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HomeMy WebLinkAbout13-6409 Supreme. Court of P ennsyTVania Cau3 ;c ai n Pleas �a1Z B COZ =e1 S leet For Paothonotm Use OnI 7j i a. Cumberlan'a� ,,. C°o in Dod;etNo. _=f 13 The information collecteWon this form is used solely for court administration purposes. This form does not Supplement or replace the filing and service ofpleadings or other papers as required b law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from another Jurisdiction ❑ Declaration of Takin E Lead Plaintiff Name: Lead Defendant's Name: VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2 GEORGE A. SHERIFF JR. C ROBIN C. SHERIFF T I Dollar Amount Requested within arbitration limits O 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 5 ❑ Premises Liability ❑ Zoning Board a ❑ Product Liability (does not include ❑ Statutory Appeal: Other E mass tort) Discrimination dispute: ❑ Slander/Libel Defamation Discrimination ❑ Other ❑Employment Dispute: Other T ❑ Other: I Q MASS TORT ❑ Other ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory ❑ Toxic Waste B ❑Other ❑Eminent Domain/Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord/Tenant Dispute ❑ Mandamus ® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order ❑ Dental ❑ Partition ❑ Quo Warranto ❑ Legal ❑ Quiet title ❑ Replevin ❑ Medical ❑ Other Professional: ❑ Other ❑ Other Pa.RC.P. 205.5 Updated 1/1/2011 KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413 -2311 WW W.KMT,I,AWGROUP.COM VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2 IN THE COURT OF COMMON PLEAS 13801 Wireless Way Oklahoma City, OK 73134 OF Cumberland COUNTY Plaintiff vs. CIVIL ACTION - LAW GEORGE A. SHERIFF JR. ROBIN C. SHERIFF ACTION OF MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) r _ L� p 5 Sunset Drive l Mechanicsburg, PA 17050 %V CT10N: MORTGAG Defendant(s) F0RECL®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 Z3 Carlisle, PA 17013 r ' LEGAL SERVICES INC 8 Irvine Row' r, Carlisle, PA 17013 Cz 717- 243 -9400 a--,' < AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO P AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. e KJ7 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 http: / /www. hp fa.org /consumers /homeowners /real aspx 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.philadelphiafed.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 homeretentionkkmllawgroup.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 124033FC. Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2, 13801 Wireless Way, Oklahoma City, OK 73134. 2. The name(s) and address(es) of the Defendant(s) is /are GEORGE A. SHERIFF JR., 5 Sunset Drive, Mechanicsburg, PA 17050 and ROBIN C. SHERIFF, 5 Sunset Drive, Mechanicsburg, PA 17050, who is /are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On January 13, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to AMC MORTGAGE SERVICES, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on February 10, 2006 as Book 1940, Page 399. The mortgage has been assigned to: VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2 by assignment of Mortgage. Plaintiff is the real party in interest pursuant to an Assignment of Mortgage to Plaintiff attached as Exhibit C. The Mortgage and Assignment(s) (if any) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ( "Property "). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: PrincipalBalance ............................... ............................... ....................$ Interest from 02/01/2013 through 09/30/2013 at 8.5000% .....................$10,296.16 Per Diem interest rate at $22.52 LateCharges ......................................... ............................... .........................$ Escrow........................................................................ ............................... $1,062.09 ApPraisalBPO...................................... ............................... ........................$ PropertyInspections .................................................. ............................... ...$55.00 Reasonable Attorney's Fee .................. ............................... ............ ..........$1,650. 00 $114,123.29 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 $114,123.29, together with interest at the rate of $22.52, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: KML LAW OUP, 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 � Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Attorneys for Plaintiff VERIFICATION I, Isabel Melendez as the representative of Caliber Home Loans, Inc., solely in its capacity as servicer for the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of Caliber Home Loans, Inc., solely in its capacity as servicer for the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: CD IZ-A IZ �� VOLT Participation Trust 2011 -NPL2, by Caliber Home Loans, Inc., s ely in its capacity as se icer Isabel Melendez Default Service Officer #1240331 - GEORGE A. SHERIFF JR. and ROBIN C. SHERIFF 5 Sunset Drive Mechanicsburg, PA 17050 hibitA ALL THOSE CERTAIN TWO TRACTS OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, CMMZRLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO HIT: TRACT NO. 1 BEGINNING AT