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. W YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE, MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE ES TO FLIGIBLE TIER-SONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine How Carlisle,PA 17013 717-243-9400 By:. KMCLAW"GROUP,P.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 ;4ill P.Jenkins Pa.ID 306588 �Alyk L.011azian Pa.ID 312912 Salvatore Filippetto Pa.ID 313897 Michael J.CoskeyPa ID 311835 215-627-1322 Attorneys for Plaintiff 114145FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: July 29,2013 TO: DANELLE L WATSON 602 Glenwood Drive Ephrata,PA 17522 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME of CurnbeTland County LOANS SERVICING,LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Plano,TX 75024 Plaintiff Action of VS. Mortgage Foreclosure DANELLE L.WATSON JAMES M.WATSON No. 13-1800-Civil (Mortgag6r(s)and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(s) TO: DANELLE L WATSON 602 Glenwood Drive Ephrata,PA 17522 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAUXI) TO EN FER A WRFrtEN APPEARANCE- PERSONALLY OR By ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SETFORI'li AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT BEARING AND YOU MAY LOSE YOUR PROPEWlY OR GIVER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SF Jr FORTH BFJ,OW. TUIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER- IF YOU CANNOT AFFORD To HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WI-1-f I INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBER LAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Cadislc^17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 ry By:- KML LAVGROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Let Pa.ED 78020 Kristins Murtha Pa.11D 61.858 David Fein Pa.ED 82628 Thomas Puleo Pa.ID 27615 Jill P Jenkins Pa.ID 306588 :2;lyk P. Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff , 114145FC 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. To: DATE.OF THIS NOTICE: July 29,2013 JAMES M.WATSON 1296 Asper Drive Boiling Springs,PA 17007 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common PIeas HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME of Cumberland County LOANS SERVICING,LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Plano,TX 75024 Plaintiff Action of vs. Mortgage Foreclosure DANF,LLE L.WATSON JAMES M. WATSON No. 13-1800-Civil (Mortgagor(s)and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(s) TO: JAMES M.WATSON 1296 Asper Drive Boiling Springs,PA 17007 EMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU A(:1'W PfI-IIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY 13h;ENTFRED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.W. TIRS OFFICE.CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO l IIRH 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 FF.1 E. CUMBERLAND COUNTY BAR ASSOCIATION 2 Labe Avenue Carlisle,PA 17013 IX GAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 7 By: ,.. KML LAW ROUP,P.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 Jill P.Jenkins Pa. ID 306588 �Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.1D 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 114 14 5FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WELL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: July 29,2013 TO: JAWS M.WATSON 1 Denver Road Denver,PA 17517 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR,BY MERGER TO BAC Common Pleas HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME of Cumberland County LOANS SERVICING,LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Plano,TX 75024 Plaintiff Action of VS. Mortgage Foreclosure DANELLE L.WATSON JAMES M.WATSON No. 13-1800-Civil (Mortgagor(s)and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(() TO: JAMES M.WATSON I Denver Road Denver,PA 17517 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE. YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF MS NCTICF,A JUDGMENT MAY BE FRIERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A i.AWYFR- IF YOU CANNOT'AFFORD T0 IJIRE A LAWYER,THIS OFFICE MAY BE AMY TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES ID ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBIAU-4ND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES WC. 8 Irvine Row Carlisle,PA 17013 717-243-9400 By:_ KML LAW GAOUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ED 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.El)82628 Thomas Puleo Pa.ID 27615 ,Tjfi P.Jenkins Pa.ID 306588 g! _Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ED 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 114145FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: July 29,2013 TO: JAMES M WATSON 602 Glenwood Drive Ephrata,PA 17522 In the Court of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC Common Pleas HONE LOANS SERVICING,LP FKA COUNTRYWIDE HOME of Cumberland County LOANS SERVICING,LP 7105 Corporate Drive CIVIL ACTION-LAW PTX B-209 Plano,TX 75024 Plaintiff Action of VS. Mortgage Foreclosure DANELLE L.WATSON JAMES M.WATSON No. 13-1800-Civil (Mortgagor(s)and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(v) TO: JAMES M WATSON 602 Glenwood Drive Ephrata,PA 17522 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ,Krl'C)RNFY AND FIIXIN WRITING wrnuri IF COUR'I'YOUR,DFFENSFS OR ORJHCFIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN(10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY 13F FN.rFRFJ)AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS PAPhR TO YOUR LAWYER AJ.' ONCF. IF YOU DO NOT HAVE A LAWYER, GO'In OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER- IF YOU CANNOT AFFORD 170 HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERWCES'll)hLIGAILF PERSONS AT REDUCED FEF.OR NOFI-'h. CUMBERLAND COUNTY BAR ASSOCIATION 21J"Avenuc Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By-- KiML LA GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ED 61858 David Fein Pa.ID 82628 Thomas Pules Pa.ID 27615 Z�Jill P. Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ED 311835 215-627-1322 Attorneys for Plaintiff i. KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME IN THE COURT OF COMMON PLEAS LOANS SERVICING,LP 7105 Corporate Drive OF CUMBERLAND COUNTY PTX B-209 Plano,TX 75024 Plaintiff VS. CIVIL ACTION LAW DANELLE L.WATSON JAMES M. WATSON ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s)and Record owner(s)) 1296 Asper Drive No. 13-1800-Civil Boiling Springs,PA 17007 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HONE LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICIN ,(L P,and against DANELLE L. WATSON h and JAMES M.WATSON for failure to file an Answer in the above aitiqn with' (20 20lays from the date of service of the Complaint,in the sum of$280,258.44. By: I 1� —_ KNM LAW V�%F MichaelMcK er Pa.U)56129 ___jay E.Kivitz Pa.11)26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.fl)82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 -C9 Andrew F.Gornall Pa.11)92382 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HONE LOANS SERVICING,LP 7105 Corporate Drive PTX B 209 Plano,TX 75024 and that the name(s)and last known address(es)of the Defendant(s)is/are DA L L. A N, I Denver Road Denver,PA 17517 and JAMES M.WATSON, I Denver Road Denver,PA 17517-1 By:_ 1KCMWML LA JORC F Michajeleevc"a 6129 rp D 26T69 ___jay E.Kivitz Pa.ID 26 69 Lisa Lee Pa-ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 �7ill 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 $233,837.11 Monthly Interest from 06/01/2010 $37,024.17 through 07/31/2013 Escrow Advances $9,397.16 C. $280, :58.By: KML LAW P Michael Mc ever 5 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff AND NOW,this day of 2013 damages are assessed as above. 13-1800-Civil/114145FC Pro Prothy r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP F= Plaintiff ' r , vs. NO. 13-1800-Civil DANELLE L.WATSON JAMES M.WATSON Defendant(s) =o ; , VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS�Clvk RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That,an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmde.osd.mil/appj/scra/scraHome.do) for the following individual(s): DANELLE L. WATSON, has a last known residence of 1 Denver Road, Denver,PA 17517. The following information was used to search the DMDC(check all that apply): X_Last Name X First Name X 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.4rel to unsworn falsification to autLb. ri Date By: KML LAW GRO ,P. .I IV Michael McKeever Pa. 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 :09:54 Department of Defense Manpower Data Center Results as of:Aug-15-2013 09 SCRA 3.0 Statm Report r Pursuant,to Servicemembe s Civil Relief Act Last Name: WATSON First Name: DANIELLE Middle Name: L. Active Duty Status As Of: Auq-15-2013 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 Lett 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 It 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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization mthe Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which m the official source mdata on eligibility for military medical care and other eligibility systems. The mvo strongly supports the enforcement m the omwcomomu*rs Civil Relief Act(5mumo App.§so1museq.us amended)(SomA)(formerly known as the Soldiers'and aa/wm'oivi|Relief Act ov1o4o). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual w currently on active duty"responses,and has experienced only a small error rate, In the event the individual referenced above,m any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,o,/u otherwise entitled mthe protections of the ncm\you are strongly encouraged m obtain further verification m the person's status bycontacting that person's Service via the ^uofe^,00nx.mirunL http:m*w~uofen°oxnxmi|xw«/pis/poonaLnR.mm|. n you have evidence the person was vn active duty for the active duty status date and you fail m obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See nouac App.yoz1(c). This response reflects the following information: (1)The individual's Active Duty status vn the Active Duty Status Date(z)Whether the individual left Active Duty status within 367days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification mrevvuuxoctive 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 muo1u only some m the active duty periods less than ao consecutive umysmmnemnemava/lame. 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)I for purposes of responding to a national emergency declared by the President and supported uy 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 m the Reserves(TAno).wunnp Corps Active Reserve(ARm)and Coast Guard Reserve Program Administrator(npAo), 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 SCRAie 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 oson 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 m the SCpm may extend m persons who have received orders to report for active duty mmuo inducted,but who have not actually begun active duty m actually reported for induction. The Last Date on Active Duty entry/a important because a number m protections m the oonx extend beyond the last dates m 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. pm"mmo erroneous information will cause an erroneous certificate muaprovided. Certificate ![}: P44BX432R4OD3380 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP Plaintiff r - VS. NO. 13-1800-Civil __ DANELLE L.WATSON � ✓� JAMES M.WATSON s s Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBIERC-)'CR4L c 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): JAMES M. WATSON, has a last known residence of 1 Denver Road, Denver,PA 17517. The following information was used to search the DMDC(check all that apply): X_Last Name X First Name X_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. 49 4 rel Etting to unswom falsification to aut o ities. Date d By: KML LAW G UP, Michael Mc eever PP ID 56129 Lisa Lee Pa. ID 78020 Kristin 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 Xlill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Aug-15-2013 09:11:37 SCRA 3.0 ` Status Report Pursuant to Servicerreembers Civil Relief Act, Last Name: WATSON First Name: JAMES Middle Name: M. Active Duty Status As Of: Aug-15-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Dale 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!eft active duty status within 367 days preceding the Active Duty Status Date r 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 histher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTERPCANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. )6k r 14. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: G4Z2S442QOD4V80 y 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 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP IN THE COURT OF COMMON PLEAS 7105 Corporate Drive PTX B-209 of Cumberland County Plano,TX 75024 Plaintiff CIVIL ACTION—LAW vs. ACTION OF MORTGAGE FORECLOSURE DANELLE L.WATSON JAMES M.WATSON Mortgagor(s)and Record.Owner(s) No. 13-1800-Civil ,. 1296 Asper Drive C=11 Boiling Springs,PA 17007 Defendant(s) rnrn rat G3 a ..<3� Gi PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: 5;c= --t tea Issue Writ of Execution in the above matter: Amount Due $280,258.44 Interest from 8/1/2013 to Date of Sale per Monthly diem at $974.32 (Costs to be added) By: j KML LAW G I UIi, Michael McKeever Pa. 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 13, 7J Joshua I. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff sb 4AL as Sow 03 f 0( No. 13-1800-Civil IN THE COURT OF COMMON PLEAS BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP VS. DANELLE L. WATSON and JAMES M.WATSON (Mortgagor(s)and Record Owner(s)) 1296 Asper Drive Boiling Springs,PA 17007 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group,P.C. Attorney for Plaintiff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 r „ ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Monroe in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows; BEING Lot No 63 on the Plan of Lots of Section C of White Rock Acres, recorded in the Office of the Recorder of Deeds of Cumberland County on November 10, 1970, in Plan Book 22, page 15, and more fully described as follows,to wit: BEGINNING at a point on the Western line of Asper Drive (50 feet wide) at the line dividing Lot Nos. 62 and 63 as shown on said Plan;thence by the Western line of Asper Drive the following Three courses and distances: 1)South 60 degrees 26 minutes East, 122.0 feet: 2) by a curve to the right having a radius of 125 feet,the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East: 3)South 22 degrees 16 minutes the right having a radius of 125 feet,the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East;3)South 22 degrees 16 minutes West, 28.56 feet;thence by the Northern line of Lot No. 64 as shown on said Plan North 74 degrees 08 minutes West, 342.18 feet to a point; thence by the Southern line of Lot No. 62 as shown on said Plan, North 50 degrees 20 minutes East. 233.66 to the Place of BEGINNING. CONTAINING 1.06 acres. HAVING THEREON ERECTED an aluminum 2 story type dwelling known as 1296 Asper Drive. Parcel#22-33-0043-011 IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY TOWNSHIP OF MONROE BEING PREMISES: 1296 Asper Drive Boiling Springs PA 17007 SOLD as the property of JAMES M. WATSON AND DANIELLE L. WATSON TAX PARCEL#22-33-0043-011 BEING the same premises which James-Mervin: Watson and Danelle-Lynne: Watson by deed dated 10/12/10 and recorded 10/12/10 in Cumberland County in Deed Book Instrument#201029172 granted and conveyed unto James M. and Danelle L. Watson KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street FILED-OrINCE Philadelphia,PA 19106-1532 1 C uli:� TH EPROTHONOTARI 215-627-1322 1 23 Attorney for Plaintiff 2013 AUG 30 AN [ '*- GOUNTY BANK OF AMERICA,N.A., SUCCESSOR BY PENNSYLVANIA MERGER TO BAC HOME LOANS SERVICING,LP IN THE COURT OF COMMON PLEAS FKA COUNTRYWIDE HOME LOANS SERVICING,LP of Cumberland County 7105 Corporate Drive PTX B-209 Plano, TX 75024 CIVIL ACTION-LAW Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE DANELLE L. WATSON JAMES M.WATSON (Mortgagor(s)and Record Owner(s)) 1296 Asper Drive No. 13-1800-Civil Boiling Springs,PA 17007 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP,Plaintiff in the above action,by counsel,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: 1296 Asper Drive Boiling Springs,PA 17007 I.Name and address of OWner(s)or Reputed Owner(s): DANELLE L.WATSON I Denver Road Denver,PA 17517 JAMES M. WATSON I Denver Road Denver,PA 17517 2.Name and address of Defendant(s)in the judgment: DANELLE L. WATSON I Denver Road Denver,PA 17517 JAMES M.WATSON I Denver Road Denver,PA 17517 A 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CITIBANK SOUTH DAKOTA NA C/O BLATT HASENMILLER,LEIBSKER1 DANIEL SANTUCCI,ESQ. 5 GREAT VALLEY PARKWAY SUITE 100 MALVERN,PA 19355 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 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 .1296 Asper Drive Boiling Springs,PA 17007 1 verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false stateme is herei are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: By: - KML LA 8';6129 Michael McKeever Pa V5 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 IV—Joshua- 1.Goldman Pa.205047 V,--Jill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff 13-1800-Civil KML Law Group,P.C. PROMAR Suite 5000-BNY Independence Center NOT 701 Market Street Philadelphia,PA 19106 AUG (215)627-1322 Attorney for Plaintiff ,UMOERLAND COUI'T BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, IN THE COURT OF COMMON PLEAS LP FKA COUNTRYWIDE HOW LOANS SERVICING,LP of Cumberland County 7105 Corporate Drive PTX B-209 Piano,TX 75024 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE VS. FORECLOSURE DANELLE L. WATSON JAMES M. WATSON Mortgagor(s)and Record Owner(s) Docket No. 13-1800-Civil 1.296 Asper Drive Boiling Springs,PA 17007 Defendant(si THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WATSON,DANELLE L. DANELLE L. WATSON I Denver Road Denver,PA 17517 Your house at 1296 Asper Drive,Boiling Springs,PA 17007 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$280,258.44 obtained by BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP,against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13-1800-Civil 1. The sale will be cancelled if you pay to BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may.also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: bttp://www.12hiladelphiafed.org-/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-1800-Civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call,the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PBFA website http://www.phfa.orgjconsumers/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 gkmllawgroup.