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Home My WebLink About13-3589 Supreme Court -of Pennsylvania Ca>u�jif C iron Pleas - - Z - WC`OS er he �, I For Pradjonotaff f'se 011k= CumMitancd) 14 County Daeke. -No: The information collected o' n this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service of leadin s or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE COURTNEY A. PARKER O FOR CERTIFICATEHOLDERS OF BEAR STEARNS JEFFREY A. PARKER T ASSET BACKED SECURITIES I LLC ASSET BACKED I Dollar Amount Requested within arbitration limits Q Are money Damages requested ?: ❑ Yes No (Check one) X_ outside arbitration limits Is this a Class Action Suit? ❑ Yes ® NO Is this an MDJ Appeal? ❑ Yes ® NO A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C. ❑ Check here if you are a Self-Represented (Pro Se Litigant 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 APPEAL ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt'Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation s ❑ Premises Liability ❑ Zoning Board ❑ Product Liability (does not include ❑ Statutory Appeal: Other ❑ Employment dispute: E mass tort) Discrimination ❑ Slander/Libel Defamation ❑Employment Dispute: Other ❑ Other T ❑ Other: Q MASS TORT ❑Other - T ❑ Asbestos ' ❑ Tobacco f ❑Toxic Tort -DES REA PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration $ ❑Other ❑ Ground Rent 11 Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑Non- Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑Partition ❑Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP P.C. SUITE 5000 — BNY MELLON INDEPENDENCE CE ER _,, " ':) ! j (a °� t 1 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413 -2311 LAwGR M •' rniln U.S. BANK NATIONAL ASSOCIATION, ASM Yb - .. IN THE COURT OF COMMON PLEAS FOR CERTIFICATEHOLDERS OF BEARS TEAD "' ` � �` ASSET BACKED SECURITIES I LLC, ASSET BACKED OF Cumberland COUNTY CERTIFICATES, SERIES 2006 -AC4 c/o 3415 Vision Drive CIVIL ACTION - LAW Columbus, OH 43219 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. COURTNEY A. PARKER C a JEFFREY A. PARKER No. Mortgagor(s) and Record Owner(s) CIVIL ACTION: mORTGAGE 713 Manor Road FOIII?CI 0SME Camp Hill, PA 17011 Defendant(s) NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en ]as paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas ]as provisiones de esta demanda. Usted puede perder dinero o sus propiedades a otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVCCO. VAYA EN PERSONA O LLAME 0 M4 434 de2- -2S i< 014 739'90 P-# Q9 2118 POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243 -9400. 2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hl!p://www.phfa.org/consumers/homeowners/real.awx 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadel.phiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 - 413 -2311 or via email at homeretentiongkmllawgroup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and /or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 1211561 Para informacion en espanol puede communicarse con Loretta a1215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2006 -AC4, c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and property address(es) of the Defendant(s) is /are COURTNEY A. PARKER, 713 Manor Road, Camp Hill, PA 17011 and JEFFREY A. PARKER, 713 Manor Road, Camp Hill, PA 17011, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On February 23, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., SOLELY AS NOMINEE FOR PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on February 28, 2006 as Book 1941 . Page 3734. The mortgage has been assigned to: U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2006 -AC4 by assignment of Mortgage recorded on December 03, 2012 as Instrument # 201237396. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for December 01, 2012 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of April 24, 2013: PrincipalBalance .......................................................... ..............................$ 144,796.17 Interest from 11/01/2012 through 03/31/2013 ....................... ......................$4,223.20 AccruedLate Charges ................................................................ ............................... EscrowAdvance ......................................... ............................... ........................$471.3 BPO /Appraisal ............................................ ............................... ........................$ PropertyInspection ..................................... ............................... ........................$283.90 Reasonable Attorney's Fee ........................ ............................... ............ ..........$1,650.00 $151,674.62 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an " personam 'judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 :of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B ". The Defendants have not had the required face -to -face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any.appropriate. Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $151,674.62, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclosure and sale of the mortgage property. By: KML LAW CROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 drew F. Gornall Pa. ID 92382 ZZAlyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION The u rsigne U` , does hereby certify that he/ l& is (t 7a, i :; of JP Morgan Chase Bank, N.A. and that JP Morgan Chase Bank, N.A. has been duly nominated and appointed by [Plaintiff], plaintiff herein, as its mortgage servicing agent in regard to the mortgage loan which is the subject of this action (the "Mortgage "). [Plaintiff] lacks sufficient information to make this verification because Plaintiff is not the entity that maintains the business records for the Mortgage. JP Morgan Chase Bank, N.A., in its capacity as mortgage servicing agent for [Plaintiff], maintains the business records for the Mortgage, and therefore does have sufficient information to make this verification in accordance with Pa.R.C.P. 1024(c)(1). I am authorized to make this Verification on Plaintiffs behalf and do hereby verify that the facts as set forth in the foregoing Complaint are true and correct to the best of my information and belief. I have access to and have reviewed the business records of JP Morgan Chase Bank, N.A. for and relating to the Mortgage, and I make this Verification based on my review of those records, which are maintained by JP Morgan Chase Bank, N.A. in the course of its regularly conducted business activities and are made at or near the time of the event, by or from information transmitted by a person with knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Dated: Nam Title: Loan No. �3 7 E.xhibitA ALL THAT CERTAIN tract or lot of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the North side foot