AN IRON PIN IN THE CENTER LINE OF A 40 FOOT PUBLIC ROAD KNOWN AS LEGISLATIVE ROUTE 597, AT THE INTERSECTION OF THE EASTERN LINE OF A PUBLIC ROAD (50 FEET HIDE), KNOWN AS OAK LANE (SHOWN IN THE PLAN OF SOTS OF WHITE BIRCH FARMS DEVELOPMENT, AS RECORDED IN PLAN BOOK 11, PAGE 37); THENCE ALONG THE' CENTER LINE OF SAID 40 FOOT PUBLIC ROAD, SOUTH 73 DEGREES 41 MINUTES EAST, 114.59 FEET TO AN IRON PIN; THENCE CONTINUING ALONG SAID CENTER LINE, SOUTH 56 DEGREES 41 MINUTES EAST, 65.06 FEET TO AN IRON PIN; THENCE CONTINUING ALONG SAID CENTER LINE SOUTH 42 DEGREES 28 MINUTES EAST, 102.85 FEET TO AN IRON PIN ON THE LINE OF LAND HOW OR FORMERLY OF GEORGE W. WAIJ= AND HARI ALICE NALXER, HIS WIFE, DUE NEST, 250.5 FEET TO AN IRCN PIN ON THE EAST SIDE OF THE PUBLIC ROAD KNOWN AS OAK LANE, AFORESAID; THENCE ALONG THE EAST SIDE OF SAM OAK LANE, DUE NORTH, 154.6 FEET TO AN IRON PIN IN THE CENTER LINE OF THE 40 FOOT PUBLIC ROAD KNOWN AS LEGISLATIVE ROUTE 597, THE PLACE OF BEGINNING. CONTAINING 0.57 ACRE. TRACT NO. 2 BEGINNING AT A POINT ON THE EASTERN LINE OF A PUBLIC ROAD (50 FEET WIDE), KNOWN AS OAK LANE (SHOWN IN THE PLAN OF LOTS OF WHITE BIRCH FARMS DEVELOPMENT, AS RECORDED IN PLAN BOOK 11, PARE 37), AT CORNER OF LAND NOW OR FORIDCRLY OF BARBARA HERSH; THENCE ALONG THE LINE OF SAID LAM NOW OR FORMERLY OF BARBARA HERSH, DUE EAST, 123.24 FEET TO A POINT; THENCE ALONG LAND NOW OR FORMERLY OF GEORGE W. W 12MR AHD !AIRY ALICE WALKER, HIS WIFE, SOUTH 22 DEGREES 05 MINUTES WEST, 133 FEET TO A POINT ON THE EASTERN LINE OF OAK NINE; THENCE ALONG THE EASTERN LINE OF OAK LANE, DUE NORTH, 50 FEET TO A POINT, THE PLACE OF BEGINNING. HAVING THEREON ERECTED A ONE -STORY BRICK AND ALUMINUM DWELLING HOUSE. FOR INFORMATIONAL PURPOSES ONLY: THE APH IS SHOWN BY THE COUNTY ASSESSOR AS 36 -14- 0647 -024; SOURCE OF TITLE IS BOOK 261, PAGE 3513 (RECORDED 02/23/04). Ey,hibit 0 *Exhibit has been redacted to remove all personally identifiable information or non-public information P.O. Box 24610 "ST Oklahoma City, OK 73124 -0610 VERIC May 28, 2013 GEORGE A SHERIFF JR 5 SUNSET DRIVE MECHANICSBURG PA 17050 -1652 Please See Attached Notice Notice to Consumers presently in Bankruptcy or who have a Bankruptcy Discharge: If you are a debtor presently subject to a proceeding in Bankruptcy Court, or if you have previously been discharged from this debt by a Federal Bankruptcy Court, this communication is not an attempt to collect a debt but is sent for informational purposes only or to satisfy certain Federal or State legal obligations. THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A CONSUMER DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 7:50 Mailing Certified prim 20130508rev Date: 05/28/13 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 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1 -800- 342 -2397. (Persons with impaired hearing can call (717) 780- 18 69). 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 VIV.IENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCION INMEDITAMENTE 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): GEORGE A SHERIFF JR ROBIN C SHERIFF PROPERTY ADDRESS: 5 SUNSET DRIVE MECHANICSBURG PA 17050 -1652 LOAN ACCT. NO.: 236 CURRENT LENDER: U.S. Bank Trust, N.A. as trustee for VOLT Participation Trust 2011 -NPL2 CURRENT SERVICER: Vericrest Financial, Inc. 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 agency 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 HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WiLL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED 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 INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTE. IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).. NATURE OF THE DEFAULT - -The MORTGAGE debt held by the above lender on your property located at: 5 SUNSET DRIVE MECHANiCSBURG PA 17050 -1652 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 months for $ 2,388.72. Other charges (expiain/itemize): Late Charges: $ 30.00 Other Charges: $ 443.15 Escrow: $ 655.92 Lender Placed Ins /Taxes: $ 0.00 TOTAL AMOUNT PAST DUE: $ 3,517.79 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 $ 3, 517.79, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Vericrest Financial, Inc. P.O Box 24610 Oklahoma City, OK 73124 Attn: Kawanna Coppage 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 al( other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's 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 SHERIFFS 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 10 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: U.S. Bank Trust, N.A. as trustee for VOLT Participation Trust 2011 -NPL2 Name of Servicer: Vericrest Financial, Inc. Address: P.O. Box 24610 Oklahoma City, OK 73124 Phone Number: 1 - 800 - 621 - 1437 Fax Number. 