HomeMy WebLinkAbout14-0447 r
Supreme Court of Peainsylvania
Couif Com Pleas
t , -/ ,. y �,
F'arPsotlaanratarr Use Only_
Giv Cocer Sheet 7 .
CU m6erlaid/-Jr C ollll Docket No:
The information collected on this form is used solely for court administration purposes. This form does not
Supplement or replace thefiling 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 Takin
E Lead Plaintiff Name: Lead Defendant's Name:
GREEN TREE SERVICING LLC RANCK ALAN BYLER
C JENNIFER L. BYLER
T
I Dollar Amount Requested within arbitration limits
O Are money Damages requested ?: ❑ Yes ® No (Check one) X outside arbitration limits
N
Is this a Class Action Suit? ❑ Yes NO Is this an MDJ Appeal? ❑ Yes ® NO
A Name of Plaintiff/appellant's Attorney: KML Law Group, P.C.
❑ Check here if you are a Self-Represented (Pro Se Litigant
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEAL
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
5 ❑ Premises Liability ❑ Zoning Board
❑ Product Liability (does not include ❑ Statutory Appeal: Other
E mass tort) ❑Employment dispute:
❑ Slander/Libel Defamation Discrimination
C
❑ Other ❑Employment Dispute: Other
T ❑ Other:
0 MASS TORT ❑Other
❑ Asbestos
❑ Tobacco
❑ Toxic Tort -DES REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory
❑ Toxic Waste ❑ Eminent Domain/Condemnation Arbitration
B ❑ Other ❑ Ground Rent ❑ Declaratory Judgment
❑ Landlord/Tenant Dispute ❑ Mandamus
® Mortgage Foreclosure: Residential ❑ Non - Domestic Relations
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial Restraining Order
• Dental ❑ Partition ❑ Quo Warranto
❑ Legal ❑ Quiet title ❑ Replevin
• Medical
• Other Professional: ❑ Other ❑ Other
Pa.RCP. 205.5 Updated 1/1/2011
KML LAW GROUP, P.C.
SUITE 5000 — BNY MELLON INDEPENDENCE CENTER,. ' .k fT _ ; Jl"a
701 MARKET STREET i f 1 i {� (J 1
PHILADELPHIA, PA 19106
(866) 413 -2311
)VWW.KMLLA W GROUP.COM
GREEN TREE SERVICING LLC G IN THE COURT OF COMMON PLEAS
345 St Peter Street PENN$ YLVA NJ
1100 Landmark Towers OF Cumberland COUNTY
St Paul, MN 55102
Plaintiff CIVIL ACTION - LAW
vs.
RANCK ALAN BYLER ACTION OF MORTGAGE FORECLOSURE
JENNIFER L. BYLER
Mortgagor(s) and Record Owner(s) 0 �. �� 209 Mooredale Road CIVIL AM I
Carlisle, PA 17013 . FORECLO
Defendant(s)
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion.
Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma
escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se
defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones
de esta demanda. Usted puede perder dinero o sus propiedades . u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR 1 �S
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. fl1V��
7 Q 0
1Z. � 3008 ay
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243 -9400.
2). Call the Consumer Credit Counseling Agency at 1- 800 - 989 -2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website http: / /www.phfa.org/ consumers /homeowners /real.aspx
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http: / /www.philadelphiafed.org /foreclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1- 866 -413 -2311 or via email
at homeretentiongkmllawgroup.com Call Seth at 215- 825 -6329 or fax 215- 825 -6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215- 825 -6318 or Fax: 215- 825 -6418. Please reference our Attorney File Number of 125786FC.
Para informacion en espanol puede communicarse con Loretta al 215- 825 -6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is GREEN TREE SERVICING LLC, 345 St Peter Street, 1100 Landmark Towers St Paul, MN
55102.
2. The name(s) and address(es) of the Defendant(s) is /are RANCK ALAN BYLER, 209 Mooredale Road,
Carlisle, PA 17013 and JENNIFER L. BYLER, 209 Mooredale Road, Carlisle, PA 17013, who is /are
the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described.
3. On October 20, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property
hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., SOLELY
AS NOMINEE FOR AMERICAN PARTNERS BANK, which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County on November 03, 2006 as Book 1971, Page 4100. The
mortgage has been assigned to: GREEN TREE SERVICING LLC by assignment of Mortgage recorded
on August 27, 2013 as Instrument # 201328554. The Mortgage and Assignment(s) (if any) are matters
of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil
Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings
if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ( "Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for June 01, 2013 and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance ............................... ............................... ....................$145,995.89
Interest from 05/01/2013 through 01/20/2014 at 5.8750 % . ......................$6,164.74
Per Diem interest rate at $23.50
LateCharges ........................................ ............................... ........................$191.16
Reasonable Attorney's Fee .................. ............................... ............ ..........$1,650.00
$154,001.79
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. Plaintiff reserves the right to request
additional attorney's fees if the complexity of the action results in fees in excess of the amount
demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not
limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other
costs of the action in accordance with the mortgage documents and applicable law.
8. Plaintiff is not seeking a judgment of personal liability (or an " personam judgment) against the
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re- establish the personal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit `B ". The Defendants have not had the required face -to -face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $154,001.79,
together with interest at the rate of $23.50, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Note and Mortgage and
Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale
of the Property.
By:
Y
KML LAW GROUP, P.C. fig
Michael McKeever PaIlly 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. ID 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Alyk L. Oflazian Pa. ID 312912
XSalvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
VERIFICATION
I, Ac n I e� �YNq as the representative of the Plaintiff corporation
within named do hereby verify that I am authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the
best of my information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Date: � I EO 14
� eUfl�v�.rL� She ' �:► Sf
# 125786FC - RANCK ALAN BYLER and JENNIFER L. BYLER
209 Mooredale Road Carlisle, PA 17013
Ey,h i 6 i tA
All that certain parcel of land and improvements therein situate in the Township of Dickinson, County of
Cumberland, and Commonwealth of Pennsylvania, and designated as Parcel Ho. 08- 10- 0626-023A and more
fully described in a Deed dated March 6, 2003 and recorded March 13, 2002 in Cumberland County in Deed
Book 256, Page 428, granted and conveyed unto Ranck Alan Byler and Jennifer L. Byler, husband and wife.
r
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f, j`11
�31 l_, iii
�.l7ill:tY
0
Recorder of Deeds
(PPF06.00576.PFDVPPF06 -M7&M)
0(4:97 1 K41 13
Ey�,,h �B
*Exhibit has been redacted to remove all personally identifiable information or non -public information
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
Date: 10/30/2013
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mort gage on your h ome i s in defaul t, an d th e
lender intends to foreclose. Specific inform ation about the nature of the default is
provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may
be able to help to save your home. This Notice explains how the program works. To see
if HEMAP can hel p, you must MEET WI TH A CONSUMER CREDIT COUNSELING
AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with
you when you meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving
your County are listed at the end of this N otice. If you have any ques tions you m ay call the
Pennsylvania Housing Finance A gency toll free at 1- 800 - 342 -2397. (Persons with im paired
hearing can call (717) 780 -1869)*
This Notice contains important legal info rmation. If you h ave an y q uestions,
representatives at the Cons umer Credit Counseling Agency may be ab le to help explain
it. You m ay also w ant to cont act an y attorn ey in yo ur a rea. T he local bar association
may be able to help you find a lawyer.
LA NOT IFICACION E N ADJUNT O E S DE SUMA IMPORT ANCIA, PUE S
AFECTA SU DERECHO A CONTI NUAR VI VIENDO EN SU CASA. SI NO
COMPRENDE E L CONT ENIDO DE ESTA NOT IFICATION OBTE NGA UNA
TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA.
PUEDE SER ELEGIBLE PARA UN PRES TAMO POR EL PR OGRAMA LLAMADO
"HOMEOWNER'S EM ERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE L A PE RDIDA DEL DERECHO A REDIMI R SU
HIPOTECA.
i
Date: 10/30/2013
HOMEOWNER'S NAME(S): RANCK ALAN BYLER and JENNIFER L. BYLER
PROPERTY ADDRESS: 209 Mooredale Road, Carlisle, PA 17013
LOAN ACCT. NO.: -4473
ORIGINAL LENDER: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,
SOLELY AS NOMINEE FOR AMERICAN PARTNERS BANK
CURRENT LENDER/SERVICER: GREEN TREE SERVICING LLC / GREEN TREE
SERVICING
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE
MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S
EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT "), YOU MAY BE
ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
* IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
* IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
* IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for
mailing). During that time you must arrange and attend a "face -to- face" meeting with one of the
consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST
OCCUR WITHIN (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY
FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP
TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE
DEFAULT ", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of
designated consumer credit counseling_ agencies for the county in which the property is located are set
forth at the end of this Notice. It is only necessary to schedule one face -to -face meeting. Advise your
lender immediately of your intentions.
