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HomeMy WebLinkAbout13-3055 r Supreme Cour-t�of Pennsylvania Cour C�,om� m n;Pleas 0 � For Prothonotary Use Only: >Cov et I CU � EN�311) County Docket No : - 5 "z `�_ 11-4 1 77ie 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 hy law or rules of court. Commencement of Action: S 0 Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiff's Name: BANK OF AMERICA, N.A., AS Lead Defendant's Name: PHILLIP P. STRINGER, II C SUCCESSOR BY MERGER TO BAC HOME LOANS T SERVICING, LP F/K/A COUNTRYWIDE HOME I LOANS SERVICING LP 0 Are money damages requested? ❑ Yes 0 No Dollar Amount Requested: ❑ within arbitration limits (Check one) ❑D outside arbitration limits N Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJ Appeal? ❑ Yes 0 No A Name of Plaintiff/Appellant's Attorney: John D. Krohn, Esa. Id. No.312244 Phelan Hallinan LLP ! ❑ Check here if you have no attorney (are a Self- Represented (Pro Se) Litigant) r Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY 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 APPEALS ❑ 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 ❑ Statutory Appeal: Other ❑ Product Liability (does not S include mass tort) ❑ Employment Dispute: E 11 Slander/Libel/ Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: 1I MASS TORT ❑ Other: v U ❑ Asbestos f N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment f ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Pa.RC.P. 205.5 Updated 0110112011 OF THE PR 1013 �4Y 29 Arl 10.43 C €'fiBERLAND COUNTY PENNS YLVANIA PHELAN HALLINAN, LLP John D. Krohn, Esq., Id. No.312244 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 21.5 -563 -7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP COURT OF COMMON PLEAS F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION 7105 CORPORATE DRIVE PLANO, TX 75024 TERM Plaintiff NO. V. CUMBERLAND COUNTY PHILLIP P. STRINGER, II LORI D. STRINGER 5714 GRANADA DRIVE, APARTMENT 216 SARASOTA, FL 34231 -8332 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE I/ jj File #: 306099 �L'17 �3s P LLagi�o� 1. Plaintiff is BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: PHILLIP P. STRINGER, II LORI D. STRINGER 5714 GRANADA DRIVE, APARTMENT 216 SARASOTA, FL 34231 -8332 who is /are the mortgagor(s) and /or real owner(s) of the property hereinafter described. 3. On 09/22/2008 PHI LLIP P. STRINGER, II and LORI D. STRINGER made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR COUNTRYWIDE BANK, FSB., which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200832809. By Assignment of Mortgage recorded 10/19/2011 the mortgage was assigned to PLAINTIFF, which Assignment is recorded ,in Assignment of Mortgage Instrument No. 201128913.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified File #: 306099 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 04/09/2013: Principal Balance $199,646.69 Interest $37,144.09 03/01/2010 through 04/30/2013 Late Charges $297.68 Property Inspections $195.00 Property Preservation $2,016.60 Title Costs $400.00 Escrow Deficit $10,976.07 TOTAL $250,676.13 7. Plaintiff is not seeking a judgment of personal" liability (or an in person am judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. The mortgage premises are vacant and abandoned 9. This action does not come under Act 91 of 1983 because the mortgage is FHA- insured. File #: 306099 WHEREFORE, Plaintiff demands an in rem judgment against the Defendants) in the sum of $250,676.13, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: John D. Kr A, Esq., Id. No.312244 Attorney for Plaintiff File #: 306099 LEGAL DESCRIPTION All that certain lot or parcel of land situate in the Village of Carlisle Springs, Middlesex Township, County of Cumberland, Commonwealth of Pennsylvania, and being more particularly described as follows: BEGINNING at a point, which point is a corner of lands now or formerly of H.R. Gutshall and lands now or formerly of Merle H. Myers, Jr. and Marlene L. Myers, his wife; thence along lands now or formerly of the said H.R. Gutshall South 71 degrees West 242.8 feet to a point; thence along lands now or formerly of Robert L. Gutshall North 15 degrees 45 minutes West 895 feet to a point; thence along lands now or formerly of Harvey Sheaffer North 80 degrees 30 minutes East 514 feet, more or less, to a point in the line of land now or formerly of Harvey Sheaffer, Ralph Sheaffer, Ira Lightner and Ruth Cornman South 14 degrees 45 minutes East 735 feet, more or less, to a point in the center of the State Highway Route No. 34; thence by the center line of said Pennsylvania Route No. 34 South 32 degrees 15 minutes West a distance of 3.3 feet to a point, the southeastern corner of land now or formerly of Mel A. Spidle and wife; thence along said lands of Spidle North 66 3/4 degrees West 222.5 feet to a point (inadvertently not included in prior deed description); thence along lands now or formerly of the said Merle H. Myers, Jr. and wife South 03 degrees East 197.5 feet to a point, the place of beginning. Containing 8.939 acres. THE IMPROVEMENTS THEREON BEING KNOWN AS 3430 SPRING ROAD, CARLISLE, PA 17013. BEING the same property conveyed by deed dated October 29, 2007 from F. Elise Gutshall to Philip P. Stringer II and Lori D. Stringer and recorded in the Office of the Register of Deeds for Cumberland County on November 1, 2007 at Instrument #200741498. PROPERTY ADDRESS: 3430 SPRING ROAD, CARLISLE, PA 17013 -8739 PARCEL # 21 -05- 0429 -005 File #: 306099 a VERIFICATION ,hereby states that h sh 's ��llY1� -���' j}`Q(�° BANK OF AMERICA, N.A., Plaintiff in this matter, that he she' authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true e and correct to the best of his r 'nformation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: �� C�n�QQQQ, BANK OF AMERICA, N.A. File #: 306099 File #: 306099 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lase money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 306099 ' IN THE COURT OF COMMON L PLEAS BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO ' OF CUMBERLAND COUNTY, BAC HOME LOANS SERVICING; LP F /K /A COUNTRYWIDE PENNSTLVANIA HOME LOANS SERVICING, LP (20237) C-) ca - c -� Plaintiff(s) 0 co rri .-< -'a vs. CD STRINGER, PHILLIP P., IIn o STRINGER, LORI D C` r Defendants �3' �J 7 Civil � n CD =CD �. NOTICE OF RESIDENTIAL MORTGAGE' FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have an attorney, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at not charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete .a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in attempt to work out a reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service ;upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward, IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: S 13 Date Signature r Plaintiff Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Please 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: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date you Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ if yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Y Amount owed: Value: Automobile #2 : Model: Y Amount owed: Value: Other transportation (automobiles boats motorcycles ): 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: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE JAMOUNT EXPENSE AMOUNT Mortgage Food 2 Id Mortgage Utilities Car Payment(s) ) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ 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 ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if you know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, named , authorize the above to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am/are under no obligation t6use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this page along with the following information to lender: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND QQUI*TrYc Ronny R Anderson C;= THE rihOTHOI101110y Sheriff r• �i��+�o.,. 3 JUN 14 A4 8t 59 Jody S Smith ` a Chor'Deputy CUMBERLAND COUNTY Richard w Stewart PENNSYLVANIA Bank of America, N.A. Case Number vs. Phillip P Stringer, II let ai.j 2013-3055 SHERIFF'S RETURN OF SERVICE 05/31/2013 Ronny R Anderson,Sheriff,being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Phillip P Stringer, II, but was unable to locate the Defendant to 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 3430 Spring Road, Middlesex Township, Carlisle, PA 17013. Residence is vacant and the Carlisle Postmaster has informed this office that the defendant has moved and left no forwarding address. 