1 - 405 - 608 - 2018 Contact Person: Kawanna Coppage E -Mail Address: kcoppaye (cDvericrestfinancial.com EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You mayor X 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 Please see the attached list of consumer credit counseling agencies serving your county, 7:50 Mailing Certified prim 20130508rev ` Comprehensive Housing C cy �,txtPsir�r" r�ir�a��� �ttii�cy Counseling Agencies Agencias de Consejo al Ciiente para Vivienda Cumberland County "CCCS of Western PA - York 55 Clover Hill Road Dallastown PA 17313 888.511.2227 / 888.511.2227 www.cccspa.org Community Action Commission - Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 www.cactricounty. org Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing & Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle PA 17013 866.683.5907 1717.249.0789 www.cchra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www.ruralisc.org /pathstone ga.htm Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www.adamscha.org NOTE; Many of the agencies offer workshops at various location sites; call to find a location near you. Report last updated 4/30/2012 9:03:04 AM Page 1 of 1 P.O. Box 24610 t Oklahoma City, OK 73124 -0610 May 28, 2013 ROBIN C SHERIFF 5 SUNSET DRIVE MECHANICSBURG PA 17050 -1652 Please See Attached Notice Notice to Consumers presently in Bankruptcy or who have a Bankruptcy Discharge: If you are a debtor presently subject to a proceeding in Bankruptcy Court, or if you have 3 previously been discharged from this debt by a Federal Bankruptcy Court, this communication is not an attempt to collect a debt but is sent for informational purposes only or to satisfy certain Federal or State legal obligations. THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A CONSUMER DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 7:50 Mailing Certified sec 20130508rev Date: 05/28/13 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 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1- 800.342 -2397. (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, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI6N OBTENGA UNA TRADUCCION IiNMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGR.AMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER NAME(S): GEORGE A SHERIFF JR ROBIN C SHERIFF PROPERTY ADDRESS: 5 SUNSET DRIVE MECHA PA 17050 -1652 � LOAN ACCT. NO.: 236 CURRENT LENDER: U.S. Bank Trust N.A. as trustee for VOLT Participation Trust 2011 - NPL2 CURRENT SERVICER: Vericrest Financial, Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE 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 agency 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 mort 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 Homeowners 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 HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED 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 INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE iS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - -The MORTGAGE debt held by the above fender on your property located at. 5 SUNSET DRIVE MECHANICSBURG PA 17050 -1652 IS SERIOUSLY IN DEFAULT because: . YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 months for $ 2,388.72. Other charges (explainlitemize): Late Charges: $ 30.00 Other Charges: $ 443.15 Escrow: $ 655.92 Lender Placed Ins/Taxes: $ 0.00 TOTAL AMOUNT PAST DUE: $ 3,517.79 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 $ 3,517.79, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to. Vericrest Financial, Inc. P.O Box 24610 Oklahoma City, OK 73124 Attn: Kawanna Coppage 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. ff 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 SHERIFFS 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 Sheriff's 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 10 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: U.S. Bank Trust, N.A. as trustee for VOLT Participation Trust 2011 -NPL2 Name of Servicer: Vericrest Financial, Inc. Address: P.O. Box 24610 Oklahoma City, OK 73124 Phone Number: 1 - 800 - 621 - 1437 Fax Number: 1 - 405 - 608 - 2018 Contact Person: Kawanna Coppage E -Mail Address: kcoppane (cDvericrestfinancial.com EFFECT OF SHERIFFS SALE -- You should realize that a Sheriff's Sale will end your ownership of .the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -- You mayor X 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 MAYALSO 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 Please see the attached list of consumer credit counseling agencies serving your county. 7:50 Mailing Certified sec 20130508rev Comprehensive Housing Counseling Agencies Agendas de Consejo al Cliente para Vivienda ! ..... _.. _.::__.... ....... ................. ............. Cumberland Count •CCCS of Western PA - York 55 Clover Hill Road Dallastown PA 17313 888.511.2227 1888.511.2227 www.cccspa.org Community Action Commission -Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 www.cactricounty.org Harrisburg Fair Housing Council 2100 N 6th St Harrisburg PA 17110 717.238.9540 Housing & Redevelopment Authority - Cumberland Cnty 114 N Hanover St; STE 104 Carlisle PA 17013 866.683.5907 / 717.249.0789 www.cehra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www.ruralisc.org /pathstone oa htm Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www.adamscha.org NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. .. Repoli last updated. 