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 114145FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 13-1800-Civil 1CV1L Law Group,P.C. HLED-OFFICE Suite 5000-BNY Independence Center 0 FTHE PROTHONIOTARY 701 Market Street D13 AUG 30 AM 11: 23 Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff CUMBERLAND COUNTY P E J%1145 U1 'L-'I'rA%N 1 A BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, IN THE COURT OF COMMON PLEAS LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP of Cumberland County 7105 Corporate Drive PTX B-209 Piano,TX 75024 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE vs. FORECLOSURE DANELLE L.WATSON JAMES M.WATSON Mortgagor(s)and Record Owner(s) Docket No. 13-1800-Civil 1296 Asper Drive Boiling Springs,PA 17007 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WATSON,!JAWS M. JAMES M. WATSON I Denver Road Denver,PA 17517 Your house at 1296 Asper Drive,Boiling Springs,PA 17007 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm.2nd FL Courthouse to enforce the court judgment of$280,258.44 obtained by BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13-1800-Civil 1. The sale will be cancelled if you pay to BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may.also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may,be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hqp:tl www.philadelphiafed.orgjforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-1800-Civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you,you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call, an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call.the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orgiconsumers/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 homeretentiongkmllawgroup.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 114145FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-1800 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due BANK OF AMERICA,N.A. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP Plaintiff(s) From DANIELLE L.WATSON,JAMES M.WATSON (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: $280,258.44 L.L;: $•50 Interest FROM 8/1/2013 TO DATE OF SALE PER MONTHLY DIEM AT$974.32 Atty's Comm: Due Prothy:$2.25 Atty Paid: $264.50 Other Costs: Plaintiff Paid: Date: AUGUST 30,2013 David 1 D.Bu 1 ,Prothonot J.4'21' (Seal) q 021 r 7) Deputy REQUESTING PARTY: Name: JILL P.JENKINS,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106-1532 Attorney for:PLAINTIFF Telephone:215-627-1322 Supreme Court ID No.306588 KML Law Group,P.C. �' Suite 5000-BNY Independence Center 7013 OCT 25 P I I. 5 701 Market Street Philadelphia,PA 19106-1532 O ,1BERLAND COUNTY 215-627-1322 r'DINS YLVANIA Attorney for Plaintiff BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, IN THE COURT OF COMMON PLEAS LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP OF Cumberland COUNTY 7105 Corporate Drive PTX B-209 Plano,TX 75024 vs. No. 13-1800-Civil DANELLE L. WATSON and JAMES M. WATSON 1296 Asper Drive Boiling Springs,PA 17007 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P.430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a mortgage upon the premises 1296 Asper Drive,Boiling Springs,PA, 17007, hereinafter,the "mortgaged premises". 2. Defendants, DANELLE L. WATSON and JAMES M. WATSON,are the mortgagors and real owners of the mortgaged premises. 3. Pursuant to Cumberland County Local Rule 208.3(a)(2)and/or Rule 208.3(a)(9), I,Alyk Oflazian, Esquire,hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. 4. The last known address of Defendant, Danelle L. Watson is 602 Glenwood Drive, Ephrata,PA 17522 and for Defendant,James M. Watson are 1296 Asper Drive,Boiling Springs,PA 17007, 31 Eisenhower Cross Road, Mill Hall, PA 17751 and 605 Canal Street,Lock Haven,PA 17745 from our investigative searches. 5. The Sheriff has been unable to effect service of the Notice of Sale upon Defendants, Danelle L.Watson and James M. Watson. Service was attempted on Defendants,Danelle L. Watson and James M. Watson at the mortgaged premises 1296 Asper Drive,Boiling Springs,PA 17007. The returns of service indicate several attempts were made without any response. Service was attempted on Defendant,Danelle L.Watson at 602 Glenwood Drive,Ephrata,PA 17522. The return of service indicates per the current residents"The Groffs"Defendant,Danelle L. Watson does not reside at said address. Service was attempted on Defendant,James M. Watson at 31 Eisenhower Cross Road,Mill Hall,PA 17751. The return of service indicates several attempts were made without any response. Service was attempted on Defendant,James M. Watson at 605 Canal Street,Lock Haven, PA 17745. The return of service indicates several attempts were made without any response. 6. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendants,Danelle L. Watson and James M. Watson. WHEREFORE,Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Notice of Sale upon Defendants,Danelle L. Watson and James M. Watson,by posting the premises and certified and regular mail to the Defendant's last known addresses. By: KML LAW ROUP,P.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 J' P.Jenkins Pa. ID 306588 Alyk Oflazian Pa. ID 312912 Attorneys for Plaintiff Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 114145FC Attorney/Law Firm:KML LAW GROUP, P.0 Subject Name:DANELLE L. WATSON Property Address:Street: 1296 Asper Drive City: Boiling Springs State: PA Zip: 17007 Skip Results: Date of Birth:amp ProVest File Number:3767866 Last Known Address(as of 9/24/2013)Street:602 Glenwood Dr City:Ephrata State: PA Zip: 17522 9783 Death Record Search As of 09/24/2013,the Social Security Administration has no death record on file for Danelle L Watson. Social Security Number [X]Verifed[] Not VerifiellIMMIN Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation. Business Records Search No business records found. Creditor Header Inquiry The latest address from the credit header info is: Address: 602 GLENWOOD DR, EPHRATA, PA 17522 9783 Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Vehlde Records Search* Drivers License Information Search No records found. Govemmental"'+ Non-govemmental Professional Licenses Search No records found. Freedom Of Information Act Inquiry The following addresses were sent to the United States Postal Made to U.S. Postal Service inspector at the zip code listed with no return information to date: 1296 ASPER DRIVE I BOILING SPRINGS{PA 1 17007 CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, 717-258-1339: Called possible relative, Jimmie McCann,there was no Neighbors,&Friends answer. Comments: 717-773-7777(Mobile): Called number listed to defendant, Danelle Watson,there was no answer. 717-773-7769(Mobile): Called number listed to defendant, Danelle Watson,there was no answer. 717-249-5778:Called number listed to defendant, Danelle Watson, there was no answer. Data not available in AL,AR,CA,HI,NH,OR,PA,VA,WA."Historical data in CO,DE,ID,IL,KY,LA,MD,MA,MS,MO,NH,ND, SC,WV. +Data available in CO,CT,DE,FL,ID,IL,KY,LA,ME,MD,MA,MI,MN,MS,MO,NH,ND,OH,SC,TN,TX,WV,WI,WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Under penalties of perjury,I declare that I have read the foregoing affidavit and that the facts stated in it are true. STATE OF FLORIDA kji �� .JL�J►/. COUNTY OF HILLSBOROUGH e E P lit 2 d ?013 Gianna Hemandez ProVest File Number: X866 Sworn to or affirmed and signed before me on this y o • Provest Services LLC (Seal) Date: aq 24\20l3 - _ HUA N. Notary JOS Public,StatePIMENTEL of Florida \ Si atur Public My Comm.Expires May 24,2015 No EE 97050 Printed Name of Notary Public Personally Known ( )Produced as identification Affidavit of Good Faith Investigation At the request of the law firm identified below I initiated an investigation into the whereabouts of the defendant identified as the subject below. The following is true and accurate representation of my investigation. Client provided information: File Number: 114145FC Attorney/Law Firm:KML LAW GROUP, P.0 Subject Name:JAMES M. WATSON Property Address: Street: 1296 Asper Drive City: Boiling Springs State: PA Zip: 17007 Skip Results: Date of Birth: Mb ProVest File Number:3767866 Last Known Address(as of 9/24/2013)Street: 1296 Asper Dr City: Boiling Springs State: PA Zip: 17007 9617 Death Record Search As of 09/24/2013,the Social Security Administration has no death record on file for James M Watson. Social Security Number [X]Verifed [] Not Verified Employment Search During a search for employment of our defendant no employment information was provided prior to the investigation or found during the Investigation. Business Records Search No business records found. Creditor Header Inquiry The latest address from the credit header info is: Address: 31 EISENHOWER CROSS RD, MILL HALL, PA 17751 9320 Department of Motor Unable to obtain Motor Vehicle Records in the State of Pennsylvania. Vehicle Records Search* Drivers Ucense Information Search License 1: []Govemmental**+ N WATSON [X]Non-governmental State Name: Pennsylvania Address: 605 CANAL ST, LOCK HAVEN, PA 17745 3715 Non Governmental:Y Issue Date: No issue date reported. Expiration Date: No expiration date reported. Date Range: (8/1994-3/2003) Professional Ucenses Search No records found. Freedom Of Information Act Inquiry The following addresses were sent to the United States Postal Made to U.S. Postal Service inspector at the zip code listed with no return information to date: PO BOX 1243 I MECHANICSBURG I PA 1 17055 1243 CUMBERLAND PO BOX 137A I SALONA I PA 1 17767 0137 I CLINTON 1296 ASPER DRIVE I BOILING SPRINGS 1 PA I 170071 CUMBERLAND COUNTY Military Search Not on Active Duty; Did not leave Active Duty within the past 367 days; Has not been notified of a future call up to Active Duty Inquiry of Relatives, 717-241-4385: Called possible neighbor, Steven and Cathy Clay, Neighbors,&Friends answering machine answered,no message left. 570-726-3061: Called possible relative, James Watson Jr,there was no answer. Comments: 717-249-5778:Called number listed to defendant,James Watson, there was no answer. *Data not available in AL,AR,CA,HI,NH,OR,PA,VA,WA.**Historical data in CO,DE,ID,IL,KY,LA,MD,MA,MS,MO,NH,ND, SC,WV. +Data available in CO,CT,DE,FL,ID,IL,KY,LA,ME,MD,MA,MI,MN,MS,MO,NH,ND,OH,SC,TN,TX,WV,WI,WY. The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Under penalties of perjury,I declare that I have read the foregoing affidavit and that the facts stated in it are true. . STATE OF FLORIDA III' • A( AA i .1 .41-t4 = COUNTY OF HILLSBOROUGH SEP 2 4 2013 /Gianna Hemandez ProVest File Number: 0. 