2
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature of
your default.) You have the right to apply for financial assistance from the Homeowner's Emergency
Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's
Emergency Assistance Program Application with one of the designated consumer credit counseling
agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications
for the program and they will assist you in submitting a complete application to the Pennsylvania
Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your
application MUST be forwarded to PHFA and received within thirty (30) days of your face -to -face
meeting with the counseling agency.
YOU SHOULD FILE A HEMAPAPPLICATION SOONAS POSSIBLE IF YOU
HAVE A MEETING WITHA COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK
DATE OF THIS NOTICE AND FILE ANAPPLICA TION WITH PHFA WITHIN 30 DAYS OF
THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM
STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN
THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILEA HEMAPAPPLICATIONEVEN BEYOND THESE
TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM
STARTING FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY
APPROVED ATANY TIME BEFOREA SHERIFF'S SALE, THE FORECLOSURE WILL BE
STOPPED.
AGEN ACTION - Available funds for emergency mortgage assistance are very limited.
They will be disbursed by the Agency under the eligibility criteria established by the Act. The
Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your
application. During that time, no foreclosure proceedings will be pursued against you if you have met
the time requirements set forth above. You will be notified directly by the Pennsylvania Housing
Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN
ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply
for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property
located at: 209 Mooredale Road, Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because:
3
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
(a) Monthly payment from 06/01/2013 thru 10/30/2013
(5 mos. at $955.93 /month) $4,779.65
(b) Late charges $191.16
(c) Other charges; Escrow, Inspec., NSF Checks:
(d) Other provisions of the mortgage obligation, if any
(e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $4,970.81
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $4,970.81 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's
check, certified check or money order made payable and sent to:
GREEN TREE SERVICING LLC
PO Box 94710
Palatine, IL 60094 -4710
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage
debt. This means that the entire outstanding balance of this debt will be considered due immediately
and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total
amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its
attorneys to start legal action to foreclose upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender brings legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender
even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which
may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY
period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
4
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at Lny time up to one hour before the Sheriffs Sale.
You may do so by pUing the total amount then past due plus any late or other charges then due
reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected
with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements
under the mortgage. Curing your default in the manner set forth in this notice will restore your
mortgage to the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6)
months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to
you before the sale. Of course, the amount needed to cure the default will increase the longer you wait.
You may find out at any time exactly what the required payment or action will be by contacting the
lender.
HOW TO CONTACT THE LENDER:
Name of Lender: GREEN TREE SERVICING LLC
Addre PO Box 94710
Palatine, IL 60094 -4710
Phone Number: 800 - 643 -0202
Fax Number: 866- 210 -6192
Contact Person: Collection Department
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the property after the
Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who
will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees
and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied.
5
YOU MAY ALSO HAVE THE RIGHT:
* TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
* TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
* TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT
HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
* TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
6
A Comprehensive Housing
AC 4:: -Y Counseling Agencies
Agencias de Consejo al Cliente para Vivienda
Cumberland County
*CCCS of Western PA - York
55 Clover Hill Road
Dallastown PA 17313
888.511.2227 / 888.511.2227
www.cccspa.org
Community Action Commission - Capital Region
1514 Derry St
Harrisburg PA 17104
717.232.9757
www. eactricounty.org
Harrisburg Fair Housing Council
2100 N 6th St
Harrisburg PA 17110
717.238.9540
Housing & Redevelopment Authority - Cumberland Cnty
114 N Hanover St; STE 104
Carlisle PA 17013
866.683.5907 / 717.249.0789
www.cchra.com
Pathstone Corporation Pennsylvania
1625 North Second St
Harrisburg PA 17102
717.234.6616
www.ruralisc.ora /r)athstone oa.htm
Pennsylvania Interfaith Community Programs, Inc.
40 E High St
Gettysburg PA 17325
717.334.1518
www.adamscha.org
NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. !
Report last updated: 4/30/2012 9:03:04 AM Page 1 of 11
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAI�tA
GREEN TREE SERVICING LLC
Plaintiff
vs. Case No. q- q
RANCK ALAN BYLER
JENNIFER L. BYLER'
Defendants)
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able
to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services
at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal
representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet
with that legal representative within twenty (20) days of the appointment date. During that meeting, you must
provide the legal representative with all requested financial information so that a loan resolution proposal can be
prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached
hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which
must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so
and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender
in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds
forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for
a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a
legal representative. However, you must provide your lawyer with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the
format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court,
which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an
attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submi d:'
(Signature of Counsel for I tiff)
1/22/2014
Date
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas locket #
BURROWER 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:
R/PRIMARY APPLICANT
Borrower name(s):
Property Address;
City: State: Zip:
Is the property for sale? Yes No Ej Listing elate: Price: $
Realtor Name: _ Realtor Phone:
Borrower Occupicd? Yes No
Mailing Address (if different)
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
BRIM;
#
of people in household: How long,
Mailing Address;
City: state Zip:
Phone ?plumbers: Home: Office:
Cell: Other:
Email:
## ofpeople in household: How long?
First Mortgage Lender:
Type of Doan:
Loan. Number mate You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary_Reason for Default:
is the loan in Bankruptcy? Yes 0 No El
If yes provide names, location of court, case number & attorney:
Assets A mount Owed Value:
{ether Real Estate.- $ �
.Retirement Funds: � $
Investments: $
Checking: $ $
Savings; $ r $
Other: $ $
Automobile #1 Model: Year:
Amount owed: Value-
Automobile-#2 Model: Year:
Amount owed: Value:
Other transportation (automobiles moats mptoMles) Model
'y'ear: Amount owed: Value
Montldy Income
Name of Employers:
I
2.
3.
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co Borrower Pay nays:
Monthly Ex enses: (Please only include expenses you are currently paying)
§2roMo rtgage NSE AMOUNT EXPENSE AMOUNT
Food
Utilities
a ont s Condo/Neigh. Fees
Auto Insurance Med. not covered
Auto fuel6re airs Other proe. payment
Install. Loan Pay ment Cable TV
Child Su WAlini, Spnding Mone
DaylChild Care/T'uit. Other Ex erases
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes 0 No E
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone.(Office): Fah:
ln�ail;
Have you made application for Homeowners Emergency Mortgage Assistance Program
(14EMAP) assistance?
Yes n 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 ycs, 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.
lAve, , authorize the above
named to use /refer this information to my lender /servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that l /we am/are under no obligation to use the services provided by the above
named
Borrower Signature Date
Ca Borrower Signature Date
Please forward this document along with the following informations to lender and
lender's counsel:
Y Proof of income
Past 2 bank statements
ti 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
{ (bardship letter)
V Listing agreement (if property is Currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson r ��� rC
Sheriff ` rr �1T !<<°:
Jody S Smith
. ,�t,!,: 1)1q.�F�s I Fi $ { I f 3
Chief Deputy _
Richard W Stewart
CUMBERLAND UUNTY
Solicitor PENNSYLVANIA
Green Tree Servicing, LLC
vs. Case Number
Ranck A. Byler(et al.) 2014-447
SHERIFF'S RETURN OF SERVICE
01/29/2014 09:40 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint&
Notice by handing a true copy to a person representing themselves to be Jennifer Byler, Wife, who
accepted as"Adult Person in Charge"for Ranck A. Byler at 209 Mooredale Roa , Di nson Township,
Carlisle, PA 17013.
LIAM CLINE, DEPUTY
01/29/2014 09:40 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint&
Notice by"personally" handing a true copy to a person representing themselves to •:' the Defendant, to
wit: Jennifer L Byler at 209 Mooredale Road, Dickinson Township, Carlisle, P, 175 .