4/30/2012 9.03:04 AM Page 1 o . f 1 Ej Exhibit has been redacted to remove all personally identifiable information or non - public information RECORDING REQUESTED BY AND WHEN RECORDED RETURN TO: CALIBER HOME LOANS 13801 Wireless Way Oklahoma City, OK 73134 Prepared By: Kolette Modlin Loan Number: 236 MERS Min: 000000000000000000 Parcel ID:: 38- 14-0847 -024 Space Above This Line For Recorder's Use ASSIGNMENT OF MORTGAGE/DEED OF TRUST FOR VALUE RECEIVED, the undersigned VERICREST OPPORTUNITY LOAN TRUST 2011 -NPL2 whose address is 13801 WIRELESS WAY, OKLAHOMA CITY, OK 73134, hereby grants, assigns and transfers to VOLT PARTICIPATION TRUST 2011 -NPL2 whose address is 13801 WIRELESS WAY, OKLAHOMA CITY, OK 73134 all beneficial interest under that certain mortgage/Deed of Trust/Security Deed dated 01/13/2006 executed by GEORGE A SHERIFF JR and ROBIN C SHERIFF to AMC MORTGAGE SERVICES, INC. in the amount of $108,000.00 and recorded on 2/10/2006 as Instrument # N /A, in Book•'Volume or Liber No. 1940 , Page/folio 399 of Official Records in the County Recorder's office of UNKNOWN County, PA, describing land herein as: 'SEE ATTACHED 'EXHIBIT A' Property Address: 5 SUNSET DRIVE, MECHANICSBURG PA 17055 TOGETHER with the note or notes therein described or referred to, the money due and to become due thereon with interest, and all rights accrued or to accrue under said mortgage/Deed of Trust/Security Deed. VERICREST OPPORTUNITY LOAN TRUST 2011 -NPL2, BY ITS TRUSTEE U.S. BANK TRUST, N.A., THROUGH CALIBER HOME LOANS, INC., F /K/A VERICREST FINANCIAL, INC., AS ATTORNEY IN FACT FOR THE TRUSTEE Wit #1 ( �i G QC1J Witness #2 dt^ 'YC` C��..t B y , a n am County of San Diego) s ice President State of California) n Title: fide O S]� O t/13 before me, �y°Afl ruri Notary Public, personally appeared who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is /are subscribed to the within instrument and acknowledged to me that he /she /they executed the same in his/her /their authorized capacity(ies), and that by his/her /their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State o alifomia that the foregoing paragraph is true and correct. BREANNA JENKINS Commission # 2027923 WITNESS my band official seal, i +D Notary Public - California s San Diego County My Comm. Expires Jun 7, 2017 r Notary Name: My Commission Expires: r I �y JU - 71201 - L certifies that the principal business and mailing address for this ass* ent and assi a is: Caliber Home Loans, Inc. 13801 Wireless Way, Oklahoma City, OK 73134. I ' ERHISZT °A•' ALL THOM C&RTATU TWO TRACTS OF LEND 6ITVATE IN TIM TOWNSHIP OF SZLV4R SPRING, CIRMISRLAM COUNTY, PENNSYLVANIA, BOOMED AND DESCRI8E0 AS FOLZ.OWs, TO WIT! TRACT HO. 1 A'15GINKIWO AT AN IR67N PIN IN THE CENTER LINE OF A 40 FOOT PUBLIC ROAD KNOW Al LEGISLATIVE ROUTE S97, AT THE INTERSECTION OF THE BASTEM LIRE Of A PUBLIC ROAD I50 FEET NMI), KHOMH AS OAK IAHE COMM IN THE PLAN OP LOTS OF WHITE BZRCH PARN6 DEVELOPMENT, AS RECORDED IN PLAN 130OR 11, RAW 371: THENCE ALONG Tog CENSER LINE OF MAID 40 FOOT PUBLIC ROM, SOUTH 73 DEGREES 41 XUMTES EAST, 114.59 FEET TO ATP IRON PIN. THENCE CC)MMrI96 ALONG SAID CEIRER LIIR, SOOT!! $6 DEMM E 41 MINUTES PAST, 65.06 FEET TO All IRON PIN; THEM COM3NOZH0 ALOND SAID CENTER LIM SOUTH 42 DEGREES 26 KWOTES EAST, 102.65 FEET TO AN ZROH PIN ON THE LINE OF LAND NON OR PORNERLT of GEORGE W. W11=R Am NARY ALIOS 7DILIRER, HIS WIFE, t DUE WEST, 250.5 FEET TO AN IRON PIN ON THE EAST SIDE OF THE PUBLIC ROAD SWOON AS OAK LANE, AFORESAID: 'ONCE ALONG IRE EAST SIDE OF SAID 0016 LANE, DUE NORTH, 154.6 FEET TO AN IRON PIN IN THE CENTER LINE OF THE 40 FOOT VUBLIC ROAD f070FFN AS LEGISLATIVE ROUTE $97, TIPS PLACE OF 9EGINNIIFC. CON?AINSNG 0.57 ACRE, TRACT ND. 2 DEGZNNING AT A POINT ON TF9 EASTERN I= OF A PUBLIC ROAD (50 . FEET RIDE), IMI" AS OAK LANE CSHO107 IN THE PLAN OF LOTS OF WHITE NIECE FAna DEVELOPMENT, AF RECMWED in PU%W DOGE 11, PAGE 37), AT CORNER OF JAM NOW OR FORMERLY Of BARBARA RUM; THENCE ALCNG ' TEE Liles OF SAZO LAND NOF OR FWNERLY OF BARBARA HERSH, DUE EMT, 123.24 FEET TO A POINT; INENCE ALONC LAND NON OR FOFVERLY OF GEORGE W. WALID:R AND MART ALICE )REAPS, NIS RIFE, SOUTH 22 DEGREES 03 NIHVTES WaST, 133 FEET TO A POINT ON THE EASTERN LINE OF OAR LANE; rNEmCS ARAM 179 EASTERN LINE OF OAR T-UM, DUE NORTH, SO FEET TO A POINT, THE PLACE OF EEGINNIN6. IAV3PG INERSON ERECTED A ONE -STORY MUM AND ALOHIN DWELLING HOUSE. 1 tT7il I17F@OATZONAL PURPOSES OMLT: THE APN T9 Sf10NR At THE COUNTY . A8319SOR AS 38 -14 -0847 -024; SOURCE OF TITZZ 19 BOOK 261, PAGE 3613 4RECOROEn 02/23/04) J Ctfj f A trjs t0 l7C reccvded In Cumberland County PA C - R corder of D i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2 Plaintiff vs. Case No. 3 GEORGE A. SHERIFF JR. ROBIN C. SHERIFF 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: M1 co CD ?? -< ` } (Signature o ounsel for Plaintiff) r � CD 6 3 . C: Dae —s Cumberland County Residential Mortgage ]foreclosure Diversion Program Financial 'Worksheet Jute Cumberland County Court of Common Pleas Docket # EORJZOWF-R REQUEST FOR HARDS141P ASSISTANCE To complete-your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower names ): Property Address: City: _ _ State: _ _ _ _ Zip: Is the property for sale? Yes EJ No Q Listing elate: Price: Realtor Name: Realtor Phone: Borrower Occupied? Yes No El Mailing Address (if different): City: State: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address; City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # ofpeople in household: How long? First Mortgage Leader: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan; Loan Number: Total Mortgage Payments Amount; $ Included Taxes & Insurance , Date of Last Payment: Primary Reason for Default: is the loan in Bankruptcy? Yes 0 No If yes provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: -- — - $ Other Real Estate: $ $ Retirement Funds: $ Investments: $ $ Checking: $ $ Savings: $ $ Gather: $� $ Autornobile #1: Model- Year: Amount owed: Value: Automobile #2 : Model: Year: Amount oared: Value: Other transportation Lautomobiles moats m tore Iles : Modch year Amount owed: Value Month! Income Name of Employers: 1. 