Loading...
HomeMy WebLinkAbout13-6442 Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: Cumberland County � , b The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Bank of America, National Lead Defendant's Name: Blake A. Woodward; C Association Heather N. Woodward T Dollar Amount Requested: F1 within arbitration limits I Are money damages requested ?: ❑ Yes ® No (Check one) ® outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: Christopher A. DeNardo, Esquire ❑ Check here if you have no attorney (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 APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not ❑ Employment Dispute: include mass tort) Discrimination E ❑ Slander /Libel /Defamation ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: Other: . I ❑ Other: O MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non- Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 SHAPIRO & DeNARDO, LLC ; BY: CHRISTOPHER A. DeNARDO ESQUIRE UIRE ATTORNEY I.D. NO. 78447, ; 'L ` F IC CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 .,' Ilan i�1Tl(�F�� 1�l1�''' KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 1f�13 NGV - AM 9: AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 CUMBERLA 3600 HORIZON DRIVE, SUITE 150 F ?�NNS`�L VANIA���' KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: J Heather N. Woodward 31 East Pine Street Mount Holly Springs, PA 17065 Blake A. Woodward 31 East Pine Street ; Mount Holly Springs, PA 17065 DEFENDANTS COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. CUA Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN 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 ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 KASSIA FIALKOFF, ESQUIRE, ATTORNEY I.D. NO. 310530 AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. ' NO: Heather N. Woodward 31 East Pine Street Mount Holly Springs, PA 17065 Blake A. Woodward 31 East Pine Street Mount Holly Springs, PA 17065 DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Bank of America, National Association, the address of which is, 400 Countrywide Way, Simi Valley, California 93065 -6298, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage Mortgagee Mortgage Electronic Registration Systems, Inc., as nominee for Vision Mortgage Capital, a division of Continental Bank, its successors and assigns Mort ag glW Blake A. Woodward and Heather N. Woodward (b) Date of Mortgage July 30, 2010 (c) Place and Date of Record of Mortgage Recorder of Deeds Cumberland County Document ID# 201020900 Date: July 30, 2010 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for Vision Mortgage Capital, its successors and assigns Assignee: Bank of America, N.A. Date of Assignment: July 1, 2013 Recording Date: July 3, 2013 Instrument No.: 201322144 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. 3. The real property which is subject to the Mortgage is generally known as 31 East Pine Street, Mount Holly Springs, PA 17065 and is more specifically described as attached as part of Exhibit "A ". 4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Note "). A true and correct copy of the Note is attached and marked as Exhibit "B ". The Plaintiff, directly or through an agent, have possession of the promissory note. The promissory note is either made payable to the Plaintiff or has been duly endorsed. 5. The naives and mailing addresses of the Defendants are: Blake A. Woodward, 31 East Pine Street, Mount Holly Springs, PA 17065; Heather N. Woodward, 31 East Pine Street, Mount Holly Springs, PA 17065 and Heather N. Woodward, 31 East Pine Street, Mount Holly Springs, PA 17065. 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of May 1, 2013 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of October 11, 2013: Principal Balance Due $149,332.29 Interest Currently Due and Owing at 4.875% $4,246.62 From April 1, 2013 through October 31, 2013 Late Charges $163.98 Escrow Advances $4,553.96 Property Inspection $314.00 TOTAL $158,610.85 9. Interest continues to accrue for each month that the debt remains unpaid, and Plaintiff may incur other expenses, costs and charges collectible under the Note and Mortgage 10. In addition to the above amounts, reasonably incurred attorneys fees and costs as well as proof of title in conformity with the mortgage documents and Pennsylvania law, shall be sought by Plaintiff and included in any request for judgment. 11. Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403 commonly known as Act 6 and demand for payment was sent to each individual Defendant by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C ". 12. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. § 1707- 1715z -18). Accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DeNARDO, LLC Date: BY: eys for PlainNff CAITLIN M. DO Y, ESQUIRE S & D File No. 13-044111 ;)1090p {� TZOA V F kGA 1� r �1` vzsxoll Mott'�il►= cULPI7eA1. 3425 SIMPBON rang ROAD, SUITS 203 C AXP HILT., PA 17011 717 - 975 -0522 After Recording Return To$ VIOION NORTGAM CAPITAL ATT11 r FXKAL DOCURNUT DBPAMM11T+ 790 PBNLLYN PIKE 8VZ 304 BLUE BBLL, PA 19422 O�CU9 APN APIs Title Order No.r 12 -079 -170 LOAN fi 8PIKge At M This Li For Regarding Do�rJ FHA Cgs Carnmonwaalth of Pennsylvania MORTGAGE _ MI THIS MORTGAGE ("Security Instrument's Is given on JULY 30, 201o. The Mortgagor Is at ARB A wooDwAnn AnD tt MUNIt » N001DWMM, HUSBAND AND w1ps ( "Borrower's. "M ERS" Is Mortgage Electronic Registration Systems, Inc. MERE Is a separate corporation that Is acting solely as a nominoe for Lender and Lender's successors and assigns. MFRS Isthe mortgages under this SoaudIly Instrumont. MFRS Is org anized and existing under 1he laws of Delaware, and has a mailing address of P.O. Box2028, Flint, ill 48W -2028, and a streal address 01 0300 S.W.34thAvenue, Suite 101, Ocala, FL 34474, The MFRS telephone number is (888) 879 -MERE, vYOxox HORTQAM CAPITAL, A DIVIOION of CONTINHNTAL BANK ( "Lender") is organized and existing under the laws of 'THH cowomwja ras OP PonsT76VAITM, and has an address of 620 w wFauNTew PZR13le350, PI4TROME MM INa,PA 19462. Borrower owes Lender the principal sum of * * * * * *Ows awwimD 7'xi@Tx PIvH THOVSAND Niter 1uxuRBD AND !rQ /100r *►rr *fx *a * * ** * * *r* * * *rt * ** Dollars (U.S. $155,9oo.o0 ), rHAPorraylvankMortit"o -4(es Initialsr W M+I OnlIne DmourwtN Ina Page 1 of 9 PARPHADX PAEFHALD 1007 • J t rt +.++.w+^�o'N'.1. ��MM��1.A.M4r..MWY..►pyy LOAX # I This debt is evidenced by Borrower's note dated the same date as this Security Instrument ( "Note "), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on AVGWST 1, 2040, This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with Interest, and all renewals, extensions and modifications of the Note; (b) the payment-of all other sums, with Interest, advanced under paragraph 7 to protect the security of this Sect,rrity Instrument; and (a) the p erformance of Sorrower's covenants and agreements underthia Socud instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERE (solely as nomineefor lender and sander's successors and assigns) and to the successors and assigns of MBRS the following described properly located In Cumberland County, Pennsylvania: BBPl LBteAL DISCRIP'd'SO8 A=ACHED 98RATO AND XADN A PAU BJ RSOS AS BXHIBIT „Au APR fi : which has the address of 31 sane Pine street, Mount Holly Springs [Strom, CRY), Pennsylvania 17065 ( "Property Address "); [Zlp Codes TOG ETHER WITH all the Improvements now or hereafter erected on the property, and all easements, appurtenances andtixtures noworhoreattera partofthe property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing Is referred to in this Security instrument as the "Property." Borrower understands and agrees that MFRS holds only legal title to the Interests granted by Borrower in this Security Instrument, but, g necessary to comply with low or custom, MFRS (as nominee for Lender and Lender's successors and assigns) has the right: to exercise any or all of those interests, Including, but not limited to, the right to foreclose and sell the Property; and to We any action required of Lender including, but not limited to, releasing and canceling this Security instrument. t3ORROWER COVENANTS that Borrower Is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the property is unencumbered, except for encumbrances of record, Borrowerwarrants and will defend ganerallythotitletothe Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenant$ for national use and nonuniform covenants with limited variations by Jurisdiction to constitute a uniform seour[tyinstrument covering real property. Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS, 1, payment of principal, Interest and Late Charge. Borrower shall pay when due the principal of, and Interest on, the debt evidenced by the Note and late charges due under the Note. FHA Pa+nsylvatde MorWego 4AG z ni1:1a1 a 1 Online Documeft, Ina Page 2 Of 9 P FIAL 11007 tw tt 1400� 2. Monthly Payment of Taxes, Insuranoo and Other Charges. Borrower shall Include In each monthly payment, together with the principal and interest as eel forth In the Note and any late charges, a sum for (a) Was and special assessments levied or to be levied against the Property, leasehold payments orground rents on the Property, and (c) premiums for insurance required under paragraph 4. !n any year In which the lender must pay a mortgage Insurance premium to the Secretary of blousing and lhban Development ("Seoretary'�, orin anyyearinwhich such premium vmuld have been required IfLender still hold the Security Instrument, each monthlypayment shall also Include either: (Q a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or 00 a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow items" and the sums paid to Lander are called 'Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U,13 0, Section 2801 at seq. and Implementing rogulations, 24 OFR Part 3300, an they may be amended from lime to time ( "RESPA"), oxce t that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available In the account may not be based on amounts due for the mortgage Insurance premium. If the amounts hold byLenderfor Escrow items exceed theamounts permitted to behold by RESPA, Lender shall accountlo Borrower for the excessfunds as required by RESPA. If the amounts of funds held by Lender at any time is not auf dent to pay the Escrow items when duo, tender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by We Security Instrument. It Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all Installment Items (a), (b), and (o) and any mortgage Insurance premium Installment that Lander has not become obligated to pay to the Secretary, and Lander shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for an Installments for Items (a), (b), and ( c). 3. Application of payments, Ai! payments under paragraphs i and 2 shall be applied by Lender as follows; EM to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary Instead of the monthly mortgage Insurance premium; Saggn{ to anytaxes, special assessments, lassohold payments or ground rents, and fire, food and other hazard Insurance premiums, as required; Mft to Interest due under the Note; Fourth, to amortization of the principal of the Note; and Mft , to late charges due under the Note, 4. Fire, Flood and Other Huard Ineuranae. Borrower shall Insure all improvements on the Property, whether now In existence or subsequently erected, against any hazards, casualties, and oontingancles, Including fire, for which Lender requires Insurance, This insurance shall be maintained In the amounts and for the periods that Lander requlres, Borrower shall also Insure all Improvements on the Property, whathernow in existence or subsequently erected, against lose byfloods to the extent required by the Secretary, All Insurance shall be carried with companies approved by Lender. The insurance poll" and any renewals shall be held by Lender and shall include toss payable clauses In favor of, and In a form acceptable to, (..ender, in the event of loss, Botrowor shall give Lender immediate notice by mall. Lender may make proof of loss if not made promptly by Borrower, Each insurance company concamed is hereby authorized and directed to make paymentfor such loss directly to Lender, Instead of to Borrower and to Lender Jointly. All or any part of the insurance proceeds may be applied by tender, at its option, either (a) to the reduction of the indebtedness under the Nate and this Seouft Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the Fi•rA Parnuylvania Mortpile • 410 Initial$ t Online Qoaintante, Ina Pago 3 of 9 P THAI p tool damage! Property. Any application of the proceeds to the principal shall not extend or postpone the due date ofthemonthly paymen swhloh arereferred toin paragraph 2,orchangetheamountofsuch payments, Any excess insurance procssda over an amount required to pay all outstanding Indebtedness under the Note and this Saourliy Instrument shall be paid to the entity legally entfiled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishesthe Indebtedness, allright, 11% and Interestof 136mmorin and tolnsurance policies In force shall pass to the purchaser. 