866 Sworn to or affirmed and signed before me on this_day of Provest Services LLC (Seal) p p1 2 2G1� -- Date: _ - `` JOSHUA N.PIMENTEL — Notary .Expires State May of Florida Signature o(Notary lic My Comm.Expires May 24,2015 (0 Notary No.EE 97050 c,Ants-.}..- f.. Printed Name of Notary Public Personally Known ( )Produced as identification -,1.24 •1Ir 1•.!. lit1. J 1 • Ltiti IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO CASE and/or DOCKET No.: 13-1800-CIVIL BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP;et seq. Sheriff's Sale Date: 12/4/2013 Plaintiff(Petitioner) V. DANELLE L.WATSON ; et al. Defendant(Respondent) • AFFIDAVIT OF NON-SERVICE r Complaint L.1 Summons RI Other:NOTICE OF SALE 1,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I attempted to serve JAMES M.WATSON the above process on the 1 day of October,2013,at 8:22 o'clock,AM,at 1296 ASPER DRIVE BOILING SPRINGS,PA 17007,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: E Moved 0 Unknown ❑No Answer 0 Vacant [ .J Other:NO ANSWER AT PROPERTY,NO RESPONSE TO CARD LEFT AT PROPERTY TO ARRANGE FOR SERVICE. UNABLE TO VERIFY IF DEFENDANT RESIDES BY SPEAKING WITH NEIGHBORS. Service was attempted on the following dates/times: 1)9/27/13 7:26 PM 2)9/29/13 4:06 PM 3) 10/1/13 8:22 AM Commonwealth/State of f A ) )SS: County of 6a vie I ) Before me,the undersigned notary pus 'c t is day,personally,appeared It yro.K /14S-000r to me known,who being duly sworn according to la/4 /- de,. _ .]lowing: I hereby swear or aff set forth in the foregoing Affidavit of Non-Service are true and correct. ,L6AJ Subscribed and sworn to before me 1.ignature of Affiant) this Z day o •• ,20-7" . File Number:11 A 45FC Case ID#:3767.85 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Eric M.Afflerbach,Notary Public Washington Twp.,Berks County My Commission Expires Nov. 18,2913 IN71411' IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO CASE and/or DOCKET No.: 13-1800-CIVIL BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP; et seq. Sheriffs Sale Date: 12/4/2013 Plaintiff(Petitioner) V. DANELLE L.WATSON ;et al. Defendant(Respondent) • AFFIDAVIT OF NON-SERVICE 1...._1 Complaint ri; _i Summons [I Other:NOTICE OF SALE I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I attempted to serve DANELLE L. WATSON the above process on the 1 day of October,2013,at 8:22 o'clock,AM,at 1296 ASPER DRIVE BOILING SPRINGS,PA 17007,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: 0 Moved ❑Unknown ❑No Answer ❑Vacant S'1 Other:NO ANSWER AT PROPERTY,NO RESPONSE TO CARD LEFT AT PROPERTY TO ARRANGE FOR SERVICE. UNABLE TO VERIFY IF DEFENDANT RESIDES BY SPEAKING WITH NEIGHBORS. Service was attempted on the following dates/times: 1)9/27/13 7:26 PM 2)9/29/13 4:06 PM 3) 10/1/13 8:22 AM Commonwealth/State of (0 )SS: County of ereKi ) Before me,the undersigned notary public,this :P'personally,appeared R ra, Nt a.WI to me known,who being duly sworn according to law,deposes th- fs owing: I hereby swear or affirm,th,.Yth: se orth in the foregoing Affidavit of Non-Service are true and correct. Subscribed and sworn to before me ignature of Affiant) this 2. day of File Number:I l 45FC Case ID#:3767885 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Eric M.Afflerbach,Notary Public Washington Twp.,Berks County My Commission Expires Nov. 18,2013 TeZ WK. IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO CASE and/or DOCKET No.: 13-1800-CIVIL BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP;et seq. Sheriff's Sale Date: 12/4/2013 Plaintiff(Petitioner) V. DANELLE L. WATSON; et al. Defendant(Respondent) AFFIDAVIT OF NON-SERVICE L......1 Complaint . ]Summons R.]Other:NOTICE OF SALE I, RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I attempted to serve DANELLE L. WATSON the above process on the 30 day of September,2013,at 10:45 o'clock,AM,at 602 Glenwood Dr Ephrata,PA 17522 9783,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: ? Moved ❑Unknown ❑No Answer 0 Vacant [ .]Other: DEFENDANT DOES NOT RESIDE AT ADDRESS PROVIDED,CURRENT RESIDENTS ARE THE"GROFF'S"CONFIRMED BY SPEAKING WITH NEIGHBOR,W/F/39/5'4/145/BLND,WHO RESIDES AT 603 GLENWOOD DR,EPHRATA PA. Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of /4 )SS: County of Before me,the undersigned notary pus ',, is day,personally,appeared Bey*4. w1 p.It f' to me known,who being duly sworn according to la depo-d.t ;:following: I hereby swear or affirm tr at"a t forth in the foregoing Affidavit of Non-Service are true and correct. Subscribed and sworn to before me (Si_na£ure o Affiant) this / day of G,<— ,29 . File Number:114145 • _ Case ID#:3771744 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Eric M.Afflerbach,Notary Public Washington Twp.,Berks County 1 My Commission Expires Nov.18,2013 T4:7 Tel IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO CASE and/or DOCKET No.: 13-1800-CIVIL BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP;et seq. Sheriffs Sale Date: 12/4/2013 Plaintiff(Petitioner) V. DANELLE L. WATSON; et al. Defendant(Respondent) • AFFIDAVIT OF NON-SERVICE ri Complaint ......1 Summons [I Other: NOTICE OF SALE I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I attempted to serve JAMES M.WATSON the above process on the 3 day of October,2013,at 7:00 o'clock,AM,at 31 Eisenhower Cross Rd Mill Hall,PA 17751 ,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: E Moved ❑Unknown ❑No Answer ❑Vacant riii Other:NO ANSWER AT PROPERTY,NO RESPONSE TO CARD LEFT AT PROPERTY TO ARRANGE FOR SERVICE. UNABLE TO MAKE CONTACT WITH NEIGHBORS TO CONFIRM DEFENDANT RESIDES. Service was attempted on the following dates/times: 1)9/29/13 6:22 PM 2)10/2/13 2:05 PM 3) 10/3/13 7:00 AM Commonwealth/State of PA ) )SS: County of 6 .er f ) Before me,the undersigned notary public,th. day,personally,appeared gr.,. A.4 rF f to me known,who being duly sworn according to law,deposes -,. owing: I hereby swear or affirm h. -t forth in the foregoing Affidavit of Non-Service are true and correct. Aid( Subscribed and sworn to iignat_of Affiant) this 7 day of G f- �. C File Number:1141 5FC Case ID#:3771744 COMMONWEALTH OF PENNSYLVANIq Notary Public Notarial Seal Eric M.Afflerbach,Notary public Washington Twp.,eerks County My Commission Expires Nov. 18,2013 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO CASE and/or DOCKET No.: 13-1800-CIVIL BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP;et seq. Sheriffs Sale Date: 12/4/2013 Plaintiff(Petitioner) V. DANELLE L. WATSON;et al. Defendant(Respondent) • AFFIDAVIT OF NON-SERVICE ...]Complaint L.. Summons RI Other:NOTICE OF SALE I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I attempted to serve JAMES M.WATSON the above process on the 3 day of October,2013,at 7:20 o'clock,AM,at 605 Canal St.Lock Haven,PA 17745, County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: Defendant was not served because: E Moved ❑Unknown ❑No Answer ❑Vacant CSI Other:NO ANSWER AT PROPERTY,NO RESPONSE TO CARD LEFT AT PROPERTY TO ARRANGE FOR SERVICE.UNABLE TO MAKE CONTACT WITH NEIGHBORS TO CONFIRM DEFENDANT RESIDES. Service was attempted on the following dates/times: 1)9/29/13 5:50 PM 2) 10/2/13 2:25 PM 3) 10/3/13 7:20 AM Commonwealth/State of e.4 ) )SS: County of A tic i ) Before me,the undersigned notary put 'c •s day,personally,appeared /l y.," /li(AilC,f' to me known,who being duly sworn according to law,depo •-,following: I hereby swear or affi th. c set forth in the foregoing Affidavit of Non-Service are true and correct. Subscribed and sworn ■ :- , - me ignature of Affiant) this 7 day of - ,20 File Number:111 45FC Case ID#:3771744 Notary Public KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP IN THE COURT OF COMMON PLEAS 7105 Corporate Drive PTX B-209 OF Cumberland COUNTY Plano, TX 75024" vs. No. 13-1800-Civil DANELLE L. WATSON and JAMES M. WATSON 1296 Asper Drive Boiling Springs,PA 17007 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P.430(a) Plaintiff has filed a Notice of Sheriff's Sale against Defendants,Danelle L. Watson and James M. Watson,which the Sheriff has been unable to personally serve upon Defendants,Danelle L. Watson and James M. Watson. As noted in the attached Motion,Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly,the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion,the Court should enter an order allowing Plaintiff to serve the Notice of Sheriff's Sale upon Defendants,Danelle L. Watson and James M. Watson,by posting the premises and certified mail and regular mail to the Defendant's last known addresses. 1 By: KML LAW OUP, P.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 Jill P. Jenkins Pa. ID 306588 ,j Alyk Oflazian Pa. ID 312912 Attorneys for Plaintiff KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, IN THE COURT OF COMMON PLEAS LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP of Cumberland County 7105 Corporate Drive PTX B-209 Plano,TX 75024 No. 13-1800-Civil vs. DANELLE L. WATSON JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 CERTIFICATE OF SERVICE Marlene Powers, an employee of KML Law Group, P.C., counsel for plaintiff, does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants, Danelle L. Watson and James M. Watson this�( of October 2013, by first class mail, postage prepaid. DANELLE L. WATSON 602 Glenwood Drive Ephrata, PA 17522 JAMES M. WATSON 605 Canal Street Lock Haven, PA 17745 DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 602 Glenwood Drive Ephrata, PA 17522 JAMES M. WATSON 31 Eisenhower Cross Road Mill Hall, PA 17751 By: KML Law Group, P.C. Marlene Powers, Legal Secretary Direct Phone: 215-825-6340 — 1 BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP IN THE COURT OF COMMON PLEAS FKA COUNTRYWIDE HOME LOANS SERVICING, LP OF Cumberland COUNTY 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. 