L�
'1!" IAM CLINE, DEPUTY
SHERIFF COST: $50.78 SO ANSWERS,
ig 'c •-.7--
January 30, 2014 RONNY R ANDERSON, SHERIFF
In the Court of Common Pleas of Cumberland County
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
(Mortgagor(s) and Record Owner(s))
209 Mooredale Road .
Carlisle, PA 17013
Plaintiff
Defendant(s)
No. 14- 447CIVIL
C
C
C
w C)
p `F1
PRAECIPE FOR JUDGMENT r-)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECTED BT,)
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE.PUItPt)SE'
OF COLLECTING THE DEBT.
Enter the Judgment in favor of Plaintiff and against RANCK ALAN BYLER and JENNIFER L. BYLER by default
for want of an Answer.
Assess damages as follows:
Debt
Interest from 4/29/2014 to
Date of Sale per diem at $23.50
Total
$156,304.79
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
By: KML LAW GRgU , P. t.
Michael McKeev a. ID 56129
_Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
_Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
!_Jill P. Jenkins Pa. ID 3065887614,w
Andrew F. Gomall Pa. ID 92382
� � Attorneys for Plaintiff
-DV AND NOW v'"t l { +N , Judgment is e
GREEN TREE SERVICING LLC and against RANCK ALAN BYLER and-JENNIFER L. BY�L,. *FR
an Answer and damages assessed in the sum of $156,304.79 as per the above certifition.
avlA sllo
No W4
ed in favor of
ult for wan tl f,I
Prothonotary
Rule of Civil Procedure No. 236 — Revised
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
RANCK ALAN BYLER
JENNIFER L. BYLER
(Mortgagors and Record Owner(s))
209 Mooredale Road
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
VS.
Defendant(s)
No. 14-447CIVIL
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
David D. Buell
Prothonotary of Cumberland County
1 Courthouse Square
Prothonotary
B y: t
,a3 Carlisle, PA 17013 •
Deputy
If you have any questions concerning the above, please contact:
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
125786FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
RANCK ALAN BYLER
BYLER, RANCK ALAN
209 Mooredale Road
Carlisle, PA 17013
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102 Plaintiff
VS.
RANCK ALAN BYLER
JENNIFER L. BYLER
(Mortgagor(s) and Record Owner(s))
209 Mooredale Road
Carlisle, PA 17013
Defendant(s)
TO: RANCK ALAN BYLER
209 Mooredale Road
Carlisle, PA 17013
DATE OF THIS NOTICE: April 4, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14-447CIVIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A wRri 1EN 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 DALE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
By:
ICML LAW ' I , P.C.
Michael ' eever Pa. ID 56129
Lisa Lee Pa. la 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa ID 316160
Salvatore Filippello Pa. ID 313897
215-627-1322
Attorneys for Plaintiff
125786FC
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
TO:
JENNIFER L. BYLER
BYLER, JENNIFER L.
209 Mooredale Road
Carlisle, PA 17013
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102 Plaintiff
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
(Mortgagor(s) and Record Owner(s))
209 Mooredale Road
Carlisle, PA 17013
Defendant(s)
TO: JENNIFER L. BYLER
209 Mooredale Road
Carlisle, PA 17013
DATE OF THIS NOTICE: April 4, 2014
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
No. 14- 447CIVIL
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS
SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A
TIIDGMF:NT MAY RE ENTERED AGAINST YOTT WITHOUT A HEARING AND YOTT MAY T OSE YOTTR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717 - 243 -9400
By:
KML LAW GR I ', ..C.
Michael Mc ve Pa. ID 56129
Lisa Lee Pa. ID 78020
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
lyk L. Oflazian Pa. ID 312912 i alvatore Filippello Pa. ID 313897
����VV//// Jennifer Lynn Frechie Pa ID 316160
215- 627 -1322
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREEN TREE SERVICING LLC
Plaintiff
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
Defendant(s)
NO. 14- 447CIVIL
VERIFICATION OF NON - MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his /her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ( "DMDC ") website
operated by the United States Department of Defense ( https:// www. dmdc .osd.millappj /scra/scraHome.do)
for the following individual(s): RANCK ALAN BYLER, has a last known residence of 209 Mooredale
Road, Carlisle, PA 17013. The following information was used to search the DMDC (check all that
apply):
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A. 4904 relating to unsworn falsification to authorities.
Date
By:
KML LAW GROUP, P.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Salvatore Filippello Pa. ID 313897
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. 1D 312912
Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
Department of Defense Manpower Data Center
Results as of : Apr -28 -2014 12:29:31 PM
SCRA 3.0
Status Report
Pursuant to Servicerne abers Civil. Relief Act
Last Name: BYLER
First Name: RANCK
Middle Name: ALAN
Active Duty Status As Of: Apr -28 -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
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Da of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response
reflects where the individual left active duty s atus within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty.
v�.
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: 79E4L363C05CX40
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREEN TREE SERVICING LLC
Plaintiff
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
Defendant(s)
NO. 14- 447CIVIL
VERIFICATION OF NON - MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL
RELIEF ACT AS AMENDED
1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in
the above entitled matter, does hereby state to the best of his/her information and belief, as follows:
2. That an inquiry has been made with the Defense Manpower Data Center ( "DMDC ") website
operated by the United States Department of Defense ( https: / /www.dmdc.osd.mil/appj /scra/scraHome.do)
for the following individual(s): JENNIFER L. BYLER, has a last known residence of 209 Mooredale
Road, Carlisle, PA 17013. The following information was used to search the DMDC (check all that
apply):
X Last Name
X First Name
X Social Security Number
3. The DMDC search results, a copy of which is attached, states that based on the information
provided, the DMDC does not possess any information indicating that the individual is on active duty or
has been on active duty within the last 367 days.
The undersigned understands that the statements herein are made subject to penalties of 18 Pa.
C.S.A. 4904 relating to unsworn falsification to authorities.
By:
KML LAW GROUrI P C.
Michael McKe er Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jay Kivitz Pa. ID 26769
Andrew Gornall Pa. ID 92382
Joshua I. Goldman Pa. ID 205047
Salvatore Filippello Pa. ID 313 897
ill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
0cu
Department of Defense Manpower Data Center
Results as of : Apr -28 -2014 12:27:57 PM
SCRA 3.0
Status Report
Pursuant to Service-members Civil, Relief Acct
Last Name: BYLER
First Name: JENNIFER
Middle Name: L.
Active Duty Status As Of: Apr -28 -2014
On Active Duty On Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
NA
No
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or HislHer Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date
Order Notification Start Date
Order Notification End Date
Status
Service Component
NA
NA
No
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his /her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely- Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http: //www.defenselink.mil /faq /pis /PC09SLDR.html. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 59LDL303B059S30
KML Law Group, P.C.
Suite 5000 — BNY Independence Center
701 Market Street
Philadelphia, PA 19106
215- 627 -1322
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
(Mortgagor(s) and Record owner(s))
209 Mooredale Road
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14- 447CIVIL
ORDER FOR JUDGMENT
Please enter Judgment in favor of GREEN TREE SERVICING LLC, and against RANCK ALAN BYLER and
JENNIFER L. BYLER for failure to file an Answer in the above action within (20) days from the date of service of the
Complaint, in the sum of $156,304.79.
By:
KML LAW P.C.
P.C.
Michael McK er Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
1161/10fa. WWItte 316"2°
I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is
GREEN TREE SERVICING LLC 345 St Peter Street 1100 Landmark Towers St Paul, MN 55102 and that the name(s) and
last known address(es) of the Defendant(s) is /are RANCK ALAN BYLER, 209 Mooredale Road Carlisle, PA 17013 and
JENNIFER L. BYLER, 209 Mooredale Road Carlisle, PA 17013;
By:
KML L OUP, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
rP,C4ue 3lGlw
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 05/01/2013 through
04/28/2014
Reasonable Attorney's Fee
Late Charges
AND NOW, this
14- 447CIVIL/125786FC
day of
By:
$145,995.89
$8,467.74
$1,650.00
$191.16
$156,304.79
KML LAW GR$, P.C.
Michael McKeev Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
ftiA,Atfrir f%-2 v e pi(o
, 2014 damages are assessed as above.
W
PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106
215-627-1322
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers IN THE COURT OF COMMON PLEAS
St Paul,MN 55102
Plaintiff of Cumberland County
vs.
CIVIL ACTION—LAW
RANCK ALAN BYLER
JENNIFER L.BYLER ACTION OF MORTGAGE FORECLOSURE
Mortgagor(s)and Record Owner(s)
209 Mooredale Road
Carlisle,PA 17013 No. 14-447CIVIL
Defendant(s)
._,
CJ i r_.. G
PRAECIPE FOR WRIT OF EXECUTION Y w
`, ...+e. _.._
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
$156,304.79
Interest from
4/29/2014 to Date of
Sale per diem at
$23.50
(Costs to be added)
By: li
T KML LA OUP,P.C.