8. Ooaupanoy, Preservation, Maintenance and Protectionof the Properly; Borrowor'a Loan Application; Lanooholdo, Borrower shall occupy, establish, and use the Property as Borrower's principal residencewithin sixtydays afterlhe execution of this Security instrument (orwithin sixtydays of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requlromantwill cause undue hardy hip for Borrower, or unless extenuating circumstances existwhich are beyond Borrower's control. Borrower shag notffy Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. (.ender may Inspect the Property If the Property Is vacant or abandoned or the loan Is In default, lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrowershall also be in default I<Borrowar, during the loan application process, gave materially false or Inaccurate information or statements to lender (or tailed to provide Lender with any material Information) in connection with the loan evidenced by the Note, Including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is an a leasehold, Borrower shall compply with the provlslons of the lease. It Borrower acquires fee tide to the Property, the leasehold and tae title shall not be merged unless i.,ender agrees to the merger in writing, 6. Condemnatlon. The proceeds of. any award or claim for damages, direct or oonsequential, in conneotion with anycondemnation or other taking ofany partof the Property, orfor conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the Indebtedness that remains unpaid under the Note and this Security Instrument, lender shall apply such proceeds to the reduction of the Indebtedness under the Note and this Security Instrument, first to an delinquent amounts applied in the ardor provided In paragraph 3, and then to prepayment of principal, Any applioatjan of the proceeds to the prinalpal shah not extend or postpone the due date of the monthly payments, which are referred to In paragraph 2, ar change the amount of such payments. Any excess procaeda over an arntw nt required to pay all outstanding in debtedness under the Note and this 9eourity Instrument shall be paid to the entity legally entitled thereto 7. Charp�ato Borroworand ProieoBon of Lender's Rights in the Property. Borrowershalipay alt governtnantai or tnunidpaf charges, fines and Impositions that are not Included in paragraph 2. Borrower shall pay these obligations on time Ireotly to the entity which Is owed the payment. It failure to pay would adversely affect Lender's Interest in the property, upon lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments, If Borrower falls to make these payments or the payments required by paragraph 2, or falls to perform any other covenants and agreements contained In this Security Instrument, or there is a legal proceeding that may slgnif ently atfeot Lender's rights in the Property (such as a proceeding In bankruptcy, for oondemnation or to enforce laws or regulations), then Lerrdermay do and paywhatever is necessary to protect the value ofthe Property and Lender's fights In the Property, including payment of taxes, hazard Irsuranoe and atltar items mentioned fi paragraph 2. Any amounts disbursed by Lender under this paragraph all become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the opliom of Lender, shall be Immediately due and payable. Borrower shall promptlydfacharg $any Hen which has prio�(tyover this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lion In a manner acceptable to Lender; (b) contests in goad faith the lien by, or defends against enforcement of the lion In, legal proceedings whloh In rho Lender's opinion operate to prevent-the enforcement o yy fthe lien; or A / � FMPannlyty4fili<Matgaga•4190 I rii:ialsr / 6 Online Document*, inch Page 4 of 9 P FHALO 1007 LOAN f � (o) secures from the holder of the lien an agreement satisfactory to Lender subordlnati 'li th.ls Security instrument. If Lender determines that any part of the Property Is subject to a lien which may attain priority overthls Security Instrument, Lender may give Borrower a notloeldeniKyingthe lien, Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. S. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations Issued by the Secretary, In the case of payment defaults, require Immediate payment in full of all sums secured by this Security instrument If: (1) Borrower defaults hyfailing to pay In full any manthlypaymentiequired by this Security Instrument prior to or on the due data of the next monthly payment, or 01) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained In this Security Instrument. (b) Sale Without Credit Approval. Lander shall, If permitted by applicable law QncludIng Section 341(d) of the Garn•St, Germain Depository Institutions Act of 1952, 12 U.S.C. 170ij3(d)) and with the prior approval of the Secretary, require Immediate payment in full of all sums secured by this Security Instrument If: (� All or part of the Property, or a beneliclai Interest In a trust owning all or part of the Property, is said or otherwise transferred (other than by devise or descent), and (il} The Property is not occupied by the purchaser or grantee as his or her principal reatdenoe, or the purofiaser or grantee dose ao F d py tits Prope but his or her credit as not been approved In aoaordanae with the remenis of the Secretary. (o} NoWalver. ffolroumnoesoacurtwouldpeendertorequirelmmedlatepayment In fullbut Lender doss not require such payments, Ledose notwaive ita rights with respect to subsequent events, (d) Regulations, of HUD Secfotary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require Immediate payment in full and foreclose R not paid. This Security Instrument does not authorize acceleration or foreclosure If not permitted by regulations of the Secretary, (e) Mortgage Not insured. t9orrowpr agrees that If this Security Instrument and the Note are not determined to be eligible for insurance under the National Mousing Aotwlthin 60 days from the date hereof, Lender may, at Its option, require immediate payment in full ofall sums secured by this Security Instrument. Awritten statementof any authorized agent of the Secretarydated subsequent to 60 days from the date hereof; declining to insure this Security Instrument-and the Note, shall be deemed conclusive proof of such ineligibitlky. NatwithstandIng theforti oing, this option may not. be exercised by Lender when the unavalllabillty of insurance Is solely due to Lender's failure to remit a mortgage Insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment In full because of Borrower's failure to pay an amount due underthe Note or this Security Instrument, This right applies even after foreclosure proceedings are instltuted. To reinstate the Security Instrument, Borrower shall tender In a lump aura all amounts r equired to bring Sorrower's account current including, to the extant they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses property associated whit the foreclosure proceeding. Upon reinstatement by Borrower, this Security instrument and the obligations that it secures shall remain in effeot as p Lender had not required Immediate payment In full. However, Lender is not required to permit reinstatement It (1) Lander has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, V Wnstatromentwlll prooludeforec(osureon different grounds in the future, or @I) reinstatement will adversely affect the priority of the lion created by this Security Instrument 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted ') b FHAPanrayNaniaMorrp va -41H InitialZe: )W Online 00a mm"1% Ine, Page 5 of 9 PAI;FHALD fool •w+w..►.rrrrr.nwru.. ...._ rr.++AMrri4Y11Mr,i - - - ... ..........,.........r,,,. none #1 Lender to any successor In interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor In Interest. Lander shall not be required to commence proceedings against any successor In interest or refuse to extend time for payment or otherwise modify amortization of the sums secured bythls Security Instrument byreasonof anydemand madebythe orlglnal Borrower or Borrower's successors in interest, Anyforbearance by Lander In exercising any dghtor remedy shall not be a walver of or preclude the exercise of any right or remedy, 12. Successors and Assigns Bound; Joint and Several Liability; Co- Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 8(b). Borrower's covenants and agreements shall be joint and several, Any Borrower who co-signs this Security Instrumentbut does not execute the Note: (a) Is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest In the Propertyunder theterms of this Security instrument; (b) Is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lander and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard tothe terms of this Security Instrument or the Note without that Borrower's consent, 13. Notions. Any notice to Borrower provided for In this Security Instrument shall be given by delivering It or by mailing it by first class malt unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mall to Lender's address stated heroin or any address Lender designates by notice to Borrower. Any notice provided for In this Security Instrument shalt be deemed to have been given to Borrower or Lender what given as provided in this paragraph. 14. Governing Law; Ssverab111ty. This Security Instrument shall be governed by Federal lawand the lawof the)udedlction In which the Propertyls located, In the eventthat any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provislons of this Security Instrument or the Notewhlch can be given effect withoutthe conillcting provision, Tothis end the provisions of this Security Instrument and the Note are declared to be severable, 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument, 16, Hazardous Subelano" Borrower shall not cause or permit the presence, use, disposal, storage. orreleaseofanyHozardousSubstancesonorinthel 'r erty.Borrowershallnotdo,norailow anyone else to do, anything affecting the Property that Is In violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are genemay recognized to be appropriate to normal residential uses and to maintenance of the Property, Borrower shall promptly give tender writlen notice of any investigation, clalm, demand, lawsuit or other action by any governmental or regulatory agency or private party Involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediatlon of any Hazardous Substances affecting the Property Is necessary, Borrower shall promptly take all necessary remedial actions In accordance with EnAronrrrental Law. As used In this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Dvtronmental Law and the following substances: gasoline, kerosene, other flammable or toxic.petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 1B, "Environmental Law" means federal laws and laws of the jurisdiction where the Propertyls located that relate to health, safety or environmental protection, NON - UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unoonditlonally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lander or Lender's Agents to collect the rents and revenues and hereby directs each tenant of the property to pay the rents to Lender or Lender's agents. FKAPofflo WoMWtpgb•4/98 Initialer gw —_ GNlno DMUMM9% Inc. Page 6 of 9 PA F1 -W4 1667 Iaa►Yr # r However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. ff Lan derglves notloo of breach to Bormwvr (a) all rents received by Sorrowershall behold by Borrower astrusteeforbenefitofLenderonly ,tobeappliedtothe sums secured b the Seourftylnstrument;(b)Lender shall be entitled to oollectandreceive all.of the rents of the Property; and (c) each tenantof the Property shall pay all rents due and unpaid to Lender or lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and VAI not perform any act that would prevent Lender from exercising Its tights under this pareggraph 17; Lender shall not be required to enter upon, take control of or malntaln the Property before or after giving notice of breach to Borrower. However, Lander or a judk:lally appointed receiver may do so at any time there is a breach. Any spplicatlgn of rente shall not cure orwalve any default or Invalidate any other right or remedy of (ender. This assignment of rents of the Property shall temtlnate when the debt aeoured by the t3ecurlty Instrument fs paid in lull. f $. Forgoioauro Procaduw, If Lander r+aqulres Immediate payment In full under paragraph 9, Lander may f'oreolww this SeouWty Instrument by Judinlal proceeding. Lander shall be entitled to col teat ell expenses incurred in purouing tha ramedlas pprovided in this paragraph 18, Including, but not ilmltod to, attamays' Igoe and costs of title Ovldenoe. If the Lender's Interest In thle Security Instrument Is hold by the Secretary and the Secretary requires Immedleta payment in full under Paragraph 9, the Secretary may Invoka the nonjudiclal power of gale provided in the Singig Famlly Mortgage Fareblosure oat of 1994 !A� (12 U.S,G. 3761 et seq.) by requesting s faroclosuwt cammlaslonor designated under the ct commence torgor0 and to sell Property as pro vided in the Act. Nothing In the ptdtng sontenao haiil dgpWw the Ssarotary o1 any rights oth0 0 liable toa Lender =derla Paragraph 1a or applicable law. 19. Release, Upon payment of all sums secured by this Security instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrowershali pay any recordation costs. 