mentioned Plan of Lots; Road, at the comer of Lot No. 21 on the hereinafter thence . along the line of said Lot No. 21, North 22 degrees 40 minutes West, 159.8 feet to a point; thence North 67 degrees 50 minutes East, 100 feet to a point; thence along the line of Lot No. 23 on the hereinafter mentioned Plan of Lots, South 22 degrees 40 minutes East, 158.93 feet to a point on the North side Of Manor Road aforesaid; thence along the North side of said road, South 67 degrees 20 minutes West, 100 feet to a point, the place of BEGINNING. BEING Lot No. 22 of the West Creek Hills Subdivision recorded in Cumberland County Plan Book 8, page 4. BEING known and numbered as 713 Manor Road, Camp Hill, Pennsylvania. Ey,hibit �B *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase (FL5-7734) CHASE ! i P.O. Box 44090 Jacksonville, FL 32231 -4090 March 8, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 00001378 HOLD ZB 6713 -BW860 COURTNEY A PARKER 713 MANOR ROAD CAMP HILL, PA 17011 Act 91 Notice Account: _7376 (the "Loan ") Property Address: 713 MANOR ROAD CAMP HILL, PA 17011 (the 'Property ") Dear COURTNEY A PARKER: " On the following page, you will find a notice regarding your home as required by Pennsylvania law. Chase (FL5 -7734) CHASE ! i P.O. Box 44090 Jacksonville, FL 322314090 March 8, 2013 CERTIFIED MAIL: Return Receipt Requested and First Class Mail 00001380 HDLO 7B 6713 -B W 860 JEFFREY A PARKER 713 MANOR ROAD CAMP HILL, PA 17011 Act 91. Notice Account: =7376 (the "Loan ") Property Address: 713 MANOR ROAD CAMP HILL, PA 1701.1 (the 'Property") Dear JEFFREY A PARKER: On the following page, you will find a notice regarding your home as required by Pennsylvania law. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official Notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM ( HEMAP) may be able to help to save your home. This Notice explains how the Program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll -free at 800 - 342 -2397. (Persons with impaired hearing can call 717- 780 - 1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): JEFFREY A PARKER COURTNEY A PARKER PROPERTY ADDRESS: 713 MANOR ROAD CAMP HILL, PA 17011 LOAN ACCOUNT NUMBER: _7376 ORIGINAL LENDER: PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK CURRENT LENDER/SERVICER: JPMorgan Chase Bank, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time, you must arrange and attend a "face -to- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY -THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice It is only necessary to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HA VE A MEETING WITH A COUNSELING AGENCY WITHIN THIRTY THREE (33) DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE ANAPPLICATION WITH THE PHFA WITHIN THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE A CTIONA GAINST YOUR PROPERTY, AS EXPLAINED ABOVE IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HA VE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME P E R I O D S . A L A TE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLYAPPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date). NATURE OF THE DEFAULT -- The mortgage debt held by the above lender on your property located at: 713 MANOR ROAD, CAMP HILL, PA 17011 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 12/01/2012 $1,388.58 01/01/2013 $1,388.58 02/01/2013 $1,388.58 03/01/2013 $1,388.58 Other charges: Late Charges: $0.00 Insufficient Funds (NSF) Fees: $0.00 Other Fees: $0.00 Advances: $602.00 Amount Held in Suspense: $0.00 TOTAL AMOUNT PAST DUE: $6,156.32 HOW TO CURE THE DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $6,156.32, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) -DAY PERIOD. Payments must be made by cash, cashier's check, certified check or money order made payable and sent to Overnight/Regular Mail: Chase Mail Code: 01-14 -7133 3415 Vision Drive Columbus, OH 43219 -6009 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) -DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) -DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriffs Sale as specified in writing by the lender, and by performing any other requirements under the mortgage Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff s Sale of the mortgaged property could be held would be approximately five to six (5 to 6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER Name of Lender: Chase Address: Mail Code: 0114 -7384 3415 Vision Drive Columbus, 01143219 Telephone Number: 800 - 848 -9380 Fax Number: 614 -500 -4605 Contact Person: Bruno Mejia E -mail Address: state .programs.intake @jpmchase.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You X may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Advantage Credit Counseling Service /CCCS of 888 - 511 -2227 2000 Linglestown Road Harrisburg 17102 Western PA Community Action Commission of Capital 717 - 232 -9757 1514 Derry Street Harrisburg 17104 Region Housing Alliance of York/Y Housing Resources 717 - 855 -2752 290 West Market Street York 17401 Maranatha 1 717- 762 -3285 43 Philadelphia Avenue Waynesboro 17268 Pennsylvania Interfaith Community Programs, 717 -334 -1518 40 E. High Street Gettysburg 17325 Inc. PHFA 717 - 780 -3940 1 211 North Front Street Harrisburg 17110 800 -342 -2397 Rev. 10/12 FM646 We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address, and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. IMPORTANT NOTICE TO SERVICEMEMBERS AND :THEIR DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state Military benefits and protections also may be available if you are the dependent of an eligible Servicemember. Eligible service may include: Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or Active service as a commissioned officer of the Public Health Service, or Service with the forces of a nation with which the United States is allied in a war or Military action, or Service with the National Guard of a state militia under a state call of duty, or Any period when you are absent from duty because of sickness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 877 - 469 -0110. AN IMPORTANT REMINDER FOR ALL OUR CUSTOMERS As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, `Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org, or by calling 888 - 995 -HOPE; 888 - 9954673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866 -550 -5705 to discuss your options. The longer you delay, the fewer options you may have. BW860 Ex,hibit *Exhibit has been redacted to remove all personally identifiable information or non-public information Inst. # 201237396 Page 3 of 3 ROBERT P. ZIEGLER RECORDER OF DEEDS. < CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717 -240- 6370�� Instrument Number - 201237396 Recorded On 12/3/2012 At 1: =42:50 PM ' Total Pages - 3 • Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 123534 User ID - K« • Mortgagor - PARKER, JEFFREY A • Mortgagee - U S BANK N A • Customer - SIlVIPLIFILE LC E- RECORDING " FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES - $12.00 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 This page is no w part FEES of this legal document. COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $51.00 I Certify this to be recorded in Cumberland County PA �.; • RECORDER OF DEEDS �rso� * - Information denoted by an asterisk may change during the verification process and cony not be reflected on this page. Inst. ff 201237396 - Page 1 of 3 Prepared By/ Return To : CERTIFIED PROPERTY IDENTIFICATION NUMERS E.Lance/NTC, 2100 Alt 19 N orth, 09 -18 -1304 -064 - EAST PENNSBOR0 Palm Harbor, FL 34683 CCGIS REGISTRY 12/03/2012 BY DC (800)346 -9152 Loan #: 376 Tax Code/PIN/i3PI #: 09 -18- 1304-064 � IIIIII Rill 111111111111111111111111111111111 hill 111111<IIII ASSIGNMENT OF MORTGAGE Contact JPMORGAN CHASE BANK, N.A. for this Instrument 780 Kansas Lane, Suite A, Monroe, LA 71203, telephone # (866) 756 -8747, which is responsible for receiving payments. FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the undersigned, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PHILADELPHIA FINANCIAL MORTGAGE, A DIVISION OF LEESPORT BANK, ITS SUCCESSORS AND ASSIGNS PO BOX 2026, FLINT, MI, 48501 (MERS Address: 1901 E Voorhees Street, Suite C, Danville, IL 61834) by these presents does convey, grant, assign, transfer and set over the described Mortgage " therein together with all interest secured thereby, all hens, and an rights due or to become due thereon to U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES SERIES 2006 -AC4, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA 71203 t866�756 -8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE). Said Mortga a is dated 02/23/2006, in the amount of $158,000,00, made by JEFFREY A. PARKER AND COURTNEY A. PARKER to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR PHILADELPHIA FINANCIAL MORTGAGE, A DIVISION OF LEESPORT BANK, recorded on 01/28/2006, in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania, in Book 1941, Page 3734, and/or Document # n/a. . Property is commonly known as: 713 MANOR ROAD TWP. OF EAST PENNSBORO, CAMP HILL, PA 17011. Dated on // / (MM/DD/YYYX� MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PHILADELPHIA FINANCIAL MORTGAGE, A DIVISION OF LEESPORT BANK, ITS SUCCESSORS AND ASSIGNS By: ASST. SECRETARY PAGE 1 JPCAS 18389707 -4 EMC CJ44113794X NI MIN 100129200123060485 MERS PHONE 1- 888 - 679 -6377 72412114516 (C] FR1vJPAt 1 11111111111111111 111111 IN 1111111 IN loll Mill III III *18389707"' .}� Inst. # 201237396 - Page 2 of 3 Loun #: 376 1111111 Ilgl II II III glli Illli IIIII i1111 IIIII 11111 Illi IIII I STATE OF LOUISIANA PARISH OF OUACHITA On ► � _ I2012 (MM/DD/YYYY), before me appeared to me per naliy known, who did say that he/she/they is/are the ASST. SECRETARY of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PHILADELPHIA FINANCIAL MORTGAGE, A DIVISION OF LEESPORT BANK, ITS SUCCESSORS AND ASSIGNS and that the instrument Was signed on behalf of the corporation (or association), by authority from its board of directors, and that he/she/they acknowledged the instrument to be the free act and deed of the corporation (or association). J 01MNIfH/y „ ti Notary - State of LOUISIANA r � Commission expires: Upon My Death Assignmen' of Mortgage from: MORTGA E ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK, ITS SUCCESSORS AND ASSIGNS PO BOX 2026, INT, MI, 48S 1(MFRS Address: 1901 E Voorhees Street, Suite C, Danville, EL 61834) to: U.S. BANJI NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR S ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES SERIFS TS UC A SORS SE OR ASSIGN I (A 700 K S S LANE, MC 8000, MONROE, LA 71203 (869)756 -8747, Mortgagor. EFFREY A. PARKER AND COURTNEY A. PARKER When Reco ,ded Return To: JPMorgan Chase Bank, NA C/O NTC 21[00 Alt. 19 North Palm Harbo#, FL 34683 All that certain lot or ppirece of ground situated in Mortgage Piemise: 7 r3 I3 MANOR ROAD TWP. OF EAST PENNSBORO r CAMP HILL, PA 17011 CUMBERLAND orough or Townshi if stated), Commonwealth of Pennsylvania. eingg more particularly described in said Mortgage. 1, /.372 c G � hereby certify that the below information and address for the assignee are correct: U.S. BAN NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIFS 2006 -AC4 HOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA 71203 (866)7568747, ITS SUCG SORS OR ASSIGNS, (ASSIGNEE) By: ASST. SECRETARY PAGE 2 *18389707* JPCAS 18389707 4 EMC C144113794X NI MIN 100129200I23060485 MERS PHONE 1- 888 - 679.6077 72412114516 [C) FRMPAI Illlf IIIIlI11111111111111111111111 [Illlglllllllll *18389707* IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C —� uU U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET = BACKED SECURITIES I LLC, ASSET BACKED r-- rr.,) C- =' CERTIFICATES, SERIES 2006 -AC4 Case No. �j S C Plaintiff .-,.i r�- vs. . r O C D COURTNEY A. PARKER JEFFREY A. PARKER -�-� (J7r Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 2 ignatur / of Counsel for Plaintiff) Date / Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUE T FOP, HARDSHIP ASSISTANCE To complete-your request for hardship assistance, your Icnder must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes [J No ❑ fisting date: Price: S Realtor Name: Realtor Phone: Borrower Occupied? Yes No Mailing Address (if different): City: State: Zip: Phone Numbers: 'Tome: Office: Cell: Other: Email- ft of people in household: How long? Mailing Address; City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email; ## of people in household: How lon INFORMATION First Mortgage Lender: Type of Loan: Loan. Number: - bate You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loam Number: Total Mortgage Payments Amount: $� Included Taxes & Insurance:� Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No e] If yes, provide names, location of court, case number & attorney; Assets Amount Owed: Value; Home: $ Other Real Estate: $ $ -- Retirement Funds: $ $ — Investments: $ _ $ Checking: $ Savings: S Other: $ $ Automobile - 'I: Model: Year: Amount owed: Value: &utomobile #2 : Model: year: Amount owed: Value: Other transpgrtation (automobiles, boats, motorcycled: Model: Year Amount owed: Value Monthly Income Name of Employers: 1. - 2. 3. Additional Income Description (trot 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 AMOUNT EXPENSE AMOUNT MorMage Food 2 Mortgage Utilities - Car Pa ens Condo/NS! . Fee_ s Auto Insurance Med. not cover Auto fuel/repairs Other prop. payment Install. Loan Pa mcnt Cable TV Child Sup port)Atim. Smnding Mone Day /Child Care/Tait, Other Ex nses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes El No [I If yes, please provide the following information: Counseling Agency: Couriselor: Phone.(Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (REMAP) 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 t3he following information, if know, regarding your lender or lender's loan servicing company. Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: _ I/We, —, authorize the above named to uselrefer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possiblic mortgage options. Me understand that Uwe am/are under no obligation to use the services provided by the above earned Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the .following information to lender and lender's counsel: Proof of income y Past 2 bank statements Proof of any expected income for the last 45 days _tt Copy of a current utility bill Y Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson _ ILrt D-OFFICE_ Sheriff fj T}iE PROT►- ONG ia'�,';;`,' ,�kx',t�p�t �ti'i��i�r;r�� Jody S Smith �W 2013 JUN 28 AM 10' 7 Chief Deputy Richard W Stewart �' CUMBERLAND COUNTY Solicitor QFrICE()FTfiE S45PfF: PENNSYLVANIA U.S. Bank National Assocation Case Number vs. Courtney A. Parker(et al.) 2013-3589 SHERIFF'S RETURN OF SERVICE 06/21/2013 06:45 PM - Deputy Tim Black, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Jeffrey Parker, Husband of defendant,who accepted as"Adult Person in Charge"for Courtney A. Parker at 713 Manor Road, East Pennsboro Township, Camp Hill, PA 17011. , TI BLA K, DEPUTY 06/21/2013 06:45 PM - Deputy Tim Black, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Jeffrey A. Parker at 713 Manor Road, East Pennsboro Township, Camp Hill, PA 17011. TIM BLA K, DEPUTY SHERIFF COST: $60.95 SO ANSWERS, June 24, 2013 RONW R ANDERSON, SHERIFF (y CountySuite Sheriff,Toleosoft,Inc t Y In the Court of Common Pleas of Cumberland County U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4 c/o 3415 Vision Drive No. 13-3589 Columbus,OH 43219 Plaintiff VS. COURTNEY A.PARKER , JEFFREY A.PARKER (Mortgagor(s)and Record Owner(s)) -0 r•._ ``� =T 713 Manor Road r-1 Camp Hill,PA 17011 Defendant(s) r- < C:'Fri FOR JUDGMENT °¢ C" x3 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT-A D`EBT-� OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against COURTNEY A.PARKER and JEFFREY A.PARKER by default for want of an Answer. Assess damages as follows: Debt $151,674.62 Interest from 4/1/2013 to Date of Sale per diem at$27.77 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the default occurred and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.237.1 By: LAW GROUP, _Michael McKeever Pa 56129 _Jay E.Kivitz Pa.ID 267 9 _Lisa Lee Pa.ID 78020 _Kristina Murtha Pa.ID 61858 _David Fein Pa.a. ID 82628 Q m4 (Q S6 Thomas Puleo Pa.ID 27615 _Joshua I.Goldman Pa.205047 �i 7 _Jill P.Jenkins Pa.ID 306588 /J�`^' _Andrew F.Gomall Pa.ID 92382 l•((�� tJ Attorneys for Plain ' , 12— � AND NOW �S x SAI&/M t1i�I (G 313,W7 "t/la -1 BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEH6L EERS OF BEAR1STEARNS ASSETf U.S. BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES -AC4 and against COURTNEY A. PARKER and JEFFREY A.PARKER by default for want of an Answejdaamis- rise in t of$151,674 s per the above certification. Rule of Civil Procedure No.236—Revised' IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4 c/o 3415 Vision Drive Columbus,OH 43219 Plaintiff vs. No. 13-3589 COURTNEY A.PARKER JEFFREY A.PARKER (Mortgagors and Record Owner(s)) 713 Manor Road Camp Hill,PA 17011 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary j By: �� t . .. :�"- Deputy If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Y 121156FC l TAUS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT_ To: DATE OF THIS NOTICE: July 15,2013 COURTNEY A.PARKER. 713 Manor Road Camp Ilill,PA 1 7011 U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR In the Court of CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED Common Pleas SECURITIES I LLC,ASSET BACKED CERTIFICATES,SERIES of Cumberland County 2006-AC4 CIVIL ACTION-LAW c%3415 Vision Drive Columbus,OH 43219 Plaintiff' Action of vs, Mortgage Foreclosure COURTNEY A.PARKER JEFFREY A.PARKER No. 13-3584 (Mortgagor(s)and Record Owner(s)) 713 Manor Road Camp Hill,PA 17011 Defendant(s) TO: COURTNEY A.PARKER 713 Manor Road Camp Hill,PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJEGFIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WTITIIN TEN (i0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPER'T'Y OR Crr`HER IMPORTANT RIGHTS. YOU SHOULD TAKE TARS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT IIAVE A LAWYER,GO Tfl 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 C)UNTY BAR ASSOCIATION 2 Liberty Avenue Cadisle,PA 17013 LEGAL SERVICES INC 8 Wine Row CMislc,PA 17013 717-243-9400 j By: r KMI,LAW RO P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puteo Pa.ID 27615 �AYII P.Jenkins Pa.ID 306588 lyk L.ORaraan Pa.ID 312912 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 121156FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DATE OF THIS NOTICE: July 15,2013 JEFFREY A.PARKER 713 Manor Road Camp Hill,PA 17011 U.S.BANK NATIONAJ,ASSOCIATION,AS TRUSTEE,,FOR In the Court of CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED Common Pleas SECURITIES I LLC,ASSET BACKED CERTIFICATES,SERIES of Cumberland County 2006-AC4 c/o 3415 Vision Drive CIVIL ACTION-LAW Columbus,OH 43219 Plaintiff VS. Action of COURTNEY A.PARKER Mortgage Foreclosure JEFFREY A.PARKER (Mortgagor(s)and Record Owaer(s)) No. 13-3589 713 Manor Road Camp Hill,PA 17011 Defendant(s) TO: JEFFREY A.PARKER 713 Manor Road Camp Hill,PA 17011 IMPORTANT NOTICE, YOU ARE IN DEFAULT BECAUSE YOU HAVE FABLED TO ENTER A WRITTEN APPEARANCE PERSONALLY ATTORNEY SET T F AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SEORTH AGAINST YOU. UNLESS YOU ACT WITHIN JUDGMENT EN (.l0) DAYS FROM THE DATE OF THIS NOTICE, A MENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THI S PAPER TO YOUR LAWYER AT ONCE. IF YOU ll0 NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITIi 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row i Carlisle,PA 17613 717-243-9400 By: KML LA GROUP,P.C. Michael McKeever Pa.ID 56129 I Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Pulco Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Z� Iyk L.OIIazian Pa.ID 312912 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES,SERIES 2006-AC4 Plaintiff NO.13-3589 VS. COURTNEY A.PARKER JEFFREY A.PARKER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(httns://www.dmdc.osd.mil/appj/scra/scraHome do} for the following individual(s): COURTNEY A. PARKER, has a last known residence of 713 Manor Road, Camp Hill, PA 17011. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date By: Al, KML LAW GFROUP C Michael McKee Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa.ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ED 313897 Jill P.Jenkins Pa.JD 306588 Alyk L. Oflazian Pa.ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Aug-14-2013 05:49:55 SCRA 3.0 stator Repoft r la' Purnuaut to Servicemiemben Civil Relief Act Last Name: PARKER First Name: COURTNEY Middle Name: A. Active Duty Status As Of:Aug-14-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA -z - - 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 Galt-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 earty notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. y6k Pq– 4A4-4��- Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Abington,VA 22350 ` ' The Defense Manpower Data Center(DMDC)is an organization mthe Department m Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which m the mficial source mdata on eligibility for military medical care and other eligibility systems. The moD strongly supports the enforcement m the Servicemembem Civil Relief Act(50oao App.8ou1 etaeq.asamended)(mnA)(formerly known as the Soldiers'and Sailors'Civil Relief Act m1n4u). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. m the event the individual referenced above,vr any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections cx the somA,you are strongly encouraged m obtain further verification m the person's status uy contacting that person's Service via the ^uefenonnnk.mruRL:xun:mwww.uoenvonnk.mimu*pimp000aLoe.mm|. x you have evidence the person was uo active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See oouoc App.&nx1(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within ao7 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty pn the Active Duty Status Date. More information On 'Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior moo1V only some m the active duty periods less than oo consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported uy Federal funds. All Active Guard Reserve(AGRI members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(Ams)and Coast Guard Reserve Program Adminmoraxx(np^m). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service"r the National Oceanic and Atmospheric Administration(mo*4nvmm/ssioneoourps). Coverage Under the SCRAiS Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported wsun Active Duty under this certificate. aoRA protections are for Title 1n and Title 1*active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check on make sure the orders vn which aoex protections are based have not been amended m extend the inclusive dates mservice. Furthermore,some protections m the sonx may extend m persons who have received orders m report for active duty mmue inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates m active duty. Those who could rely m`this certificate are urged m seek qualified legal counsel m ensure that all fights guaranteed m Service members under the aona are protected vw\nw|wG: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided uy the requester. pmwmnn erroneous information will cause un erroneous certificate mmaprovided. | Certificate ID: J4V6PDA13D507EO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES,SERIES 2006-AC4 Plaintiff NO.13-3589 VS. COURTNEY A.PARKER JEFFREY A.PARKER Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her infortnation and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (Littps://www.dmdc.osd.miUappj/scra/scraHome.do) for the following individual(s): JEFFREY A. PARKER, has a last known residence of 713 Manor Road, Camp Hill,PA 17011. The following information was used to search the DMDC(check all that apply): • Last Name • First Name • Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. C-1-1 I Date By: ew ;f_,t_LIZI� KML LAW GROUP —Michael McKeev:rfa. ID 56129 -Lisa Lee Pa. ID 78020 Kristina Murtha Pa. rD 61858 David Fein Pa.ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa.ID 26769 —Andrew Gomall Pa. ID 92382 Joshua 1. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa.ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Aug-14-2013 05:42:32 SCRA 3.0 Status Report uant to SeMeemembm Civil Relief Act- Last Name: PARKER First Name: JEFFREY Middle Name: A. Active Duty Status As Of: Aug-14-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA r 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 Servica Component NA - w 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 Cell-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 earty notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. )&Ut s JT Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pisIPC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c)_ This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: S473AD01805B3DO KML Law Group,P.C. Suite 5000–BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR IN THE COURT OF COMMON PLEAS STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES,SERIES 2006-AC4 of Cumberland County c/o 3415 Vision Drive Columbus,OH 43219 Plaintiff CIVIL ACTION LAW VS. COURTNEY A.PARKER ACTION OF MORTGAGE FORECLOSURE JEFFREY A.PARKER (Mortgagor(s)and Record owner(s)) 713 Manor Road No. 13-3589 Camp Hill,PA 17011 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4,and against COURTNEY A.PARKER and JEFFREY A.PARKER for failure to file an Answer in the above action within(20)days from the date of service of the Complaint,in the sum of$151,674.62. By: KML LAW G P'P.C. Michael McKee ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff, * 11MV7 I hereby certify that the above names are correct an that the precise residers address of the judgment creditor is U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4 c/o 3415 Vision Drive Columbus, OH 43219 and that the name(s)and last known address(es)of the Defendant(s)is/are COURTNEY A.PARKER, 713 Manor Road Camp Hill,PA 17011 and JEFFREY A.PARKER,713 Manor Road Camp Hill,PA 17011; By: KML LAW GROXPV.C-. Michael McKeever`Pfi. ED 56129 —Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa. ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff 3t3ti'l A ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $144,796.17 Interest from 11/01/2012 through $4,223.20 03/31/2013 Reasonable Attorney's Fee $1,650.00 Escrow Advance BPO/Appraisal $471.35 Property Inspection $250.00 $283.90 $151,674.62 By: / *- a . KML LAW GRC. Michael McKeev 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff -x- AND /,'��e,( �� 3131'7 NOW,this I� day of ��1.�� .,2013 damages are assessed 1 above. V Pro Prothy 13-3589/121156FC r PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C.. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, IN THE COURT OF COMMON PLEAS ASSET BACKED CERTIFICATES, SERIES 2006-AC4 c/o 3415 Vision Drive of Cumberland County Columbus,OH 43219 Plaintiff CIVIL ACTION—LAW VS. ACTION OF MORTGAGE FORECLOSURE COURTNEY A.PARKER JEFFREY A.PARKER Mortgagor(s)and Record Owner(s) No. 13-3589 713 Manor Road Camp Hill,PA 17011 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION r7` (. TO THE PROTHONOTARY: CD-11 C ) 3 C:)r =, Issue Writ of Execution in the above matter: a, y Amount Due $151,674.62 Interest from 4/1/2013 to Date of Sale per diem at$27.77 l (Costs to be added) sx,s6 L! to 6 -q S Ch's �� 03.7s By: KML LAW GROU C. Michael McKeever 56129 Q�� Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff a,at� X Sal"j-dre. itt 1, 1C 3 I Vr " No. 13-3589 IN THE COURT OF COMMON PLEAS U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES,SERIES 2006-AC4 vs. COURTNEY A. PARKER and JEFFREY A.PARKER (Mortgagor(s)and Record Owner(s)) 713 Manor Road Camp Hill,PA 17011 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group,P.C. Attorney for Plaintiff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 ALL THAT CERTAIN tract or lot of land situate in East Pennsboro Township,Cumberland County,Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point on the North side of a 50 foot road known as Manor Road,at the corner of Lot No.21 on the hereinafter mentioned Plan of Lots;thence along the line of said Lot No.21,North 22 degrees 40 minutes West, 159.8 feet to a point;thence North 67 degrees 50 minutes East, 100 feet to a point;thence along the line of Lot No. 23 on the hereinafter mentioned Plan of Lots, South 22 degrees 40 minutes East, 158.93 feet to a point on the North side of Manor Road aforesaid;thence along the North side of said road, South 67 degrees 20 minutes West, 100 feet to a point,the place of BEGINNING. BEING Lot No.22 of the West Creek Hills Subdivision recorded in Cumberland County Plan Book 8,page 4. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY EAST PENNSBORO TOWNSHIP BEING PREMISES: 713 Manor Road Camp Hill PA 17011 SOLD as the property of Jeffrey A. Parker and Courtney A. Parker, husband and wife TAX PARCEL#09-18-1304-064 BEING the same premises which Jeffrey A. Parker, a married man by deed dated 2/23/2006 and recorded 2/28/2006 in Cumberland County in Deed Book Volume 273 at Page 1703 granted and conveyed unto Jeffrey A. Parker and Courtney A. Parker, husband and wife KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street F IL E- 6 F-F I C' Philadelphia,PA 19106 C'F THE PROI-H01401AR i 215-627-1322 Attorney for Plaintiff 7D 13 AUG 15 PH U.S.BANK NATIONAL ASSOCIATION,AS f UMB RLAND COUNTY TRUSTEE FOR CERTIFICATEHOLDERS OF P E I IN S Y LVWhE COURT OF COMMON PLEAS BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES of Cumberland County 2006-AC4 c/o 3415 Vision Drive Columbus,OH 43219 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE COURTNEY A.PARKER JEFFREY A.PARKER (Mortgagor(s)and Record Owner(s)) 713 Manor Road No. 13-3589 Camp Hill,PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 713 Manor Road Camp Hill,PA 17011 I.Name and address of Owner(s)or Reputed Owner(s): COURTNEY A.PARKER 713 Manor Road Camp Hill,PA 17011 JEFFREY A.PARKER 713 Manor Road Camp Hill,PA 17011 2.Name and address of Defendant(s)in the judgment: COURTNEY A.PARKER 713 Manor Road Camp Hill,PA 17011 JEFFREY A.PARKER 713 Manor Road Camp Hill,PA 17011 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: EAST PENNSOBOR TOWNSHIP 98 S ENOLA DRIVE ENOLA,PA 17025 BL COMPANIES INC 355 RESEARCH PARKWAY MERIDEN,CT 06450 FIRST FINANCIAL INVESTMENT FUN C/O MICHAEL F RATCHFORD,ESQ/EDWIN A ABRAHAMSEN&ASSOC 120 N KEYSER AVE SCRANTON,PA 18504 BL COMPANIES INC C/O KODAK&IMBLUM PC 407 N.FRONT STREET PO BOX 11848 HARRISBURG,PA 17108 BLUESTONE INVESTMENTS INC C/O JUSTIN N.DAVIS,ESQ/AMATO&LESSA PC 107 N.COMMERCE WAY BETHLEHEM,PA 18017 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 713 Manor Road Camp Hill,PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. DATED: U �/4•� By: KML LAW GROUP,P.C. _Michael McKeever Pa.ID 5 _Jay E.Kivitz Pa.ID 26769 _Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 _David Fein Pa.ID 82628 _Thomas Puleo Pa.ID 27615 _Joshua L Goldman Pa.205047 _Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff a x 541 V&-o re" PI'S # 13-3589 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 i (215)627-1322 Attorney for Plaintiff (�� ( � � �z U.S.BANK NATIONAL ASSOCIATION,AS VA NIA TRUSTEE FOR CERTIFICATEHOLDERS OF IN THE COURT OF COMMON PLEAS BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES of Cumberland County 2006-AC4 c/o 3415 Vision Drive Columbus, OH 43219 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE vs. FORECLOSURE COURTNEY A. PARKER JEFFREY A. PARKER Mortgagor(s)and Record Owner(s) i Docket No. 13-3589 713 Manor Road Camp Hill,PA 17011 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PARKER COURTNEY A. COURTNEY A. PARKER 713 Manor Road Camp Hill,PA 17011 Your house at 713 Manor Road,Camp Hill,PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$151,674.62 obtained by U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: y 13-3589 1. The sale will be cancelled if you pay to U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment,was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale.(See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hqp://www.philadelphiafed.ore/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 1( 13-3589 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orgjconsumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention gkmllawg_roup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 121156FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 13-3589 z - KML Law Group,P.C. t°J 'r Suite 5000-BNY Independence Center PRO i f l N0 7A� ,i 701 Market Street , Philadelphia,PA 19106 P �,, (215)627-1322 C `�� Attorney or Plaintiff � $ ��+�t`Q !Q ; 9 ,. y ��I�EC`n.�� - _ - U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF IN THE COURT OF COMMON PLEAS BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES of Cumberland County 2006-AC4 c/o 3415 Vision Drive Columbus,OH 43219 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE VS. FORECLOSURE COURTNEY A. PARKER JEFFREY A.PARKER Mortgagor(s) and Record Owner(s) Docket No. 13-3589 713 Manor Road Camp Hill,PA 17011 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PARKER,JEFFREY A. JEFFREY A. PARKER 713 Manor Road Camp Hill,PA 17011 Your house at 713 Manor Road,Camp Hill,PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$151,674.62 obtained by U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13-3589 1. The sale will be cancelled if you pay to U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4,the back payments, late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: htti)://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-3589 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionAa kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 121156FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. t"?L-ED-OFF IC ,Law Group,P.C. [�'�t ii N 0 TAI i Suite 5000–BNY Independence Center 701 Market Street 7013. AUG r 5 P11 3, 08 Philadelphia,PA 19106 215-627-1322 CUMBERLAND COUNTY Attorney for Plaintiff I E I '_'-'Y LV A 11;1 A U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED IN THE COURT OF CERTIFICATES, SERIES 2006-AC4 COMMON PLEAS c/o 3415 Vision Drive Columbus, OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW COURTNEY A.PARKER ACTION OF JEFFREY A.PARKER MORTGAGE FORECLOSURE Mortgagor(s)and Record Owner(s) 713 Manor Road Camp Hill,PA 17011 , Defendant(s) NO. 13-3589 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: —d LAW GROU .C. Michael McKeever ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F. Gomall Pa.ID 92382 Attorneys for Plaintiff SO.JVAJ"O rR. �i j��p tc1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 2013-3589 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES,SERIES 2006-AC4 Plaintiff(s) From COURTNEY A.PARKER,JEFFREY A.PARKER (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 gamishee(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:$151,674.62 L.L.:$.50 Interest FROM 04/01/2013 TO DATE OF SALE PER DIEM AT$27.77 Atty's Comm: Due Prothy: $2.25 Atty Paid:$209.70 Other Costs: Plaintiff Paid: Date:August 15,2013 ` 1 A �- '"Z(L David D.Buell, rothonotary- (Seal)) Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO,ESQUIRE Address:KML LAW GROUP,PC. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for:PLAINTIFF Telephone:215-627-1322 Supreme Court ID No.313897 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson t.f1_ 1.•CF 0-, ofClur r, . I fit PRO7f10HOj , .� w y '2'11f Jody S Smith Chief Deputy �. + 2 1;1 � I ^�, '� ? Richard W Stewart Solicitor oFF1cE FTHESHERIFF CUMBERLAND COUNTY PENNSYLVANIA U.S. Bank National Assocation vs. Case Number Courtney A. Parker(et al.) 2013-3589 • SHERIFF'S RETURN OF SERVICE 09/27/2013 05:15 PM -Deputy Stephen Bender, 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 713 Manor Road, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County. 10/25/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $806.80 SO ANSWERS, December 09, 2013 RONNR ANDERSON, SHERIFF ,Sa i L /d a9 p,//9_3 ,e .2.9933 (C)CountySuite Sheriff,Teleosott,Inc. J TKML Law Group,P.C. , Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF IN THE COURT OF COMMON PLEAS BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES of Cumberland County 2006-AC4 do 3415 Vision Drive Columbus, OH 43219 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE COURTNEY A.PARKER JEFFREY A.PARKER (Mortgagor(s)and Record Owner(s)) 713 Manor Road No. 13-3589 Camp Hill,PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES,SERIES 2006-AC4,Plaintiff in the above action,by counsel,KML Law Group,P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 713 Manor Road Camp Hill,PA 17011 1.Name and address of Owner(s)or Reputed Owner(s): COURTNEY A.PARKER 713 Manor Road Camp Hill,PA 17011 JEFFREY A.PARKER 713 Manor Road Camp Hill,PA 17011 2.Name and address of Defendant(s)in the judgment: COURTNEY A.PARKER 713 Manor Road Camp Hill,PA 17011 JEFFREY A.PARKER 713 Manor Road Camp Hill,PA 17011 I 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: EAST PENNSOBOR TOWNSHIP , 98 S ENOLA DRIVE ENOLA,PA 17025 BL COMPANIES INC 355 RESEARCH PARKWAY MERIDEN,CT 06450 FIRST FINANCIAL INVESTMENT FUN C/O MICHAEL F RATCHFORD,ESQ/EDWIN A ABRAHAMSEN&ASSOC 120 N KEYSER AVE SCRANTON,PA 18504 BL COMPANIES INC C/O KODAK&IMBLUM PC 407 N.FRONT STREET PO BOX 11848 HARRISBURG,PA 17108 BLUESTONE INVESTMENTS INC CIO JUSTIN N.DAVIS,ESQ/AMATO&LESSA PC 107 N.COMMERCE WAY BETHLEHEM,PA 18017 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 713 Manor Road Camp Hill,PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.Section 4904 relating to unsworn falsification to authorities. DATED: U i /13 , //- By i KML LAW GROUP,P.C. / / Michael McKeever Pa.ID 5, Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff X SIX1 V6±0 re., epX/1 103i3rirl 13-3589 KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF IN THE COURT OF COMMON PLEAS BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES of Cumberland County 2006-AC4 c/o 3415 Vision Drive Columbus, OH 43219 CIVIL ACTION-LAW Plaintiff ACTION OF MORTGAGE vs. FORECLOSURE COURTNEY A. PARKER JEFFREY A.PARKER Mortgagor(s)and Record Owner(s) Docket No. 13-3589 713 Manor Road Camp Hill,PA 17011 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PARKER,COURTNEY A. COURTNEY A. PARKER 713 Manor Road Camp Hill,PA 17011 Your house at 713 Manor Road,Camp Hill,PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$151,674.62 obtained by U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES, SERIES 2006-AC4 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 13-3589 1. The sale will be cancelled if you pay to U.S.BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC,ASSET BACKED CERTIFICATES,SERIES 2006-AC4,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment,was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale.(See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4: If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 13-3589 •Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout 1 Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 121156FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. • ALL THAT CERTAIN tract or lot of land situate in East Pennsboro Township,Cumberland County,Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point on the North side of a 50 foot road known as Manor Road,at the corner of Lot No.21 on the hereinafter mentioned Plan of Lots;thence along the line of said Lot No.21,North 22 degrees 40 minutes West, 159.8 feet to a point;thence North 67 degrees 50 minutes East, 100 feet to a point;thence along the line of Lot No. 23 on the hereinafter mentioned Plan of Lots, South 22 degrees 40 minutes East, 158.93 feet to a point on the North side of Manor Road aforesaid;thence along the North side of said road,South 67 degrees 20 minutes West, 100 feet to a point,the place of BEGINNING. BEING Lot No.22 of the West Creek Hills Subdivision recorded in Cumberland County Plan Book 8,page 4. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY EAST PENNSBORO TOWNSHIP BEING PREMISES:713 Manor Road Camp Hill PA 17011 SOLD as the property of Jeffrey A. Parker and Courtney A. Parker, husband and wife TAX PARCEL#09-18-1304-064 BEING the same premises which Jeffrey A. Parker, a married man by deed dated 2/23/2006 and recorded 2/28/2006 in Cumberland County in Deed Book Volume 273 at Page 1703 granted and conveyed unto Jeffrey A. Parker and Courtney A. Parker, husband and wife N WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 2013-3589 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due U.S. BANK NATIONAL ASSOCIATION,AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES,SERIES 2006-AC4 Plaintiff(s) From COURTNEY A. PARKER,JEFFREY A. PARKER (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:$151,674.62 L.L.: $.50 Interest FROM 04/01/2013 TO DATE OF SALE PER DIEM AT$27.77 Atty's Comm: Due Prothy: $2.25 Atty Paid: $209.70 Other Costs: Plaintiff Paid: Date: August 15,2013 David D.Buell,Prothonotary 1°y i ielet = Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO,ESQUIRE Address: KML LAW GROUP,PC. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 313897 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa This IS day of 20/5 Prothonotary k LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No.2013-3589 Civil Term A. Parker.and Courtney A. Parker, husband and wife. U.S.BANK NATIONAL ASSOCATION vs. COURTNEY A.PARKER Jeffrey A.Parker Atty.:Michael McKeever ALL THAT CERTAIN tract or lot of land situate in East Pennsboro Town- ship,Cumberland County,Pennsyl- vania, more particularly bounded and described as follows,to wit: BEGINNING at a point on the North side of a 50 foot road known as Manor Road,at the corner of Lot No.21 on the hereinafter mentioned Plan of Lots;thence along the line of said Lot No.21,North 22 degrees 40 minutes West, 159.8 feet to a point; thence North 67 degrees 50 minutes East,100 feet to a point;thence along the line of Lot No. 23 on the herein- after mentioned Plan of Lots, South 22 degrees 40 minutes East, 158.93 feet to a point on the North side of Manor Road aforesaid;thence along the North side of said road,South 67 degrees 20 minutes West, 100 feet to a point,the place of BEGINNING. BEING Lot No. 22 of the West Creek Hills Subdivision recorded in Cumberland County Plan Book 8, page 4. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY EAST PENNS- BORO TOWNSHIP BEING PREM- ISES: 713 Manor Road Camp Hill PA 17011. SOLD as the property of Jeffrey A. Parker and Courtney A. Parker, husband and wife. TAX PARCEL#09-18-1304-064. BEING the same premises which Jeffrey A. Parker,a married man by deed dated 2/23/2006 and recorded 2/28/2006 in Cumberland County in Deed Book Volume 273 at Page 1703 granted and conveyed unto Jeffrey 92 a. k PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. Lis Marie Coyne, Edi r SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 C_ , , / i / //' .11.." Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. • e atriotXews 2020 Technology Pkwy ' Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. P1SBLICATION COPY This ad ran on the date(s)shown below: 10/13/13 4 / / N- / 10/20/13 /- 10/27/13 Sworn to d s scribed before met is 1 day of November, 2013 A.D. b COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel,Notary Public Washington Twp.,Dauphin County My Commission Expires Dec.12,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES • 013-3589 Chill Term 4.S.BANK NATIONAL ASSOCATION vs. COURTNEY A.PARKER Jeffrey A.Parker Atty: Michael McKeever ALL THAT CERTAIN tract or lot of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point on the North side of a 50 foot road known as Manor Road,at the corner of Lot No.21 on the hereinafter mentioned Plan of Lots; thence along the line of said Lot No.21,North 22 degrees 40 minutes West,159.8 feet to a point;thence North 67 degrees 50 minutes East,100 feet to a point;thence along the line of Lot No. • 23 on the hereinafter mentioned Plan of Lots, South 22 degrees 40 minutes East,158.93 feet to a point on the North side of Manor Road aforesaid;thence along the North side of said road,South 67 degrees 20 minutes West,100 feet to a point,the iftace of BEGINNING. BEING Lot No.22 of the West Creek Hills Subdivision recorded in Cumberland County Plan Book 8,page 4. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY EAST PENNSBORO TOWNSHIP BEING PREMISES: 713 • Manor Road Camp Hill PA 17011 SOLD as the property of Jeffrey A.Parker and Courtney A.Parker,husband and wife TAX PARCEL#09-18-1304-064 BEING the same premises which Jeffrey A. Parker, a married man by deed dated 2/23/2006 and recorded 2/28/2006 in Cumberland County in Deed Book Volume 273 at Page 1703 granted and conveyed unto Jeffrey A.Parker and Courtney A.Parker, husband and wife KML LAW GROUP, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 -1532 215- 627 -1322 Attorney for Plaintiff CCU: i PENNSYLVANIA U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIF:ICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2006 -AC4 do 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. COURTNEY A. PARKER JEFFREY A. PARKER (Mortgagor(s) and Record owner(s)) 713 Manor Road Camp Hill, PA 17011 TO THE PROTHONOTARY: Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County PRAECIPE TO VACATE JUDGMENT Kindly vacate the judgment upon payment of your costs only. No. 13 -3589 By: keA161, KML LAW GR t+� i ' . P.C. Michael McKe•ve 'a. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Attorney ID 313897 Attorneys for Plaintiff rreollit 31&101 alhd" F-1-21sLis2-) KML LAW GROUP, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627 -1322 ATTORNEY FOR PLAINTIFF U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2006 -AC4 Plaintiff vs. COURTNEY A. PARKER JEFFREY A. PARKER (Mortgagor(s) and Record Owner(s)) Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13 -3589 CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he /she did serve true and correct copies of Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre -paid, on -_1—/c( . COURTNEY A. PARKER 713 Manor Road Camp Hill, PA 17011 JEFFREY A. PARKER 713 Manor Road Camp Hill, PA 17011 By: KML LAW ROUP, P.C. Angela M. Smith , Legal Assistant asmith@kmllawgroup.com 215- 825 -6325 (Direct Phone) KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 -1532 215- 627 -1322 j -Lrrft L � hE�tPi�0THON0Tta, s 2414 APR 17 AM10=1 +1 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF IN THE COURT OF COMMON PLEAS BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED OF CUMBERLAND COUNTY CERTIFICATES, SERIES 2006 -AC4 c/o 3415 Vision Drive Columbus, OH 43219 PENNSYEVANiA Plaintiff No. 13 -3589 vs. COURTNEY A. PARKER JEFFREY A. PARKER (Mortgagor(s) and Record owner(s)) 713 Manor Road Camp Hill, PA 17011 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F /K/A GOLDBECK McCAFFERTY & McKEEVER By: Michael McK a er Pa. ID 56129 Jay E. Kivitz a ID 26769 Lisa Lee Pa. ID 8020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 /Salvatore Filippello, Pa. ID 313897 Jennifer Lynn Frechie, Pa. ID 316160 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627 -1322 Attorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS OF BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2006 -AC4 Plaintiff vs. COURTNEY A. PARKER JEFFREY A. PARKER (Mortgagor(s) and Record Owner(s)) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13 -3589 Defendant(s) CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he /she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre -paid, on COURTNEY A. PARKER 713 Manor Road Camp Hill, PA 17011 JEFFREY A. PARKER 713 Manor Road Camp Hill, PA 17011 KML LAW GROUP, P.C. F/K/A GOLDB CK McCAFFER Y & McKEEVER Bv: Ange M. Smith , Legal Assistant asmith @kmllawgroup.com 215- 825 -6325 (Direct Phone)