2. 3. Additional Income Description (not. wages): 1. monthly amount: 2. monthly amount Borrower Pay Days Co- Borrower Pay Days: Monthly Exgq ses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT lio Food 2 Mort a s Utilities Car Pa ent s Condo/Nei , Fees Auto Insurance Med. not covered Auto fuelhe airs Other prop. payment Install. loan Payment Cable TV Child Su rt/Alim. SLm riding Mone Da r /Child Care/` uit, Other Ex eases Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes El No Q If yes, please provide the following information: Counseling Agency: Counselor: Phone.(Office): Pax: - Email; Have you made application for Homeowners Emergency Mortgage Assistance Program 14EMAP) assistance? yes F 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 Q If yes, please indicate the status of these negotiations, Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone- Servicing Company (Wame): Contact: Phone: Itwe, , authorize the above named to use ?refer this information to racy lenderlservicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Itwe am/are under no obligation to use the services provided by the above named Borrower Signature. Date Co- Borrower Signature Date Tease forward this document along with the following information to lender and lender's counsel: f Proof of income iE Post 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation d (hardship letter) Y Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ,� FF� . Sheriff JF THE PRO THONU)"t,;;`,° Jody S Smith Chief Deputy 2013 OV 25 PAM L.- 03 Richard W Stewart ."°' Solicitor OFFICE OF THE SHERIFF CUMBERLAND PENNSYLVANIA Y AH A Vericrest Opportunity Loan Trust 2011 NPL2 Case Number vs. George A Sheriff, Jr(et al.) 2013-6409 SHERIFF'S RETURN OF SERVICE 11/19/2013 07:41 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mo ge Foreclosure by handing a true copy to a person representing themselves to be Robin Sh accept'ed as"Adult" Person in Charge"for George A Sheriff, Jr at 5 Sunset Drive, Silver Spring Township,_Mechanicsburg, PA 17050. JASON'KINS ER, DEPUTY 11/19/2013 07:41 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by igWersonally" handing a true copy to a person representing themselves to be the Defendant, to wit' eriff at 5 Sunset Drive, Silver Spring Township, Mechanicsburg, PA 17050. Lh 1 JASO KINS DEPUTY I SHERIFF COST: $66.60 SO ANSWERS, (ix. November 20, 2013 R0ONNY R ANDERSON, SHERIFF (c)Countysuite Sheriff,Teleosott,Inc. a-" .r 'LEO- r,,, OFFft KML LAW GROUP, P.C. HQNOTAR y Suite 5000—BNY Mellon Independence Center 2013 DEC 701 Market Street �,� 20 Am � 36 Philadelphia, PA 19106 PEENS AND COUNTY 215-627-1322 Attorney for Plaintiff ��ANjQ VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2 13801 Wireless Way Oklahoma City, OK 73134 IN THE COURT OF COMMON PLEAS Plaintiff vs. OF Cumberland COUNTY GEORGE A. SHERIFF JR. CIVIL ACTION—LAW ROBIN C. SHERIFF (Mortgagor(s)and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE 5 Sunset Drive Mechanicsburg,PA 17050 Defendant(s) No. 13-6409 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P.2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of VOLT PARTICIPATION TRUST 2011-NPL2 for Voluntary Substitution under Pa.R.C.P. 2352 due to Assignment of Mortgage and attached Statement of Material Facts in Support of Voluntary Substitution,Verification, Certification of Service. The address for the new Plaintiff is 13801 Wireless Way, Oklahoma City, . By: v KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa. ID 312912 Attorneys for Plaintiff NitkA 9, bop d CkjL 75tilis-9 - aGa(os6 KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2 13801 Wireless Way IN THE COURT OF COMMON PLEAS Oklahoma City,OK 73134 Plaintiff OF Cumberland COUNTY vs. CIVIL ACTION—LAW GEORGE A. SHERIFF JR. ROBIN C. SHERIFF ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s)and Record Owner(s)) 5 Sunset Drive Mechanicsburg,PA 17050 No. 13-6409 Defendant(s) STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P.2352 VOLT PARTICIPATION TRUST 2011-NPL2,by counsel,hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: 1. The above-captioned Action of Mortgage Foreclosure relates to a property located at 5 Sunset Drive Mechanicsburg,PA 17050("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Book 1940,Page 399 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2. 4. VOLT PARTICIPATION TRUST 2011-NPL2 is the successor in interest to the Plaintiff by an assignment of mortgage recorded in land records of Cumberland County on December 10,2012 in Instrument# 201338997 and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. Respectfully submittedd, te By: G�' .,/ KML LAW GROUP,P.C. Michael McKeever Pa. ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Jill P.Jenkins Pa. ID 306588 ),Alyk L.Oflazian Pa.ID 312912 Attorneys for Plaintiff KML LAW GROUP, P.C. SUITE 5000—BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 215-627-1322 ATTORNEY FOR PLAINTIFF VERICREST OPPORTUNITY LOAN TRUST 2011 NPL2 13801 Wireless Way IN THE COURT OF COMMON PLEAS Oklahoma City, OK 73134 OF Cumberland COUNTY Plaintiff vs. CIVIL ACTION-LAW GEORGE A. SHERIFF JR. ACTION OF MORTGAGE ROBIN C. SHERIFF FORECLOSURE (Mortgagor(s)and Record Owner(s)) Term 5 Sunset Drive No. 13-6409 Mechanicsburg,PA 17050 Defendant(s) CERTIFICATE OF SERVICE Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first v class mail, postage pre-paid, on U�,�I GEORGE A. SHERIFF JR. 5 Sunset Drive Mechanicsburg, PA 17050 ROBIN C. SHERIFF 5 Sunset Drive Mechanicsburg, PA 17050 B Y� - KML Law Group,P.C. Doris Guzman, Legal Assistant Dguzman @kmllawgroup.com 215-825-6402 (Direct Phone) In the Court of Common Pleas of Cumberland County VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 VS. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF ' (Mortgagor(s) and Record Owner(s)) 5 Sunset Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s) r --- C,( •, No. 13-6409 c;.,N • PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against GEORGE A. SHERIFF JR. and ROBIN C. SHERIFF by default for want of an Answer. Assess damages as follows: $124,595.09 Debt Interest from 1/9/2015 to Date of Sale per diem at $22.52 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. 23711-�-�� By: l,/il'-LtAitte c-. 614111 KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 _Jay E. Kivitz Pa. ID 26769 _Lisa Lee Pa. ID 78020 _Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 _Thomas Puleo Pa. ID 27615 _Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gomall Pa. ID 92382 _Salvatore Filippello Pa. ID 313897 —Jennifer L. Oflazian Pa. ID 312912 _Jennifer Lynn Frechie Pa ID 316160 Attorneys for Plaintiff _46118-1111a Lynn C6.110(/8Y31 • AND NOW 1? -C%° , Judgment is entered in favor of VOLT PARTICIPATION TRUST 2011-NPL2 and against GEORGE A. SHERIFF and RN C. "' 'L' 1141- by def for want of an Answer and damages assessed in the sum of $124,595.09 as per the aboo certific, coot s 1G, tth, -Cut vs -)a2 3154tb2:. �3o_ cG Prothot, Rule of Civil Procedure No. 236 — Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 GEORGE A. SHERIFF JR. ROBIN C. SHERIFF (Mortgagors and Record Owner(s)) 5 Sunset Drive Mechanicsburg, PA 17050 Plaintiff vs. Defendant(s) No. 13-6409 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 By: If putt'' 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 - 124033 FC 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: GEORGE A. SHERIFF JR. SHERIFF JR., GEORGE A. 5 Sunset Drive Mechanicsburg, PA 17050 VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 Plaintiff vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF (Mortgagor(s) and Record Owner(s)) 5 Sunset Drive Mechanicsburg, PA 17050 Defendant(s) TO: GEORGE A. SHERIFF JR. 5 Sunset Drive Mechanicsburg, PA 17050 DATE OF THIS NOTICE: December 9, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-6409 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT UN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (I0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A 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 ATA 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 By: 11. }CIVIL LAW GROUP, R.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 Tennifer Lynn Frechie Pa ID 316160 215-627-1322 Attorneys for Plaintiff 124033 FC 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: ROBIN C. SHERIFF SHERIFF, ROBIN C. 5 Sunset Drive Mechanicsburg, PA 17050 VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 Plaintiff vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF (Mortgagor(s) and Record Owner(s)) 5 Sunset Drive Mechanicsburg, PA 17050 Defendant(s) TO: ROBIN C. SHERIFF 5 Sunset Drive Mechanicsburg, PA 17050 DATE OF THIS NOTICE: December 9, 2014 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure No. 13-6409 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIIThN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A 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 Michael McKeever Pa. ID 56129 Lisa Lee Pa. 1D 78020 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello Pa. ID 313897 ennifer Lynn Freebie Pa ID 316160 215-627-1322 Attorneys for Plaintiff. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VOLT PARTICIPATION TRUST 2011-NPL2 Plaintiff vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF Defendant(s) NO. 13-6409 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.mil/appj/scra/scraHome.do) for the following individual(s): GEORGE A. SHERIFF JR., has a last known residence of 5 Sunset Drive, Mechanicsburg, PA 17050. 