05131/2013 Ronny R Anderson, Sheriff,being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit; Lori D Stringer, 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 3430 Spring Road, Middlesex Township, Carlisle, PA 17013. Residence is vacant and the Carlisle Postmaster has informed this office that the defendant has moved and left no forwarding address. SHERIFF COST: $60.76 SI/O/ANSWERS, rJ7�j)_`_ June 07, 2013 RONNY R ANDERSON, HERIFF PHELAN HALLINAN,LLP 24,13 AUG 29 AM IO: 48 Meredith Wooters,Esq.,Id.No.307207 161.7 JFK Boulevard,Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia,PA 19103 Meredith.Wooters@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR COURT OF COMMON PLEAS BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE CIVIL DIVISION HOME LOANS SERVICING, LP Plaintiff CUMBERLAND COUNTY vs. PHILLIP P. STRINGER, 11 No. 13-3055-CIVIL LORI D. STRINGER : Defendants : PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN,LLP By. Meredith Wooters,Esq.,Id. No.307207 Attorney for Plaintiff Date: /bsp, Svc Dept. File#799861 a g5oa' PHELAN HALLINAN,LLP '=# v ix Meredith Wooters,Esq.,Id.No.307207 1617 JFK Boulevard,Suite 1400 " ��r 1 r � COUNTY One Penn Center Plaza 9p��YLVA NIA Philadelphia,PA 19103 Mei-edith.Wooters@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR COURT OF COMMON PLEAS BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE CIVIL DIVISION HOME LOANS SERVICING, LP Plaintiff CUMBERLAND COUNTY vs. PHILLIP P. STRINGER, 11 No. 13-3055-CIVIL LORI D. STRINGER Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN, LLP By: Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Date: `(JAS 3 /nru, Svc Dept. File#799861 Q AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE PH#799861 HOME LOANS SERVICING,LP DEFENDANT SERVICE TEAM/knm t� �t PHILLIP P.STRINGER,II COURT NO.: 13-3055-CIVIL c***) LORI D.STRINGER � SERVE LORI D.STRINGER AT: TYPE OF ACTION ° 4194 NEW HAVEN CT XX Mortgage Foreclosure %��� �� PORT ORANGE,FL 32127-4918 XX Civil Action tfx-ji 0 SERVED (1,0 ir Served and made known to LORI D.STRINGER,Defendant on the i O day of bvicem OQI,20 13,at � . o'clockp_.M.,at 'II 1'I New e!, G(- A0 , ,in the manner described below: .. Defendant personally served. Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: rd Description: Age t ll Height 4 Weight I RaceiNktSex 1"--- Other I, cis ' 1r Q - , a competent adult,being duly sworn according to law,depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and sub ribed before me this it day of Paithib&r-,20!? Notary: ^O' � 1 � NOT SERVED "•°: On the day of ,20_,at o'clock .M.,I, ,a competent adult hereby state that S •` Defendant NOT FOUND because: '' *,, _Vacant Does Not Exist _Moved _Does Not Reside(Not Vacant) No Answer on at ,• at x Service Refused g5-5&m z m us Other: z o m Sworn to and subscribed o z m before me this day °m of ,20 . By: S otary: ATTORNEY FOR PLAINTIFF Chrisovalante P.Fliakos,Esq.,Id.No.94620 Lawrence T.Phelan,Esq.,Id.No.32227 Courtenay R.Dunn,Esq.,Id.No.206779 ti Francis S.Hallinan,Esq.,Id.No.62695 Mario J.Hanyon,Esq.,Id.No.203993 Daniel G.Schmieg,Esq.,Id.No.62205 John M.Kolesnik,Esq.,Id.No.308877 Michele M.Bradford,Esq.,Id.No.69849 Matthew G.Brushwood,Esq.,Id.No.310592 Judith T.Romano,Esq.,Id.No.58745 Zachary J.Jones,Esq.,Id.No.310721 Jenine R.Davey,Esq.,Id.No.87077 Justin F.Kobeski,Esq.,Id.No.200392 Lauren R.Tabas,Esq.,Id.No.93337 Adam Davis,Esq.,Id.No.203034 Jay B.Jones,Esq.,Id.No.86657 Joseph E.DeBarberie,Esq.,Id.No.315421 Andrew L.Spivack,Esq.,Id.No.84439 One Penn Center at Suburban Station 1617 John F.Kennedy Blvd., Suite 1400 Philadelphia,PA 19103-1814 '' a 41/-t G-4 a • PHELAN HALLINAN, LLP Attorney for Plaintiff Emily M. Phelan, Esq., Id. No.315250 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 emily.phelan @phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC . HOME LOANS SERVICING, LP F/K/A COURT OF COMMON PLEASc:- — COUNTRYWIDE HOME LOANS me SERVICING, LP CIVIL DIVISION = vs. : No. 13-3055-CIVIL r _ PHILLIP P. STRINGER, II c5 ' • LORI D. STRINGER c= PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against PHILLIP P. STRINGER,II and LORI D. STRINGER, Defendants for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $250,676.13 TOTAL $250,676.13 I hereby certify that(1) the Defendants' last known addresses are 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231-8332, 3430 SPRING ROAD, CARLISLE, PA 17013-8739, and 4194 NEW HAVEN COURT, PORT ORANGE, FL 32127-4918, and (2) that notice has been given in accordance with Rule Pa.R.C.P 24 . Date Emily M. Phelan, Esq., Id. No.315250 Attorney f Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: A.,3011_4_ PH#799861 PROTHONOTARY ail0116)‘ gilLi 9861 # 3a ioSb NChCe* PHELAN HALLINAN, LLP Attorney for Plaintiff Emily M. Phelan, Esq., Id. No.315250 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 emily.phelan@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS : CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A : COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS SERVICING, LP : CIVIL DIVISION vs. : No. 13-3055-CIVIL PHILLIP P. STRINGER, II LORI D. STRINGER AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant PHILLIP P. STRINGER, II is over 18 years of age and last known addresses are 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231- 8332 and 3430 SPRING ROAD, CARLISLE, PA 17013-8739. (c) that defendant LORI D. STRINGER is over 18 years of age and last known addresses are 4194 NEW HAVEN COURT, PORT ORANGE, FL 32127-4918 and 3430 SPRING ROAD, CARLISLE, PA 17013-8739. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. / Date z1G' 1� 1 � Phelan H,0inan, LLP Emily M. Phelan, Esq., Id. No.315250 Attorney for Plaintiff PHELAN HALLINAN, LLP I 6 I 7 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 799861 Department of Defense Manpower Data Center Results as of:Jan-29-20141205:57 AM SCRA 3.0 •,"l dd Status Report Pursuant to Servicemeixbers Civil Relief Act Last Name: STRINGER First Name: PHILLIP Middle Name: P Active Duty Status As Of: Jan-29-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. f,. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Department of Defense Manpower Data Center Results as of:Jan-29-201412:06:06 AM SCRA 3.0 A'', Status Report :a° Pursuant to Servieemembets Civil Relief Act Last Name: STRINGER First Name: LORI Middle Name: D Active Duty Status As Of: Jan-29-2014 On Active Duty On Active Duty Status Date Active Duty Start Date, Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. )110,1, yit / - f Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Department of Defense Manpower Data Center Results as of:Jan-29-2014 12:06:06 AM SCRA 3.0 t rir t : "' Status Report Pursuant to Servicetnembers Civil Relief Act Last Name: BAUGHMAN First Name: LORI Middle Name: Active Duty Status As Of: Jan-29-2014 On Active Duty On Active Duty Status Date Active Duty Start Date- Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Da s of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. )111U" Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 — .. .. . . . .. .... .... .................„„t„..t.................„„E..„„„.E.„.....„..............,.„,_... EH:. . ..........................„E„.........„..„...„...............„................... .......... . .. . . . . . .BANK OF AMERICA;N.A,, AS SUCCESSOR BY (1,01..YRI:OE C()MMON Pl.,F,AS MERGER'TO BAC HOME.I.:0AN1.; SERVICING, CIVIL I)IVISIC)N L .FIKIA COUNTRYWIDE ROME LOANS SERVICING,LP , . . NO. 13-3055-CIVIL PIainta V. CAIN'IBERLANTD C.4/UNT0 .. - PEEILIIP,P.STRINGER,I.I. LORI D.STRINGER " Defor,dant.(s) TO; PHILLIP 0,STRINGF.R.1.1 57 14 GRANi"dlIA DR,,INE APARTMENT 2 / SARASOTA,H.:1423 I•8....../i2 , ,. ' • 6 .... 1 .04 61 7 CI 1.)/VIT,OF NOTICE: /.....,...... ./1„....„..„...........„11_......... ....E.:2 Titts FIRM TS A 'DEBI CX.g.,LECTOR ATFFNI.VEINC.;717(.-)C01...1.„„L(..11- A 1..)ET71'. ITIIS 10 /Al IS SF:MI."10 YOU IN AN 0010011 10 001 110')' `1111.:: I0I0'ATI,;D0I0S .1...iiFERRED TO HEREIN, AND ANY .INFORNIATI.(..).N ( BTATNET) FROM YOU .\liffi... hi' tafa.,) FOR "II TAT 11,11R.POSI.',. IF 'YOU HAVE PRI-.1.\711.)1„iSTA RECE1\iED A 1:117 110R001 01. tiANKRISTYruy., Ttus C.()RRESPONDENCE IS Nc..yir :/400 SHOULT) N•(,)T FE H ('0) 017 71 TO BF:. AN 2:\.1.1E,MI'T IT) e001 LECT A .1)EBT, IVIJT C..0N1,0 .,,,6 FNI:C)RLIP,IENT OF 1,112N AGA,INS:12 P.R()PERTY, U.N.Vjl,k.TANT NgTicV, 0Th ARE iN Df'11'..Akil:T.' .i.il',CAt.)SE 0(.)1..i II :01 l'AI1 E.1.) TO F.,.„INTER A ',VP11-1:EN A 11-I.'7,,R.A.,NCTi PET SONA LTA OR BY /V1“)1011J.:1 AND Fil,Th. IN 0101Ti:\•,-. W 11 THI.Y. (......OU WI' 00111.1)iF,7„FEN5ES•Olz OBn.x711.0Ns-to THE c,I,,,vrvis sf:1- of,RTIf AC:,...:.'\INS'T Y(Ai, 101LE;;L:001I ACT WITHIN TEN DAYS I-ROM "PIE DATE(....7' 11 III...‘•••1,'."..11'ICIH, ..•:\ ,11:1):". ME...NT NIA y BE ENTI••',Rfq:) ACI„,\JNST YCYU AvVrTIRAII A 1.1-1,-:AluNG .AND 4:01) 5100 1.....OSE );(.)UR P.R12:tf1.-',RTY OR OTHIT INAPORTANT RIanTs, YOU SHOULD 'IAKE "FFITS l'..:';.,,,,FET: 'Ff.) IF 1....t`t.SVER :',El.' o0 th11.1:. 11 s1:011 110 N(...i(: HA.Vrt A I re',WYER., ii:J(O TO 01Z I FIF,PLION.I:_ :FIJI:. OFT:CF. Y.:,II Fi":=R::FH: liFix..;\:,,,.. ii us oruluF., CAI', PROVIDE YOU WITH 'NIT) 141001'.. ;0130L:I Hriz!N(.;A. i,...,,,,,,-i-J.,:,.k. H.; 01 1: Cl:',I.NCrIT /01:101) "1111) 111.11th .•:\ 1Estst):It.R, (Iti nt: (WhltE11. TI lir'. ,E;BLIE PP.ht TT)'' 4`01.1i Willi hfFCitEtRIATION i1RL..rh r.... st.E1tt. :Htt,T :N.It•:\ : ry,-:Al, ii;•;-:t•:,,;:it T1.1 rttt;1(31711...F.PERSONS tel:::A.hrti1IthECI(T) Ft.E.ET tRrt R1•;.•.; RIT httflich,of ttle.Prothontttay t.R.":mitt'r tts l'st.)tEt.:4 1,1.n' 'ii tt-timberlanti(AA:m) C:ottrtir(ut: ,1,.1;. :..)t1.1.:1ttsTit.)N. : Courthouse scithitrs. RI....AN1.1(1):):EENTy:tEtsh: i.:ErFitEtusit (Arlislt. 114 E7(.7 t3 2 H :R.". 2)01 rd 9.5 •tEAR11RR...1:::. Pi Et '.1: , •:(..1Ch7 1)12.4•StE:t hEiht: tt „....7/ i trit•••••••:::;•-••• -- B-tt• ::1::::::„±-te';•:::::r.••••1 t" PeREERrEtEht.: ittts F?I Pt.': . .... .. .... ..... .. . ...................„.„.....,.........„0„.....„„...............................„..-„,-....... ......„......„......................._„...„.„.-„:„--.............................,... ............„....„....-000,0,---------„---- . .......