.� 02F Michael eever Pa.ID 56129
Jay E. Kivitz Pa.ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
r -�U David Fein Pa.ID 82628
a. Thomas Puleo Pa.ID 27615
Joshua I.Goldman Pa. 205047
Jill P.Jenkins Pa.ID 306588
Andrew F.Gornall Pa. ID 92382
Attorneys for Plaintiff
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All that certain parcel of land and improvements therein situate in the Township of
Dickinson, County of Cumberland, and Commonwealth of Pennsylvania, and designated
as Parcel No. 08-10-0626-023A and more fully described in a Deed dated March 6, 2003
and recorded March 13, 2003 in Cumberland County in Deed Book 256, Page 428,
granted and conveyed unto Ranck Alan Byler and Jennifer L. Byler, husband and wife.
MORE FULLY DESCRIBED AS:
ALL THAT CERTAIN tract or parcel of land and premises, situate,lying and being in the Township of
Dickinson,in the County of Cumberland,and the Commonwealth of Pennsylvania,more particularly
described as follows:
BEGINNING at an iron pin on the eastern side of Township Road T-466,known as the Mooredale Road,
said iron pin being 25 feet from a point in the center line of said Road, which said point is 527 feet,more or
less,south of the center line of Township Road T-465 measured along the center line of said Township
Road T-466;thence from said iron pin by land now or formerly of Timmothy David and Ann Cockrell
Stokes, South 82 degrees 43 minutes East 272.25 feet to an iron pin;thence by same South 7 degrees 15
minutes West 160 feet to an iron pin;thence by same North 82 degrees 45 minutes West 272.25 feet to an
iron pin on the eastern side of said road;thence by the eastern side of said road North 7 degrees 15 minutes
East 160 feet to an iron pin,the place of BEGINNING. CONTAINING 1.0 acre,more or less.
THE above description is in accordance with the Subdivision Plan for Jeanette E.Jones which is recorded
in the office of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Plan Book 30,page
59.
IMPROVEMENTS consist of a residential dwelling.
MUNICIPALITY Township of Dickinson
BEING PREMISES: 209 Mooredale Road,Carlisle,PA 17013
SOLD as the property of Ranck A. Byler and Jennifer L. Byler, husband and wife
TAX PARCEL#08-10-0626-023A
BEING the same premises which R. Alan Byler a/k/a Ranck Alan Byler by deed dated
3/6/2003 and recorded 3/13/2003 in Cumberland County in Deed Book Volume 256 at
Page 428 granted and conveyed unto Ranck Alan Byler and Jennifer L. Byler, husband
and wife.
KML Law Group, P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia,PA 19106 ,
215-627-1322
Attorney for Plaintiff J U E
GREEN TREE SERVICING LLC CO '
345 St Peter Street IN THE COURT OF COMPS ,,VLEAS
1100 Landmark Towers
St Paul, MN 55102 of Cumberland County
Plaintiff
vs.
CIVIL ACTION-LAW
RANCK ALAN BYLER
JENNIFER L. BYLER
(Mortgagor(s)and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE
209 Mooredale Road
Carlisle,PA 17013
Defendant(s)
No. 14-447CIVEL
AFFIDAVIT PURSUANT TO RULE 3129
GREEN TREE SERVICING LLC,Plaintiff in the above action,by counsel, KML Law Group,P.C.,sets forth as of
the date the praecipe for the writ of execution was filed the following information concerning the real property located at:
209 Mooredale Road
Carlisle,PA 17013
1.Name and address of Owner(s)or Reputed Owner(s):
RANCK ALAN BYLER
209 Mooredale Road
Carlisle,PA 17013
JENNIFER L. BYLER
209 Mooredale Road
Carlisle,PA 17013
2.Name and address of Defendant(s)in the judgment:
RANCK ALAN BYLER
209 Mooredale Road
Carlisle,PA 17013
JENNIFER L. BYLER
209 Mooredale Road
Carlisle,PA 17013
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O. Box 2675
Harrisburg,PA 17105-2675
4.Name and address of the last recorded holder of every mortgage of record:
BANK OF AMERICA,N.A.
c/o BAC,M/C:CA6-914-01-43
1800 Tapo Canyon Road
Simi Valley,CA 93063
5.Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
209 Mooredale Road
Carlisle,PA 17013
1 verify that the statements made in this affidavit are true and correct to the best of my information and belief.I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
By:
KML LAW GR P.C.
Michael McKeever Pa.ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa. ID 27615
Joshua I.Goldman Pa. 205047
Jill P.Jenkins Pa. ID 306588
Andrew F.Gornall Pa.ID 92382
Attorneys for Plaintiff
Atbo
14-447CIVIL
KMIL Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106
(215)627-1322
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street IN THE COURT OF COMMON PLEAS
1100 Landmark Towers
St Paul, MN 55102 of Cumberland County
Plaintiff
CIVIL ACTION-LAW
vs.
RANCK ALAN BYLER ACTION OF MORTGAGE
JENNIFER L. BYLER FORECLOSURE
Mortgagor(s) and Record Owner(s)
209 Mooredale Road
Carlisle,PA 17013
Docket No. 14-447CIVIL
Defendant(s�
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: BYLER,RANCK ALAN
RANCK ALAN BYLER
209 Mooredale Road
Carlisle,PA 17013
Your house at 209 Mooredale Road,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of$156,304.79 obtained by GREEN TREE SERVICING LLC against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to GREEN TREE SERVICING LLC,the back payments,
late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at
215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
14-447CIVIL
4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened,you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the
date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be
paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is
wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphjafed.orl4/foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
14-447CIVIL
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender(and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.gWx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
125786FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
14-447CIVfL
KML Law Group,P.C. ;
Suite 5000-BNY Independence Center
701 Market Street ` ' '_, 30
Philadelphia,PA 19106
(215)627-1322 t,
Nov,;'
i' n
Attorney for Plaintiff ` i'LVi
GREEN TREE SERVICING LLC
345 St Peter Street IN THE COURT OF COMMON PLEAS
1100 Landmark Towers
St Paul,MN 55102 of Cumberland County
Plaintiff
CIVIL ACTION-LAW
vs.
RANCK ALAN BYLER ACTION OF MORTGAGE
JENNIFER L. BYLER FORECLOSURE
Mortgagor(s)and Record Owner(s)
209 Mooredale Road
Carlisle, PA 17013
Docket No. 14-447CIVIL
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: BYLER,JENNIFER L.
JENNIFER L. BYLER
209 Mooredale Road
Carlisle,PA 17013
Your house at 209 Mooredale Road,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday,September 03,2014,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of$156,304.79 obtained by GREEN TREE SERVICING LLC against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to GREEN TREE SERVICING LLC,the back payments,
late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at
215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
14-447CIVIL
4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened,you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the
date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be
paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is
wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
r
14-447CIVIL
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender(and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.g_ov-for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention @kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
125786FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street ¢;
Philadelphia,PA 19106
215-627-1322 1 IN h if
`D ,
Attorney for Plaintiff E t ` S'i _VA141 r
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers IN THE COURT OF
St Paul,MN 55102 COMMON PLEAS
Plaintiff
vs. of Cumberland County
RANCK ALAN BYLER CIVIL ACTION-LAW
JENNIFER L. BYLER
Mortgagor(s) and Record Owner(s) ACTION OF
209 Mooredale Road MORTGAGE FORECLOSURE
Carlisle,PA 17013
Defendant(s)
NO. 14-447CIV IL
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
Plaintiff,by counsel,hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real
property in question is not subject to the Act.
By:
KML LAW P,P.C.