13-1800-Civil-'3...a, , DANELLE L. WATSON and JAMES M. WATSON -(7 N, 1296 Asper Drive v-,- Boiling Springs,PA 17007 `- ORDER .. AND NOW,this ‘04 day lip4,2Q+3,upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a)and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants,Danelle L. Watson and James M. Watson,have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendants,Danelle L. Watson and James M. Watson,by posting a copy of the Notice upon the premises 1296 Asper Drive,Boiling Springs,PA, 17007, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known addresses at 602 Glenwood Drive, Ephrata,PA 17522, 1296 Asper Drive,Boiling Springs,PA 17007, 31 Eisenhower Cross Road,Mill Hall,PA 17751 and 605 Canal Street, Lock Haven, PA 17745,and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants, Danelle L. Watson and James M. Watson, by sending copies of same to Defendant's last known addresses by certified and regular mail and by posting the premises. Service is complete upon mailing. ;30,11:vliellfAir- iordire ..00. ow coeo, Distribution list: ,/Michael T. McKeever, Esquire, Suite 5000—BNY Independence Center, 701 Market Street, n, Philadelphia, PA 19106-1532 �5J DANELLE L. WATSON, 602 Glenwood Dr. Ephrata, PA 17522 c1a JAMES M. WATSON, 605 Canal St. Lock Haven, PA 17745 , r KML LAW GROUP,P.C. 114145FC Suite 5000 CF: 04/08/2013 BNY Mellon Independence Center SD: 12/04/2013 701 Market Street P i:a: $280,258.44 Philadelphia,PA 19106-1532 215-627-1322 r '_k" xit ' Attorney for Plaintiff BANK OF AMERICA,N.A., SUCCESSOR BY � f4, "' � 1 r' II tt ar— OURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, o Y L'► LP FKA COUNTRYWIDE HOME LOANS of Cumberland County SERVICING,LP 7105 Corporate Drive CIVIL ACTION—LAW PTX B-209 Plano,TX 75024 ACTION OF MORTGAGE FORECLOSURE Plaintiff vs. Term No. 13-1800-Civil DANELLE L. WATSON JAMES M. WATSON Mortgagor(s)and Record Owner(s) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c) (2) Veronica Cosme, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriffs Office/competent adult(copy of return attached). ( ) Certified mail by KML Law Group, P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group, P.C.to Attorney for Defendant(s)of record(proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. (X) Premises was posted by Sheriffs Office/competent adult(copy of return attached). ( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached). (X) Certified Mail&ordinary mail by KML Law Group,P.C. (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, BY: Veronica Cosme Legal Assistant billoc:tiigc.., ;•:,---,,.. O 01 [D ill1 to}C)%1 a N tl 0 to t4 h Q L �a 2 N r a-ry 1 0 ,C .N..172. yr. r -a. C+}y{164.14, 1 a. w Cl)) ♦+ V `a v Q > �L a m a) c V) ti. m L H °0 N E = 8 _ x° Z h- a) R r SVI Ec a7a N w.O C 5 O. < O.R 0 W y D a)a c a d V'_ 6 7 V.t�U H 0 at U C rn N Fe ,t L'L 0 0 C X N• O L .0. Z co ya. rn Qm co W N' p d o• c n F-a-m m c = _ a If? 0 .c.. N 0 . r ° I Z c d '-• n c d O Q' 8 a o - L 1.D. re a W FW_- m W c) c 0.0. d"3. Om.... = CO m D E d H �� zin a' ZW D U v E o ❑❑❑❑ ' }- Q 00 -./°a m °' W(J Otj r� � C, --I U)Z a- -t N > E co 0 Q—WQ ,n u_ O_ , `a C 0 m 0� -d r) Q 0 Qm O g. 0 o y O H co V W (h Z V)at r °� NO • z�.0 01zeri CC t I-� )iO< ? a- m 2 m to o cfl o a• Fi of x H v YQQF-(ni_ Z �, Md Q4-CN a w d U UowS ZJJ� II U)H X a) 0 a. fa U n - Z ❑❑❑❑❑ mmW > WZm N N=m'� 0 0 h=0Q0Q 000 14 Q "' MO N ', H O 000Ln 000.0 0.m_n.= 0 U Q �U d N 9+ y+ a o C cG o = w r° N, °0 0 0 2 a ) 0 m d -a -Q7 : 7 Z N N 06 _ co L N e t°0. n 0 cn W a. a0 i V O Ct a � Q a ti °UDYJM �c CO LL J WDQWQ� a� d W Q '-° ii Z -1tW--�-Io _ a - 0 Z▪ O 5 p 2 p� r N M V' cci co t� oD f°.3 0 CO N.0.a- . • s O(° ' C.. ,P e �tg t, = w _ -•k .. : =OG� � v S3-tltittt o o :.: 2 - c lr ,. is __ to _ - ��. ...:... . t� ' . .. • : A: - R. w c � 6);,1:::.,..,;:.:E ;'•_� W w ter N fq V fQ t--o cR m a Q v : _O U WJ Q F W 4� W ��N LlI::• Q' �-- -` a. W ,:: !t z a ;- �` Q-yti -,,,,,,i ,;,..,!:•::' C,kr ..� ' n :?ao l.te : ';'1. oR 4V q o �: Q `i , o 6 4Q. .v t a : }61:''.•-• � r M' ''' • Z e. z.0 ;'2 : Z- •-.d p •. C9 es r • •.':'-:• � .I) , w E.,:0 c Qp ; Qw Q o ': • • • Print�Your Documents _ Page 2 o:: USPS:'Maniteyt'Mallingyatem _ - Page ' 1 - .. Mai1EZ 5 Mama:; Address I Parmit Number:' : I MAC Ver Num6r_r . ...:...,,.- .RY4L Law Coup: -- �.° I 123 .. ..- r ? I fionnectS5ip:;POgiatiCS::6.5• 701:j Maxket Street :,.';.:!,.:.''..1.:!1.1......1:..-T....:::::...-::—..... .- -- _ Saxfe 5000 :" 1 Sequence ilumbei - E Class; of Mail:" - Philadelphlar PA 19106: :5 j l 1544-3 ';! 1 Mired -- y :Azt cle_81 i-; Addte5aee•Name .FS ,,, `£5,' InsUZ2nce AyP = TQTal....;:....;r.„......::...,...-- :•. i: :Piece IA ,..: ::, - Dlivery Address • ::.Type:• • Postage -lee P.mouot Sender Char ._ - :; WATSON JAMES.x ?: :;;: ,_ ' ;0 460 9 91 ,: ,, 517199999170332236351.7: 605:Canal•St : 'i; _"'.ERR 1 :25 : LCCk:Naven,..PA 117-05-- - C :C: -.'3210 WATSON JAMES.M :-.:'0 440 „51. = :,•917195 917033223 3524: 31 Eisenhower-Cram:. r3 ;ERR -.1:25 ..:: :` :�. :'.. 411''4-} �PA- /iSL::..: . -: 7:, •WATSON JAMES M 0.4Q 4 81 9171999991703322363571" �602Glenwood-Dr .•ERR 125 " Eph:rat PIS-T'S�2 is ." WATSON, DIIIELLE L :'.-0 460 f 81.:.:.•9171999991703.32236354,9" 605•Cana1 t,'! .:ER1 1125 - . " LOCI; Hagen,.:PA 17745::,. ;:r ": 3`:10 .. WPTSON D 43JELL£ L A 460• 917194 9991103322363595: '31:EieenhOwei.Crb s Rd "ERR - 1 25 . }till;d4li-:.PA 17751 is ::c . 3:;10. • WATS01t, DANELLE L . • •" :.0 460 Q.s]• 9 7199999 ?03322363562 602'Glen ood'Or -ERR' 1-.25 ... s;-:';• '•'- WATSON JAMES k ;0 460 4 81 - 5171999991703322363579 1296_Asper:Drive '`�' ..'ERR 1;25 ..• . - ' ..t.` . .:Boiling�Spridgs PA-1'1007 C 3.10 WATSON, DANELLE L ':0 460 - < 1..3.1 .: 9171999991?0.3322363586 1246:ASUer Drive„ :j !FRR 1.25•!:.: .'Soiling Springs PA-1.1007 ,,.,,•_ .. ,-;' 3,10 - ERRO7£x CPR]srORaER J 0 460 4 81 '' 917199.9991703322363597. 470:Croa ngs Way -`: FAR .....4.-..,F. ..:•:::.;;;:.:.....5• .... ' ... ��Hanche�rei S PA-L7395'�.. -:.C �;: ::�. -3-.70 : ,'. ..9AR4EY M);LISSA L .'. : ;,:i.:460,.-. ,. 4 81 91?i:999991Z033•L2363609 470:'Crossings way .;;:; ,,E4R 1.25 : Manchester;.::PA-17345 ::::;;C .<' 3':le r _ Page..Totals:.; 16 "i� :'; : .:4 60 43 15 -i 48 10 . fanxlative'.Totals ;}0,;. _4• 0 43.:50 -.:::.,i4.../6,...: e '. hup,//pbpc/sendsuite%2 a 1rvefprojectshmage aspx?pd.1 „ I.1/4/2013 • IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO CASE and/or DOCKET No.: 13-1800-CIVIL BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP;et seq. Sheriffs Sale Date: 12/4/2013 Plaintiff(Petitioner) V. DANELLE L.WATSON;et al. Defendant(Respondent) AFFIDAVIT OF SERVICE �l Complaint [Ti Summons RI Other:NOTICE OF SALE I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I served DANELLE L.WATSON the above process on the 3 day of November,2013,at 9:50 o'clock,PM,at 1296 ASPER DRIVE BOILING SPRINGS,PA 17007,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: .2 By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of Pa )SS: County of IJ4 I if 1 ) Before me,the undersigned notary public,this•ay,personally,appeared R yeket M w..is 1 to me known,who being duly sworn according to law,deposes the f. • I hereby swear or affirm that e,ftc se orth in the foregoing Affidavit of Service are true and correct. ■ / Subscribed and e ore me (Sign"ure of Affiant) this 7 da Ins✓ ,20 1, . File Number:l 14145F Case ID#:3804981 Notary Public CbmmoNwEt_kup-1 or.Pt=PiNSYL'JANIA tVu1 irt,f Se Eri5jthj3 M. Public ounty18 1013 • t T .11.E. it.t. IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA,N.A.,SUCCESSOR BY MERGER TO CASE and/or DOCKET No.: 13-1800-CIVIL BAC HOME LOANS SERVICING,LP FKA COUNTRYWIDE HOME LOANS SERVICING,LP;et seq. Sheriffs Sale Date: 12/4/2013 Plaintiff(Petitioner) V. • • DANELLE L.WATSON;et al. Defendant(Respondent) AFFIDAVIT OF SERVICE El Complaint El Summons Other:NOTICE OF SALE • 1,RYAN MARKS,certify that lam eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that I served JAMES M.WATSON the above process on the 3 day of November,2013,at 9:50 o'clock,PM,at 1296 ASPER DRIVE BOILING SPRINGS,PA 17007,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: [J] By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of 94, )SS: County of /j e i to t ) Before me,the undersigned notary public is day,personally,appeared 1QYL� �� — tome known,who being duly sworn according to la ,depose following: I hereby swear or affirm t'' f set forth in the foregoing Affidavit of Service are true and correct. �� Subscribed and sw. - , 1- ore me ( gnature of Affiant) this 7 day of • t{ 20/1 File Number:l 1414,FC Case ID#:3804981 Notary Public COM11010100;?a 0•fFI 11`x„.NNSyLVA "^ Not ct'iei seal Eric N.Afilertach,Notary Public UVashingtart Trip.,Desks i'ounty My Commission F';ti,i,-=.s rtov.10,2013 • • BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP IN THE COURT OF COMMON PLEAS FKA COUNTRYWIDE HOME LOANS SERVICING, : • LP - OF Cumberland COUNTY 7105 Corporate Drive PTX B-209 Plano,TX 75024 vs. 13-1800-Civil '-`' - DANELLE L.WATSON and JAMES M.WATSON te-- L' 1296 Asper Drive . c: Boiling Springs,PA 17007 ORDER AND NOW,this 2 9 day ofO bcg2013,upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P.430(a)and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants,Danelle L.Watson and James M. Watson,have been unsuccessful,it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendants,Danelle L.Watson and James M.Watson,by posting a copy of the Notice upon the premises 1296 Asper Drive,Boiling Springs,PA, 17007,and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known addresses at 602 Glenwood Drive,Ephrata,PA 17522, 1296 Asper Drive,Boiling Springs,PA 17007,31 Eisenhower Cross Road,Mill Hall,PA 17751 and 605 Canal Street,Lock Haven,PA 17745,and that all further service of legal papers,including but not limited to motions,petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants,Danelle