- - _ . BANK OF AMERICA,NA.,AS SUCCESSOR BY CQURil,OF COMMON PLEAS MERGER 10 BAC HOME LOANS SERVICIN(..l, CIVIL DIVISION EP FIKIA COUNTRYWIDE.1-1.0.ME LOANS SERVICING,LP NO,. 13-30.55,CIVIL Plaintiff v. CUMBERLAND COUNTY 99[IL.1...TP P. STRINGER,I.1 LORI I),STRINGER .17)eferidant( ) T(.1: .PHILLIP P.STRINGER, II :343()SPRING R.GAIll) (2..AFIIST....E.PA .170E3-8739 /,'..:;.; I/fill DATT,OF NOTICE: ...................1„....f .E!-1,,f ' l,,.................„____ lIHIS FIR.VI IS A I)E131 COLLE(2,TOR AllITEMFTING'10 C01.1 E(7 A DEBT. THIS NII)TICE IS SENT TO YOU IN AN KfTENII'll-10 coLitzt-si"FHE INDEBTEDNESS RIITT:IRRED ID() F)EREIN„ AND ,A,NY INFORMATION OBTAINED FROM YOU WILT. 131 usliu) Rik -11.1,A1- PlRIA/SE. IF YOU HAVE PREVICIISSLY RECEIVED A 0IS(.11.AR(liE IN .BANERLIFRlY, THIS (IK)RRESPONDTINCE IS NI IT A:I\ID SII01.111) N(f)71" BE CONSTRUED 'DID BE A' ATTEMPT TO CCIIITFECT A DEBT, BUT ONLY ./Nli ENTOREENIENT (:)fI HEN AGAINST PROPERTY. 1.11.PQX3TANT 0011 FL YOU ARE IN EYERAl.n.,T BECAUSE. YOI.1 HAVE 101 .t IIDE ENTER A VERN:II:EN APPLAI.-&ANCE EE.RSONALIX OR BY ATTORNEY AND Ill E IN 01 010 wrriq TIDE (70EIRT '1I(AIR D.DIENSES OR OBSPICTIONS TO TTIR CLAIMS SI:7.FORTH /..viii,:-N,:-:•-r yoLT. LINLESS I.'s.EII..; ACT 01 11 TIN"NAYS FROM THE.DATE OF THIS NCIFICE, A IDIXIINEINT 0/0' BT.,:F.NTER-D. .,'.V.IDNINST YOU Y,TrtiouT A ITEARINO AN/) YOI1 MAY I„,OSE YOUR PROPERTY II,:iD OTHER I1I1 IC1'A.NT 11101(19 ycl'Ll SI:II.RILD ID.AKE niis PAPLOI TO YOUR LAM:IYER i',T ONIAIII, 11390 ( 1 .30009 IN(..) 'EC) OR TELEPHONE 109 OFFICE SIFF EORTII DIFILOW. TIPS ()FIER 1 I P10090 YOU \IVITI.1 INFORIVIATION 2...1'<)I.IT HIRING/“.,..,t>,VVYIER. IF YM.i GANNoT ,),E11-:c.RD 'Bi) 01111. A 1..„AWNI.IIN THII,Ei PILINIIIIIII MAY BIF, ,:(\„1::ILI. 1 IIII pTz(i)via,..',.. NOU WIIII.INSI:(...)RMATION ABOUT ACEN(..I.IES IIITIFED IEI-4Y OPFER LIEfIIIAL SERVICES '.3F-‘).F.LIGIBE1..1 prjzsoN ) AT A RE1)1:CL,1) 1.-E,0: ()R.N,•;1 10r1.,:., Offi,::..c.0'; 0'10 i.'0.fll.10001:ary ASS09I.,A0;ioN 1lyNIBL',R1..,,V.-qi.)C'.•...):...'H',41'y (..;i......:,:,.....'...P.0H.....,,.....;0...‘,0. carkse_. P.0: :7013 2 LIBIIIIDET :-WIII,I.--ITID CAREN::II,PA. •.'-:'.L:',...•.,. „..,....' ) ,., i.,,,,,,,h ......0........-- r0,0 ..."..........k.:1(.../ '..:.-' C... . • BANK OF AMERICA, NA., AS SUCCESSOR 0? COURT OF COMMON PLEAS , MERGER TO BikC IIOME WASS,SERVICING, CIVIL,DIVISION LP F1KIA COUNTRYWIDE.HOIVIE.E0ANS SERVICING,LP . NO. ,13-3055-CIVIL Plaintiff v. CIIIMREIZ,LAND COUNTY PHILLIP P.$TRINGER, ii LORI 1151 RINGER I)efeniiant(s) 'Fa 1,0R1 D. S`FRIN(II.R .1194 NEW HAVIIiN PORT ORANGE, FL 32:27 '1918 DAT O E F NOTICII: - TI(IS Eli2\-1 IS A [)EBT COLLECTOR ATTEM,BTINCi TO COLLECT A DIRT. THIS NC.H'S/I.: IN AN .ATTEMPT (.1)1A 'THE INDEBTEDNESS REFERRED "I HLREIN. ND .'I‘NY (NR)RMATION OBTAINED PROM YkI)II WILL BE USED F02 11, YCIII HAVE PRENTOLISIN RECEIVED A DISCI-LAR(il: IN BANI'IRUF („‘Y. THLS CCIRRESP(..)NLENCE IS N(Y1 SIIOULD NO1 (II()NSIRLIED TO RE ArY; TIT1NPI" TO; oNpi 1 1 OEM) BLIT (VEY AS FINF(IRC.FVINNT OF LIJEN :ADAIPEEI PROPIEPE Y. you DEFAul:r Bro,ADsL you HAvi); To ENTER A ,:\PPEL,14.ANC1. 2, 351W 3 N' iTY kETORNEY AND FILL IN WPIITIN(3 WILT HE Co:1'LT Nil FiENSES OP. 01.111,IC'111.)ISS TEILI DECLAIMS SET NORTH A.CiAfNST Y011 IN AC'1.'WITHIN TEN DiSY)S FRON1 1((ii DATE 0.F THIS N(JIICH, A JUD(IMENT MAY Kri. `OUT A I FEAR-INC; AND Y(L NIA'Y LOSE Y01..R. PROPERTY I 13 ()1 LILE 1N13OR1/3NT PRAM'S ; LIE SRO; 11 PAPER 'PO 'VEL'S 1...A.WYER AT ON(„'E. IF YOE IN' WYER, IO 1EIIII1NF 112 1IFFICII SET F'Iy)RTH 1j-I,II,0):A/ TIES CAN PE: ; III ::•;)N 0:11 3121 111 LA\V , -s•I'.;;:u owl-, To Md.': A LAWYER, TIES LECIERIE MAY bi.; 1): II IL :ET"EI E: AR";)11T TPIAT OPSET. SEP A I1 y, ( AND CO LT ,ASSOC:NDEIN O';;;EIELNLAND CI:Pi:N.1-Y :1:R1 2 ! t Rt2J E PA 1701:', „ . 4.! " . ..„.......„.........„2............„.................—.—.....„--,....„.„....„—....._...........,.........-------„T„...................---- , .. . , „...„ ..--...„.................. J.- . ... . . . .- ..F.3t,554K OF AMERICA,N.A.,AS StICCES;i0R BY COURT()r COMMON PLEAS M../IiiRiiiER TO BAC HOME LOANS SERVE( CIVIL DIVISION 1.P F1.K/A COUNTRYWIDE IIONilE LOANS SERVICING,LP ' NO. 13-3055-CIVIL . . Plaintiff CUMBERLAND COUNTY PHIL UP P. STRINOER, U LORI I),STRINGER Defendant(s) T(*. EiORI r).STRINGER S PR Iii'40 ROAD CAR.I.,,ISLiii,I'PS 17013-ST 39 I :,,6 ..,, ,,...t j. DATF OR N(yrif7E, r,,,'. P_.....e.. ., 1..... THIS FIRM IS.A IiiiiHT COLLECT I-)B A.1"1-1ilviPTINc.`i'To( 1 1.1 A IyEltif, 'yHis NoTici.. IS SEN.'TO YOU IN AN ATTEMPT 'If) (A.:).[...-1...ECT THE IND.E1.311.U.INESI-3 -REFERRED -1--0 liERIP,IN., AND 1541' -INFORMATION OBT/TINED FROM Y(A: WILL. 1,3E USED FOR THAT PURPOSE. IF YOU IIAME l'REVICITITSLA RFT.TT.ErVIil..) A., TOTSCtIARHE EN BANKRi.IFICY, THIS ciOR.R.ESPONI)IiiiiN(IE IS NOT AND SHOULD .5405 BE CONS'IRLIED TO BE .554 ATTEMPT TO CO. UN!' A II‘PIBT, BUT ONLY ,• S ENFORCEMENT OP 1..,1-EN A(E'.\ANSTr PROPRI-,ITY. IMPORTANT NOTICI, YOLI 1111', IN DEF,AULT BECT,,kETSE YOU HAVE E=IBLED CO' ENTER A WR1 T11.1:Nt :,:%.PPI..."..A R 554(11 5[P5(CA! OR BY ,ATITORNEN AND 1:,,n..f., p.....i vvErrit.,:(3 75 13! THE coENT YOUR 0.ETENSI0(„IR OBJECTIONS TO THY',C.I.AINP SI:Pr FORTE ACIAINST yoI,. rj:NLEss AC! WrIMIN"IITi T)AYS FRT.,-.W1 THAI:DATE OF TII IS ),1012KA.E. .A...1 Li DGMENT MAY II!' i..iNTIiRED AGAINST YOU WITITCRIT ' III AND YOU M.,Ay t...c)sFi. Y(...)11R PROPER';Y OR 4iiiTHF.1, i'MPORT/\NT.R.R.IPETS. YOE SH(S)ULD TAKE': '1 ISIS PAPP.:R IT) YOUR LAWYER Ai' 010 F, Ii' 54013 DO NCH' PIAVE A LAWYER, CO "N) (IR 10'110. TILP FEFEJO" SET FORIFE RIELOW. TIM OFFRIIT 0,554 PI05v:15 L..YOIT WEN INFo.RmAilc).1,...L.,,,Euiyul. i I-1-11)EIN 0A0.A554 FR yr ..,:\..fTkAi:;..1) TO .....\ 1... A/Y1'i.R., 1•1:11S; Clit•IACE MA U BF, ABLIT YIJ 'IT 015'!.. YI,R... \'':/I11-.-I INETIEMATITS'I .,T.FATILIT AGCIITS -IEFFII)T )\)1 A-'::.-- (5'!i)is P1,EGAT STIIII,OP(IFS )).)ELPIII.R.:E PERSONS ATT .A. RB.1..)[ ..:E 1) I!; LEM 3 fi- iTh):::.(E) ..,.. .,,.: E E.,(•.,:(,-. E.(:). ,....:::; ) (Rule of Civil Procedure No. 236) - Revised BANK OF AMERICA, N.A., AS : CUMBERLAND COUNTY SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/KJA : COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS SERVICING, LP : CIVIL DIVISION vs. : No. 13-3055-CIVIL PHILLIP P. STRINGER, II LORI D. STRINGER Notice is give that a Judgment in the above captioned matter has been entered against you on )(4 . By: If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Emily M. Phelan, Esq., Id. No.315250 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 799861 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC : COURT OF COMMON PLEAS HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. PHILLIP P. STRINGER, II LORI D. STRINGER Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due : CIVIL DIVISION : NO.: 13-3055-CIVIL : CUMBERLAND COUNTY $250,676.13 Interest from 01/31/2014 to Date of Sale $5,151.25 ($41.21 per diem) TOTAL Note: Please attach description of property. PH # 799861 C Ph $255,827.38 allinan, LLP os ph E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff C) (cDcf)(s d 77,3-14,e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FA COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. PHILLIP P. STRINGER, II LORI D. STRINGER Defendant(s) RA CIPE FOR WRIT OF E ECUT ON (Mortgage Foreclosure) P can Hallinan, LLP o h E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff Address where papers may be served: PHILLIP P. STRINGER, 11 5714 GRANADA DRIVE, APARTMENT 216 SARASOTA, FL 34231-8332 LORI D. STRINGER 4194 NEW HAVEN COURT PORT ORANGE, FL 32127-4918 LEGAL DESCRIPTION ALL that certain tract of land situate in the Village of Carlisle Springs, Middlesex Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point, which point is a corner of lands now or formerly of H.R. Gutshall and lands now or formerly of Merle H. Myers, Jr. and Marlene L. Myers, his wife; thence along lands now or formerly of the said H.R. Gutshall, South 71 degrees West 242.8 feet to a point; thence along lands now or formerly of Robert L. Gutshall, North 15 degrees 45 minutes West 895 feet to a point; thence along lands now or formerly of Harvey Sheaffer, North 80 degrees 30 minutes East 514 feet, more or less, to a point in the line of land now or formerly of Harvey Sheaffer, Ralph Sheaffer, Ira Lightner and Ruth Coalman, South 14 degrees 45 minutes East 735 feet, more or less, to a point in the center of the State Highway Route No. 34; thence by the center line of said Pennsylvania Route No. 34, South 32 degrees 15 minutes West, a distance of 3.3 feet to a point, the southeastern corner of land now or formerly of Mel A. Spidle and wife; thence along said lands of Spidle, North 66 3/4 degrees West 222.5 feet to a point (iron pin); thence South 23 degrees 15 minutes 00 seconds West 39.8 feet to a point (inadvertently not included in prior deed description); thence along lands now or formerly of the said Merle H. Myers, Jr. and wife, South 3 degrees East 197.5 feet to a point, the place of BEGINNING. CONTAINING 8.939 acres. TITLE TO SAID PREMISES IS VESTED IN Phillip P. Stringer, II and Lori D. Stringer, hiw, by Deed from F. Elise Gutshall, fka F. Elise Knaub, dated 10/29/2007, recorded 11/01/2007 in Instrument Number 200741498. PREMISES BEING: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 PARCEL NO. 21-05-0429-005 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2, You'may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PHELAN HALLINAN, LLP Joseph E. DeBarberie, Esq., Id. No.315421,. 