Michael McKe er Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa. ID 27615
Joshua 1. Goldman Pa. 205047
Jill P.Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
.1Ith Fir 31 b1�0
Of C
THE COURT OF COMMON PLEAS
_+ A, CUMBERLAND COUNTY PA
o Z DAVID D. BUELL,PROTHONOTARY
" ° One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717)240-6195
s o www.ccpa.net
GREEN TREE SERVICING LLC
Vs. NO 14-447 Civil Term
CIVIL ACTION—LAW
RANCK ALLEN BYLER
JENNIFER L.BYLER
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: $156,304.79 L.L.: $.50
Interest FROM 4/29/2014 TO DATE OF SALE PER DIEM AT$23.50
Atty's Comm: Due Prothy: $2.25
Atty Paid: $199.53 Other Costs:
Plaintiff Paid:
Date: 4/30/2014 ���
David D. Buell,Prothonotary
(Sall) By: *aejL�
Deputy
REQUESTING PARTY:
Name: JENNIFER FRECHIE,ESQUIRE
Address: KML LAW GROUP,P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No.316160
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
FILED -OFFICE
j hL. Pi OTNONOTAr I
2Bit, AUG -5 AM 10: 314
CUMBERLAND COUNTY
PENNSYLVANIA
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER and JENNIFER L. BYLER
209 Mooredale Road
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
No. 14-447CIV1L
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
MOTION FOR SUBSTITUTED SERVICE
UNDER PA.R.C.P. 430(a)
Plaintiff, by and through its attorney, in support of its Motion for Substituted Service,
represents as follows:
1. Plaintiff is the holder of a mortgage upon the premises 209 Mooredale Road, Carlisle,
PA, 17013, hereinafter, the "mortgaged premises".
2. Defendants, RANCK ALAN BYLER and JENNIFER L. BYLER, are the mortgagors and
real owners of the mortgaged premises.
3. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, Alyk
Oflazian, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify
that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion,
it was not possible to locate or contact the Defendant to request his concurrence.
4. The last known addresses of Defendant, Ranck Alan Byler, are 700 Salem Road Trailer
6, Etters, PA 17319 and 209 Mooredale Road, Carlisle, PA 17015 from our investigative search.
5. The Sheriff has been unable to effect service of the Notice of Sale upon Defendant,
Ranck Alan Byler. Service was attempted on Defendant, Ranck Alan Byler at the mortgaged premises
209 Mooredale Road, Etters, PA 17319. The return of service indicates several attempts were made
without any response however notices left were removed. Service was attempted on Defendant, Ranck
Alan Byler at 700 Salem Road, Trailer 6, Etters, PA 17319. The return of service indicates several
attempts were made without any response however notices left were removed.
6. The following investigation was conducted in a good faith attempt to ascertain the
whereabouts of Defendant, Ranck Alan Byler.
WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff
to serve the Notice of Sale upon Defendant, Ranck Alan Byler, by posting the premises and certified and
regular mail to the Defendant's last known address.
By:
KML LAW CROUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David. Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
kA1yk Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
Affldavit of Good Faith Investigation
At the request of the law firm ide Ufiudbelow|hnihutedmninvouUgaUoninto0he whereabouts of the
defendant identified as the subject below. The foliowing is true and accurate representatiori of my
investigation.
Client provided information: File Number: 125786FC
Attomey/Law Firm: KML LAW GROUP, P.C.
Subject Name: RANCKALAN BYlER
Property Address: Street: 209 Mooredale Road
City: Carlisle State: PA
Zip: 17013
Skip Results: Date of Birth: 1971
Last Known Address (as of 7/8/2014) Street: 70OSalem RdTdr6
City: Etters State: PA
ProVest File Number: 4030519
Zip: 17319 9538
Death Record Search
As of 07/08/2014, the Social Security Administration has no death
record on file for Ranck Alan Byler
Social Security Number
[X]VnhAed[]Not Verified G3N#XXKXX-XX78
Employment Search
ing a search for emplent of our defendant no current em|oymmnt
information was provided prior to the investigation or found during the
Investigation.
Business Records Search
No verifiable business records tound.
Creditor Header lnquiry
The latest address from the credit header info is:
Address: 209 MOOREDALE RD, CARLISLE, PA 17015 9456
Department of Motor
Vehicle Records Search
Unabe to obtain Motor Vehicle Records in the State of Pennsylvania.
Drlvers Ucense lnformation Search
[1 Govemmental"+
[X] Non-govemmental
No verifiable information.
Professional Licenses Search
No records found.
Freedom Of Information Act Inquiry
Made to U.S. Postal Service
The following addresses were sent to the United States Postal
inspector at the zip code listed with no return information to date:
POBOX G241NEW CUMBERLAND 1PA{17O7O08241
CUMBERLAND
POBOX 1322{/NECHAN(CSBURG1PA/17U561322/
CUMBERLAND
209 MOOREDALE ROAD | CARLISLE )PA\17O131CUMBERLAND
COUNTY
Military Search
Not on Active Duty; Did not leave Active Dwithin the past 367days;
Has not been notified ofafuture call up to Active Duty
Inquiry of Relatives,
Neighbors, & Friends
717'24S-7G95:Spoke with possible neighbor, William Walker, does not
know defendant.
717-249-6837: Spoke with possible neighbor, Dennis Schmohl, does
not know defendant.
Comments:
•
717'258'GO85(Nobi|a):Called number listed todefendant, Rannh
Byler, number has been disconnected.
A search of Federal Bureau of Prisons resulted in no records for our
defendant.
A search of Penns | i Department of Corrections resufted in no
records for our defendant.
Our defendant was not found to be currently incarcerated searching
Pennsylvania County Jails.
A search of Philadelphia Prison Systems resulted in no records for our
defendant.
Additional address reporting current is 700 Salem Rd TrIr 6, Etters, PA
17319.
* Data not available in AL, AR, CA, HI, NH, OR, PA, VA, WA.** Historical data in CO, DE, ID, IL, KY, LA, MD, MA, MS, MO, NH, ND,
SC, WV.
+ Data available in CO, CT, DE, FL, ID, IL, KY, LA, ME, MD, MA, MI, MN, MS, MO, NH, ND, OH, SC, TN, TX, WV, WI, WY.
The foregoing statement is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A.
§4904 relating to unswom falsification to authorities. Under penalties of perjury, I declare that I have read the foregoing affidavit and
that the facts stated in it are true.
ylLiguivra- 1-teitiNurcip_
ianna Hemandez ProVest File Number: 403
STATE OF FLORIDA
COUNTY OF HILLSBOROUGH JUL Q 8 ?014
Sworn to or affirmed and signed before me on this _ day o
Provest Services LLC (Seal)
Date: 0''11 O `2,(3 t �1
JOSHUA N. PIMENTEL
Notary Public, State of Florida
My Comm. Expires May 24, 2015
No. EE 97050
Printed Name of Notary Public
(ZQPersonally Known
( ) Produced as identification
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
GREEN TREE SERVICING LLC; et seq.
Plaintiff (Petitioner)
V.
RANCK ALAN BYLER; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 14-447CIVIL
Sheriffs Sale Date: 9/3/2014
AFFIDAVIT OF NON -SERVICE
❑ Complaint ❑ Summons 0 Other: NOTICE OF SALE
I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I
attempted to serve RANCK ALAN BYLER the above process on the 22 day of May, 2014, at 2:24 o'clock, PM, at 209 MOOREDALE ROAD CARLISLE,
PA 17013 , County of Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
Defendant was not served because: 0 Moved 0 Unknown 0 No Answer 0 Vacant
0 Other: NO ANSWER AT PROPERTY, CARD LEFT ON PROPERTY DOOR WAS REMOVED WITH NO RESPONSE TO ARRANGE FOR
SERVICE.
Service was attempted on the following dates/times:
1) 5/18/14 7:13 PM 2) 5/21/14 7:31 AM 3) 5/22/14 2:24 PM
Commonwealth/State of fS )
) SS:
County of hip•ati )
Before me, the undersigned notary public, this day, personally, appeared
duly sworn according to law, deposes the following:
I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Non -Service are true and correct.
(Signature of Affiant)
File Number:125786FC
Case ID #:3983341 Notary Public
to me known, who being
Subscribed and sworn to be ore me
this 1" day of ,Jk. a 720 "1 .
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Eric M. Afflerbach, Notary Public
Washington Township, Berks County
My Commission Expires November 18, 2017
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
GREEN TREE SERVICING LLC; et seq.
Plaintiff (Petitioner)
V.
RANCK ALAN BYLER; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 14-447CIVIL
Sheriffs Sale Date: 9/3/2014
AFFIDAVIT OF NON -SERVICE
❑ Complaint ❑ Summons Q Other: NOTICE OF SALE
I, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I
attempted to serve RANCK ALAN BYLER the above process on the 21 day of July, 2014, at 7:50 o'clock, AM, at 700 Salem Rd Trlr 6 Etters, PA 17319
9538 , County of Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
Defendant was not served because: 0 Moved 0 Unknown 0 No Answer ❑ Vacant
❑d Other: NO ANSWER AT PROPERTY, CARD LEFT TO ARRANGE FOR SERVICE WAS REMOVED WITH NO RESPONSE.