L.Watson and James M.Watson, by sending copies of same to Defendant's last known addresses by certified and regular mail and by posting the premises. Service is complete upon mailing. BY C T: 1s J. Distribution list: Michael T. McKeever,Esquire, Suite 5000—BNY Independence Center, 701 Market Street, Philadelphia,PA 191064 532 DANELLE L.WATSON, 602 Glenwood Dr.Ephrata,PA 17522 JAMES M.WATSON,605 Canal St. Lock Haven,PA 17745 KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff BANK OF AMERICA,N.A., SUCCESSOR BY IN THE COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS of Cumberland County SERVICING,LP 7105 Corporate Drive PTX B-209 CIVIL ACTION-LAW Plano,TX 75024 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. Term DANELLE L.WATSON No. 13-1800-Civil JAMES M.WATSON Mortgagor(s)and Record Owner(s) 1296 Asper Drive Boiling Springs,PA 17007 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA,N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP,Plaintiff in the above action,by and through an authorized employee of its attorneys,KML Law Group,P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1296 Asper Drive Boiling Springs,PA 17007 1.Name and address of Owner(s)or Reputed Owner(s): DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 2.Name and address of Defendant(s)in the judgment: DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg,PA 17105-2675 CITIBANK SOUTH DAKOTA NA C/O BLATT HASENMILLER LEIBSKER/DANIEL SANTUCCI, ESQ. 5 GREAT VALLEY PARKWAY SUITE 100 MALVERN,PA 19355 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 1296 Asper Drive Boiling Springs,PA 17007 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 22, 2013 ML Law Group, P.C. BY: Veronica Cosme Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ;='! = - -, c-)E; :� Sheriff ,^r r i till }�iUfV �rrtaaarape f. Jody S Smith ''` Chief Deputy t'.114 FE8 -6 FM 2: 09 Richard W Stewart CUMBERLAND Solicitor 4FFIcEOF SHE sw..ERIF �,ULAND COUNTY PENNSYLVANIA Bank of America, N.A. vs. Case Number Danelle Watson (et al.) 2013-1800 SHERIFF'S RETURN OF SERVICE 09/30/2013 01:34 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 1296 Asper Drive, Monroe-Township, Boiling Springs, PA 17007, Cumberland County. 11/26/2013 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 1/8/2014 01/07/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 2/5/2014 02/05/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $1,001.39 SO ANSWERS, February 06, 2014 RONNK ANDERSON, SHERIFF S"i t L.. Pill 7A z7 c;Coon,ySu tr.E.hen`I:l"elrarsoft:Inc. On September 9, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA, -- Known and numbered as, 1296 Asper Drive, ,� - M m Boiling Springs, as Exhibit "A" filed with this L� r A writ and by this Reference incorporated herein. Date: September 9, 2013 By: (11: fut Real Estate Coordinator 9 • LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No.2013-1800 Civil Term IMPROVEMENTS consist of a residential dwelling. BANK OF AMERICA,N.A. MUNICIPALITY TOWNSHIP OF vs. MONROE. DANELLE WATSON BEING PREMISES: 1296 Asper James M.Watson Drive Boiling Springs PA 17007. Atty.:Michael McKeever SOLD as the property of JAMES M. WATSON AND DANELLE L. ALL THAT CERTAIN tract or par- WATSON. cel of land and premises, situate, TAX PARCEL#22-33-0043-011. lying and being in the Township of BEING the same premises Monroe in the County of Cumberland which James-Mervin: Watson and Commonwealth of Pennsylvania, Danelle-Lynne:Watson by deed dated more particularly described as fol- 10/12/10 and recorded 10/12/loin lows;BEING Lot No 63 on the Plan of Cumberland County in Deed Book Lots of Section C of White Rock Acres, Instrument#201029172 granted and recorded in the Office of the Recorder conveyed unto James M.and Danelle of Deeds of Cumberland County on L.Watson. November 10,1970,in Plan Book 22, page 15,and more fully described as follows,to wit: BEGINNING at a point on the Western line of Asper Drive (50 feet wide) at the line dividing Lot Nos. 62 and 63 as shown on said Plan; thence by the Western line of Asper Drive the following Three courses and distances: 1) South 60 degrees 26 minutes East, 122.0 feet: 2)by a curve to the right having a radius of 125 feet,the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East:3)South 22 degrees 16 minutes the right having a radius of 125 feet,the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East;3)South 22 degrees 16 minutes West,28.56 feet;thence by the Northern line of Lot No.64 as shown on said Plan North 74 degrees 08 minutes West, 342.18 feet to a point; thence by the Southern line of LOt No.62 as shown on said Plan, North 50 degrees 20 minutes East. 233.66 to the Place of BEGINNING. CONTAINING 1.06 acres. HAVING THEREON ERECTED an aluminum 2 story type dwelling known as 1296 Asper Drive. Parcel#22-33-0943-011. 131 • • 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: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. Jisa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 5 da of October, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY'` My Commission Expires Apr 28,2014 The.Patriot-News Co. atriotXews`' 20 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 P 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. toi3-1100 Civil tam OF ANNOUcx N This ad ran on the date(s)shown below: .. 10/13/13 V 10/20/13 W , (-� / e- 10/27/13 1 ItaY pf's - Z �� Adif . as Loth of-Lots of Section G ol~ _ orn o and subscribed be • e - this 11 day of November, 2013 A.D. 1 tie ia` ',, ' 0 r ru�uyB°0t?�rhs,aod` r 1 ! / _ A. 4_I !_la.�_ B�'�M14G rotary Public II more line f wide)at the ' '92_said Plan;thence nsper wive 63. W-mi o ' dlsttances, f) and es COMMONWEALTH OF PENNSYLVANIA 122.0 feet:2)by a a minutes __.�. having a radius right men 18(1.42 feet and a N,:-'-'r i eoi o Holly Lynn W,-7.11,21,notary Public on a chord f 165.16 feet Washington wp, Dauphin Canty the right °f South 19 My Commission Expires Dec.12,2016 minutes East:3)�22+,,,1. :�� length of 1�a radius,;— th,,u rc MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES feet and' nd a 165.16 feet On a Chord Ord length of degrees 05 minutes 3 22 deem 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 -1532 215- 627 -1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B -209 Plano, TX 75024 vs. DANELLE L. WATSON JAMES M. WATSON Mortgagor(s) and Record Owner(s) 1296 Asper Drive Boiling Springs, PA 17007 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13- 1800 -Civil PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due 53.oc.) Ll Lt Pd Interest from 8/1/2013 to Date of Sale per Monthly diem at $974.32 (Costs to be added) By: $280,258.44 7 cD i p • r KML LAkV GI OUP, P.C. Michael M eelver 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 Attorneys for Plaintiff . a aS 16ln F 3!btbD cyitw- 76,77') 3 pi- 36 ggia�j No. 13- 1800 -Civil IN THE COURT OF COMMON PLEAS BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP vs. DANELLE L. WATSON and JAMES M. WATSON (Mortgagor(s) and Record Owner(s)) 1296 Asper Drive Boiling Springs, PA 17007 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group, P.C. Attorney for Plaintiff KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215- 627 -1322 ALL THAT CERTAIN tract or parcel of land and premises situate, Iying and beirig in the T�wnship. of Monroe in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows; BEING Lot No 63 on the Plan of Lots of Section C of White Rock Acres, recorded in the Office of the Recorder of Deeds of Cumberland County on November 10, 1970, in Plan Book 22, page 15, and more fully described as foliows, to wit: BEGINNING at a point on the Western line of Asper Drive (50 feet wide) at the line dividing Lot Nos. 62 and 63 as shown on said Plan; thence by the Western line of Asper Drive the following Three courses and distances: 1) South 60 degrees 26 minutes East, 122.0 feet: 2) by a curve to the right having a radius of 125 feet, the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East: 3) South 22 degrees 16 minutes the right having a radius of 125 feet, the arc length of 180.42 feet and a chord length of 165.16 feet on a chord bearing of South 19 degrees 05 minutes East; 3) South 22 degrees 16 minutes West, 28.56 feet; thence by the Northern line of Lot No. 64 as shown on said PIan North 74 degrees 08 minutes West, 342.18 feet to a point; thence by the Southern line of Lot No. 62 as shown on said Plan, North 50 degrees 20 minutes East. 233.66 to the Place of BEGINNING. CONTAINING 1.06 acres. HAVING THEREON ERECTED an aluminum 2 story type dwelling known as 1296 Asper Drive. Parcel #22-33-0043-011 IMPROVEMENTS consist of a residential dwelling MUNICIPALITY TOWNSHIP OFK4ONROE BEING PREMISES: 1296 Asper Drive Boiling Springs PA 17007 SOLD as the property of JAMES M. WATSON AND DANELLE L. WATSON TAX PARCEL #22'33'OO43'O11 BEING the same premises which James-Mervin: Watson and Danelle-Lynne: Watson by deed dated 10/12/10 and recorded 10/12/10 in Cumberland County in Deed Book Instrument # 201029172 granted and conveyed unto James M. and Dane Ile L. Watson KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 VS. DANELLE L. WATSON JAMES M. WATSON Mortgagor(s) and Record Owner(s) 1296 Asper Drive Boiling Springs, PA 17007 Plaintiff Defendant(s) t OP, -14 I 1 5 I PENNSYLVANIA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 13-1800-Civil 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. By: A UP, P.C. Michael Mce 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 Attorneys for Plaintiff flqaftlitf 3 164-0 KML Law Group, P.C. Suite 5000 BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 VS. DANELLE L. WATSON JAMES M. WATSON (Mortgagor(s) and Record Owner(s)) 1296 Asper Drive Boiling Springs, PA 17007 Plaintiff Defendant(s) ■.v 20 Pi CR -4 Art ti 1 ri '-' :ibat!kiRT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 13-1800-Civil BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by counsel, 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: 1296 Asper Drive Boiling Springs, PA 17007 1.Name and address of Owner(s) or Reputed Owner(s): DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 DANELLE L. WATSON 1 Denver Road Denver, PA 17517 DANELLE L. WATSON 602 Glenwood Drive Ephrata, PA 17522 DANELLE L. WATSON 31 Eisenhower Cross Road Mill Hall, PA 17751 DANELLE L. WATSON 605 Canal Street Lock Haven, PA 17745 JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 1 Denver Road Denver, PA 17517 JAMES M. WATSON 602 Glenwood Drive Ephrata, PA 17522 JAMES M. WATSON 31 Eisenhower Cross Road Mill Hall, PA 17751 JAMES M. WATSON 605 Canal Street Lock Haven, PA 17745 2. Name and address of Defendant(s) in the judgment: DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 DANELLE L. WATSON 1 Denver Road Denver, PA 17517 DANELLE L. WATSON 602 Glenwood Drive Ephrata, PA 17522 DANELLE L. WATSON 31 Eisenhower Cross Road Mill Hall, PA 17751 DANELLE L. WATSON 605 Canal Street Lock Haven, PA 17745 JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 1 Denver Road Denver, PA 17517 JAMES M. WATSON 602 Glenwood Drive Ephrata, PA 17522 JAMES M. WATSON 31 Eisenhower Cross Road Mill Hall, PA 17751 JAMES M. WATSON 605 Canal Street Lock Haven, PA 17745 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 CITIBANK SOUTH DAKOTA NA C/0 BLA'I"1 HASENMILLER LEIBSKER/ DANIEL SANTUCCI, ESQ. 5 GREAT VALLEY PARKWAY SUITE 100 MALVERN, PA 19355 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 1296 Asper Drive Boiling Springs, PA 17007 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 statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: By: ICMI ,AtW GROUP, P.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 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff _ti freinkcib° 1/2 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff 13-1800-Civil _:Jk . P 0 1!-.ON 0 i 2014 APR -14 AM 11: 51 CUMBERLAND COUNTY BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 VS. DANELLE L. WATSON JAMES M. WATSON Mortgagor(s) and Record Owner(s) 1296 Asper Drive Boiling Springs, PA 17007 Plaintiff Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-1800-Civil THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE AT 1EMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN AT'l'EMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: WATSON, DANELLE L. DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 Your house at 1296 Asper Drive, Boiling Springs, PA 17007 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $280,258.44 obtained by BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13-1800-Civil 1. The sale will be cancelled if you pay to BANK OF AMERICA, N.A., SUCCESSOR BY - MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFFS SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 13-1800-Civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.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 114145FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. KNIL Law Group, P.C. Suite 5000- BNY 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, IN THE COURT OF COMMON PLEAS LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B -209 Plano, TX 75024 20111 APR - 4 AM I I : 51 CUMBERLAND COUNTY 13 -1800 -Civil vs. DANELLE L. WATSON JAMES M. WATSON Mortgagor(s) and Record Owner(s) 1296 Asper Drive Boiling Springs, PA 17007 Plaintiff Defendant(s of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13- 1800 -Civil 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: WATSON, JAMES M. JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 Your house at 1296 Asper Drive, Boiling Springs, PA 17007 is scheduled to be sold at Sheriff's Sale on Wednesday, September 03, 2014, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $280,258.44 obtained by BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13-1800-Civil 1. The sale will be cancelled if you pay to BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 13-1800-Civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.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 114145FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP Vs. NO 13-1800 Civil Term CIVIL ACTION — LAW DANELLE L. WATSON, JAMES M. WATSON WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $280,258.44 L.L.: Interest FROM 8/1/2013 TO DATE OF SALE PER MONTHLY DIEM AT $974.32 Atty's Comm: Due Prothy: $2.25 Atty Paid: $1,294.39 Other Costs: Plaintiff Paid: Date: 4/4/14 (Seal) David D. Buell, Prothonota B: REQUESTING PARTY: Name: JENNIFER FRECHIE, ESQUIRE Address: KML LAW GROUP SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No, 316160 Deputy KML LAW GROUP, P.C. Suite 5000 BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. DANELLE L. WATSON JAMES M. WATSON Mortgagor(s) and Record Owner(s) 1296 Asper Drive Boiling Springs, PA 17007 Plaintiff Defendant(s) OF HE p1 2014 AUG 114 2: 2L CUP; EpLANfi P`l'iJ S Y Lgrfrit, COURT OF COMMON PLEAS 114145FC CF: 04/08/2013 SD: 09/03/2014 $280,258.44 of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13 -1800 -Civil CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Andrew Hauck, 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 Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. (X) 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). () (X) ( ) The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Res .ctfully submitted, BY: Andrew Hauck Legal Assistant i?!.‘7•11 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 VS. DANELLE L. WATSON and JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 ORDER IN THE COURT OF COMMON PLEAS • OF Cumberland COUNTY 13 -1800 -Civil 0 —4 FN.) Lc AND NOW, this 2 [ i day ofOt bbC(k2013, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.RC.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants, Danelle L. Watson and James M. Watson, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendants, Danelle L. Watson and James M. Watson, by posting a copy of the Notice upon the premises 1296 Asper Drive, Boiling Springs, PA, 17007, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known addresses at 602 Glenwood Drive, Ephrata, PA 17522, 1296 Asper Drive, Boiling Springs, PA 17007, 31 Eisenhower Cross Road, Mill Hall, PA 17751 and 605 Canal Street, Lock Haven, PA 17745, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rale of Civil Procedure 3129 may be made upon Defendants, Danelle L. Watson and James M. Watson, by sending copies of same to Defendant's last known addresses by certified and regular mail and by posting the premises. Service is complete upon mailing. BY C T: 1s J. Distribution list: Michael T. McKeever, Esquire, Suite 5000 —BNY Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 DANELLE L. WATSON, 602 Glenwood Dr. Ephrata, PA 17522 JAMES M. WATSON, 605 Canal St. Lock Haven, PA 17745 • IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP; et seq. Plaintiff (Petitioner) V. DANELLE L. WATSON; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13 -1800 -CIVIL Sheriffs Sale Date: 9/3/2014 AFFIDAVIT OF SERVICE El Complaint ❑ Summons Pi Other: NOTICE OF SALE 1, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served DANELLE L. WATSON the above process on the 7 day of May, 2014, at 5:35 o'clock, PM, at 1296 ASPER DRIVE BOILING SPRINGS, PA 17007 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: [] By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: 1) 2) 3) Commonwealth/State of 19, ) ) SS: County of Belt) ) Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: k et. Ca w f' to me known, who being I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) Subscribed and sworn to before me this ' day of-2.0rY . File Number:114145FC Case ID #:3973927 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Affierbach, Notary Public Washington Township, Berks County My Commission Expires November 13, 2017 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP; et seq. Plaintiff (Petitioner) V. DANELLE L. WATSON; et al. Defendant (Respondent) CASE and/or DOCKET No.: 13 -1800 -CIVIL Sheriff's Sale Date: 9/3/2014 AFFIDAVIT OF SERVICE El Complaint E] Summons Pi Other: NOTICE OF SALE I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I served JAMES M. WATSON the above process on the 7 day of May, 2014, at 5:35 o'clock, PM, at 1296 ASPER DRIVE BOILING SPRINGS, PA 17007 , County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: Li By posting a copy of the original process on the most public part of the property pursuant to an order of court Service was attempted on the following dates/times: I) 2) 3) Commonwealth/State of /A ) ) SS: County of 8r r lof ) Before me, the undersigned notary public, this day, personally, appeared duly sworn according to law, deposes the following: Ktvt.. G i; a f c to me known, who being I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct. (Signature of Affiant) Subscribed and sworn to before ems, this i day of , 20/Y . File Number:114145FC Case ID #:3973927 Notar COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Eric M. Afflerbach, Notary Public Washington Township, Clerks County My Commission Expires November 13, 2017 Name and Address of Sender :ML LAW GROUP, P.C. iUITE 5000 01 MARKET STREET 01 MA ELPHIA PA 9106-1532 Check type of mail or service; ❑ Certified LI Recorded Delivery (International) ❑ COD El Registered ❑ Delivery Confirmation LI Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑ Insured Affix Stamp Here (If issued asa certificate of mailing, or for additional copies of this bill) Postmark and Date of Receipt t 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 RG) Fee RR Fee 1. WATSON, DANELLE L. 1296 Asper Drive Boiling Springs, PA 17007 WATSON, 605 Canal Lock Haven, DANELLE Street PA 17745 L. 2. WATSON, JAMES M. 1296 Asper Drive_ Boiling Springs, PA 17007 WATSON, DANELLE L. WATSON, 1 Denver Denver, WATSON, JAMES Road PA 17517 JAMES M. M. .s, .36. ` i .k... �' ,; '� •o�r Q a J i'\4 401\1 pen w . 