20. Walvere, Borrower, to the extent permitted by applicable law, waives and releases any error or defects In prooeadings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extanslon of time, exemption from attachment, levy and sale, and homestead exemption. . 21. Rolrtatatonrent Period. Borrower's time to reinstate provided In paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security instrument. 22. Purchase Money Mortgage, If any of the debt secured by this Security Instrument Is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgago. 23. Interest Hate After Judgment. Borrower agrees that the Interestfate payable after a judgment Is entered on tho Note or in an action of mortgage foreclosure shall bathe rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded togetherwlth this Security Instrument, the covenants of each such rider shall be Incorporated Into and shall amend and supplement the covenants and agreements of this Security Instrument as If the rlder(s) were a part of this Security Instrument. [Check applicable box(es)] CpCondominlum Rider C=Qrowing (rqulty Rider C=Pianned Unit Development Rider MGraduated Payment Rider =Other(s) (specify) FHA Pennsyrvmis Monpoo .4/06 W OMIns oaaumenta, Inc. Page 7 of 9 PAEPHALO tool LOAM /3 IMMOM BY SIGNING BELOW, Borrower accepts and agrees to the terms contalned In thta Security Instrument and In any rlder(s) executed by Borrower and recorded with It Witnesses; "1 (Seal) B aI ke A Woodward D IAM'f 7 )AjopC 1t Reatber R Woodward FHA POWMI . IS 8s • 00 069ne Doounwnts, Ino, Page 0 of 9 PAWMLD 1007 LOAN #1 Y CerUfloate of Residence I, T a F eLdho! do hem by cettify that le coned address e Withi n-named gages is O N (M IgNUM P IKE6390, PLY1iom M8yT&j.10LPA 124,62 Witness my hand this Q day of Jtt C4_�Lvi 0 Agent of Mottgagoe Com onwealth of FBXNBiLVARIA County of CVKBRAI AAD on this, the day of �� .�3 _t (� , before on, the undersigns of ioer, personally appeared Blake A Woodward �►Bri seat ar it Hoadward, known to see (or satisfactorily pr4Ve0) to be the peraon(o) whose name(a) is lare subscribed to the within instrument and acknowledged that he /ahe /they executed the sane Ear the purposes therein contained. Yn witness whereof i hereunto set my hand and offiaial veal. My compsisaion expires] (M C 0 t H$ V Title of OfE car N*AW SW • NivenJl �lalyd,Notery Ptlb�o SM, 0A*gdW4Oozy L F�nnaylv*M AasooWon at NMdvs FHA PenmyI nIS1Modoge•4/90 iaitiais� onune DownwnM.Inc, Page 9 O 9 PAOF M . 1. - .Nwr..Mnh11�.M. n�r......n.•yr4./� VNwAWyryM .T. r n..l'A•.Mn1 I EXHIBIT " A " LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected situated on the north side of East Pine Street, in the Borough of Mount Holly Sprites, Cumberland County, Pennsylvania, bounded and described as follows: 13EO114MG at a point on the north side of East Pine Street; thence by the same, North 80 degrees 45 minutes East, a distance of 54 feet to a stake; thence along property now or formerly of Chalmer D. Toner and Sarah Virginia Toner, North 11 degrees 15 minutes West, it distance of 39.6 feet to a point; thence by same North 25 degrees 45 minutes West, a distance of 135 feet to a post; thence along the south side of a public alley, North 42 degrees 15 minutes West, a distance of 7.9 feet to a point; thence by same, North 85 degrees West, a distance of 17 feet to a point, thence along lands now or formerly of Chester L. Sheaffer, South 10 degrees 30 minutes East, a distance of 181.5 feet to a point on the north side of least Pine Street and the place of 13E011iNZNG. CONTAININO 7,000 square feet, more or less and being improved with a dwelling house known as 31 East Pine Street. 5 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMERLAND COUNTY ^� 1 COURTHOUSE SQUARE ." CARLISLE, PA 17013 717 -240 -6370 Instrument Number - 201020900 Recorded On 7/30/2010 At 4:24:52 PM *Total Pages - * Instrument Typd - MORTGAGE Invoice Number - 70084 Vser ID • KW * Mortgagor - WOODWARD, BLAKE A * Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC * Customer - DAMP * FEES STATE WRIT TAX 00.50 Certifi Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDIM FEES — $23 ,50 RECORDER OF DEEDS This page is now part PARCEL CERTIVXCATxON $10. of this legal document. pass AMRDADLE HOUSING $11,50 CQUMY ARCHIVES nz 42 ,00 ROD ARCHIVES 1Pzz 43.00 TOTAL PAID $74,00 I Certify this to be recorded in Cumberland County PA RECORDER A D >EDS • %formption denoted by an asterisk may chnage during the verification process and may not be reflected on this Page. ��� I�Ifflllll IIN II��IIII� CRPRDNRBS46a 7/2/2013 11:10 :18 AM PAGE 52/069 888- 294 -5658 9iJililARRle�see�� i ism LOAN NOTE Mu11lsteta JULY 80, 2010 Carlisle, PSMNSYLVANIA I Data I [City) Istatel 31 Zest Pine street, Moa HoUy springs, PA 17055 [Property Address] 1. PARTIES "Borrower" means each person signing at the and of this Note, and the person's sucoessors and assigns. 'Lender" means VISION MORTOAGR CAPITAL, A DIVIS OF CONTINENTAL BANK. and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST in return for a loan received from Lender, Satrower promiges to pay the principal sum of : #n.. +ONE 8UXbRlW FIM FIVE THOUSAND MINE tlUNDRBD AND Dollars (U.S. 4155,900.00 ), plus Interest, to the order of Lender, Inl4arest Will be charged on unpaid principal, lrom the data of disbursement of the ban proceeds by Lender, at the rata of FOUR 1UM SMK- =GHTR6 percent ( 4.8751 ) per year until the full amount of principal has been paid, 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security Instrument that Is dated the same date as this Note and called the 'Security instrument." The Security Instrument protects the Lander from losses which might result if Borrower defautb under this Note, 4. MANtNER OF PAYMENT (A) Time Borrower shall make 8 payment of prnrlpal and interest to Lander on the 1sT day of each month beginning on ORK M ER 1, 2010. Any principal and interest remaining on the 1sT day of i AUMM, 2040 will be due on that date, which is called the "Maturity Date." (5) Plape PPayment shall bs made at 620 K QZRK 6iTOKN PIK11#350 PLYMOUTH MEETING^ 19462 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest YA14 be In the amount of U.S. $8215.04. This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, Interest and other items in the order described to the Security Instrument. (0) Allongo to this Note for pays eeni a4ustments Han ailonge providing for payment adjustmenta is executed by Borrawar togathef with this Nate, the covenants of the allonge shall be incorporated into and sh ail amend and supplement the *ova nants of this Note as if ttw sponge were apart of this Note. [Check applicable box) =Graduated Payment Ailongs = Growing Equity Allonge =Other Ispecify) 5. BORROWER'S RIGHT TO PREPAY i Borrower has the right to pay the debt evidenced by this Note, in Whole or to part, without charge or penalty, on the first dayof any month. tandershall accept prepaymenton other days provided that borrower pays Interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. It Borrower maicesa partial prepayment, therewitlbeno changes Inthe dusdateor In the amount ofthe moMhly payment unless Lender agrees in writing to those changes. Q. BORROWER'S FAILORE TO PAY (A) Late Ctrarge for Overdue Payments If lender has not received thefull monthly payment required by the Security Inatru merit, as described in Paragraph 4(C) of this Note, by the end of 15 calendar days after the payment is dve, Lender may collect a late charge In the amount of FOUR percent { 4.00613 ) of the overdue amount of each payment. (B) Default If Sorrower clatufts byfailing to pay in full any mvhthly payment, than Lender may, except as Gmffed by regulations of the Secretary in the ease of peymont defeutts, require Immeadlate payment in full otthe principal balance remaining due em! all aocrued interest. Len der maychoose not to exercise this option without wahring Its rights In the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require Immediate paynwnt in tut in the taco et payment defautts. This Mote does not authcrize acceleration when not permitted by HUD regulations. As used In this Niote, °Secretary" means the Secretary of Housing arrd Urban DeWopmen't or his or her deelgnee. FWA AhOttaw fted Res Now -1eNs Initialer f'�1t/ Onllno Documents, Inc. Page 1 of 2 Pa T eels " CRPRDNRBS46a 7/2/2013 11:10:18 AM PAGE 54/069 888 - 294 -5658 LOAN A (C) Payment of Costa and Expenses if Lender has required immediate payment In foil, as described above, Lender may require Borrower to pay costs and expenses Including reasonable and customary attorneys' fees for enforcing this Note fib the oxtent notprohiNfed byappl€cable law. Such lees and costs shoo bear €nterestfrom the date of disbursement atthe same rate asthe principal cf this Note. 7. WAIVERS Borrower and any other person who hat obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require tender to demand payment of amounts due. "Notice of dishonor' means the right to require gender to give notice to other persons that amounts due have not been paid. S. 01VING OF NOTICES LWass applicable lawroquirss a different method, any notice that must be given to Borrower under this Note will be given by delivering It or by malting it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated In Paragraph 4(8) or at a different address If Borrower €s given a notice of that dtHerent address. 9. OBLIGiA'"ONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all cf the promises made In this Note, Including the promise to pay thefull amount owed. Any person who Is a guarantor, suretyorendomer of this Note is afro obiigated to do these things, Any person who lakes over these obligations, Including the otrilgat(ons of a guarantor, surety or endorser of this Note, Is also obligated to keep all of the promises made in this Note. Lender may enforceits rights underth€s Noteagalneleach person IndividuaNyor against all signatories together. Anyone person signing this Note may be required to pay all ct the amounts owed under this Note. SY SIGNING BELOW, Borrower accepts and agrees to the to an covenants contained in t Note. "L (Seal) Blake A Woodward �j�N (Seal) H eather 9 'wooer . i t f FHA rduldtUto 1-ked Itaw wile . 101" ontns Deeunvxms tiro Page 2 01 2 PwooNOr ilea CRPRDNRBS46a 7/2/2013 11;10;18 AM PAGE 56/069 888 - 294 -5658 Aft qP ALLONGE TO NOTE LOAN #e LOAN AMOUNT, $155,900.00 PROPERTY ADDRESS: 31 East Pine Street Mount Holly Springs, PA 17065 ALLONGE TO NOTE DATED JULY 30, 2010 IN FAVOR OF vis MoRTCacm CAPITAL, A DIVISION 08 CONTINENTAL B AND EXECUTED BY Blake A Woodward AND Heather 5 Woodward i PAY TO THE ORDER OF BANx or AMERICA, NA WITHOUT RECOURSE VISION MORTGAGE CAPITAL, A DIVISION Of CONTINENTAL BANx BY ANTHONY SRUNO I TITLE vice PRESIDENT PAYTOTHEOMEROF �_. BANK 0UTR E � ^ R ,A BY M"ELE BJOLANOER •'• SENIOR VICE PRESIDENT Documont #LA44 LFF806 01986 -2003 OnIMe Dwunvrk Inc. GN13 0301 Bankof America Hom Loans PRESORT First -Class Mail PO Box 9048 U.S. Postage and Temecula, CA 92589.9048 Fees Paid W SO 7196 9006 9296 7950 9374 Return Receipt Requested Send Payments to: PO Box 15222 Wilmington, DE 198865222 20130701 -213 Send Correspondence to: PO Box CA 93062 -5170 �liiilill��llllll�l��lll�ll�ill�ll- il-il lli Jill ll1.l1 [it 1III HEATHER N WOODWARD 31 EAST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 -1420 BREACHPA {CM} July 1, 2013 Sent Certified Mail 7196 9006 9296 7950 9374 Return Receipt Requested HEATHER N WOODWARD Account No.: 31 EAST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 -1420 NOTICE OF INTENT TO FORECLOSE MORTGAGE Dear HEATHER N WOODWARD, The MORTGAGE held by BANK OF AMERICA, N.A. and serviced by Bank of America, N.A. (hereinafter we, us or ours) on your property located at 31 EAST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 IS IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts shown below for the months of May 1, 2013 - July 1, 2013. Monthly Charges: Month Due Principal & Interest Escrow Amount Optional Products Total Monthly Charge Amount Amount 05/01/2013 $825.04 $541.51 $0.00 $1,366.55 06/01/2013 $825.04 $541.51 $0.00 $1,366.55 07/01/2013 $825.04 $541.51 $0.00 $1,366.55 Late Charges: Month Amount 05/01/2013 $54.66 06/01/2013 $54.66 Total Monthly Charges: $4,099.65 Current Late Charges: $109.32 Prior Unpaid Late Charges: $0.00 Total Other Charges /Fees: $0.00 Partial Payment Balance: I 0.00) TOTAL DUE $4,208.97 Late charges and other charges have also accrued to this date in the amount of $109.32. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $4,208.97. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,208.97, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at Bank of America, N.A. PO Box 15222 Wilmington, DE 19886 -5222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorneys fees even if they are over $50.00. E li Any attorneys fees will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period, you will not be required to pay attorney's fees. 7196 9006 9296 7950 9374 We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty 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 foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriff's sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of the Sheriff 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 will be by calling us at the following number: 1- 800 -669 -1904. This payment must be in cash, cashiers check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. 7196 9006 9296 7950 9374 C3 3222 BRECDISC 15353 09/24/12 IMPORTANT DISCLOSURES If you are currently in a bankruptcy proceeding, or have previously obtained a discharge of this debt under applicable bankruptcy law, this notice is for information only and is not an attempt to collect the debt, a demand for payment, or an attempt to impose personal liability for that debt. You are not obligated to discuss your home loan with us or enter into a loan modification or other loan- assistance program. You should consult with your bankruptcy attorney or other advisor about your legal rights and options. Bank of America, N.A., the servicer of your home loan, is required by law to inform you that this communication is from a debt collector. There has been a payment default or other default on your loan that could result in acceleration of all sums due under the Note, As a result, Bank of America, N.A. will use companies, including its affiliates LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, N.A., and LandSafe Appraisal Services, Inc., to provide services required to protect the Noteholder's interest and rights in the property and under the note and security instrument, including any remedies thereunder (the "Default Related Services "). Bank of America, N.A. will assess fees to your loan account for the Default Related Services, including those provided by its affiliates. A schedule of fees that may be charged to your account for Default Related Services is available at the following web address: htto: / /www.bankofamerica.com /defaultfees If you do not have internet access, please contact us at 1- 800 - 669 -6607, Monday through Thursday 8 a.m, - 11 p.m. Eastern, Friday 8 a.m. - 9 p.m. Eastern, Saturday 9 a.m. - 3 p.m. Eastern, to have a fee schedule mailed to you. The fee schedule contains a complete list of the default - related services you could be charged, but does not include a complete list of all fees or charges that could be assessed on your loan account. MILITARY PERSONNEL/SERVICEMEMBERS If you or your spouse is a member of the military, please contact us immediately. The federal Servicemembers Civil Relief Act and comparable state laws afford significant protections and benefits to eligible military service personnel, including protections from foreclosure as well as interest rate relief. For additional information and to determine eligibility please contact our Military Assistance Team toll free at 1- 877 - 430 -5434. If you are calling from outside the U.S, please contact us at 1- 817 -685 -6491. 7196 9006 9296 7950 9374 C3 3222 BRECDISC 15353 09/24/12 DIVULGACIONES IMPORTANTES Si usted se encuentra actualmente en un procedimiento de quiebra, o ha obtenido previamente una exoneraci6n de esta deuda bajo la ley aplicable sobre quiebra, este no es un intento de recaudaci6n, una demands de pago o un intento de imponer una responsabilidad personal por esa deuda. Usted no est6 obligado(a) a hablar de su pr6stamo para vivienda con nosotros ni a participar en un programa de modificaci6n de pr6stamos u otro programa de asistencia para pr6stamos. Usted debe consultar con su abogado especializado en quiebras u otro asesor acerca de sus opciones y derechos legates. Bank of America, N.A., el administrador de su pr6stamo para vivienda est6 obligado por ley a informarle a usted que esta comunicaci6n proviene de un cobrador de deudas. Ha ocurrido un incumplimiento de pago u otro tipo de incumplimiento con su prbstamo que podria resultar en la aceleraci6n de todas las cantidades adeudadas bajo el Pagar6. Como resultado, Bank of America, N.A. utilizarb compaMas, incluyendo sus afiliados LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, NA, y Landsafe Appraisal Services, Inc., para proporcionar servicios necesarios para proteger los intereses del Titular en la propiedad y sus derechos bajo el instrumento de seguridad y el pagar6, incluyendo cualquiera de sus recursos (los " Servicios relacionados a un incumplimiento "). Bank of America, N.A. aplicar6 cargos a la cuenta de su pr6stamo por los servicios relacionados a un incumplimiento, incluyendo los servicios proporcionados por sus afiliados. Una lista de los cargos que podrian cobrarse a su cuenta por servicios relacionados a un incumplimiento estb disponible en el sitio de Internet: f htto:// www. bankofamerica.com /defaultfees Si usted no tiene acceso a internet, por favor comuniquese con nosotros al 1- 800 - 669 -6607 de lunes a jueves de 8 a. m. a 11 p. m. hora del este, viernes de 8 a. m. a 9 p. m. hora del este, s6bados de 9 a. m. a 3 p. m. hora del este. para pedir que se le envie una lista de cargos por correo. La lista de cargos contiene una lista completa de los servicios relacionados por incumplimiento que le podian cobrar, pero no incluye una lista completa de todos los costos y cargos que podrian ser aplicados a la cuenta de su pr6stamo. PERSONAL MILITARI MIEMBROS DE LAS FUERZAS ARMADAS Si usted o su c6nyuge es un miembro del servicio militar, por favor comuniquese con nosotros inmediatamente. La Ley federal de Ayuda Civil para Miembros de las Fuerzas Armadas y las leyes estatales comparables otorgan protecciones y beneficios significativos al personal del servicio militar gue califique incluidas protecciones contra la ejecuci6n hipotecaria asi como tambi6n ayuda en la tasa de inter6s. Para obtener mbs informaci6n y determinar su ca[ificaci6n por favor [lame sin costo a nuestro Equipo de Asistencia para el Servicio Militar al 1- 877 -430 -5434. Si usted llama desde fuera de los Estados Unidos por favor comuniquese con nosotros al 1- 817 - 685 -6491. 7196 9006 9296 7950 9374 C3_5088 OPTAVDFC 15319 09/24/2012 Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home :: :.:.............................................. ............................... Home Affordable A federal government program that allows you to repay the loan on newly agreed upon terms, Modification which may include lowering the interest rate, placing past due amounts at the end of the loan, Program (HAMP) and /or extending the term of the loan. You may be eligible for this program if you meet the following requirements: • The amount you owe on the first mortgage is equal to or less than $729,750 for a single - family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have documented a financial hardship and represented that you do not have sufficient liquid assets to make the monthly mortgage payments. • Your mortgage was obtained before Jan. 1, 2009. • The property securing the mortgage loan has not been condemned or is not in such poor physical condition that it is not habitable even if not condemned • The mortgage is secured by a one to four unit propert Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the Reinstatement loan up to date until the day of your foreclosure sale. Repayment Plan A repayment plan allows you to make your regularly scheduled mortgage payments, plus pay off a portion of the past due amounts over time. This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and /or collection of payments Forbearance for a period of time, to allow you to re- establish your ability to make the required payments. Agreement Loan Modification A loan modification is a change to the original terms of your loan, Loan modifications could (non -HAMP) include lowering your interest rate, extending the term or maturity date of the loan, moving from an adjustable to a fixed -rate loan, deferring some portion of the unpaid principal balance to the end of the loan, and /or forgiving some portion of the unpaid principal balance, Partial Claim (FHA If you have a Federal Housing Administration (FHA) loan and your payments are past due but loans only) you are now able to make your regular monthly mortgage payment, this program is designed to bring your loan up to date by creating a second mortgage /lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home up Home Affordable Designed to help borrowers who are eligible for the Home Affordable Modification Program Foreclosure (HAMP) but were unsuccessful in securing a permanent modification through the program. Alternatives HAFA provides the option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A Program (HAFA) short sale is a transaction in which you sell your property for less than the total amount owed on the loan (subject to agreement by your servicer /lender /investor), resulting in the release of our lien on your home and avoidance of foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ If you can no longer afford to make your mortgage payments and your home is worth less than Pre- foreclosure you owe, a short sale may allow you to sell your home to pay off the mortgage. In a short sale, Sale (non -HAFA) the lender agrees to accept an amount less than what is actually owed on the loan. Offered to borrowers who are not eligible for HAMP or other home retention alternatives. Deed in Lieu of Used as an alternative to foreclosure, with a deed in lieu of foreclosure, you transfer ownership Foreclosure of your house and all property secured by your mortgage loan. This may satisfy the total (non -HAFA) amount due on that mortgage. Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not able to sell the property through a short sale. We are here to help you. Please call us today. 7196 9006 9296 7950 9374 C35088 OPTAVDFC 15319 09/24/2012 Hay opciones disponibles para ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notificacion adjunta para obtener mas informacion Cuando (lame, por favor tenga a la mano la informacion de sus ingresos y gastos para que podamos discutir cu3les opciones podrian funcionar para usted. Opciones a considerar si su objetivo es permanecer en su casa >! In o . ........................... . Home Affordable Es un programa del gobierno federal que le permite pagar el pr6stamo bajo los nuevos Modification t6rminos acordados, que pueden incluir la reducci6n de la tasa de inter6s, agregar Program (RAMP) cantidades vencidas al final del pr6stamo, y/o extender el plazo del pr6stamo. Usted puede calificar para este programa si cumple con los siguientes requisitos: • La cantidad que usted adeuda de su primera hipoteca es igual o menor que $729,750 d6lares para una vivienda unifamiliar, $934,200 d6lares para una propiedad de 2 unidades, $1,129,250 d6lares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades • Usted ha documentado que atraviesa por una dificultad financiera y declarado que no tiene suficiente liquidez para hacer los pagos mensuales de la hipoteca. • Obtuvo su hipoteca antes del 1 de enero de 2009. • La propiedad que garantiza el pr6stamo hipotecario no ha sido condenada o no est3 en malas condiciones fisicas Como para no poder habitarse incluso si no estb condenada. • La hipoteca est6 garantizada por una propiedad de una a cuatro unidades, Restablecimiento Si usted puede poner al dia los pagos de su pr6stamo, aceptaremos los Tondos del Pr6stamo necesarios para que el pr6stamo est6 al dia hasta la fecha de la venta por ejecuci6n hipotecaria. Plan de Pago Un plan de pago le permite a usted hacer sus pagos hipotecarios regulares, adem6s de pagar una porci6n de los montos vencidos a trav6s del tiempo. Esto puede incluir capital, inter6s, cargos o costos aplicados a su pr6stamo. Acuerdo Temporal Es un acuerdo en el cual aceptamos no proceder con la ejecuci6n hipotecaria y/o el de Tolerancia por cobro de los pagos por un periodo de tiempo, para permitirle que restablezca su incumplimiento habilidad de hacer los pagos requeridos. Modificaci6n de Una modificaci6n del pr6stamo es un cambio en los t6rminos originales de su pr6stamo, Pr6stamo Las modificaciones podrian incluir reducir su tasa de inter6s, extender el t6rmino o la (no por medio de fecha de pago del pr6stamo, cambiar de un pr6stamo de tasa de inter6s ajustable a uno RAMP) de tasa de inter6s fija, diferir una parte del saldo del capital impagado al final del pr6stamo, y/o condonar una parte del saldo de capital impagado. Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos (solamente estbn vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, pr6stamos de la este programa est6 disenado para que su pr6stamo este al dia mediante la creaci6n de FHA) una segunda hipoteca / gravamen sobre su propiedad por el monto que est6 vencido. 7196 9006 9296 7950 9374 C35088 OPTAVDFC 15319 09/24/2012 Opciones a considerar si no puede o no desea quedarse en su casa ...... ... r Home Affordable Disehado para ayudar a los prestatarios que califican para el Programa de Home Foreclosure Affordable Modification (HAMP), pero no consiguieron obtener una modificaci6n Alternatives Program permanente a trav6s del programa. HAFA ofrece, la posibilidad de una venta en (HAFA) descubierto y, si no tiene 6xito, una escritura de traspaso voluntario de propiedad en lugar de la ejecuci6n hipotecaria. Una venta en descubierto es una transacci6n en la que usted vende su propiedad por menos de la cantidad adeudada en el pr6stamo (sujeto a previo acuerdo de su administrador / prestamista / inversionista), resultando en la liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una escritura de traspaso voluntario de propiedad en lugar de la ejecuci6n hipotecaria es una transacci6n en la que usted estA de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. Venta en descubierto Si usted ya no puede hacer sus pagos hipotecarios y su vivienda vale menos de lo que / Venta previa a la usted adeuda, una venta en descubierto le podria permitir vender su vivienda para pagar ejecuci6n hipotecaria la hipoteca. En una venta en descubierto, el prestamista acepta recibir una monto (no por medio de menor de lo que actualmente se adeuda en el pr6stamo. Se ofrece a los prestatarios que HAFA) no califican para HAMP o para otras alternativas de retenci6n de la vivienda. Escritu ra de traspaso Se usa como una alternative de la ejecuci6n hipotecaria. Con una escritura, de traspaso de propiedad en voluntario de propiedad en lugar de la ejecuci6n hipotecaria, usted transfiere la lugar de la ejecuci6n titularidad de su vivienda y toda la propiedad que garantiza su pr6stamo hipotecario. hipotecaria (no por Esto puede hacer que el monto total vencido de esa hipoteca se considere como medio de HAFA) pagado. Se ofrece a prestatarios que no califican para HAMP u otras opciones de retenci6n de vivienda, y que no pudieron vender la propiedad a trav6s de una venta en descubierto. Estamos aqu'i para ayudarle. Por favor lia'menos hoy. 7196 9006 9 7950 9374 BankofAmerica Home loans PO Box 9048 Temecula, CA 92589 -9048 7196 9006 9296 7950 8735 Return Receipt Requested Send Payments to: PO Box 15222 Wilmington, DE 19886 -5222 20130701 -213 Send Correspondence to: PO Box 5170 Simi Valley, CA 93062 -5170 I "'�I�' 1 1 11 '1 "���II "I�II 1 ' "1 " BLAKE A WOODWARD 31 EAST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 -1420 BREACHPA {CM }_U July 1, 2013 Sent Certified Mail 7196 9006 9296 7950 8735 Return Receipt Requested BLAKE A WOODWARD Account No.: 31 EAST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 -1420 NOTICE OF INTENT TO FORECLOSE MORTGAGE Dear BLAKE A WOODWARD, The MORTGAGE held by BANK OF AMERICA, N.A. and serviced by Bank of America, N.A. (hereinafter we, us or ours) on your property located at 31 EAST PINE STREET MOUNT HOLLY SPRINGS, PA 17065 IS IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts shown below for the months of May 1, 2013 - July 1, 2013. Monthly Charges: Month Due Principal & Interest Escrow Amount Optional Products Total Monthly Charge Amount Amount 05/01/2013 $825.04 $541.51 $0.00 $1,366.55 06/01/2013 $825.04 $541.51 $0.00 $1,366.55 07/01/2013 $825.04 $541.51 $0.00 $1,366.55 Late Charges: Month Amount 05101/2013 $54.66 06/01/2013 $54.66 Total Monthly Charges: $4,099.65 Current Late Charges: $109.32 Prior Unpaid Late Charges: $0.00 Total Other Charges /Fees: $0.00 Partial Payment Balance: ($ TOTAL DUE $4,208.97 Late charges and other charges have also accrued to this date in the amount of $109.32. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $4,208.97. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $4,208.97, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at Bank of America, N.A. PO Box 15222 Wilmington, DE 19886 -5222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attomeys to start a lawsuit to foreclose your mortgaged property. if the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorneys fees even if they are over $50.00. Any attorneys fees will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period, you will not be required to pay attorney's fees. 7196 9006 9296 7950 8735 We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty 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 foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attomey's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of the Sheriff 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 will be by calling us at the following number: 1 -800 -669 -1904. This payment must be in cash, cashiers check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU 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. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE 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 UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. 7196 9006 9296 7950 8735 C3_3222_BRECDISC 15353 09/24/12 IMPORTANT DISCLOSURES If you are currently in a bankruptcy proceeding, or have previously obtained a discharge of this debt under applicable bankruptcy law, this notice is for information only and is not an attempt to collect the debt, a demand for payment, or an attempt to impose personal liability for that debt. You are not obligated to discuss your home loan with us or enter into a loan modification or other loan- assistance program. You should consult with your bankruptcy attorney or other advisor about your legal rights and options. Bank of America, N.A., the servicer of your home loan, is required by law to inform you that this communication is from a debt collector. There has been a payment default or other default on your loan that could result in acceleration of all sums due under the Note. As a result, Bank of America, N.A. will use companies, including its affiliates LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, N.A., and LandSafe Appraisal Services, Inc., to provide services required to protect the Noteholder's interest and rights in the property and under the note and security instrument, including any remedies thereunder (the "Default Related Services "). Bank of America, N.A. will assess fees to your loan account for the Default Related Services, including those provided by its affiliates. A schedule of fees that may be charged to your account for Default Related Services is available at the following web address: htto:// www .bankofamerica.com /defauitfees If you do not have internet access, please contact us at 1- 800 - 669 -6607, Monday through Thursday 8 a.m. - 11 p.m. Eastern, Friday 8 a.m. - 9 p.m. Eastern, Saturday 9 a.m. - 3 p.m. Eastern, to have a fee schedule mailed to you. The fee schedule contains a complete list of the default - related services you could be charged, but does not include a complete list of all fees or charges that could be assessed on your loan account. MILITARY PERSONNEL/SERVICEMEMBERS If you or your spouse is a member of the military, please contact us immediately. The federal Servicemembers Civil Relief Act and comparable state laws afford significant protections and benefits to eligible military service personnel, including protections from foreclosure as well as interest rate relief. For additional information and to determine eligibility please contact our Military Assistance Team toll free at 1- 877 - 430 -5434. If you are calling from outside the U.S. please contact us at 1- 817 - 685 -6491. 7196 9006 9296 7950 8735 y C3 3222 BRECDISC 15353 09/24/12 DIVULGACIONES IMPORTANTES Si usted se encuentra actualmente en un procedimiento de quiebra, o ha obtenido previamente una exoneracibn de esta deuda bajo la ley aplicable sobre quiebra, este no es un intento de recaudacibn, una demanda de pago o un intento de imponer una responsabilidad personal por esa deuda. Usted no est;� obligado(a) a hablar de su pr6stamo para vivienda con nosotros ni a participar en un programa de modificacibn de pr6stamos u otro programa de asistencia para pr6stamos. Usted debe consultar con su abogado especializado en quiebras u otro asesor acerca de sus opciones y derechos legales. Bank of America, N.A., el administrador de su pr6stamo para vivienda estA obligado por ley a informarle a usted que esta comunicaci6n proviene de un cobrador de deudas. Ha ocurrido un incumplimiento de pago u otro tipo de incumplimiento con su pr6stamo que podria resultar en la aceleracibn de todas las cantidades adeudadas bajo el Pagar6. Como resultado, Bank of America, N.A. utilizar6 companias, incluyendo sus afiliados LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, NA, y Landsafe Appraisal Services, Inc., para proporcionar servicios necesarios para proteger los intereses del Titular en la propiedad y sus derechos bajo el instrumento de seguridad y el pagar6, incluyendo cualquiera de sus recursos (los "Servicios relacionados a un incumplimiento "). Bank of America, N.A. aplicar6 cargos a la cuenta de su pr6stamo por los servicios relacionados a un incumplimiento, incluyendo los servicios proporcionados por sus afiliados. Una lista de los cargos que podrian cobrarse a su cuenta por servicios relacionados a un incumplimiento est6 disponible en el sitio de Internet: fhtto: / /www.bankofamerica.com /defaultfees Si usted no tiene acceso a internet, por favor comuniquese con nosotros al 1- 800 - 669 -6607 de lunes a jueves de 8 a. m. a 11 p. m. hora del este, viernes de 8 a. m. a 9 p. m. hora del este, sAbados de 9 a. m. a 3 p. m. hora del este. para pedir que se le envie una lista de cargos por correo, La lista de cargos contiene una lista completa de los servicios relacionados por incumplimiento que le podian cobrar, pero no incluye una lista completa de todos los costos y cargos que podrian ser aplicados a la cuenta de su pr6stamo. PERSONAL MILITAR/ MIEMBROS DE LAS FUERZAS ARMADAS Si usted o su cbnyuge es un miembro del servicio militar, por favor comuniquese con nosotros inmediatamente. La Ley federal de Ayuda Civil para Miembros de las Fuerzas Armadas y las leyes estatales comparables otorgan protecciones y beneficios significativos al personal del servicio militar cue califique inclufdas protecciones contra la ejecucibn hipotecaria asi como tambi6n ayuda en la tasa de inter6s. Para obtener m6s informacibn y determinar su calificacibn por favor Ilame sin costo a nuestro Equipo de Asistencia para el Servicio Militar al 1- 877 - 430 -5434. Si usted llama desde fuera de los Estados Unidos por favor comuniquese con nosotros al 1- 817 - 685 -6491. 