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 / (T By: 4CPPN-A)1 KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 J nnifer Lynn Frechie Pa. ID 316160 Cristina Lynn Connor Pa. ID 318389 -Victoria W. Chen Pa. ID 317741 Attorneys for Plaintiff .Department of Defense Manpower Data Center Status Report Pursuant to Sere cernem Civil Last Name: SHERIFF JR First Name: GEORGE Middle Name: A. Active Duty Status As Of: Jan -08-2015 ie Act Results as of : Jan -08-2015 10:4925 AM SCRA 3.0 On Active Duty On Active Duty Status Dale - Active Duty Start Date " Active Duty End Date Status Service Component NA NA a.,j � - ,,:.f, l., No..�x NA 0/ H'4� . t x �._•,, 'Sr'; "',1 -,'E. This response reflects the Individuals active duty status' based on the Active Duly Status Dale i1 L oft Active Duly Within 367 Days of Active Duly Status Date - - Active Duty Start Date Duty End Date Status Service Component. NA ,AccJtive k t r i^ NA «° {.3, {, i tt�' ....;, «"?f^,-`t+fQ', a;" 1'] f 44'i NA This response reflects Where, the individual left &leve duty, status"wlthin,.367 tlays-preceding the Active Duty Status Date The Member or His/Her Unit Was Noted of a Futu e Call -Up to Active Duty on Active Miry Status Date . Order Notification Start Date Order Notification End Date - Status Service Component, NA 71,` NA.,.s;_3... ..,.�.., i {'a�No , NA This response reflects whetherhe mA_hsxdual �drhis"he-0nilhas:recejved,e,'l-,inoott}t,catrontoeort 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. • 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/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: V1ZCI8AAC134580 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: SHERIFF First Name: GEORGE Middle Name: A. Active Duty Status As Of: Jan -08-2015 Results as of : Jan -08-2015 10:48:26 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA • '. - No - NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date This response reflects the individuals' active duty status based on the Active Duty Status Date • Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA , . NA �, . No .:- NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA - No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 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/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: A142W8FA1134U80 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VOLT PARTICIPATION TRUST 201.1-NPL2 Plaintiff - vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF Defendant(s) NO. 13-6409 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd.miLlappj/scra/scraHome.do) for the following individual(s): ROBIN C. SHERII~r, has a last known residence of 5 Sunset Drive, Mechanicsburg, PA 17050. 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 1 Vl I T By: C,(1)r) iil KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall. Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Jill P. Jenkins Pa. ID 306588 yAI k L. Oflazian Pa. ID 312912 ennifer Lynn Frechie Pa. ID 316160 Cnstina Lynn Connor Pa. ID 318389 Victoria W. Chen Pa. ID 317741 Attorneys for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicemernbers Civil Relief Act Last Name: SHERIFF First Name: ROBIN Middle Name: C. Active Duty Status As Of: Jan -08-2015 Results as of : Jan -08-2015 10:51:06 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ,,,2:r: :.?:;.' '....,,..-', :-•-•r:-:-:-, ;. f, NO:2`:-, NA This response reflects the indi1/iduala active duty datitatased on the Attive DtitY,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 fr f..i... NA '' '''''::', -•',-:-"‘,/1,1 . "" - ' ' NA This response reflects where the individual left aCtWe duty'statutwithih367:days preceding the Active Duty Status Date • The Member or Hisft-ler Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA ,, ki ",, ::;-,. "'-'. :-:;,•(;2J''4C):-,'-': '- • NA This response reflects whether the individual or hiPheilinit has receivedearlyo6tifica-tion to:report for active duty • Upon searching the data banks of the Department of Defense Manpower Dataeenteri,baSed'itin,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 tiniformedSerVices (Ariny, 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. ' 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/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: T1 MDE86A0170D10 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 vs. GEORGE A. SHER1F1- JR. ROBIN C. SHERIFF (Mortgagor(s) and Record owner(s)) 5 Sunset Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 13-6409 ORDER FOR JUDGMENT Please enter Judgment in favor of VOLT PARTICIPATION TRUST 2011-NPL2, and against GEORGE A. SHERIFF JR. and ROBIN C. SHERIFr 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 $124,595.09. ;�-{—�By: L1���`�P� 619/)" KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 � eins tin a Lynn OMNI Thomas Puleo Pa. ID 27615 O1838? Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 and that the name(s) and last known address(es) of the Defendant(s) is/are GEORGE A. SHERIFF JR., 5 Sunset Drive Mechanicsburg, PA 17050 and ROBIN C. SHERIFF, 5 Sunset Drive Mechanicsburg, PA 17050; -- By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 7C�, l n q syn n Curl n by 3 f $3 1 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $100,727.64 Interest from 02/01/2013 through $20,767.96 01/08/2015 Reasonable Attorney's Fee $1,650.00 Late Charges $30.00 Escrow $1,062.09 Appraisal/BPO $302.40 Property Inspections $55.00 AND NOW, this 1 p day of 13-6409/124033FC Bv: $124,595.09 KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 -.einW C Lynn Nom( Thomas Puleo Pa. ID 27615 Le31M9 Joshua I. Goldman Pa. 205047 U Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff , 2015 damages are assessed as above. 