3, r b 1 Denver Road - Denver, PA 17517 WATSON, DANELLE L. 602 Glenwood Drive 602 Glenwood Ephrata, WATSON, Drive PA 17522 JAMES M. Eo ST 9 g N -, O0 D ' Ephrata, PA 17522 WATSON, DANELLE L. `31 Eisenhower Cross Road Mill Hall, WATSON, —605 Canal PA 17751 JAMES Street M. si 5.t r ®, m 70706 Mill Hall, PA 11751 Lock Haven, PA 17745 0fi, t 6. =.' ..�� -"r, 7. 8. Total Nurfcber of Pie e, Listed by Sender `Total Number of PiQ s Received at P07O}fi4e Postmaster, Per me of r ceiving employee) See Privacy Act Statement on Reverse PS Form 37Z,-Eebk 2002 (Pageilpf 2) Complete by Typewriter, Ink, or Ball Point Pen 114145FC Cumberland County Sale Date: 09/03/2014 DANELLE L. WATSON & JAMES M. WATSON Name and Address of Sender :ML LAW GROUP, P.C. U ITE 5000 01 MARKET STREET °HILADELPHIA, PA 9106-1532 Check type of mail or service; ❑ Certified ❑ Recorded Delivery (International) ❑ COD E 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. DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 TENANTS/OCCUPANTS 1296 Asper Boiling Springs, Drive PA 17007 2. PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 4.,:; .;.: ='r: �•r �: i.:t� Harrisburg, PA 17105-2675 CITIBANK SOUTH DAKOTA NA C/O BLATT HASENMILLER LEIBSKER/ DANIEL SANTUCCI, ESQ. ��.,;, •�. =' y,^ 'r . J�aAtEp$Tq ' o fr- c o 3• .; yt . Spm +'' v • o.0:3 �\ � i- . • �' 4. rt., C.-7 o 9'0.9 p `�" '• 5 GREAT VALLEY PARKWAY SUITE 100 MALVERN, PA 19355 . .41 .�� N881 ' s� -Pp s� \‘,.‘ -f',0�17� 5. vY �O � � 6® o 57- 6, 6. 7. 8. Total Number Listed by Sen i Pieces et r i,. Total Number of Pces ceived at Poffice Postmaster, Per (Nam o reiy(ng employee) I/ See Privacy Act Statement on Reverse PS Form 387 , brua 2 (Page 1 of 2) Complete by Typewriter, Ink, or Ball Point Pen 114145FC Cumberland County Sale Date: 09/03/2014 DANELLE L. WATSON & JAMES M. WATSON Print Your Documents USPS Manifest Mailing System Page 6 of 8 Page 6 Mailer's Name & Address KML Law Group 701 Market Street Suite 5000. Philadelphia, PA 19106 Permit Number 123 MAC Ver. Number ConnectShip Progistics 6.5 Sequence Number 2069-2 Class of Mail Mixed Artide #1 Piece ID Addressee Name, Delivery Address ES Typo Postage ES Fee Insurance Amount Due/ Sender Total Charge 9171999991703406847773 9171999991703406847780 9171999991703406847797 9171999991703406847803 9171999991703406847810. 9171999991703406847827 9171999991703406847834 9171999991703406847841 9171999991703406847858 9171999991703406847865 9171999991703406847872 9171999991703406847889 CALLAHAN, MICHAEL F. 8218 Codex Street Philadelphia,PA 19136 LETONA, COOPER P. 5973 Woodbine Avenue Philadelphia, PA 19131. LETONA, COOPER P. 6744 Woodland Avenue Philadelphia, PA 19142 VALDEZ, EDWARD PO Box 1 00 Fountalnvile, PA 18923 'VALDEZ, EDWARD 1601 Broad St. Perkasie, PA 18944- VALDEZ, EDWARD 713 Shady Grove Circle Doylestown, PA 18901 WHITE, DENISE R. 13495 PORTSMOTH COURT FONTANA, CA 92336 1(ASPER, ROSEMARIE. 148 Oak Place Blakeslee, PA 18334 COLLINS, ROBERTA 220 SAPPLING HILL WAY GAITHERSBURG, MO 20877 WATSON. JAMES M. 1296 Asper Drive Boiling Springs. PA 17007 WATSON, DANELLE L. 1 Denver Road Denver, PA 17517 WATSON, DANELLE L 602 Glenwood Drive Ephrata, PA 17522 ERR C ERR c ERR C ERR. C ERR C ERR c ERR C ERR, C ERR C ERR C ERR C ERR C 0.490 0.490 0.490 0.490 0.490 0.490 0.490 0.490 0.490'. 0.490 0.490 0.490 1.35 3.30 1.35 3.30 1.35 3.30 1.35. 3.30 1.35 3.30 1.35 3.30 1.35 3.30, 1.35 3.30 1.35 3.30 1.35 3.30 1.35 3.30 1.35 3.30 5.34 5.34 5.34 5.34 5.34 5.34 5.34 5.34 5.34 5.34 5.34 5.34 Page Totals Cumulative 'Totals 12 72 5.88 35.28 55.80 334.80 64.08 384.48 http://pbpc/sendsuite%2Olive/projects/image.aspx?pd=1 4/30/2014 Print Your Documents USPS Manifest Mailing System Page 7 of 8 Page 7 Mailers Name & Address KML Law Group 701 Market Street Suite 5000 Philadelphia, PA 19106 Permit Number 123 MAC Ver. Number ConnectShip Progistics 6,5 Sequence Number 2069-2 Article #I Piece ID Addressee Name Delivery Address ES Type Postage ES Fee Class of Mail Mixed Insurance Amount Due/ Sander Total Charge 9171999991703406847896 9171999991703406847902 9171999991703406847919 9171999991703406847926 9171999991703406847933 9171999991703406847940 9171999991703406847957 9171999991703408847964 9171999991703405847971 9171999991703406847998 9171999991703406847995 91719999917034066480 WATSON, DANELLE t. 31 Eisenhower Cross Road MB Han, PA 17751 WATSON. DANELLE L. 605 Canal Street Lock Haven, PA 17745 WATSON.JAMES M. 602 Glenwood Drive Ephrata, PA 17522 WATSON. JAMES M. 1 Denver Road Denver, PA 17517 WATSON, JAMES M. .31 Eisenhower Cross Road Mill Hail. PA 17751 WATSON, JAMES M. 005 Canal Street Lock Haven, PA 17745 HAIR. TODD R. 169 East North Street Carlisle, PA 17013 WATSON, DANELLE L. 1296 Asper Drive Boiling Springs,PA 17007 .NAYOU-VAYE, MONUE H. 133 Larose Olive Coatesville. PA 19320 KALUGIN, ERIC S. 315 Old Eagle School Road Wayne. PA 19007 CROMWELL, ALMA J.L PO Box2492 Westminster, MD 21155 CROMWELL, ALMA J.L. 20 West Kang Street Littleslown, PA 17340 0.490 ERR 1,35 C 3,30 0.490 ERR 1.35 C 3.30 0.490 ERR 1.35 C 3.30 0.490 ERR 1.35 C 3,30 0.490 ERR 1,35 C 3.30 0.490 ERR 1.35 C 3,30 0.490 ERR 1.35 3.30 0.490 ERR 1.35 C 3.30 0.490 ERR 1.35 C 3.30 0.490 ERR 1.35 C 3.30 0.490 ERR 1,35 C 3,30 0.490 ERR 1.35 C 3.30 5.34 5.34 5.34- 5.34 5.34 5.34 5.34 5.34 5.34 5.34 5.34 5.34 Page Totals 12 5.88 55.80 64.08 84 Cumulative Totals httn://obnc/sendsuiteV Olive/nrninri=1 41,16 390.60 448.56 /I /7nPiA14 KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP 7105 Corporate Drive PTX B-209 Plano, TX 75024 vs. DANELLE L. WATSON JAMES M. WATSON Mortgagor(s) and Record Owner(s) 1296 Asper Drive Boiling Springs, PA 17007 Defendant(s) Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 13 -1800 -Civil AFFIDAVIT PURSUANT TO RULE 3129 BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by and through an authorized employee of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1296 Asper Drive Boiling Springs, PA 17007 1.Name and address of Owner(s) or Reputed Owner(s): DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 2. Name and address of Defendant(s) in the judgment: DANELLE L. WATSON 1296 Asper Drive Boiling Springs, PA 17007 JAMES M. WATSON 1296 Asper Drive Boiling Springs, PA 17007 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 CITIBANK SOUTH DAKOTA NA CIO BLATT HASENMILLER LEIBSKER/ DANIEL SANTUCCI, ESQ. 5 GREAT VALLEY PARKWAY SUITE 100 MALVERN, PA 19355 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 1296 Asper Drive Boiling Springs, PA 17007 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: August 12, 2014 KML Law Group, P.C. BY: Andrew Hauck Legal Assistant Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFI CE OF THE ff P+.Ff r,. HE. PROTK F ICE THE. 1' OCT 30 MI 91147 CIJ PENNSY'LVANI ` UNTY Bank of America, N.A. vs. Danelle Watson (et al.) Case Number 2013-1800 SHERIFF'S RETURN OF SERVICE 06/17/2014 10:00 AM - 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 1296 Asper Drive, Boiling Springs, PA 17007, Cumberland County. 09/03/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on Wednesday, September, 3, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP FKA, Countrywide Home Loans Servicing, LP , being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $788.34 SO ANSWERS, October 07, 2014 RONNR ANDERSON, SHERIFF (::) cbuniySu:'e Sheriff. Te eosoft, nc 44 q 3 - 1 On May 19, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Known and numbered as, 1296 Asper Road, Boiling Springs, as Exhibit "A" filed with this Writ and by this Reference incorporated herein. Date: May 19, 2014 [ 0 :E d L - HdV 4101 By: LLS t,,J)) Da* Real Estate Coordinator LXIII 29 CUMBERLAND LAW JOURNAL r,, 07/11/14 Writ No. 2013-1800 Civil BANK OF AMERICA, N.A. DANELLE WATSON ,James M. Watson Atty.: Michael McKeever IMPROVEMENTS consist of a residential' dwelling 0.° .•BEING PREMISES: 1296 Asper, Drive, Boiling Springs, PA 17007. SOLD as the PrOPertY of DANELLE L. WATSON and JAMES M: WATSON.. Y ' i • ' TAX PARCEL #2233-0043-011. 107 The Patriot -News Co. ,.— �.900 Patriot Drive Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 1ie atriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2013.1800 Civil Term BANK OF AMERICA, N.A. vs. DANEU.E WATSON James M. Watson Atty: Michael McKeever IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 1296 Asper Drive Boiling Springs, PA 17007 SOLD as the property of DANELLE L. WATSON and JAMES M. WATSON TAX PARCEL #22-33-0043-011 Sworn t This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 ubscpbed before me this 20 day of August, 2014 A.D. ( „� N•tary'P bf COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Sheryl Marie Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bank of America SBM BAC Home Loan Ser LP FKA Countrywide Horne Loans Ser LP is the grantee the same having been sold to said grantee on the 3rd day of September A.D., 2014, under and by virtue of a writ Execution issued on the 4th day of April, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 1800, at the suit of Bank of America SBM BAC Home Loan Ser LP FKA Countrywide Home Loan Ser LP against Danelle L & James M Watson is duly recorded as Instrument Number 201424910. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this (34;P:p.it4 c.to day of Recorder of Deeds eeds. Cumberland County, Carlisle, PA My Co T ission Expires the First Monday of Jan. 2018 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: July 11, July 18 and July 25, 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. 'e Ma Coyne, ditor SWORN TO AND SUBSCRIBED before me this 25 day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018