7196 9006 9296 7950 8735 C3_5088 OPTAVDFC 15319 09/24/2012 Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home Home Affordable A federal government program that allows you to repay the loan on newly agreed upon terms, Modification which may include lowering the interest rate, placing past due amounts at the end of the loan, Program (RAMP) and/or extending the term of the loan. You may be eligible for this program if you meet the following requirements: • The amount you owe on the first mortgage is equal to or less than $729,750 for a single - family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have documented a financial hardship and represented that you do not have sufficient liquid assets to make the monthly mortgage payments. • Your mortgage was obtained before Jan. 1, 2009. • The property securing the mortgage loan has not been condemned or is not in such poor physical condition that it is not habitable even if not condemned • The mortgage is secured by a one to four unit propert Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the Reinstatement loan up to date until the day of your foreclosure sale. Repayment Plan A repayment plan allows you to make your regularly scheduled mortgage payments, plus pay off a portion of the past due amounts over time, This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and /or collection of payments Forbearance for a period of time, to allow you to re- establish your ability to make the required payments. Agreement Loan Modification A loan modification is a change to the original terms of your loan. Loan modifications could (non -HAMP) include lowering your interest rate, extending the term or maturity date of the loan, moving from an adjustable to a fixed -rate loan, deferring some portion of the unpaid principal balance to the end of the loan, and/or forgiving some portion of the unpaid principal balance. Partial Claim (FHA If you have a Federal Housing Administration (FHA) loan and your payments are past due but loans only) you are now able to make your regular monthly mortgage payment, this program is designed to bring your loan up to date by creating a second mortgage /lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home U X Home Affordable Designed to help borrowers who are eligible for the Home Affordable Modification Program Foreclosure (RAMP) but were unsuccessful in securing a permanent modification through the program. Alternatives HAFA provides the option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A Program (HAFA) short sale is a transaction in which you sell your property for less than the total amount owed on the loan (subject to agreement by your servicer /lender /investor), resulting in the release of our lien on your home and avoidance of foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ If you can no longer afford to make your mortgage payments and your home is worth less than Pre - foreclosure you owe, a short sale may allow you to sell your home to pay off the mortgage. In a short sale, Sale (non -HAFA) the lender agrees to accept an amount less than what is actually owed on the loan. Offered to borrowers who are not eligible for HAMP or other home retention alternatives. Deed in Lieu of Used as an alternative to foreclosure, with a deed in lieu of foreclosure, you transfer ownership Foreclosure of your house and all property secured by your mortgage loan. This may satisfy the total (non -HAFA) amount due on that mortgage. Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not able to sell the property through a short sale. We are here to help you. Please call us today. 7196 9006 9296 7950 8735 C3_5088 OPTAVDFC 15319 09/24/2012 Hay opciones disponibles para ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notificacion adjunta para obtener mas informacion Cuando Ilame, por favor tenga a la mano la informaci6n de sus ingresos y gastos para que podamos discutir cubles opciones podrian funcionar para usted. Opciones a considerar si su objetivo es pennanecer en su casa Qescri " dtar� ............ . . Home Affordable Es un programa del gobierno federal que le permite pagar el pr6stamo bajo los nuevos Modification t6rminos acordados, que pueden incluir la reducci6n de la tasa de inter6s, agregar Program (RAMP) cantidades vencidas al final del pr6stamo, y/o extender el plazo del pr6stamo. Usted puede calificar para este programa si cumple con los siguientes requisitos: • La cantidad que usted adeuda de su primera hipoteca es igual o menor que $729,750 d6lares para una vivienda unifamiliar, $934,200 d6lares para una propiedad de 2 unidades, $1,129,250 d6lares pars una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades • Usted ha documentado que atraviesa por una dificultad financiera y declarado que no tiene suficiente liquidez para hacer los pagos mensuales de la hipoteca. • Obtuvo su hipoteca antes del 1 de enero de 2009. • La propiedad que garantiza el pr6stamo hipotecario no ha sido condenada o no est6 en malas condiciones fisicas como para no poder habitarse incluso si no est6 condenada. • La hipoteca est6 garantizada por una propiedad de una a cuatro unidades. Restablecimiento Si usted puede poner al dia los pagos de su pr6stamo, aceptaremos los fondos del Pr6stamo necesarios para que el pr6stamo est6 al dia hasta la fecha de la venta por ejecuci6n hipotecaria. Plan de Pago Un plan de pago le permite a usted hacer sus pagos hipotecarios regulares, adem6s de pagar una porci6n de los montos vencidos a trav6s del tiempo. Esto puede incluir capital, inter6s, cargos o costos aplicados a su pr6stamo. Acuerdo Temporal Es un acuerdo en el cual aceptamos no proceder con la ejecuci6n hipotecaria y/o el de Tolerancia por cobro de los pagos por un periodo de tiempo, para permitirle que restablezca su incumplimiento habilidad de hacer los pagos requeridos. Modificaci6n de Una modificaci6n del pr6stamo es un cambio en los t6rminos originales de su pr6stamo, Pr6stamo Las modificaciones podrian incluir reducir su tasa de inter6s, extender el t6rmino o la (no por medio de fecha de pago del pr6stamo, cambiar de un pr6stamo de tasa de inter6s ajustable a uno HAMP) de tasa de inter6s fija, diferir una parte del saldo del capital impagado al final del pr6stamo, y/o condonar una parte del saldo de capital impagado. Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos (solamente est6n vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, pr6stamos de la este programa est6 disenado para que su pr6stamo este al dia mediante la creaci6n de FHA) una segunda hipoteca / gravamen sobre su propiedad por el monto que est6 vencido. 7196 9006 9296 7950 8735 C3_5088 OPTAVDFC 15319 09/24/2012 Opciones a considerar si no puede o no desea quedarse en su casa Ora mm .............................. ..........:..... :.:...:.::.::.. 1::.::.::::::..:.::.::._:::::::::::::::.::: ::::.:::::::::::::.:::.::::.::. Home Affordable Diseriado para ayudar a los prestatarios que califican para el Programa de Home Foreclosure Affordable Modification (HAMP), pero no consiguieron obtener una modificaci6n Alternatives Program permanente a trav6s del programa. HAFA ofrece la posibilidad de una venta en (HAFA) descubierto y, si no tiene 6xito, una escritura de traspaso voluntario de propiedad en lugar de la ejecuci6n hipotecaria. Una venta en descubierto es una transacci6n en la que usted vende su propiedad por menos de la cantidad adeudada en el pr6stamo (sujeto a previo acuerdo de su administrador / prestamista / inversionista), resultando en la liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una escritura de traspaso voluntario de propiedad en lugar de la ejecuci6n hipotecaria es una transacci6n en la que usted est6 de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. Venta en descubierto Si usted ya no puede hacer sus pagos hipotecarios y su vivienda vale menos de to que / Venta previa a la usted adeuda, una venta en descubierto le podria permitir vender su vivienda para pagar ejecuci6n hipotecaria la hipoteca. En una vents en descubierto, el prestamista acepta recibir una monto (no por medio de menor de to que actualmente se adeuda en el pr6stamo. Se ofrece a los prestatarios que HAFA) no califican para HAMP o para otras alternativas de retenci6n de la vivienda. Escritura de traspaso Se usa como una alternativa de la ejecuci6n hipotecaria. Con una escritura de traspaso de propiedad en voluntario de propiedad en lugar de la ejecuci6n hipotecaria, usted transfiere la lugar de la ejecuci6n titularidad de su vivienda y toda la propiedad que garantiza su pr6stamo hipotecario. hipotecaria (no por Esto puede hacer que el monto total vencido de esa hipoteca se considere como medio de HAFA) pagado, Se ofrece a prestatarios que no califican para HAMP u otras opciones de retenci6n de vivienda, y que no pudieron vender la propiedad a trav6s de una vents en descubierto. Estamos aqui para ayudarle. Por favor Ilamenos hoy. 7196 9006 9296 7950 8735 VERIFICATION P Gct ft X41 —e hereby states that@/she is ��St S�n{ ��ce ✓es � dew 1 of Bank of America, N.A., for Plaintiff, in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best oo/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. — /'_6 I Name:p, - i m,�.+,GZ i b, I I DATE: ( °l�• Title: Company: Bank of America, N.A. S & D FILE NO: 13- 044111 Blake A. Woodward and Heather N. 'Woodward � T FORM 1 IN THE COURT OF COMMON PLEAS OF Bank of America, National Association CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Heather N. Woodward C' 31 East Pine Street Mount Holly Springs, PA 17065 C- ',, A -< Blake A. Woodward r" 2_' 31 East Pine Street > M = Mount Holly Springs, PA 17065 nc .' CO DEFENDANTS v ` Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. I 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: S14APIRO & DeNARDO, LLC ACV Date AhQrr ys fo lain ff CAITLIN M. DO LLY, ESQUIRE FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? C O-BOR R O WER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household How Long? FIN ANCIAL •' • First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount:$ Included Taxes & Insurance:_ Date of Last Payment: Primary Reason for Default: Is the Loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount Owed: Value: Automobile #2: Model: Year: Amount Owed: Value: Other transportation (automobiles, boats, motorcycles ): Model: Year: Amount Owed: Value: Monthly Income: Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food 2 d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Mone Day /Child Care /Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 4 � Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those'negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTH ORIZATIO N I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating m financial situation for possible mortgage options. I /We understand that I /We am /are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 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 (hardship letter) Listing agreement (if property is currently on the market) � 1 FORM 3 IN THE COURT OF COMMON PLEAS OF Bank of America, National Association CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Heather N. Woodward 31 East Pine Street Mount Holly Springs, PA 17065 Blake A. Woodward 31 East Pine Street Mount Holly Springs, PA 17065 DEFENDANTS Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date h FORM 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. Defendant(s) Civil CASE MANAGEMENT ORDER AND NOW, this day of , 20 , the defendant/borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (2 1) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 0 HE PROTHONOTARY Sheriff �a�4irtr at CRr;rrtarrt�� Jody S Smith 1813 NOV 25 PM 4. 014 Chief Deputy Richard W Stewart # CUMBERLAND JSiy, Solicitor OFFICE OF TI-E$KRIF9 P E NN S Y LVA N I to 1 Bank of America National Association Case Number vs. 2013-6442 Blake A Woodward (et al.) SHERIFF'S RETURN OF SERVICE 11/12/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 31 E. Pine Street, Mt. Holly Borough, Mt. Holly Springs, PA 17065. Residence is vacant and the Mt. Holly Postmaster confirms that mail is still delivered to the address provided. 11/12/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Heather N Woodward,-�169MTluffffffl r0c6te the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 31 E. Pine Street, Mt. Holly Borough, Mt. Holly Springs, PA 17065. Residence is vacant and the Mt. Holly Postmaster confirms that mail is still delivered to the address provided. 11/12/2013 05:27 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Blake A Woodward, but was unable tp I�(cate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 103 Pine Road, South Middleton, Boiling Springs, PA 17007. This is defendant's grandmother's address and she informed deputies that the defendant did reside here for a short time but moved out and she is unaware of where he is currently residing. The defendant did contact the office and was to come in to pick up Complaint on November 18, 2013 but did not show. SHERIFF COST: $84.82 SO ANSWERS, November 20, 2013 RONNY R ANDERSON, SHERIFF (c)CountySuite Shenff,Teleosoft,Inc. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044111 Bank of America,National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 13-6442 Blake A. Woodward and Heather N.Woodward r ; rryn DEFENDANTS c17 PRAECIPE FOR REINSTATEMENT , f.. TO THE PROTHONOTARY: v Kindly reinstate the Complaint in the above-captioned matter. SHAPIRO & DeNARDO, LLC "/ Date: i5 ILA BY: A/Mr A�tt�aQ e r i r Plaintiff �iRAD' L OSBORNE,ESQUIRE 004 11 �5 1 orthi F-W aZS3 SHERIFF'S OFFICE OF CUMBERLAND COUN Ronny R Anderson TY! "; ''�' Sheriff F` i� r.l Jody S Smith FEB I I ' Chief Deputy CUMBERL;N f Richard W Stewart PENNSYLVANIA/31 � . Solicitor Bank of America National Association vs. Case Number Blake A Woodward (et al.) 2013-6442 SHERIFF'S RETURN OF SERVICE 01/27/2014 04:46 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Brittany Bookwalter, girlfriend,who accepted as "Adult Person in Charge"for Blake A Woodward at 4A Melron Court, Middlesex Township, Carlisle, PA 17013. DEN FRY, DE' 01/31/2014 03:06 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Zach Frank, Brother, who accepted as"Adult Person in Charge"for Heather N Woodward at 405 Juniper Street, Carlisle Borough, Carlisle, PA 17013. J I E D I M A R T L U T Y SHERIFF COST: $57.56 SO ANSWERS, g.")