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 joseph.debarberie@phelanhallinan.com 215-563-7000 r 1-1-17.c Pk 1(114141AR -1 NIA III OZ CUMBERLAHO COUta'( PE.NSSYLVAtIl BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/KJA COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff v. PHILLIP P. STRINGER, II LORI D. STRINGER Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 13-3055-CIVIL : CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non-owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Y3(2 By: P4Ian Hallinan, LLP Jo 'ph E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff BANK OF AMERICA, N.A., AS SUCCESSOR BY COURT OF COMMON PLEAS MERGER TO BAC HOME LOANS SERVICING, LP FWIA. COUNTRYWIDE HOME LOANS SERVICING, LP CIVIL DIVISION Plaintiff NO.: 13-3055-CIVIL v. PHILLIP P. STRINGER, II CUMBERLAND COUNTY LORI D. STRINGER Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 3430 SPRING ROAD, CARLISLE, PA 17013-8739. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) PHILLIP P. STRINGER, II 5714 GRANADA DRIVE APARTMENT 216 SARASOTA, FL 34231-8332 LORI D. STRINGER 4194 NEW HAVEN COURT PORT ORANGE, FL 32127-4918 2. Name and address of Defendant(s) in the judgment: Name PHILLIP P. STRINGER, II Address (if address cannot be reasonably ascertained, please so indicate) 5714 GRANADA DRIVE APARTMENT 216 SARASOTA, FL 34231-8332 LORI D. STRINGER 4194 NEW HAVEN COURT PORT ORANGE, FL 32127-4918 C) 371. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. PH # 799861 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT COMNIONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY UNIT, ESTATE RECOVERY PROGRAM DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE INTERNAL REVENUE SERVICE ADVISORY U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 3430 SPRING ROAD CARLISLE, PA 17013-8739 6TH FLOOR, STRAWBERRY SQ. DEPT 280601 HARRISBURG, PA 17128 P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswom falsification to authorities. PH 14 799861 By: P n Hallinan, LLP Joseph E. DeBarberie, Esq., Id. No.315421 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F /K/A COUNTRYWIDE HOME LOANS SERVICING, LP vs. PHILLIP P. STRINGER, II LORI D. STRINGER : COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff : NO.: 13-3055-CIV Defendant(s) : CUMBERLAND'- rCtNT? NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PHILLIP P. STRINGER, II LORI D. STRINGER 5714 GRANADA DRIVE, APARTMENT 216 4194 NEW HAVEN COURT SARASOTA, FL 34231 -8332 PORT ORANGE, FL 32127 -4918 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 3430 SPRING ROAD, CARLISLE, PA 17013 -8739 is scheduled to be sold at the Sheriffs Sale on 06/04/2014 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $250,676.13 obtained by BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215 -563 -7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you w have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. SHORT DESCRIPTION By virtue of a Writ of Execution No. 13-3055-CIVIL BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/KIA COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II LORI D. STRINGER owner(s) of property situate in the TOWNSHIP OF MIDDLESEX, CUMBERLAND County, Pennsylvania, being 3430 SPRING ROAD, CARLISLE, PA 17013-8739 Parcel No. 21-05-0429-005 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $250,676.13 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL that certain tract of land situate in the Village of Carlisle Springs, Middlesex Township, County of Cumberland, Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point, which point is a corner of lands now or formerly of H.R. Gutshall and lands now or formerly of Merle H. Myers, Jr. and Marlene L. Myers, his wife; thence along lands now or formerly of the said H.R. Gutshall, South 71 degrees West 242.8 feet to a point; thence along lands now or formerly of Robert L. Gutshall, North 15 degrees 45 minutes West 895 feet to a point; thence along lands now or formerly of Harvey Sheaffer, North 80 degrees 30 minutes East 514 feet, more or less, to a point in the line of land now or formerly of Harvey Sheaffer, Ralph Sheaffer, Ira Lightner and Ruth Cornman, South 14 degrees 45 minutes East 735 feet, more or less, to a point in the center of the State Highway Route No. 34; thence by the center line of said Pennsylvania Route No. 34, South 32 degrees 15 minutes West, a distance of 3.3 feet to a point, the southeastern comer of land now or formerly of Mel A. Spidle and wife; thence along said lands of Spidle, North 66 3/4 degrees West 222.5 feet to a point (iron pin); thence South 23 degrees 15 minutes 00 seconds West 39.8 feet to a point (inadvertently not included in prior deed description); thence along lands now or formerly of the said Merle H. Myers, Jr. and wife, South 3 degrees East 197.5 feet to a point, the place of BEGINNING. CONTAINING 8.939 acres. TITLE TO SAID PREMISES IS VESTED IN Phillip P. Stringer, II and Lori D. Stringer, h/w, by Deed from F. Elise Gutshall, fka F. Elise Knaub, dated 10/29/2007, recorded 11/01/2007 in Instrument Number 200741498. PREMISES BEING: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 PARCEL NO. 21-05-0429-005 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-3055 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff (s) From PHILLIP P. STRINGER, II, LORI D. STRINGER (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: $250,676.13 Li.: $.50 Interest FROM 1/31/3014 TO DATE OF SALE ($41.21 PER DIEM) - $5,151.25 Atty's Comm: Atty Paid: $233.03 Plaintiff Paid: Date: 3/7/14 (Seal) REQUESTING PARTY: Name: JOSEPH E. DEBARBERIE, ESQUIRE Address: PHELAN HALLINAN LLP 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 315421 Due Prothy: $2.25 Other Costs: David D. B ell, Prothonota Deputy Commonwealth of Pennsylvania VERIFIED RETURN OF SERVICE County of Cumberland Common Pleas Court Case Number: 13-3055 CIVIL Court Date: 6/4/2014 10:00 am Plaintiff: BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS vs. Defendant: PHILLIP P. STRINGER, II and LORI D. STRINGER For: Phelan Hallinan, LLP 11111,11211411,111111111111 Received by Full Spectrum Services on the 20th day of March, 2014 at 4:29 pm to be served on PHILLIP P. STRINGER II, 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231. I, Mike Barberio, being duly sworn, depose and say that on the 31st day of March, 2014 at 7:55 pm, 1: SUBSTITUTE served by delivering a true copy of the NOTICE OF SHERIFF'S SALE OF REAL PROPERTY with the date and hour of service endorsed thereon by me, to: LENA EURICE as CO-RESIDENT at the address of: 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231, the within named person's usual place of Abode, who resides therein, who is fifteen (15) years of age or older and informed said person of the contents therein, in compliance with state statutes. Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United States of America. Marital Status: Based upon inquiry of party served, Defendant is not married. Additional Information pertaining to this Service: 3/22/2014 3:32 pm Attempted Service. Saturday. Unit dark, blinds closed, no answer. 3/24/2014 8:31 pm Attempted Service. Monday. Lights on, no answer. Server feels people inside. Description of Person Served: Age: 35+, Sex: F, Race/Skin Color: WHITE, Height: 5'6", Weight: ?, Hair: WHITE, Glasses: N I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process Server in good standing in the judicial circuit in which the process was served. Under penalties of perjury, I declare that I have read the forgoing Verified Return of service and the facts stated iti.4re ue. Pursuant to F.S. 92.525(2), Notary not required. Date: -;1' • t Subscribed and Sworn to before me on the 31st day of 014 by the affia wh personally known to me. NOTARY PUBLIC Fieb.‘cca L. Searcy COMMISSICN # EE 039076 IV EXPIRES: NOV. 01, 2014 ` *VA, AARONNOTARY.com e Barberio CPS#0328 Full Spectrum Services 2727 West Cypress Creek Road Ft. Lauderdale, FL 33309 (856) 813-1460 Our Job Job Serial Number: DPP-2014001358 Ref: PH #799861 Copyright 0 1992-2011 Database Services, Inc. - Process Server's Toolbox V6.5n CO • • PHELAN HALLINAN, LLP Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Adam.Davis @PhelanHallinan.com 215-563-7000 s' E P() T HONOTAt ?,0I II ti's Y — 6 kAt i'ney for Plaintiff CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS . CIVIL DIVISION v. No.: 13 -3055 -CIVIL PHILLIP P. STRINGER, II LORI D. STRINGER Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". Date: r/(5 -//v Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PH # 799861 Name and Address Of Sender Phelan Hallinan, LLP I=10 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 191.03 AZK/SCS - 06/04/1014 Line Article Number Name of Addressee, Street, and Post Office Address Postage t e to `�• 4 �„ �.' r o t' m;~ M 0 0 ` , '" 1 **** TENANT/OCCUPANT 3430 SPRING ROAD CARLISLE, PA 170134739 $0.47 2 **** COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION 6TH FLOOR, STRAWBERRY SQ. DEPT 280601 HARRISBURG, PA 17128 $0.47 qz.V. v� 3 **** DEPARTMENT OF PUBLIC WELFARE, TPL CASUALTY UNIT, ESTATE RECOVERY PROGRAM P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105 $0.47 Sa�� 4 **** DOMESTIC RELATIONS OF CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, PA 17013 $0.47 �4 z co , . 