Service was attempted on the following dates/times:
1) 7/11/14 1:32 PM 2) 7/16/14 6:47 PM 3) 7/21/14 7:50 AM
Commonwealth/State of 10a
) SS:
County of 8• • re a )
Before me, the undersigned notary public, this day, personally, appeared
duly sworn according to law, deposes the following:
ir«
C. oft
I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Non -Service are true and correct.
(Signature of Affiant)
File Number.125786FC
Case ID #:4033227
Subscribed and sworn to be
this Za day of
to me known, who being
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Eric M. A.ffierbach, Notary Public
Washington Township, Berks County
my Commission Expires November 16, 2017
Notary Public
KML Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102"
vs.
RANCK ALAN BYLER and JENNIFER L. BYLER
209 Mooredale Road
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
No. 14-447C1VIL
MEMORANDUM OF LAW IN SUPPORT OF MOTION
FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a)
Plaintiff has filed a Notice of Sheriff s Sale against Defendant, Ranck Alan Byler, which
the Sheriff has been unable to personally serve upon Defendant, Ranck Alan Byler. As noted in the
attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without
success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a).
CONCLUSION
For reasons stated above and in the attached Motion, the Court should enter an order
allowing Plaintiff to serve the Notice of Sheriff s Sale upon Defendant, Ranck Alan Byler, by posting the
premises and certified mail and regular mail to the Defendant's last known address.
By:
KML LAW GROUP, P.C.
Michael McKeever Pa. ID 56129
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Jill P. Jenkins Pa. ID 306588
XAlyk Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
Attorneys for Plaintiff
KA/IL Law Group, P.C.
Suite 5000 - BNY Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
209 Mooredale Road
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
of Cumberland County
No. 14-447C1VIL
CERTIFICATE OF SERVICE
Marlene Powers, an employee of KML Law Group, P.C., counsel for plaintiff, does
hereby certify that true and correct copies of the foregoing Motion for Substituted Service have
been served upon the Defendants, Ranck Alan Byler and Jennifer L. Byler this Lay of
August 2014, by first class mail, postage prepaid.
RANCK ALAN BYLER
700 Salem Road
Trlr 6
Etters, PA 17319
RANCK ALAN BYLER
209 Mooredale Road
Carlisle, PA 17013
By:
JENNIFER L. BYLER
700 Salem Road
Trlr 6
Etters, PA 17319
JENNIFER L. BYLER
209 Mooredale Road
Carlisle, PA 17013
KML Law Group, P.C.
Marlene Powers, Legal Secretary
Direct Phone: 215-825-6340
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER and JENNIFER L. BYLER
209 Mooredale Road
Carlisle, PA 17013
AND NOW, this
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
n �., curry
14-447CIV1L
3 r ---t
rri _°w ▪ =-,
rn--
a `.. `�a
cr> r—
r�- • - ,
ORDER z �=v,
.s.
/ day of /dim— 2014, upon consideration of the Plaiiffs7
I -71
Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant, Ranck Alan Byler, have been
unsuccessful, it is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of
Sheriff's Sale upon Defendant, Ranck Alan Byler, by posting a copy of the Notice upon the premises 209
Mooredale Road, Carlisle, PA, 17013, and Plaintiff is directed to serve the Notice of Sheriff Sale by
certified and regular mail to the Defendant's last known addresses at 700 Salem Road Trailer 6, Etters,
PA 17319 and 209 Mooredale Road, Carlisle, PA 17015, and that all further service of legal papers,
including but not limited to motions, petitions and rules be made by certified and regular mail to
Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil
Procedure 3129 may be made upon Defendant, Ranck Alan Byler, by sending copies of same to
Defendant's last known addresses by certified and regular mail and by posting the premises. Service is
complete upon mailing.
BY THE COURT:
167
J.
Dyibution list:
Michael T. McKeever, Esquire, Suite 5000 — Y Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
RANCK ALAN BYLER, 700 Salem Rd. Trlr 6 Etters, PA 17319
e? ►
E3)I/1y41 -
N
KML LAW GROUP, P.C.
`Suite 5u00 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
Mortgagor(s) and Record Owner(s)
209 Mooredale Road
Carlisle, PA 17013
Defendant(s)
Plaintiff
F I .ED -O F IL; ;.
t!; SHE PROTHONO T;\H
2f111 A JG 27 Phi 20
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 14-447C1V1L
Book:
Writ:
NOTICE OF THE DATE OF CONTINUED SHERIFF'S SALE
The Sheriff's Sale scheduled for September 03, 2014 at 10:00 AM in the above matter has been continued
until October 01,2014 at 10:00 t
Date: 9
By:
K) L 1 AW GROUP, P.C.
70 M rket Street, Suite 5000
Philadelphia, PA 19106
(215) 825-6332
Michael McKeever Pa. ID 56129
David Fein Pa. ID 82628
Jill P. Jenkins Pa. ID 306588
Alyk L. Oflazian Pa. ID 312912
Salvatore Filippello Pa. ID 313897
/Jennifer Lynn Frechie Pa. ID 316160
Attorneys for Plaintiff
KML. LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
Mortgagor(s) and
Record Owner(s)
209 Mooredale Road
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
CERTIFICATE OF FILING
Term
No. 14-447CIVIL
Book:
Writ:
I hereby certify that matter was filed or sent for filing with the prothonotary and was served the Notice of
Continued Sheriff's Sale in the above upon the following parties on the date listed below:
RANCK ALAN BYLER
209 Mooredale Road
Carlisle, PA 17013
JENNIFER L. BYLER
700 Salem Rd.
Trlr 6
Etters, PA 17319 defendant(s)
SHERIFF OF CUMBERLAND COUNTY
Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
(via facsimile or e-mail)
PROTHONOTARY OF CUMBERLAND COUNTY
Prothonotary of Cumberland County
1 Courthouse Square
Carlisle, PA 17013
(via e -filing if applicable)
Date: 695-0207e7 By:
KML LAW GROUP, P.C.
701 Market Street, Suite 5000
Philadelphia, PA 19106
(215) 825-6332
Veronica Cosme
KML LAW GROUP, P.C.
Suite 5000
BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1 100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
Mortgagor(s) and
Record Owner(s)
209 Mooredale Road
Carlisle, PA 17013
Plaintiff
Defendant(s)
UF THE PF?0 ONO !A2014
SEP f 7 Pt; 2: 12
CUMBER PENN3Y'v4N( IFI E
1.25786FC
CF: 01/24/2014
SD: 10/01/2014
$156,304.79
COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION — LAW
ACTION OF MORTGAGE FORECLOSURE
Term.
No. 14-447CIV1L
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Andrew Hauck, an employee of KML Law Group, P.C., counsel of Plaintiff, hereby certifies that service
on the Defendants of the Notice of Sheriff Sale was made by:
()
(X)
( )
( )
( )
()
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
(X) Premises was posted by Sheriffs Office/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
(X) Certified Mail & ordinary mail by KML Law Group, P.C. (copy of receipt(s) for Certified Mail
attached).
( ) Published in accordance with court order (copy of publication attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by
ordinary mail KML Law Group, P.C. (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A.
Section 4904.
Personal Service by the Sheriffs Office/competent adult (copy of return attached).
Certified mail by KML Law Group, P.C. (copy of green Postal return receipt attached).
Certified mail by Sheriffs Office.
Ordinary mail by KML Law Group, P.C. to Attorney for Defendant(s) of record (proof of mailing
attached).
Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached).
Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record.
Resp-ctfully submitted,
BY: Andrew Hauck
Legal Assistant
GREEN TREE SERVICING LLC •
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
VS.
RANCK ALAN BYLER and JENNIFER L. BYLER
209 Mooredale Road
Carlisle, PA 17013
ORDER
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
c)
C:=3
ni
z
14-147CWL2
<cJ C.)