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 VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF Mortgagor(s) and Record Owner(s) 5 Sunset Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 13-6409 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due ear ®ag-. 0`A d` ct SO" k1.o5©t' `k Interest from 1/9/2015 to Date of Sale per diem at $22.52 (Costs to be added) $124,595.09 £«7vL4"? By: � KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 0 David Fein Pa. ID 82628 v CnShha Lyhn CCniid 31831 &_Thomas Puleo Pa. ID 27615 .101, � S Joshua I. Goldman Pa. 205047 , SO LC— Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Salvatore Filippello Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 Jennifer Lynn Frechie Pa. ID 316160 CAL," 1 1ltorneys for Plaintiff 31 s' -t BS KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF (Mortgagor(s) and Record Owner(s)) 5 Sunset Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s) l- 1 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 13-6409 AFFIDAVIT PURSUANT TO RULE 3129 VOLT PARTICIPATION TRUST 2011-NPL2, 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: 5 Sunset Drive Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): GEORGE A. SHERIFF JR. 5 Sunset Drive Mechanicsburg, PA 17050 ROBIN C. SHERIFF 5 Sunset Drive Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: GEORGE A. SHERIFF JR. 5 Sunset Drive Mechanicsburg, PA 17050 ROBIN C. SHERIFF 5 Sunset Drive Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement 'Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 AMERICAN EXPRESS 429 FOURTH AVENUE APT/STE 1600 ' C/O SWARTZ LOVEJOY & ASSOC PITTSBURGH, PA 15219 r CAPITAL ONE BANK LASHIN ARTHUR ; HAYT HAYT & LANDAU LLC 123 S. BROAD STR. STE 1660 PHILADELPHIA, PA 19109-1003 AMERICAN EXPRESS SWARTZ LOUIS B. ; SWARTZ LOVEJOY & ASSOCIATES 429 4TH AVENUE STE 1600 PITTSBURG , PA 15219 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 5 Sunset Drive Mechanicsburg, PA 17050 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: By: KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 S. � fla Lynn eMnoY J 19331 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 Salvatore Filippel]o Pa. ID 313897 Alyk L. Oflazian Pa. ID 312912 • Jennifer Lynn Frechie Pa. ID 316160 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff 13-6409 VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF Mortgagor(s) and Record Owner(s) 5 Sunset Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE - Docket No. 13-6409 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: SHERIFF JR., GEORGE A. GEORGE A. SHERIFF JR. 5 Sunset Drive Mechanicsburg, PA 17050 Your house at 5 Sunset Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, June 03, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $124,595.09 obtained by VOLT PARTICIPATION TRUST 2011-NPL2 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to VOLT PARTICIPATION TRUST 2011-NPL2, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1=866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 13-6409 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 71.7-240-6390. 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 13-6409 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. ‘. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 124033FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. .KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff i:,a, :. ,i.•, 1 ; a Y .iJ.;j lf'.Y:t 1 2015 Ji 1 s t 8.43 CCU;TY . 1�lJ.i.iI! 13-6409 VOLT PARTICIPATION TRUST 2011-NPL2 13801 Wireless Way Oklahoma City, OK 73134 vs. GEORGE A. SHERIFF JR. ROBIN C. SHERIFF Mortgagor(s) and Record Owner(s) 5 Sunset Drive Mechanicsburg, PA 17050 Plaintiff Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 13-6409 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: SHERIFF, ROBIN C. ROBIN C. SHERIFF 5 Sunset Drive Mechanicsburg, PA 17050 Your house at 5 Sunset Drive, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, June 03, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $1.24,595.09 obtained by VOLT PARTICIPATION TRUST 2011-NPL2 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to VOLT PARTICIPATION TRUST 2011-NPL2, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 13-6409 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 t.T 13-6409 Resources available for. Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 124033FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net VOLT PARTICIPATION TRUST 2011-NPL2 Vs. NO 13-6409 Civil Term CIVIL ACTION — LAW GEORGE A. SHERIFF JR. ROBIN C. SHERIFF WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $124,595.09 L.L.: $.50 Interest FROM 1/9/2015 TO DATE OF SALE PER DIEM AT $22.52 Atty's Comm: Atty Paid: $224.85 Plaintiff Paid: Date: 1/12/15 (Seal) Due Prothy: Other Costs: David D. Buell, Prothonota Deputy REQUESTING PARTY: Name: Cl tRISTINA LYNN CONNOR, ESQUIRE Address: KML LAW GROUP, P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 318389