5 **** COMMONWEALTH OF PENNSYLVANIAb DEPARTMENT OF WELFARE P.O. BOX 2675 HARRISBURG, PA 17105 $0.47 `, Ods \�, f j da 6 **** INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM '704 PITTSBURGH, PA 15222 $0.47 7 **** U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 $0.47 fiWM:iti1P!PNV! I I (Mi1Mtiiii1 i21i A. "'', ,,,i. $3.29 Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Ertployec) The till declaration of value is required on all domestic and huemational registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $50,000 per piece subject to a limit of $500:000 peioccw ente. The maximum indemnity payable on Express Mail merchandise is 3500. The mtxtmum indemnity payable is $25,000 for registered mail, sant with optional insurance. Sec Domestic Mail Manual R900 S9t3 and S921 for limitations of coverage. orm.sis i r r acs �tl tia ; " c 2 r, .1I f sErRL AND COUNTY FENNSYLVANIA PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff, v. PHILLIP P. STRINGER, II LORI D. STRINGER Defendant(s) : CIVIL DIVISION : No.: 13 -3055 -CIVIL NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriff's Sale scheduled for 06/04/2014 at 10:00 AM in the above -captioned matter has been continued until 08/06/2014 at 10:00 AM. Date: PH # 799861 /4,/ly Jona n Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff, v. PHILLIP P. STRINGER, II LORI D. STRINGER Defendant(s) Attorney for Plaintiff : CIVIL DIVISION : No.: 13 -3055 -CIVIL CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Notice of the Date of Continued Sheriff's Sale and Certificate of Filing were served by regular mail on the person(s) on the date listed below: PHILLIP P. STRINGER, II 5714 GRANADA DRIVE, APARTMENT 216 SARASOTA, FL 34231-8332 PHILLIP P. STRINGER, II 4302 39TH STREET WEST, APARTMENT 6 PH # 799861 PHILLIP P. STRINGER, II 3430 SPRING ROAD CARLISLE, PA 17013-8739 LORI D. STRINGER 4194 NEW HAVEN COURT BRADENTON, FL 34205 LORI D. STRINGER 3430 SPRING ROAD CARLISLE, PA 17013-8739 Date: PH # 799861 /c Y PORT ORANGE, FL 32127-4918 LORI D. STRINGER 200 73RD AVENUE NORTH, APARTMENT 304 ST PETERSBURG, FL 33702-5953 44.7 Jona an 1Lobb, Esq., Id. No.3I 2174 Attorney for Plaintiff PHELAN HALLINAN, LLP Attorney for Plaintiff One Penn Center Plaza 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME : LOANS SERVICING, LP Plaintiff v. PHILLIP P. STRINGER, II LORI D. STRINGER Defendants J1,/ -3 r©' 32 CIM&E PENNS} COUNTY CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 13 -3055 -CIVIL MOTION FOR SERVICE OF NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan, LLP, petitions this Honorable Court for an Order directing service of the Notice of Sale upon the above -captioned Defendants, PHILLIP P. STRINGER, II and LORI D. STRINGER, by regular mail to PHILLIP P. STRINGER, II at 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231-8332 and 3430 SPRING ROAD, CARLISLE, PA 17013-8739, and LORI D. STRINGER at 3430 SPRING ROAD, CARLISLE, PA 17013-8739 and posting 3430 SPRING ROAD, CARLISLE, PA 17013-8739 and publication pursuant to PA.R.C.P. 3129.2 (D) and in support thereof avers the following: 1. A Sheriffs Sale of the mortgaged property involved herein has been scheduled for August 6, 2014. 2. Pennsylvania Rule of Civil Procedure (Pa.R.C.P.) 3129.2 requires that the Defendants be served with a notification of Sheriffs Sale at least thirty (30) days prior to the scheduled sale date. 3. Attempts to serve Defendants, PHILLIP P. STRINGER, II and LORI D. STRINGER, with the Notice of Sale at the mortgaged premises, 3430 SPRING ROAD, CARLISLE, PA 17013-8739, have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". The property was found to be vacant. 4. Attempts to serve Defendants, PHILLIP P. STRINGER, II and LORI D. STRINGER, with the Notice of Sale at 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231, have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". There was no response after several attempts. 5. Attempts to serve Defendant, LORI D. STRINGER, with the Notice of Sale at 4194 NEW HAVEN COURT, PORT ORANGE, FL 321727, have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". The Defendant does not reside at this address. 6. Attempts to serve Defendant, LORI D. STRINGER, with the Notice of Sale at 200 73rd AVENUE NORTH, APARTMENT 304, ST. PETERSBURG, FL 33702, have been unsuccessful, as indicated by the Return of Service attached hereto as Exhibit "A". The Defendant does not reside at this address. 7. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendants. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B". 8. In accordance with'CUMBERLAND County Local Rule 208.3(9), Plaintiff sent a copy of its Proposed Motion for Special Service and Order to the Defendants on JUNE 19, 2014 and requested Defendants' concurrence. Plaintiff did not receive any written response from the Defendants. A true and correct copy of Plaintiffs JUNE 19, 2014 letter and postmarked certificate of mailing pursuant to Local Rule 208.3(9) attached hereto, made part hereof, and marked Exhibit "C". 9. Plaintiff submits that it has made a good faith effort to locate the Defendants, PHILLIP P. STRINGER, II and LORI D. STRINGER, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests that the allowance of service of the Notice of Sale upon Defendants in accordance with Pa.R.C.P., Rule 430 by regular mail to PHILLIP P. STRINGER, II at 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231-8332 and 3430 SPRING ROAD, CARLISLE, PA 17013-8739, and LORI D. STRINGER at 3430 SPRING ROAD, CARLISLE, PA 17013-8739 and posting 3430 SPRING ROAD, CARLISLE, PA 17013-8739 and by publication. DATE: Phelan Hallinan, L By: J6'nathan Lobb, Esquire Bar ID No: 312174 Attorney for Plaintiff PHELAN HALLINAN, LLP Attorney for Plaintiff One Penn Center Plaza 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME : LOANS SERVICING, LP Plaintiff v. PHILLIP P. STRINGER, II LORI D. STRINGER Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 13 -3055 -CIVIL PLAINTIFF'S MEMORANDUM OF LAW Pursuant to Pennsylvania Rule of Civil Procedure Rule 3129.2, it is necessary in a foreclosure action for the Sheriff or Process Server to serve upon the Defendants Notice of the Sale of the mortgaged premises. Specifically, Pa.R.C.P. Rule 3129.2(c) provides in applicable part as follows: The written notice shall be prepared by the plaintiff, shall contain the same information as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the notice shall be made: (i) upon a defendant... (A) by the sheriff or by a competent adult in the manner prescribed by Rule 402(a) for the service of original process upon a defendant, or (B) by the plaintiff mailing a copy in the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court. Because the whereabouts of Defendants, PHILLIP P. STRINGER, II and LORI D. STRINGER, are unknown, a reasonable investigation of their last known address was made in accordance with Pa.R.C.P. 430(a). Pennsylvania Rule of Civil Procedure Rule 430(a) provides as follows: (a) If service cannot be made under the applicable rule the Plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Note: A sheriff's return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales v. Polis, 238 Pa.Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and employers of the defendant, and (3) examinations of local telephone directories, voter registration records, local tax records and motor vehicle records. As indicated by the return of service, hereto as Exhibit "A", the process server has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendants has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked as Exhibit "B". WHEREFORE, Plaintiff respectfully requests the allowance of service of the Notice of Sale upon Defendants in accordance with Pa.R.C.P. Rule 430 by regular mail to PHILLIP P. STRINGER, II at 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231-8332 and 3430 SPRING ROAD, CARLISLE, PA 17013-8739, and LORI D. STRINGER at 3430 SPRING ROAD, CARLISLE, PA 17013-8739, posting 3430 SPRING ROAD, CARLISLE, PA 17013-8739 and by publication pursuant to PA.R.C.P. 3129.2. DATE: 76 lig Phelan Hallinan, LL By: nathan Lobb, Esquire Bar ID No: 312174 Attorney for Plaintiff PHELAN HALLINAN, LLP Attorney for Plaintiff One Penn Center Plaza 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME : LOANS SERVICING, LP Plaintiff v. PHILLIP P. STRINGER, II LORI D. STRINGER Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 13 -3055 -CIVIL CERTIFICATE OF SERVICE I hereby certify that true and correct copies of the foregoing Motion for Service of Notice of Sale Pursuant to Special Order of Court, Proposed Order, Memorandum of Law, Certification of Service and Exhibits in the above captioned matter were sent by first class mail, postage prepaid to the following interested parties on the date indicated below. PHILLIP P. STRINGER, II 5714 GRANADA DRIVE, APARTMENT 216 SARASOTA, FL 34231-8332 PHILLIP P. STRINGER, II 3430 SPRING ROAD CARLISLE, PA 17013-8739 LORI D. STRINGER 3430 SPRING ROAD CARLISLE, PA 17013-8739 DATE: 7 /21/ Phelan Hallinan, LLP By: Jonaobb, Esquire Bar No: 312174 Attorney for Plaintiff LAUREN MATTER, Service Department July 1, 2014 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail LAUREN.MATTER@fedphe.com Legal Assistant, Ext. 1399 PHILLIP P. STRINGER, II 5714 GRANADA DRIVE, APARTMENT 216 SARASOTA, FL 34231-8332 Representing Lenders in Pennsylvania RE: BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II and LORI D. STRINGER Premises Address: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 CUMBERLAND County, No. 13 -3055 -CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by JUNE 26, 2014. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, LAUREN MATTER, Legal Assistant for Phelan Hallinan, LLP 799861 LAUREN MATTER, Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail LAUREN.MATTER@fedphe.com Legal Assistant, Ext. 1399 Representing Lenders in Service Department Pennsylvania July 1, 2014 PHILLIP P. STRINGER, II 3430 SPRING ROAD CARLISLE, PA 17013 RE: BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II and LORI D. STRINGER Premises Address: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 CUMBERLAND County, No. 13 -3055 -CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by JUNE 26, 2014. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, LAUREN MATTER, Legal Assistant for Phelan Hallinan, LLP 799861 LAUREN MATTER, Service Department July 1, 2014 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail LAUREN.MATTER@fedphe.com Legal Assistant, Ext. 1399 LORI D. STRINGER 3430 SPRING ROAD CARLISLE, PA 17013 Representing Lenders in Pennsylvania RE: BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II and LORI D. STRINGER Premises Address: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 CUMBERLAND County, No. 13 -3055 -CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by JUNE 26, 2014. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, LAUREN MATTER, Legal Assistant for Phelan Hallinan, LLP 799861 EXHIBIT "A" 799861 AFFIDAVIT OF SERVICE PLAINTIFF CIAIRERLAND COUNTY BANS OF AMERICA, N.A., AS SUCCESSOR nY MERGER TO EAC HOME LOANS SERVICING, LP EWA COUNTRYWIDE PH 1794661 HOME LOANS SERVICING, LP DEFENDANT PMLLIP P. STRINGER, II LORI D. STRINGER SERVE PHILLIP P STRINGER,Il ATt 3430 SPRING ROAD CARLISLE, PA 170138739 Served and made known to pHIU1I> P. SIRINGPIL Ii. Defendant on the day of , o'clock _. M., at in the manner deacdhed Defendant personally saved Adult family member with whom Defendsnt(8) reside(s). Relationship is Adult in cbar ,e of»ckwie it's tcsidct ce who refused to gh,e n re) p. Ma uiscriC1*k of-pincoof lodging in which 'Defend:mt(tjreside( 1 /gent or person in ei;riga of Defendant's alit= or uFsut t plo.cx orhtmuttk un of iter of sales J)ef t1t rst's tor. p *ny. I, n. con1%tnnt,t tuli herthy verify that.I personally haaxi l 0 tti rsrsti tzi[tect copy d the Notice of Sheiffa Sale in the manner as act forth Ixtnin, laved in the captioned 1a on "tits tits and at the addtiaa indicated about. I undentand that this statement is made subject to the penalties of. 18 Pa, C.S. Set. 4904 relating to wseworo falsification to at*hot tics. DATE: Cin the'`'�yt�f Wale lh TrasdatrtI' rt, " Getause: ✓Vacant _ Does Not Exist _No Answer on at _ Service Refused Other: I.;umi ishifica BY: PRIIVTm h%AA1l?: Ronald Moil term made Jed to the penalties of 15 Pa. C.S. Sc*. 4904 A'iTORNEY FOR PLAJIIFF Phelan Hallinan, l3.P 1617 MK Rouiavard, Suite 1400 One Penn Center Plata Phibtddp61a, PA 19103 (215) 563-7000 to unsworn AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, IP F/K/A ODUNTRYWIDE PHA ?94461 HOME LOANS SERVICING, LP DEFENDANT PHIL LIP P. STRINGER, II LOW D. SPRINGER SERVE LORI D. STRINGER AT: 3430 SPRING ROAD CARLISLE, PA 17413.8739 TYPE OF ACFION XX Nadel of Sheriff's Sala SALE DATE: June 4, 2014 Mafia Served and made known to LORI D. STRII GER. Defendant on the day of 20. o'clock _. M., at a in the Manna described below: _ Defendant personally =vet _ Adult family member with whom Defendant(a) reside(s). Relationship is Adult in charge of Defitedai 'a residence who refused to give name or relationship. Manager/Clods of place of lodging in which Defeodam(a) reside(s). Y Agent or parson in charge of Defendant's office or usual place of business an officer of said Defendant's company. __. Other Dngiplion: Age Height Weight Race Sex Other I. , a competent adult, hereby verify that I personally handed a true and (orax copy of the 13011 S riffs_Sal@ in the manner as set forth herein, lasted in the captioned ease on the date lard at the address indicated above. I understand that this statement is made subject to the pc a1dcs of 18 Pa. C.S. Set., 4904 relating to unsworn falsification to authorities. DATE NAME . PRINTED NAME. TTI'L8: NCiT S Eml on tlacy�.9 dryy €if c 20„ , at 9? o'clock s. M., I— Ron:tjl�Qit , a competent ad•,dt hereby intc that lir rnriaa t r u i t Ocr•uust: f Vacant _ Does Not Exist Moved __ Does Not Reside (Not Wort at Na Answer on _ at Service Refused . Other: 1 unc..' . , tlsut. this Stt+tcnscnt is o auhjeci to the penalties of 18 Pa. C -S. Sec. 4904 raisin Tides. BY: PRINTED NAME: T t 71:t(C) Moll AEIdEY FOR PLAINTIFF Mho HallMan, UP 1617 WK Reviewed, Suite 1400 One Penn Center Plsza Philadelphia. PA 19103 (215) 563-7000 to unsworn AFFIDAVIT OF SERVICE PLAINTIFF HANK OF AM.ER1.CA, N.A., AS SUCCESSOR BY MERGER' t'0 BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, EP DEFENDANT PHILLIP P. STRINGER, II I,OR1 D. STRINGER SERVE LORI D. STRINGER AT: 4194 NEW HAVEN COURT PORT ORANGE, FL 32127.4918 SERV) P Served and made known to 1.0RI.L). STRLNOER, Defendant on the ___.__, o'clock __. M., at in the Del'cudant personally served. Adult family member with whom Defendant(s) reaicle(s), Relationship is._..,,.._..._..._ Adult in charge ot•Defendant's residence who refused to give name Manager/Clerk of place of lodging in which Defendant(s) reside(.). Agent or person in charge of Dafrndanes office m• usual place of hu _______________ an officer of said Defendant's company. CUMBERLAND COUNTY PH it 799861 COURT NO.; 13 3055 -CIVIL TYPE OF ACTION XX Notice of Sheriff's Salo SALE DATE; Juno 4, 2014 day of , 20 __, ut manner described below: at relationship. sines;;. Description: Age Height Weight Race Sex Other a competent, adult, being duly sworn according to law, depose and state that I personally handed a true and coiieet copy of the Notice of Sheriffs Sae in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before the this day of 20_ Notary: Byt On the _�.„!'1�, day of o r .�_ . 201(, at ^s–; SS o'clock F. M., 1, � �° , a competent adult hereby state thin �turencfant N' T €ONI.) bet.tsusc; 1 Vacant —Does Na Answer on _ Service Refused Other; Sworn to and ata hefbne nit Pik fiy;. ..;Hy .2;', j:i4! Not Exist tit A led-Oh.� lrt)za l tt Phelan rtiihi 1617 JFK lsoulcvtrd, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215)563.7000 Moved Does Not Reside (toot Vacant) Commonwealth of Pennsylvania RETURN OF NON -SERVICE. County of CUMBERLAND Common Pleas Court Case Number. 13-3055 CIVIL Court Date: 6/4/2014 Plaintiff: BANK OF AMERICA, N.A., ETC. vs. Defendant: PHILLIP P. STRINGER, II, ET AL For: PHELAN HALLINAN, LLP Received by Jeff Verl on the 19th day of March, 2014 at 11:53 am to be served on LORI D. STRINGER, 4194 NEW HAVEN CT, PORT ORANGE, FL 32127. 1, Jeff Verl, do hereby affirm that on the 19th day of March, 2014 at 5:55 pm, I: NON -SERVED NOTICE OF SHERIFF'S SALE. After careful Inquiry and diligent attempts I was unable to serve the NOTICE OF SHERIFFS SALE for the reason that I failed to find LORI D STRINGER. or information to allow further search. Additional information pertaining to this Service: 3/19/2014 5:55 pm Attempted Service © 4194 NEW HAVEN CT, PORT ORANGE, FL 32127— DOES NOT LIVE AT ADDRESS PER OCCUPANT/ JUDITH WEBBER. I certify that I am over the age of 18, have no interest In the above action, and am a Legally Authorized Process Server for this Judicial Circuit .teff Vert Process :S FULL SPE UM LEGAL SERVICES 400 Fellowship Rd Suite 220 Mt Laurel, NJ 08054 (856) 813.1460 Our Job Serial Number MJG-2014005360 Ref: PH# 799861 Cwy:lght m 1992.2011 Database earv}cer., 3n4 - Prcose 9ervei a Toolbox VB.Sn III 111 111E111111111 11111111111H! III Commonwealth of Pennsylvania VERIFIED RETURN OF SERVICE County of Cumberland Common Pleas Court Case Number: 13-3055 CIVIL Court Date: 614/2014 10:00 am Plaintiff; BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP FIKIA COUNTRYWIDE HOME LOANS vs. Defendant: PHILLIP P. STRINGER, II and LORI 0, STRINGER For: Phalan Hallinan, LLP siu 11111111111 1111 Received by Full Spectrum Services on the 20th day of Maroh, 2014 et 4:29 pm to be served on PHILLIP P. STRINGER II, 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231. I, Mike Barberlo, being duly swum, depose and say that on the 31st day of March, 2014 at 7:56 pm, I: SUBSTITUTE served by delivering a true copy of the NOTICE OF SHERIFF'S SALE OF REAL PROPERTY with the date and hour of service endorsed thereon by me, to; LENA EURICE as CO -RESIDENT at the address of: 5714 GRANADA DRIVE, APARTMENT 218, SARASOTA, FL 34231, the within named person's usual place of Abode, who resides therein, who Is fifteen (15) years of age or older and Informed Bald person of the contents therein, In compliance with state statutes. Military Status: Based upon Inquiry of party served, Defendant is not In the military service of the United States of America. Marital Status: Based upon Inquiry of party served, Defendant Is not married. Additional Information pertaining to this Service: 3/22/2014 3:32 pm Attempted Service, Saturday. Unit dark, blinds closed, no answer. 