Cil
AND NOW, this /41k -day of 2014, upon consideration of the Plaintiffs
Motion for Substituted Service under Pa.RC.P. 430(a) and it appearing to the Court that Plaintiffs good
faith efforts to ascertain the present whereabouts of Defendant, Ranck Alan Byler, have been
unsuccessful, it is,
ORDERED and DECREED:
that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Notice of
Sheriff's Sale upon Defendant, Ranck Alan Byler, by posting a copy of the Notice upon the premises 209
Mooredale Road, Carlisle, PA, 17013, and Plaintiff is directed to serve the Notice of Sheriff Sale by
certified and regular mail to the Defendant's last known addresses at 700 Salem Road Trailer 6, Etters,
PA 17319 and 209 Mooredale Road, Carlisle, PA 17015, and that all further service of legal papers,
including but not limited to motions, petitions and rules be made by certified and regular mail to
Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil
Procedure 3129 may be made upon Defendant, Ranck Alan Byler, by sending copies of same to
Defendant's last known addresses by certified and regular mail and by posting the premises. Service is
complete upon mailing.
BY TBE COURT:
PI 40 -k -a ILLs
Distribution list:
Michael T. McKeever, Esquire, Suite 5000 — BNY Independence Center, 701 Market Street,
Philadelphia, PA 19106-1532
RANCK ALAN BYLER, 700 Salem Rd. Trlr 6 Etters, PA 17319
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA
GREEN TREE SERVICING LLC; et seq.
Plaintiff (Petitioner)
V.
RANCK ALAN BYLER; et al.
Defendant (Respondent)
CASE and/or DOCKET No.: 14-447CIVIL
Sheriff's Sale Date: 9/3/2014
AFFIDAVIT OF SERVICE
❑ Complaint [(Summons 0 Other: NOTICE OF SALE
1, KEVEN CHASE, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party , and that I
served RANCK ALAN BYLER the above process on the 23 day of August, 2014, at 3:13 o'clock, PM, at 209 MOOREDALE ROAD CARLISLE, PA
17013 , County of Cumberland, Commonwealth of Pennsylvania:
Manner of Service:
Q By posting a copy of the original process on the most public part of the property pursuant to an order of court
Service was attempted on the following dates/times:
1) 2) 3)
Commonwealth/State of Pa,
) SS:
County of Qs. ro ,
Before me, the undersigned notary public, this day, personally, appeared kave.e4 G>" •a c
duly sworn according to law, deposes the following:
I hereby swear or affirm that the facts set forth in the foregoing Affidavit of Service are true and correct.
Aeu. 2-44—
(Signature of Affiant)
File Number:I25786FC
Case ID #:4072669 Notary Public
to me known, who being
Subscribed and o Before me
this Zr day of , 20// .
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Eric M. Afflerbach, Notary Public
Washington Township, Berks County
My Commission Expires November 18, 201 7
UNITED STATES
POSTAL SERVICE
Date: July 18, 2014
kalilah osei:
The following is in response to your July 18, 2014 request for delivery information on
your Certified MaiITM item number 9171999991703431212140. The delivery record
shows that this item was delivered on July 14, 2014 at 12:17 pm in ETTERS, PA 17319.
The scanned image of the recipient information is provided below.
Delivery Section
Signature of Recipient :
Address of Recipient :
c ,•• 1. -or.
17oo -01, 4
Thank you for selecting the Postal Service for your mailing needs.
If you require additional assistance, please contact your local Post Office or postal
representative.
Sincerely,
United States Postal Service
Name and Address of Sender
:ML LAW GROUP, P.C.
iUITE 5000
'Ol MARKET STREET
' HILADELPHIA, PA
HILA532
Check type of mail or service;
ED Certified ❑ Recorded Delivery (International)
❑ COD ❑ Registered
❑ Delivery Confirmation ❑ Return Receipt for Merchandise
❑ Express Mail El Signature Confirmation
❑ Insured
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional copies '
of this bill)
Postmark and
Date of Receipt
Article Number
Addressee (Name, Street, City, State, & ZIP Code)
Postage
Fee
Handling
Charge
Actual Value
if Re istered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
SH
Fee
RD
Fee
Rq
Fee
1 •
DOMESTIC RELATIONS OF CUMBERLAND
COUNTY
PO Box 320
Carlisle, PA 17013
BANK OF
c/o BAC
1800 Tapo
Simi Val
AMERICA,
M/C: CA6-914-01-43
Canyon
ey, CA 93063
N.A.
Road
2.
a` y
PA DEPARTMENT OF PUBLIC WELFARE -
Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
TENANTS/OCCUPANTS
209 Mooredale
Carlisle,
Road
PA 17013;
i,:it t,.• =•
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Ca U.S. POSTAGE»
- - (/ /^
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0001391829
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j//
See Privacy Act Statement on Reverse
PS Form 3877,Faar r�2002 (Page 1 of 2)
Complete by Typewriter, Ink, or Ball Point Pen
125786FC Cumberland County Sale Date: 09/03/2014
RANCK ALAN BYLER & JENNIFER L. BYLER
S
Name and Address of Sender
ML LAW GROUP, P.C.
UITE 5000
J1
31 A MARKETESTREET A
HILA532
106-10
Check type of mail or service;
❑ Certified ❑ Recorded Delivery (International)
0 COD 0 Registered
0 Delivery Confirmation ❑ Return Receipt for Merchandise
❑ Express Mall 0 Signature Confirmation
Insured
Affix Stamp Here
(If issued as a
certificate of mailing,
or for additional copies
of this bill)
Postmark and
Date of Receipt
Article Number
Addressee (Name, Street City, State, & ZIP Code)
Postage
Fee
Handling
Charge
Actual Value
if Registered
Insured
Value
Due Sender
if COD
DC
Fee
SC
Fee
,:H
=ee
RD
Fee
RR
Fee
1.
BYLER, RANCK ALAN
209 Mooreda/e Road
Carlisle, PA 17013
BYLER,
700 Salem
Trlr 6
Etters,
RANCK ALAN
Rd.
PA 17319
:. .
. -'• U.S.
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001.391829
POSTAGE)»PITNEY
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See Privacy Act Statement on Reverse
PS Form 3877, February 2002 (Page 1 o 2)
125786FC Cumberland CLunty
RANCK ALAN BYLER & JENNIFER L.
Complete by Typewriter, Ink, or Ball Point Pen
Sale Date: 09/03/2014
BYLER
Print Your Documents
USPS Manifest Mailing System
Page 4 of 5
Page 4
Mailers Name & Address
KML Law Group
701 Markel Street
Suite 5000
Philadelphia, PA 19106
Permit Number
123
MAC Ver. Number
Connect5hip Progistics 6.5
Sequence Number
2453-2
Class of Mail
Mixed
Article
Piece ID
Addressee Name
Delivery Address
ES
Type Postage
ES
Fee
Insurance
Amount
Due/
Sender
Total
Charge
NORSTMAN, ANNA MARIE .-411!rt ANNA HORST MAN 0.480
9171999991703430285817 314 Roseberry Siseet ERR,
Philadelphia, PA 19148 C 3.30
1,35
CORSELLO. MICHAEL P. 0.480
9171999991703430285824 1222 Edinburg Circle ERR 1.35
New Cumberland, PA 17070 C 3.30
BROOKS, MARY 0.480
9171999991703430285831 5532 Addison Street ERR 1.35
Philadelphia, PA 19143 C 3.30
GERLACH. JENNIFER M. 0.480
9171999991703430285848 3628 6th Ave. ERR. 1.35
Altoona, PA .16602 C 3.30
SMITH, KEVIN 0.480
9171999991703430285855 7377 Rugby Street ERR
Philadelphia. PA 19130
COX, SUSAN 0.480
9171999991703430285862 114 Wein Street ERR
Philadelphia, PA 19148
1.35
3.30
1.35
3,30
MURRAY, III, IRA R. 0.480
9171.999991703430285879 1431 North Felton Street 'ERR 1.35
Philadelphia, PA 19151 C 3.30
SINGLETON, LESLIE M. 0.480
9171999991703430285886 2209 North Salford Street ERR
Philadelphia, PA 19131
1.35
3.30
SABATO. MICHAEL 0.480
9171999991703430285893 2069 Margaret Street ERR 1.35
Philadelphia, PA 19124 C 3.30
SABATO. MICHAEL 0.480
9171999991703430285909 119 Haines Avenue ERR
Elkins Park. PA 19027
BYLER, RANCK ALAN 0.480
9171999991703430285916 209 Mooredale Road ERR
Carlisle, PA 17013 C
1.35
3.30
1.35
3,30
BYIER, RANCK ALAN 0.480
71999991703430285923 700 Salem Rd, ERR J:35
Tdr 6 C 3.30
Otters, PA 17319
5.13
5.13
5.13
5.13
5.13
5.13
5.13
Page Totals 12 5.76 55.80 61.56
Cumulative Totals 48 23.04 223.20 24624
http://pbpc/sendsuite%2Olive/projects/image.aspx?pd=1 8/25/2014
KML LAW GROUP, P.C.