- February 05, 2014 RONNT R ANDERSON, SHERIFF SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 784471uJ V ATR 16 iC CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044111 Bank of America, National Association PLAINTIFF VS. Blake A. Woodward and Heather N. Woodward DEFENDANTS h �r� COUH j l t i'Fi.j SYLV HlA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:13 -6442 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $164,474.50 in favor of the Plaintiff and against the Defendants, jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of Mortgage Debt Due and Unpaid Interest Accrued Late Charges Escrow Advances Property Inspection Attorney Fees & Costs of Foreclosure TOTAL AND NOW, judgment is entered in favor o damages are assessed as above in the sum of $164, 13- 044111 iRNE. ESQUIRE Atto aintiff an 0. $149,332.29 $7,279.92 $163.98 $4,949.96 $1,232.85 $1,515.50 $164,474.50 09`) a*\ ZOLI St-1p. 6 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044111 Bank of America, National Association COURT OF COMMON PLEAS 400 Countrywide Way CUMBERLAND COUNTY Simi Valley, CA 93065 PLAINTIFF 13 -6442 VS. Blake A. Woodward and Heather N. Woodward DEFENDANT(S) STATE OF: Pennsylvania COUNTY OF: Montgomery AFFIDAVIT OF NON - MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he /she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Date: y I5/iti BY: Sworn to and subscribed before me this 64--- day SHAP,' 0 & DeNARDO, LLC s for Plaintiff I. OSBORNE, ESQUIRE COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Sharkey, Notary Public Upper Merlon Twp., Montgomery County My Commission Expires Oct. 19, 2014 Member. Pennsylvania Assodation of Notaries • Department of Defense Manpower Data Center Results as of : Apr•15 -2014 05.'04:02 AM SCRA 3.0 Stag Report Pursuant to Servicemembers Civil Relief Act Last Name: WOODWARD First Name: BLAKE Middle Name: A. Active Duty Status As Of: A -15 -2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA— No NA This response reflects the Individuals': active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA . NA No NA This response reflects where the individual left active dufy'status within 367 days preceding the Active Duty Status Date The Member or His /Her Unit Was Notified of e 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 hlslher 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. YA. 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 /PCO9SLDR.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 accordanceWith 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: 58LCU7FF9097RBO • Department of Defense Manpower Data Center Results as of : Apr-15-2014 0503:53 AM SCRA 3.0 Status Rcport Pursuant to Servicemembers Civil Relief Act Last Name: WOODWARD First Name: HEATHER Middle Name: N. Active Duty Status As Of: Apr-15-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA. .. No ' NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA : - No . NA This response reflects ■iiheie the individual left actiVe-duty status within 367 days preceding the Active Duty Status Date If I 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 : - NA This response reflects whethei the individual or hisTher unit has received eartynotificatkn 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 /PCO9SLDR.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: 98YAX78FK0977E0 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 13-6442 Blake A. Woodward and Heather N. Woodward DEFENDANTS CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, April 2, 2014 to the following Defendants: Blake A. Woodward, 4A Melron Court, Carlisle, PA 17013 Heather N. Woodward, 405 Juniper Street, Carlisle, PA 170 Megh Williams, Legal Assistant to Christopher A. DeNardo, Esquire for Shapiro & DeNardo, LLC SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Blake A. Woodward and Heather N. Woodward NO:13 -6442 DEFENDANTS CERTIFICATE OF SERVICE I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Blake A. Woodward, 4A Melron Court, Carlisle, PA 17013 Heather N. Woodward, 405 Juniper Street, Carlisle, PA 17013 Date Mailed: Date: BY: SHAPIRO & DeNARDO, LLC L eys for Plaintiff J. OSBORNE, ESQUIRE SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Blake A. Woodward and Heather N. Woodward NO:13 -6442 DEFENDANTS CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Bank of America, National Association 400 Countrywide Way Simi Valley, CA 93065 and that the last known addresses of the judgment debtors (Defendants) are: Blake A. Woodward 4A Melron Court Carlisle, PA 17013 Heather N. Woodward 405 Juniper Street Carlisle, PA 17013 Date: (1 \s -iL\ BY: 13- 044111 SHAPIRO & DeNARDO, LLC neys for Plaintiff OSBORNE, ESQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Blake A. Woodward 4A Melron Court Carlisle, PA 17013 Bank of America, National Association PLAINTIFF VS. Blake A. Woodward and Heather N. Woodward DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 13 -6442 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE AT (610)278 -6800. tAroVeP 47/0/1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Heather N. Woodward 405 Juniper Street Carlisle, PA 17013 Bank of America, National Association PLAINTIFF VS. Blake A. Woodward and Heather N. Woodward DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 13 -6442 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE AT (610)278 -6800. 1#4-41P: Lib &jig SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION CUMBERLAND COUNTY VS. NO: 13-6442 Blake A. Woodward and Heather N. Woodward DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Blake A. Woodward DATE OF NOTICE: April 2, 2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se .encuentra en estado de rebeldia por no haber tonnado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o Si no tient diner° suficiente para ta1 servicio, vaya en persona o llame por telefono a la oficina cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Blake A. Woodward, 4A Meiron Court, 'Carlisle, PA 17013 Heather N. Woodward, 405 Juniper Street, Carlisle; PA 1701.3 Date: 101 BY: SHAPIRO & DeNARDO, LLC A ey8 for Plainti CAITLIN M. 'DON;',,TLLY. ETC , TU77, THE CQURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net BANK OF AMERICA, NATIONAL ASSOCIATION Vs. NO 13 -6442 Civil Term CIVIL A CTION — LAW BLAKE A. WOODWARD AND HEATHER N. WOODWARD 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: $164,474.50 L.L.: $.50 Interest FROM APRIL 2, 2014 TO SEPTEMBER 3, 2014 IS $3,404.89 Atty's Comm: Atty Paid: $302.88 Plaintiff Paid: Date: 4/16/14 Due Prothy: $2.25 Other Costs: LtsLL REQUESTING PARTY: Name: BRADLEY J. OSBORNE, ESQUIRE Address: SHAPIRO & DENARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610- 278 -6800 Supreme Court ID No. 312169 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Bank of America, National Association PLAINTIFF VS. Blake A. Woodward and Heather N. Woodward DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: ) Confessed Judgment ) Other File No. I Li_ LILO, Amount Due $164,474.50 Interest April 2, 2014 to September 3, 2014 is $3,404.89 Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment safer, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) See attached Legal Description PRAECIPE FOR ATTACHEMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: oLtut OAF I SI. SU (t1.1 Cc U.1511 ti 1 Q) S I SIS Signature: Print Name: B J Osborne Address: 60 Horizon-Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 312169 eloi- J1/e)/R!9'iL5 •;,LIL,1 ALL THAT CERTAIN tract of land with improvements thereon erected situated on the North side of East Pine Street, in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of East Pine Street; thence by the same, North 80 degrees, 45 minutes East, a distance of 54 feet to a stake; thence along property now or formerly of Chalmer D. Toner and Sarah Virginia Toner, North 11 degrees, 15 minutes West, a distance of 39.6 feet to a point; thence by same North 25 degrees, 45 minutes West, a distance of 135 feet to a post; thence along the South side of a public alley, North 42 degrees, 15 minutes West, a distance of 7.9 feet to a point; thence by same, North 85 degrees West, a distance of 17 feet to a point; thence along lands now or formerly of Chester L. Sheaffer, South 10 degrees, 30 minutes East, a distance of 181.5 feet to a point on the North side of East Pine Street and the place of beginning. CONTAINING 7,000 square feet, more or less and being improved with a dwelling house known as 31 East Pine Street. PARCEL No. 23-32-2336-264A BEING the same premises which Victoria L. Gay, single woman, by Deed dated July 26, 2010 and recorded July 30, 2010 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 201020899, granted and conveyed unto Blake A. Woodward and Heather N. Woodward, husband and wife. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044111 Bank of America, National Association PLAINTIFF VS. Blake A. Woodward and Heather N. Woodward CASE NO, 13-6442 DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129.1 PR 16 10: 20 COTY PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Bank of America, National Association, Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 31 East Pine Street, Mount Holly Springs, PA 17065. Name and address of Owner(s) or Reputed Owner(s) Blake A. Woodward 4A Melron Court Carlisle, PA 17013 Heather N. Woodward 405 Juniper Street Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Blake A. Woodward 4A Melron Court Carlisle, PA 17013 Heather N. Woodward 405 Juniper Street Carlisle, PA 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bank of America, National Association 400 Countrywide Way Simi Valley, CA 93065 4. Name and address of the last recorded holder of every mortgage of record: Bank of America, National Association 400 Countrywide Way Simi Valley, CA 93065 5. Name and address of every other person who has any record lien on the property: PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 31 East Pine Street Mount Holly Springs, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. BY: 13-044111 SHA RO & DeNARDO, LLC ey J Osborne t SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 -- S & D FILE NO. 13-044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Blake A. Woodward and Heather N. Woodward NO: 13-6442 DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Blake A. Woodward 4A Melron Court Carlisle, PA 17013 Your house (real estate) at: 31 East Pine Street, Mount Holly Springs, PA 17065 23-32-2336-264A is scheduled to be sold at Sheriffs Sale on September 3, 2014 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $164,474.50 obtained by Bank of America, National Association 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: The sale will be cancelled if you pay back to Bank of America, National Association the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278 -6800. 6. 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. 7. 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 717- 240 -6390. 8. 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. 9. 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 11. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 -249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 13- 044111 • ALL THAT CERTAIN tract of land with improvements thereon erected situated on the North side of East Pine Street, in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of East Pine Street; thence by the same, North 80 degrees, 45 minutes East, a distance of 54 feet to a stake; thence along property . now or formerly of Chalmer D. Toner and Sarah Virginia Toner, North 11 degrees, 15 minutes West, a distance of 39.6 feet to a point; thence by same North 25 degrees, 45 minutes West, a distance of 135 feet to a post; thence along the South side of a public alley, North 42 degrees, 15 minutes West, a distance of 7.9 feet to a point; thence by same, North 85 degrees West, a distance of 17 feet to a point; thence along lands now or formerly of Chester L. Sheaffer, South 10 degrees, 30 minutes East, a distance of 181.5 feet to a point on the North side of East Pine Street and the place of beginning. CONTAINING 7,000 square feet, more or less and being improved with a dwelling house known as 31 East Pine Street. PARCEL No. 23 -32- 2336 -264A BEING the same premises which Victoria L. Gay, single woman, by Deed dated July 26, 2010 and recorded July 30, 2010 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 201020899, granted and conveyed unto Blake A. Woodward and Heather N. Woodward, husband and wife. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Blake A. Woodward and Heather N. Woodward NO: 13-6442 DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Heather N. Woodward 405 Juniper Street Carlisle, PA 17013 Your house (real estate) at: 31 East Pine Street, Mount Holly Springs, PA 17065 23-32-2336-264A is scheduled to be sold at Sheriffs Sale on September 3, 2014 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $164,474.50 obtained by Bank of America, National Association 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 back to Bank of America, National Association the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call: (610)278-6800. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278 -6800. 6. 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. 7. 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 717- 240 -6390. 8. 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. 9. 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. 10. 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 no later than thirty days after the Sheriff Sale. This schedule will state who will be receiving the 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 date of filing of said schedule. 11 You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 13- 044111 ALL THAT CERTAIN tract of land with improvements thereon erected situated on the North side of East Pine Street, in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the North side of East Pine Street; thence by the same, North 80 degrees, 45 minutes East, a distance of 54 feet to a stake; thence along property now or formerly of Chalmer D. Toner and Sarah Virginia Toner, North 11 degrees, 15 minutes West, a distance of 39.6 feet to a point; thence by same North 25 degrees, 45 minutes West, a distance of 135 feet to a post; thence along the South side of a public alley, North 42 degrees, 15 minutes West, a distance of 7.9 feet to a point; thence by same, North 85 degrees West, a distance of 17 feet to a point; thence along lands now or formerly of Chester L. Sheaffer, South 10 degrees, 30 minutes East, a distance of 181.5 feet to a point on the North side of East Pine Street and the place of beginning. CONTAINING 7,000 square feet, more or less and being improved with a dwelling house known as 31 East Pine Street. PARCEL No. 23 -32- 2336 -264A BEING the same premises which Victoria L. Gay, single woman, by Deed dated July 26, 2010 and recorded July 30, 2010 in the Cumberland County Recorder of Deeds Office as Deed Instrument No. 201020899, granted and conveyed unto Blake A. Woodward and Heather N. Woodward, husband and wife. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044111 Bank of America, National Association COURT OF COMMON PLEAS 400 Countrywide Way CUMBERLAND COUNTY Simi Valley, CA 93065 PLAINTIFF 13-6442 VS. Blake A. Woodward and Heather N. Woodward DEFENDANT(S) Notice of the Date of Continued Sheriff's sale The Sheriff's Sale scheduled for September 3, 2014 at 10:00 AM in the above -captioned matter has been continued until November 5, 2014. Date: BY: SHAPI 0 & DeNARDO, LLC ys for Plaintiff 4-4 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION vs. CUMBERLAND COUNTY Blake A. Woodward and Heather N. Woodward NO:13-6442 DEFENDANT(S) CERTIFICATE OF SERVICE I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Blake A. Woodward 4A Melron Court Carlisle, PA 17013 Heather N. Woodward 405 Juniper Street Carlisle, PA 17013 Date: g:TY BY: SHAPIRO & DeNARDO, LLC A,c _eys for Plaintiff B&R Services for Professionals Inc. 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 546-7400 FAX: (215) 985-0169 Bank of America, National Association -vs- Blake A. Woodward and Heather N. Woodward COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: National Association of Philadelphia Association Professional Process Servers of Professional Process Servers COURT Court of Common Pleas of Pennsylvania COUNTY Cumberland County CASE NUMBER 13-6442 AFFIDAVIT OF SERVICE B&R Control # =16987 - 1 Reference Number 13-044111 SERVICE INFORMATION On 19 day of August, 2014 we received the Notice of Sheriff Sale for service upon Blake A. Woodward at 103 Pine Road Mount Holly Springs, PA 17065 *** Special Instructions *** CgServed Date oa_4131901(4 Time In the manner described below. CZPersonally served. Li Adult family member. Relationship is 1:14qppl Accepted By:'PACt\e— A. v1/4)00(4wctic1 Adult in charge of residence who refused to give name and/or relationship. Manager/Clerk of place of residence lodging Agent or person in charge of office or usual place of business Other Description of Person Age n Not Served Date Height (10.'' Weight 4Q Race t kyle._ Sex yyv2k, Other jAggictjma,. Time Not Served Information I I Moved j Unknown No Answer Vacant Other CD - The Process Server, being duly sworn, deposes and says that the facts set forth herein are true and correct to the best of their knowledge, information and belief. Process Server/Sheriff- COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Brittany Edcius, Notary Public Lower Paxton Township, Dauphin County My commission expires April 11,2018 Sworn to and subscribed before me this dayofSvrziy Notary ublic Law Firm Phone (610)278-6800 Bradley J Osborne, Esquire Shapiro and DeNardo LLC 3600 Horizon Drive Suite 150 King of Prussia, PA 19406 ServeBy Date 9/19/2014 Filed Date sale date 11/5/2014 . . ORIGINAL 23108. , SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, 2 oi 5 ATTORNEY I.D. NO. 78447 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY LD, NO. 203437 LEEANE 0, HUGGINS, ATTORNEY LD. NO. 85144 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S &D FILE NO. 13-044111 Bank of America, National Association COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION VS. CUMBERLAND COUNTY Blake A. Woodward and Heather N. Woodward NO:13-6442 DEFENDANTS CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I,Meghan Williams,Legal Assistant for Shapiro&DeNardo,LLC,attorneys for the Plaintiff, Bank of America,National Association,hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on July 11, 2014, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. SHAPIR & DENARDO, LLC Date: /0 45'- // By: avy Meghan Williams Legal Assistant 13-044111 Ce if a 3 Ill T". '20 oXIDAIpQ parau1sa}J d; N utlput fptaadt: O _, `_ uotimun1.uo3 ainmu2Is u... i ro ("4 8 LT uotl1uuguo3 ic-tantlaU 44 0�M in0O Y r CJ) Q c c o` • c D hA0O O E ' CO1 • ala .• r m 4) �E > a �i v C �j a C a) ,02) CO 4 g w_ v s � ammnro Emo :•E &12 12-a m ° m O 0 <,,,. ^ b $4Q p0 c m O Ta as as4. CN To '12 10 E d E U 1. 2 Z a`ra O Y gs 0 c I; i a c g 4) 0at .t, N U 0 iia 1.1.2 4) 0. 'o �c N O a ro a6 "iii c 871) n DODO Al 1 s ce U njuo c UO Q to ,. a� w c gg ts bD c4 G No is a U2 a b o it. a "R'. E a 08O ? m ,..g '6. ocv xon �,. yY 00000 ( z ' gS R 8 .'c EN 3` FqC - V c�rjsa a:x - CL d U 928 Q R f O -5 O a r, 41 iu z,> Q 0 'ta > d ¢ 3 N za°' u • 4 o R ,i--- v: o °' t~� C C) Om m a0 ro w co C1 ro.4 .a 3 'mv LL. znM� .- N M h. CO Y6 J d Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE i" RO i HONC mi t ow �t .trinfarr/�'0 221.11 DEC 31 PM 2: 39 . ., CUMBERLAND COUNTY PENNSYLVANIA OFFICE OF' THE $KERIFF Bank of America National Association vs. Blake A Woodward (et al.) Case Number 2013-6442 SHERIFF'S RETURN OF SERVICE 06/16/2014 03:34 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Heather N Woodward at 405 Juniper Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 06/16/2014 06:42 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Blake A. Woodward, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 4A Melron Court, Carlisle, PA 17013, residence is vacant, defendant did not leave a forwarding address with the post office. cab. 06/16/2014 08:26 PM - Deputy Shawn Harrison, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 31 East Pine Street, Mount Holly Springs, PA 17065, Cumberland County. 08/05/2014 As directed by Christopher Denardo, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/5/2014 11/05/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on November 05, 2014 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Christopher Denardo, on behalf of Bank of America, NA, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,037.03 SO ANSWERS, November 17, 2014 RONNY R ANDERSON, SHERIFF fci ;ountySu to Sheriff, Teleosaft, Inc. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net BANK OF AMERICA, NATIONAL ASSOCIATION Vs. NO 13-6442 Civil Term CIVIL ACTION — LAW BLAKE A. WOODWARD AND HEATHER N. WOODWARD 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: $164,474.50 L.L.: $.50 Interest FROM APRIL 2, 2014 TO SEPTEMBER 3, 2014 IS $3,404.89 Atty's Comm: Due Prothy: $2.25 Atty Paid: $302.88 Other Costs: Plaintiff Paid: Date: 4/16/14 David Buell, Protho t (Seal) By: • Deputy REQUESTING PARTY: Name: BRADLEY J. OSBORNE, ESQUIRE Address: SHAPIRO & DENARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 312169 TRUE COPY FROM RECORD !n Testimony whereof, I here unto set my hand and the seal of said Co t at Carlisle, Pa. This )(Al day of ) f • • . 20 /y Prothonotary„.47., The Patriot -News Co. 1900 Patriot Drive Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 bepatriot*Ncws Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Amy Kotula, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2013.2 Civil Term BANK OF AMERICA NATIONAL ASSOCIATION vs. BLAKE A W0ODWARD Heather N. Woodward Atty: Christopher Denardo d ALL improvementT s thereon hereon erecIN tract of ted situated onwith the North side of East Pine Street, in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described BEGINNING as follows: at a point on the North the side of East Pine Street; th4ncm by same, North 80 degrees: East, a distance of 54 feet to a stake; thence along property now or formerly of Chalmer l'�T`-1°and Sarah Virginia Toner, North II degrees, 15 minutet t es West, a d then e' ce byname North of 39.6 e25 toap This ad ran on the date(s) shown below: 07/13/14 07/20/14 07/27/14 Sworn to nd ubscribed before me this 20 day of August, 2014 A.D. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Sheryl Mane Leggore, Notary Public Hampden Twp., Cumberland County My Commission Expires July 16, 2018 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11, July 18 and July 25, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisrie Coyne, Editc r SWORN TO AND SUBSCRIBED before me this 25 day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE KORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 cbhe patriot -Yews Now you know 2020 Technology Parkway Mechanicsburg, PA (717) 255-8237 BILL TO: Cumberland County Sheriffs Office Cumberland County Court House Carlisle, PA 17013 ACCT. # 2260 DUPLICATE BILL Date Description Sale # Size Rate Net Cost Of Ad 07/13/14 Sheriff Sale 6442 8.36 $14.29 $ 119.46 07/20/14 Sheriff Sale 6442 8.36 $14.29 $ 119.46 07/27/17 Sheriff Sale 6442 8.36 $14.29 $ 119.46 Notary Fee $5.00 Digital Penn Live Charge $ 17.38 TOTAL DUE FOR THIS SALE: JLC $ 380.76 LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2013-6442 Civil BANK OF AMERICA NATIONAL ASSOCIATION vs. BLAKE A. WOODWARD Heather N. Woodward Atty.: Christopher DeNardo ,ALL THAT .CERTAIN tract of land with improvements thereon erected situated on. the North side of East Pine Street, in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at a point on the North side of East Pine Street; thence by the same, North 80 degrees, 45 minutes East, a distance of 54 feet to a stake; thence along property now or formerly of Chalxner D. Toner and Sarah Virginia Toner, North II degrees, 15 minutes West, a distance of 39.6 feet to a point; thence by same North 25 degrees, 45 minutes West, a distance of 135 feet to a post; thence along the South side of a public alley, North 42 degrees, 15 minutes West, a distance of7.9 feet to a point; thence by same, North 85 degrees West, a distance of 17 feet to a point; thencealong lands now or formerly of Chester L. Sheaffer, South 10 degrees, 30 minutes East, a distance of 181.5 feet to a point on the North side of East Pine Street and the place of beginning. CONTAINING 7,000 square feet, more or less and being improved with a dwelling house known as 31 East Pine Street. PARCEL No. 23-32-2336-264A. BEING the same premises which Victoria L. Gay, single woman, by Deed dated July 26,2010 and record- ed July 30, 2010 in the Cumberland County Recorder of Deeds Office. as Deed Instrument No. 201020899, granted and conveyed unto Blake A. Woodward and Heather N. Wood- ward, husband and wife. 111 i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Bank of America N A is the grantee the same having been sold to said grantee on the 5th day of November A.D., 2014, under and by virtue of a writ Execution issued on the 16th day of April, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 6442, at the suit of Bank of America N A against Blake A & Heather N Woodward is duly recorded as Instrument Number 201430357. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ,t9j,c9..u,„,k, A.D. 0,7011- day of ecorder of Deeds ecora , o' eeds, Cumberland County,. Ca is e, PA My Co fission Expires the First Monday of Jan. 2016