3/24/2014 8:31 pm Attempted Service, Monday, Lights on, no answer. Server feels people Inside. Description of Person Served: Age; 35+, Sex: F, Race/Skin Color: WHITE, Height; 511', Weight: 7, Hair: WHITE, Glasses: N 1 certify that I am over the age of 18, have no interest In the above action, and am a Certified Process Server In good standing In the Judicial circuit In which the process was served, Under penalties of perjury, I declare that I have read the forgoing Verified Return of service and the facts stated frg,Jtfire o Pursuant to F.S. 92.625(2), Notary not required. Data: --5 Subscribed and Sworn to before me on the 31st day of o Brbrbe frlt1 .014 by the Mlle 1_v�rt , personally known to me. t� $¢0328 fL *.✓ L Y. b-4+.?a'r«P m.^.ar'/tq".'"W..i"n 4v' tdOTAIlY Ptlt i -I F' -_v. Full Spectrum Servtcea 2727 West Cypress Creek Road Ft. Lauderdale, FL 33309 (856) 813-1460 Our Job Serial Number: DPP -2014001358 Ref: PH #799861 Capy1409 1092-2011 r?olAiXon SWeirire, Inc Proreen San, ere Tonibcr:l. .r.r 1 A PF/DAVIT OF SERVICE( Yt.A1NTI F CUMBERLAND COUNTY RANK OF AMERICA, N,A., AS SUCCESSOR BY MF3tGER'1 O BAC ILOME LOANS SERVICING, LI' F!k/A COUNTRYWIDE; til N 79?961. 1IOME LOANS SERVICING, LP DEFENDANT t'rfil7,id1' P, STRINGER, It LORI 1), STRINGIER SERVE D, STRINGER AT. 11)D 7381) AVENUE? NORTH APARTMENT 304 ST I'kTI3RBtIORO, Irt, 337+12.5953 SERVED Saved And tondo known to LORI , ST2INfJER, D0'941410' an the _, o'clock M. at , in the Defend;lnt Inunonnlly sawed, __ Adult fxmlly t 'ember wltb whom Dorcndant(a) leslde(s). Relitti(lnthip;iq Adult in chinuorDurentibtOriteideoco who rc unud tt1 g1a nano conger/C'lerk of ploor, or lati3fnil in which Defection ito) m$i /Rola sir p aztyu1 in (:huge 1)7Iittstanr(nni°a cillo 3=or usithl plass tel tut ailBoor of quid Defendant's ctiupnliy Other: iMr,I�Y'Ity TEAK 4.4 COURT NO, t i3-:105.CI1UL TYPE, OF ACTION XXNotice etShrell tNaly SALE DATE: !um:. 4, 2614 thy or 2U nt mmoncr t105ctibed 1it'owi nr t11ntiunl^hlp DescrIptlon; Age..._.....,_.. Height _. Weight . Race ....., 91x. _ _., Othor 1, t(cox>lpetent ndttli, fining it awc,eo i f41aw t?cyv enc, 81ata thnl t porsonnity handed 4 truc:artti oUrra4i A n?y or.theihall .c or Sbu rrit.S trt'(l riianner ue tti forth heroin, incited in the captioned cuss on 111 :ditto:nod oi tt�ie.ttilciursi'tndh.nl44 ptstive�. Sworn to nud Subserjbad holoto mo this ___ Jay Notary; By: tuft °n tits 2uy da of 20A. at LDo'clock M. Y, . ya (.1,.- y -a.�-'.:� n corupeictrl ttdtrlt Ircrchy state that cntlantl; 5y i�FJN15Tir,enuaci , __1 AMANDA 60LDMAN Notary Public - Slala al Florida My Comm, Explrns Aug 22, 2014 Commission N EE 19374 7ocxNot Lb( i.t _Moved I.1at:5 Not RcAitin (Not Vncnnr) By; Pi 4:34 144.x.. ,... �„ Q'I TOJ(NEY FOR PLA1NTD1' Pludxn Ilelltilan, 1611 )RK Ftaultanrd, Sun 1400 One Penn Contr,. Piny( Philadelphia, PA 19103 (213) 563-7O00 >q �, t:,+ C � ter-., fit° � � tF fe�4an ter �' 4. 5.4.:.1 h e /11 >< +,�c ctgl a �ti� dt:es 4 L- k- De ef�dflt. I9866L AFFIDAVIT OF GOOD FAITH INVESTIG.ATION Pile Number: 709861 Attorney Firm: Phelan liailinan LLP Subj:•:!ct: Phillip P. Stringer 11 & Lori D. Stringer Property Address: 3430 Spring Road, Carlirde, PA 17013 Possible Mailing Address: (Phillip P. Stringer11) 5714 Granada Drive Apartment 216, Sarasota, PL 34231 (Lori D. Stringer) 4194 New Haven Court, Port Orange, PL 32127 1, CREDIT INFORMATION A, SOCIAJ,SECURay NUMBER. Our search verified the following information to be true and correct Phillip P. Stringer - xxx-xx-8739 Lori D. Stringer - xxx-xx.3633 B. EMPLOYMENT SEARCH Phillip P. SIringer & Lori D. Stringer - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDr1OR5 Our inquiry of creditors indicated that Phillip P. Stringer 13 reside(s) at: 5714 Granada Drive Apartment 216, Sarasota, Fi. 34231 & Lori D. Stringer reside(s) at: 3430 Spring Rod, Carlisle, PA 17013. 11, INQUIRY 013 TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Ow office searched directory assistance databases, which indicated that Lori D. Stringer reside(s) at: 3430 Spring Road, Carlisle, PA 17013 and Phillip P. Stringer 11 reside(s) at: 5714 Granada Drive Apartment 216, Sarasota, 34231, which Ls an Apartment Corrylex. On 04-08-14 our office made a telephone call to the subjects' phone number (717) 218-8333 and received the following inforinatiou: disconnected, On 04-08-14 our office made a telephone call to the subject's phone number (717) 386-5527 and received the following information: disconnected. On 04-08-14 aur office trade Several telephone calls to the subject's phone number (941) 739-2549 and received the following information: answering machine. 13. On 04-08-14 our office made a telephone call to a possible phone number of the subject(s) (717) 243-7694 and received the following information: disconnected. 111. INQUIRY OF NEIGHBORS On 04-08-14 our office made a phone call in an attempt to contact Dorothy M, Spidte (717) 249- 9903, 3420 Spring Road, Carlisle, .PA 17013: disconnected, On 04-08-14 our office made a phone coil in an attempt to contact Edward J. Miller (717) 211-G237, 3440 Spring Road, Carlisle, PA 17013: disconnected, On 04-08-14 OUT office made several phone calls in an attempt to contact Prank 13, Frey 111 (717) 241-3008, 3410 Spring Road, Carlisle, PA 17013: no answer. On 04-0844 our office made e phone call in an attempt to contact Gayle Roberts (307)775.70911, 5714 Granada Drive Apartment 116, Sarasota, 10.. 34231: disconnected. On 04-08-14 our office made several phone calls in an attempt to contact Daniel C Drab (941) 953- 7967, 5710 Granada Drive ApMsnent 118, Sarasota, FL. 34231: answering machine. On 04-08-14 our office made a phone cat in an attempt to contact John Paas (941) 388-7319, 5722 Granada Drive Apartment 112; Sarasota, FL 34231: disconnected. On 04-08-:14 our office made n phone call in an attempt to contact Shelby L. Snow (386) 256-7713, 4196 New .Haven Court, Port Orange, TI, 32127: fax tone. On 04-08-14 our office made a phone call in an attempt to contact David Peterson (386) 492-3756, 4202 New Haven Court, Port Orange, FL 32127: Spoke with an unidentifine female who could not confirm that the subjects reside(s) at 4194 New Haven Court, Port Orange, F1., 32127. On 04-08-14 our office made a phone call in an attempt to contact Jill G. Autalec (386) 788-3438, 4192 New Haven Court, Port Orange, FL 32127: disconnected. IV. ADDRESS INQUIRY A, NATIONAL ADDRESS UPDATE On 04-08-14 we reviewed the National Address database and found the following information: Phillip P. Stringer 11 - 5714 Granada Drive Apartment 216, Sarasota, FL 34231 & Lori D. Stringer - 3430 Spring Road, Carlisle, PA 17013, B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: (Phillip P. Stringer Il) 5714 Granada Drive Apartment 21.6, Sarasota, FL34231 & (Lori D. Stringer) 4194 New Haven Court, Port Orange, FL 32127, V. OTHER INQUIRIES A, DEATH RECORDS As of 04-08-14 Vital Records end all public databases have no death record on file for Phillip 1'. Stringer I1 & Lori D. Stringer, VI, ADDITIONAL INFORMATION OF SUBJECT' A. YEAR OF BIRTH Phillip P. Stringer IT - 1976 Lori D, Stringer - 1962 B. A.K.A. Phillip Patrick Stringer Lori Dawn Baughman; Lori Dawn Stringer • Our accessible databases have been checked and cross-referenced for the above named individual(s), * Please he advised our database inforination indicates the Subject resides at the current address. I hereby verify that the statements made .herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. Sir, 4904,`r� tt�jl,;-trs tt a r7 Inn to authorities. The above information is obtained froth available public records and we are only liable far the cost of the affidavit, 1F.XHIBIT "C" Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Perm Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail LAUREN.MATTER@fedphe.com LAUREN MATTER, Legal Assistant, Ext. 1399 Representing Lenders in Service Department Pennsylvania June 27, 2014 PHILLIP P. STRINGER, II 5714 GRANADA DRIVE, APARTMENT 216 SARASOTA, FL 34231-8332 RE: BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II and LORI D. STRINGER Premises Address: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 CUMBERLAND County, No. 13 -3055 -CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by JUNE 26, 2014. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, LAUREN MATTER, Legal Assistant for Phelan Hallinan, LLP 799861 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail LAUREN.MATTER@fedphe.com LAUREN MATTER, Legal Assistant, Ext. 1399 Representing Lenders in Service Department Pennsylvania June 19, 2014 PHILLIP P. STRINGER, II 3430 SPRING ROAD CARLISLE, PA 17013-8739 RE: BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II and LORI D. STRINGER Premises Address: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 CUMBERLAND County, No. 13 -3055 -CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by JUNE 26, 2014. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, LAUREN MATTER, Legal Assistant for Phelan Hallinan, LLP 799861 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 E-mail LAUREN.MATTER@fedphe.com LAUREN MATTER, Legal Assistant, Ext. 1399 Representing Lenders in Service Department Pennsylvania June 27, 2014 LORI D. STRINGER 3430 SPRING ROAD CARLISLE, PA 17013-8739 RE: BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/KIA COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II and LORI D. STRINGER Premises Address: 3430 SPRING ROAD, CARLISLE, PA 17013-8739 CUMBERLAND County, No. 13 -3055 -CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by JUNE 26, 2014. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, LAUREN MATTER, Legal Assistant for Phelan Hallinan, LLP 799861 Nmc i1 Addie, Of Sender Phelan I411Ii,Tn. LLP IMMO1617 JFK Boulevard, Saila 1400 One Penn Center Plaza Pfldhl1a. PA 19103, 1.1$1114 Une Article Number Name of Addressee, treat, add Poll OfIlee Address PHILLIP P. STRINGFX, 11 3430 SPRING ROAD CARL1SL.E, PA 17013 ' Poste 4 $0.47 1 Oa.. 2 • itth* PHILLIP P. bl'R1NGER, 11 714 GRANADA DRIVE APARTMENT 216 SARASOTA, FL 34231-S133 $0.47 3 •,..• LORJ D. STRINGER 3430 SPRING ROAD CARLISLE, PA 17013 30.47 RE: PHILLIP p. STRING E.II (CUMBERLAND) TEAM 4 PH N79936E4021 Pap 1 of 1 S1.41 ?ono 3877 Fa Ojos 13LtAA 799861 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME : LOANS SERVICING, LP Plaintiff v. PHILLIP P. STRINGER, II LORI D. STRINGER Defendants ORDER AND NOW, this 17 day of CIVIL DIVISION NO. 13 -3055 -CIVIL 97 , 2014, after Zir cx� consideration of Plaintiff's Motion for Service of Notice of Sale Pursuant to Special Order of Court, it is hereby: ORDERED that pursuant to Pa. R.C.P. 430(a), service of the Notice of Sale is permitted on Defendants PHILLIP P. STRINGER, H and LORI D. STRINGER by: REGULAR MAIL TO PHILLIP P. STRINGER, II at 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231-8332 and 3430 SPRING ROAD, CARLISLE, PA 17013- 8739, and LORI D. STRINGER at 3430 SPRING ROAD, CARLISLE, PA 17013-8739 Service by mail is complete upon the date of mailing PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2 (D). CC PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 '41// U P1 'Ect_ 'Y n JUL 2 9 AH !U: CUMBERLAND CDUjlTy ENNSYLVA�dIA PHELAN HALLINAN, LLP Attorney for Plaintiff Mario J. Hanyon, Esq., Id. No.203993 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 mario.hanyon@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP Plaintiff, CIVIL DIVISION V. No.: 13-3055-CIVIL PHILLIP P. STRINGER,II LORI D. STRINGER Defendant(s) NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE The Sheriffs Sale scheduled for 08/06/2014 at 10:00 AM in the above-captioned matter has been continued until 10/01/2014 at 10:00 AM. Date: Mario f. 11anyon, Esq., Id. o.20 0 3 Attorney for Plaintiff PH#799861 PHELAN HALLINAN, LLP Attorney for Plaintiff Mario J. Hanyon, Esq., Id. No.203993 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 mario.hanyon@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA BANK OF AMERICA,N.A.,AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING,LP F/K/A COUNTRYWIDE HOME LOANS SERVICING,LP Plaintiff, CIVIL DIVISION V. No.: 13-3055-CIVIL PHILLIP P.STRINGER,II LORI D.STRINGER Defendant(s) CERTIFICATION OF SERVICE I hereby certify that true and correct copies of the foregoing Notice of the Date of Continued Sheriffs Sale and Certificate of Filing were served by regular mail on the person(s) on the date listed below: PHILLIP P. STRINGER, II PHILLIP P. STRINGER, II 5714 GRANADA DRIVE, APARTMENT 216 3430 SPRING ROAD SARASOTA, FL 34231-8332 CARLISLE,PA 17013-8739 PHILLIP P. STRINGER, II LORI D. STRINGER 4302 39TH STREET WEST, APARTMENT 6 4194 NEW HAVEN COURT BRADENTON, FL 34205 PORT ORANGE,FL 32127-4918 LORI D. STRINGER LORI D. STRINGER 3430 SPRING ROAD 200 73RD AVENUE NORTH, CARLISLE, PA 17013-8739 APARTMENT 304 ST PETERSBURG, FL 33702-5953 Date: � Mario J. Hanyon, Esq., Id. Wo.103993 Attorney for Plaintiff PH#799861 PHELAN HALLINAN, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff vs. PHILLIP P. STRINGER, II LORI D. STRINGER Defendants FILED-OFFICL iF THE PRO THONO 2014 AUG 1 4 All 10: 08 CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 13 -3055 -CIVIL AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail, to PHILLIP P. STRINGER, II and LORI D. STRINGER on 7/21/2014 in accordance with the Order of Court dated 7/7/2014. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. Phelan Hallinan, LLP DATE: By: Jonat Attorney obb, Esq., Id. No.312174 or Plaintiff 'r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., AS SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. PHILLIP P. STRINGER, II LORI D. STRINGER Defendants ORDER AND NOW, this "Pkday of CIVIL DIVISION NO. 13 -3055 -CIVIL � 3 rnW rn u,r r o D n •"moo D C , 2014, after consideration of Plaintiff's Motion for Service of Notice of Sale Pursuant to Special Order of Court, it is hereby: ORDERED that pursuant to Pa. R.C.P. 430(a), service of the Notice of Sale is permitted on Defendants PHILLIP P. STRINGER, II and LORI D. STRINGER by: REGULAR MAIL TO PHILLIP P. STRINGER, II at 5714 GRANADA DRIVE, APARTMENT 216, SARASOTA, FL 34231-8332 and 3430 SPRING ROAD, CARLISLE, PA 17013- 8739, and LORI D. STRINGER at 3430 SPRING ROAD, CARLISLE, PA 17013-8739 Service by mail is complete upon the date of mailing PUBLICATION WHICH SHALL BE IN ACCORDANCE WITH PA.R.C.P. 3129.2 (D). BY'i`kik. COURT: l r �p,. � � l ItAJ J // J. PH # 799861 CC PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 Name and Address of Sender PHELAN HALLINAN LLP One Penn Center at Suburban, Suite 1400 Philadelphia, PA 19103 Line Article - Number Name of Addressee,. Street, and Post Office Address Postage Fee 1 * I'HILLIP P. STRINGER, 11 3430 SPRING ROAD CARLISLE, PA 17013-8739 2 s*ss t•_HILLIP P. STRINGER, II .714 GRANADA DRIVE, APARTMENT 216 •ARASOT- FL 34231-8332 — — 3 4 6 ®L ® 111111 sss: D. 3430430 SPRING ING ROAD D CARLISLE PA 17013-8739 i 1 s rLr 7 8 11111 ®MN 10 11 ssss 12 13 ssss 14 15 RE: STRINGER PH- CUMBERLAND Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster, Per (Name of Receiving Employee) SPL -CERTIFICATE OF MAILING -NOS CODE -1020 x Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY —_~— F\L—D-O��lL� Oy '-\��--�T���O}/\"' �F \..^ �» . , � »�y ~~~bet ?R4..01 3 ow 2: ` 1 4!vk OFFICE OF TRE SHERIFF CUMBERLAND COUNTY ~''~^~ PENNSYLVANIA ' Bank of America, N.A. vs_ Phillip P Stringer, II (et al) Case Number 2013-3055 SHERIFF'S RETURN OF SERVICE 03/24/2014 03:04 PM - Deputy Dennis Fry, 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 3430 Spring Road, Carlisle, PA 1713, Cumberland County. 05/29/2014 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 07/09/2014 As directed by Joseph Schalk, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014 10/81/2014 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 on October 01, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Joseph Schalk on behalf of Bank of America, N.A., As Successor By Merger To BAC Home Loans Servining, LP F/K/A Countrywide Home Loans Servicing, LP, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $804.83 SO ANSWERS, October 23, 2014 RON R ANDERSON, SHERIFF (c)counlySwie Sheriff, Teleoscrft, Inc, ter,co U. ' On March 17, 2014 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA, Known and numbered as, 3430 Spring Road, Carlisle, as Exhibit "A" filed with. this Writ and by this Reference incorporated herein. Date: March 17, 2014 By: Real Estate Coordinator • LXIII 16 " • CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2013-3055 Civil Term Bank of America, N.A. vs. Phillip P. Stringer, II 1;'• Lori D.!Stringer Atty.: Joseph Schalk By virtue of a Writ of Execu- tion No. 13-3055:CIVIL; "BANIC OF1' AMERICA, N.A. AS .-SUCCESSOR* BY MERGER TO BAC HOME LOANS SERVICING, LP 4/-Q a COUNTRY- • WIDE HOME LOANS SERVICING, LP v. PHILLIP P. TRINGER, II, LORI D. STRINGER owner(s) of property situate in the TOWNSHIP OF MID- DLESEX, CUMBERLAND Co).flity, Pennsylvania, 'being 3430 SPRING s ROAD, CARLISLE, PA 17013-8739. Parcel No. 21-05-0429-005. Improvements thereon: RESIDEN- TIAL DWELLING. Judgment Amount: $250,676.13. The Patriot -News Co. 2020 Technology Pkwy v ,Suite,'300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the 2iatriotXcws Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. _PURIlf_erinMi -nov_ 2013-3055 Civil Term Bank of America, N.A. Vs Phillip P Stringer, II Lori D Stringer Atty: Joseph Schalk By virtue of a Writ of Execution No. 13 -3055 -CIVIL BANK OF AMERICA, N.A., • AS. SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP v. PHILLIP P. STRINGER, II LORI D.'STRINGER owner(s) of property situate in the TOWNSHIP OF MIDDLESEX, CUMBERLAND County, Pennsylvania, being 3430 SPRING ROAD, CARLISLE, PA 17013-8739 Parcel No. 21-05-0429-005 (Acreage or street address) Improvements thereon: RESIDENTIAL'D WELLING Judgment Amount: $250,676.13 This ad ran on the date(s) shown below: 04/13/14 04/20/14 04/27/14 subscribed before me thj02 day of May, 2014 A.D. ublFc WEALTH Of- r'toiluar ' otariP c^_I k®;fy Lynn tlf rrc;, ,dry pug. 1"/4sh! t� ngton � a:��., D;uphtn Counq M CommIsslon Exp'res Dec. 12, 2016 ,tom S 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 is the grantee the same having been sold to said grantee on the 1st day of October A.D., 2014, under and by virtue of a writ Execution issued on the 7th day of March, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 3055, at the suit of Bank of America N A against Phillip P II & Lori D Stringer is duly recorded as Instrument Number 201426277. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of eJj , A D ,2 0/ ? At / • or My Comm ecorder of Deeds . Cumberland County, Carlisle, PA ion Expires the First Monday of Jan. 2018 7.% PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952,and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Coyne Editor SWORN TO AND SUBSCRIBED before me this da of May, 2014 GC • No y COMMONWEALTH OF PENNSYLVNNA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO.. CUMBERLAND CM My Commission Expires Apr 28. 2018