Suite 5000 — BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
GREEN TREE SERVICING LLC
345 St Peter Street
1100 Landmark Towers
St Paul, MN 55102
vs.
RANCK ALAN BYLER
JENNIFER L. BYLER
Mortgagor(s) and Record Owner(s)
209 Mooredale Road
Carlisle, PA 17013
Defendant(s)
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Tenn
No. 14-447C1VIL
AFFIDAVIT PURSUANT TO RULE 3129
GREEN TREE SERVICING LLC, Plaintiff in the above action, by and through an authorized employee
of its attorneys, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed
the following information concerning the real property located at:
209 Mooredale Road
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
RANCK ALAN BYLER
209 Mooredale Road
Carlisle, PA 17013
JENNIFER L. BYLER
700 Salem Rd.
Trlr 6
Etters, PA 17319
2. Name and address of Defendant(s) in the judgment:
RANCK ALAN BYLER
209 Mooredale Road
Carlisle, PA 17013
JENNIFER L. BYLER
700 Salem Rd.
Tilt -6
Etters, PA 17319
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
BANK OF AMERICA, N.A.
do BAC, MIC: CA6-914-01-43
1800 Tapo Canyon Road
Simi Valley, CA 93063
5. Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale.
TENANTS/OCCUPANTS
209 Mooredale Road
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
DATED: September 15, 2014
KML Law Group, P.C.
BY: Andrew Hauck
Legal Assistant
SHERIFF'S OFFICE OF CUMBERLAND.. COUNTY
i
w
Sheriff F\',:St, i‘f
Ronny R Anderson
OFFICES1.ESJTEE' �jS�ViiiP
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Green Tree Servicing, LLC
vs.
Ranck A. Byler (et al.)
Case Number
2014-447
SHERIFF'S RETURN OF SERVICE
06/17/2014 02:23 PM - Deputy William Cline, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 209 Mooredale Road, Carlisle, PA 17013, Cumberland
County.
07/03/2014 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: Jennifer L. Byler, but was unable to locate the Defendant in
his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ,
Notice and Description, in the above titled action, according to law.
07/03/2014 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: Ranck A. Byler, but was unable to locate the Defendant in
his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ,
Notice and Description, in the above titled action, according to law.
07/03/2014 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: Ranck A. Byler, 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 209 Mooredale Road, Carlisle, PA 17013, address is vacant, defendant left
forwarding address with post office of: 700 Salem Road, Trailer 6, Etters, PA 17319. cab.
07/03/2014 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: Jennifer L. Byler, 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 209 Mooredale Road, Carlisle, PA 17013, address is vacant, defendant left
forwarding address with post office of: 700 Salem Road, Trailer 6, Etters, PA 17319. cab.
08/12/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of York County upon Ranck A. Byler, personally, at 700 Salem Road, Trailer 6, Etters, PA 17319 on
7/11/14 at 1827 hrs. So Answers: Corey Strine, Deputy Sheriff.
08/12/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff
of York County upon Ranck A. Byler, Husband who accepted for Jennifer L. Byler, at 700 Salem Road,
Trailer 6, Etters, PA 17319 on 7/11/2014 at 1827 am. So Answers: Corey Strine, Sheriff.
08/25/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014
10/01/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on October 01, 2014 at 10:00 a.m.
He sold the same for the sum of $1.00 to Attorney Michael McKeever on behalf of Federal National
Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of $
SHERIFF COST: $1,304.81
October 08, 2014
ifg'90o fd -
,sD Li --
40,4
c) C.ourityStxt9 S'leriff. 7eleosaft Inc.
,Lf- 3 iaff
SO ANSWERS,
RONNIS' R ANDERSON, SHERIFF
LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14
Writ No. 2014-447 Civil
GREEN TREE SERVICING, LLC
vs.
RANCK A. BYLER
Jennifer L. Byler
Atty.: Michael McKeever
All that certain parcel of land and
improvements therein situate in the
Township of Dickinson, County of
Cumberland, and Commonwealth of
Pennsylvania, and designated as Par-
cel No. 08-10-0626-023A and more
fully described in a Deed dated March
6, 2003 and recorded March 13, 2003
in Cumberland County in Deed Book
256, Page 428, granted and conveyed
unto Ranck Alan Byler and Jennifer
L. Byler, husband and wife.
MORE FULLY DESCRIBED AS:
ALL THAT CERTAIN tract or par-
cel of land and premises, situate,
lying and being in the Township of
Dickinson, in the County of Cum-
berland, and the Commonwealth
of Pennsylvania, more particularly
described as follows:
BEGINNING at an iron pin on the
eastern side of Township Road T-466,
known as the Mooredale Road, said
iron pin being 25 feet from a point in
the center line of said Road, which
said point is 527 feet, more or less,
south of the center line of Township
Road T-465 measured along the cen-
ter line of said Township Road T-466;
thence from said iron pin by land
now or formerly of Timothy David
and Ann Cockrell Stokes, South 82
degrees 43 minutes East 272.25 feet
to an iron pin; thence by same South
7 degrees 15 minutes West 160 feet
to an iron pin; thence by same North
82 degrees 45 minutes West 272.25
feet to an iron pin on the eastern side
of said road; thence by the eastern
side of said road North 7 degrees 15
minutes East 160 feet to an iron pin,
the place of BEGINNING. CONTAIN-
ING 1.0 acre, more or less.
THE above description is in ac-
cordance with the Subdivision Plan
for Jeanette E. Jones which is re -
27
corded in the office of the Recorder
of Deeds in and for Cumberland
County, Pennsylvania in Plan Book
30, page 59.
IMPROVEMENTS consist of a
residential dwelling.
MUNICIPALITY Township of Dick-
inson.
BEING PREMISES: 209 Mooredale
Road, Carlisle, PA 17013.
SOLD as the property of Ranck A.
Byler and Jennifer L. Byler, husband
and wife.
TAX PARCEL # 08-10-0626-023A.
BEING the same premises which
R. Alan Byler a/k/a Ranck Alan
Byler by deed dated 3/6/2003 and
recorded 3/13/2003 in Cumberland
County in Deed Book Volume 256
at Page 428 granted and conveyed
unto Ranck Alan Byler and Jennifer
L. Byler, husband and wife.
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.
ari`e Coyne, Editor
SWORN TO AND SUBSCRIBED before me this
da of July, 2014
Notary
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE 80RO., CUMBERLAND CNTY
My Commission Expires Apr 28, 2018
''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
patriogews
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.
at iRLICATION C PY
014.447 Civil Term
GRE TREE SERVICING, LC
vs.
RANCK A. BYLER
Jennifer L Byler
Atty: Michael McKeever
All that certain parcel of land and
improvements therein situate in the
Township of Dickinson, County of 3
Cumberland, and Commonwealth
of Pennsylvania, and designated as t
Parcel No. 08-10-0626-023A and more I
fully described in a Deed dated March
6, 2003 and recorded March 13, 2003
M Cumberland County in Deed Book
256, Page 428, granted and conveyed
unto Ranck Alan Byler and Jennifer
L. Byler, husband and wife.
MORE FULLY 1QESCRJBED AS:
ALL THAT CERTAIN tract or parcel
of land and premises, situate, lying and
This ad ran on the date(s) shown below:
07/13/14
07/20/14
07/27/14
Sworn to ands bscribed before me this 20 day of August, 2014 A.D.
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL 1
Sheryl Marie Leggore, Notary Public 1
Hampden Twp., Cumberland County I
My Commission Expires July 16, 2018
EMCER, PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
} SS:
I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the
Sheriff's Deed in which Federal National Mtg Assoc is the grantee the same having been sold to said
grantee on the 1st day of October A.D., 2014, under and by virtue of a writ Execution issued on the 30th
day of April, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2014
Number 447, at the suit of Green Tree Ser LLC against Ranck Alan & Jennifer L Byler is duly recorded
as Instrument Number 201424915.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 3o
, A.D.,9� f
6. 7441
day of
Recorder of Deeds
Reeder of Deeds, Cumberland County, Carlisle, PA
My ommission Expires the First Monday of Jan. 2018