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Home My WebLink About14-0981 r For Prothonotary Use Only: Swprem a Court. f P�e:nn$yIvanIa. Co ail Edo Ire n Pleas t'_ i!w, `het . ��Illt� I' and Docket No. unity The ii7formation collected on this_forni is used solely court administration purposes. This form does trot supplement or replace lace the tlin and service of leadin s or other papers as required by Icnv or rules of court. Commencement of Action: j N Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E . Lead Plaintiffs Name: U.S. Bank National Association, as Indenture Lead Defendant's Name: Deirdre A. Nowak C Trustee, successor in interest to Bank of America, National Association, as T Indenture Trustee, successor by merger to LaSalle Bank National I Association, as Indenture Trustee for AFC Trust Series 1999 -2 I I O Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits N (check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No Name of Plaintiff/Appellant's Attorney: McCabe, Weisberg & Conway, P.C. ❑ Check here if you have no attorney (a Self - Represented [Pro Se] Litigant) f Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. Ifyou are making more than one type of claim, check the one that you consider most important. 4 TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Department of Transportation ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) E ❑ Slander/Libel/ Defamation ❑ Employment Dispute: ❑ Other: Discrimination E C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other O ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS B ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent DomaWCondemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations N Mortgage Foreclosure: Residential Restraining Order Quo Warranto PROFESSIONAL LIABILITY ❑Mortgage Foreclosure: Commercial ❑ Q ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: i Updated 1/1/2011 I YL VA�!� f <�,r McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH L FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790 -1010 U.S. Bank National Association, as Indenture Cumberland County Trustee, successor in interest to Bank of Court of Common Pleas America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank Number National Association, as Indenture Trustee for AFC Trust Series 1999 -2 10790 Rancho Bernardo Road San Diego, CA 92127 V. Deirdre A. Nowak 531 Harding Street New Cumberland, PA 17070 COMPLAINT IN MORTGAGE FORECLOSURE 0 C1 n File # 75975 NOTICE AVISO You have been sued in court. If you wish to Le han demandano a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notification. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisioner de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO BELOW. THIS OFFICE CAN PROVIDE TIENE A UN ABOGADO, VA A O YOU WITH INFORMATION ABOUT TELEFONEA LA OFICINA EXPUSO HIRING A LAWYER. ABAJO. ESTA OFICINA LO PUEDE IF YOU CANNOT AFFORD TO PROPORCIONAR CON INFORMATION HIRE A LAWYER, THIS OFFICE MAY BE ACERCA DE EMPLEARA UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES PROPORCIONAR PARA EMPLEAR UN THAT MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 File # 75975 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Please Note: (1) unless, within thirty (30) days after your receipt of this notice, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid; (2) if you notify us in writing within thirty (30) days of your receipt of this notice that the debt, or a portion of the debt, is disputed, we will cease collection of the debt until we obtain verification of the debt or a copy of the judgment against you and mail to you a copy of the verification or judgment that we obtain; (3) upon your written request to us within thirty (30) days of your receipt of this notice for the name and address of the original creditor of your debt, we will cease collection of the debt until we mail to you the name and address of the original creditor, if different from the current creditor. Case Name: U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999 -2 v. Deirdre A. Nowak Cumberland County File # 75975 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999 -2. 2. The Defendant is Deirdre A. Nowak, who is the mortgagor and owner of the mortgaged property hereinafter described, whose last -known address is 531 Harding Street, New Cumberland, PA 17070. 3. On April 23, 1999, Deirdre A. Nowak, mortgagor, made, executed and delivered a mortgage upon the premises hereinafter described to Alliance Funding, a Division of Superior Bank FSB which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1537, Page 24 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On April 23, 1999, Defendant, Deirdre A. Nowak, also executed a promissory note secured by the aforementioned mortgage. Plaintiff, directly or through an agent, is in possession of the note and is the holder of the note with the right to enforce it; the note is either made payable to plaintiff or has been duly endorsed. 5. The aforesaid mortgage was thereafter assigned by The Federal Deposit Insurance Corporation, in its capacity as Conservator for Superior Federal Bank, FSB to LaSalle Bank National Association, f /k/a LaSalle National Bank, in its capacity as trustee under that certain Pooling and Servicing Agreement dated June 1, 1999 between LaSalle National Association, as Trustee, and Superior Bank FSB, as Depositor and Servicer, AFC Mortgage Loan Asset Backed Certificates, Series 1999 -2, and any amendments thereto, by Assignment of Mortgage, executed on March 21, 2002 and recorded on September 5, 2002 in the Office of the Recorder of Cumberland County in Mortgage Book 689, Page 4994, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 6. U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999 -2 is Plaintiffherein, through chain of succession as stated. File # 75975 Page 4 d 7. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 235 State Street, West Fairview, Pennsylvania 17025. 8. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following amounts are due on the mortgage as of 01/06/14: Principal Balance $ 41,189.95 Interest from January 1, 2013 through December 31, 2013 $ 4,582.44 (Interest due and owing at a variable rate, currently $12.55 per diem) Late Charges $ 137.04 Attorney's Fee $ 1,650.00 Escrow Advance $ 1,580.98 BPO /Appraisals $ 275.00 Property Preservation $ 3,080.00 Property Inspections $ 216.50 GRAND TOTAL $ 52,711.91 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff s sale. If the mortgage is reinstated prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 10. Plaintiff complied with all notice requirements as prescribed by 41 P. S. §101, et seq. (Act 6), and 35 P.S. 1680.401c, et seq. (Act 91), as applicable. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $52,711.91, together with interest due and owing at a variable rate, currently $12.55 per diem, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG & CO Y, P. BY: [ ]Terrence J. McC e, E i [ ] Marc S. Weisberg, Esquire [ ] Edward D. Co squ' [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Asa J. Cohen, Esquire [ ] Christine L. Graham, Esquire LKBrian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff File # 75975 Page 5 VERIFICATION OF COMPLAINT The undersigned, Rosalva Cardenas , does hereby certify that he she s Vice President of JPMorgan Chase Bank, N.A. ( "Chase "), and that Chase has been duly nominated and appointed by the Plaintiff as its mortgage servicing agent in regard to the mortgage loan which is the subject of this action (the "Mortgage "). Plaintiff lacks sufficient information to make this verification because Plaintiff is not the entity that maintains the business records for the Mortgage. Chase, in its capacity as mortgage servicing agent for Plaintiff, maintains the business records for the Mortgage, and therefore, as an employee of Chase, I have sufficient information to make this verification in accordance with Pa.R.C.P. 1024(c)(1). I am authorized to make this Verification on Plaintiff's behalf and do hereby verify that I i the facts as set forth in the foregoing Complaint are true and correct to the best of my information and belief. I have access to and have reviewed the business records of Chase for and relating to the Mortgage, and I make this Verification based on my review of those records, which are maintained by Chase in the course of its regularly conducted business activities and are made at or near the time of the event, by or from information transmitted by a person with knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: I ._ 2 0 l L l Name: Rosalva Cardenas Vice President, JPMorgan Chase Bank, N.A. Loan No. XXX - 7234 • EXHIBIT "A" • ALL THAT CERTAIN lot or tract of land situate in the Borough of West Fairview, County of Cumberland & State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of State Street which point is 9.20 feet eastwardly corner of Third and State Streets; thence North 23 degrees 50 minutes East 47.03 feet to a point on the southerly line of Clay Street; thence along same North 75 degrees 45 minutes East 24 fast to a point; thence South 7.1 degrees 41 minutes Eaat 21.47 feet to a point; thence South 3 degrees 34 minutes West 50.15 feet to a point on the northerly line of State Street aforesaid; thence along same North 63 degrees West 48.81 feet to a point the place of BEGINNING. HAVING thereon erected a dwelling house known as and numbered 235 State Street. Email: k; + t; Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ fi If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑No❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: L I/We, �'' 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 I /we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of aiay expected income for the last 45 days f Copy of a4urrent utility bill Letter exp fining reason for delinquency and any supporting documentation (hardship letter) Listing a_' " (if property is currently on the market) i 3 FORM 1 U.S. Bank National Association, as Indenture Trustee, IN THE COURT OF COMMON PLEAS.�OF, � successor in interest to Bank of America, National CUMBERLAND COUNTY, PENNSY.QZ�AIS Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999 -2 jj qoc a 'Plaintiff ivil <- ,) P C-) t », G 3:> Deirdre A. Nowak . Defendant 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 provid('the legal representative with all requested financial information so that a loan resolution proposal can be4prepared 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. 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 th' mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. 3 Respectful) matt d: Date [ i _ e of nsel for Plaintiff] �n. 4 75975 Page FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County CeVrt of Common Pleas Docket # BORROWER REQUE, T FOR HARDSHIP ASSISTANCE To complete your requcist for hardship assistance, your lender must consider your circumstances to determine possible options while working 5 -ith your Please provide the following information to the best of your knowledge: t CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes 0 No ❑ Listing date: Price $ Realtor Name: Realtor Phone: Borrower Occupied? Yes O No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? C O-BORRO WER Mailing Address (if different): City: State: Zip: Phone Numbers: ut Home: Office: Cell: Other: Email: # of people on household: How long? FINANCIAL INF OIJMATIO N First Mortgage Lender': Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes O No O 3r. 3z' tik �Y A a f: If yes, provide names, location of court, case number & attorney: h t Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: - $ $ . Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value; Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. ; Additional Income Description (not wages): 1. mont'lly amount: 2. monfrlly amount: Borrower Pay Days: � ° Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE „. AMOUNT EXPENSE AMOUNT Mortgage Food 2 " Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care /Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working,with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide tl following information: Counseling Agency: ;k Counselor: Phone (Office): Fax: r 2 c Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY CUM rriCP Or- 3;t- =c2 erg C_on4 Us Bank National Association vs. Deirdre A Nowak Case Number 2014 -981 SHERIFF'S RETURN OF SERVICE 02/24/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Deirdre A Nowak, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 235 State Street, E. Pennsboro/West Fairview, West Fairview, PA 17025. Residence is vacant. 03/04/2014 07:16 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Deirdre A Nowak at 531 Harding Street, New Cumberland Borough, New Cumberland, PA . CLIA..5"Y‘, U—Q DAWN KELL, DEPUTY SHERIFF COST: $83.37 SO ANSWERS, March 05, 2014 RONN ( R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National. Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-981 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT C) N TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant, Deirdre A. Nowak, in the above - captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Amount Due Interest from 01/01/14 to 05/05/14 Total AND NOW, thisday of McCABE, WEISBERG BY: $ 52,711.91 $ 1,568.75 $ 54,280.66 ONStY, P.C. [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff ,x-16 . So Poi A� C#ai57Q3 3ot 5%6 Marc S. Weisberg, Esq.` [ ] Margaret Gairo, Esq. • [ 1] Heidi R. Spivak, Esq. / S O 4 C (44- [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. , 2014, Judgment is entered in favor of Plaintiff, U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2, and again Defendant, Deirdre A. Nowak, in rem only and not in personam, and damages are asse BY ,280.66, plus Y: est and costs. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-981 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Deirdre A. Nowak, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendant, Deirdre A. Nowak, is over eighteen (18) years of age, and resides as follows: Deirdre A. Nowak, 531 Harding Street New Cumberland, PA 17070 CCIMMO SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF M , 20/14 NOTAR /PUBLIC C;P AIR':,YLVi^MiA NQjA"iAL SEAL SAITLYN M. HADDA , Notary P uarc Phila. County Comte ephiallovember 22. 2017 McCABE, WEISBERG BY: CONWAY, P.C. [ ] Terrence J. McCabe, Es [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. L/] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. Department of Defense Manpower Data Center Results as o1: May -13-2014 06:00:26 AM SCRA 3.0 Status Report Pursuant t© Servicemembers civil Relief Act Last Name: NOWAK First Name: DEIRDRE Middle Name: A Active Duty Status As Of: May -13-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA('. '.i, ..;:x''s. 7 r - *. No ". NA This response reflects the indiv duals' act` duty status based on.tho Active Duty Status Date 4 o )}+ J Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA 1 , NA ,..>' . ; NA This response reflects where'the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA .-.� _ .No -, 1 NA This response reflects whether the individual or his/herunit 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/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: J9B7VAE9I0B7S60 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH L FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-981 AFFIDAVIT OF LAST -KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last -known mailing address of the Defendant is: Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 SWORN AND SUBSCRIBED BEFORE ME THIS 13 DAY OF 1'^1ch4 , 2014 NOTAR PUBLIC T$P ARIAL SEAL MITLYN M. HADDAD, Notary Public City of Philadelphia, Phil 2t 2017 Commission Ex ' LVANIA SS. McCABE, WE BY: [ ] Terrence J. Mc abe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff S:'RG CO AY, P.C. [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [�] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-981 CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS t3 DAY OFA t. OM ,2014 NOTAR%: PUBLIC PENNSYLVANIA COMMONWEA N ' ARIAL SEAL KAITLYN M. HADDAD, Notary Public City of Philadelphia,, PhiCountyy2017M Commission • November a McCABE, WEISBERG BY: [ ] Terrence J. McCabe [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff CONWAY, P.C. arc S. Weisberg, Esq. Margaret Gairo, Esq. Heidi R. Spivak, Esq. Christine L. Graham, Esq. Ann E. Swartz, Esq. Joseph I. Foley, Esq. Jennifer L. Wunder, Esq. Carol A. DiPrinzio, Esq. VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBER BY: CONWAY, P.C. [ ] Terrence J. McCabe, Es [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 v. Deirdre A. Nowak Cumberland County; Number: 14-981 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary April 3, 2014 To: Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust. Series .1999-2, . . vs. Deirdre A. Nowak Cumberland County Court of Common Pleas Number 14-981 NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ds NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGA DO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: /711 (2" C. [ 1 Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff [ -`Marc S. Weisberg, Esquire [ 1 Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Carol A. DiPrinzio, Esquire OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-981 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Prothonotary If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 v. Deirdre A. Nowak FILE NO.: 14-981 Civil Term AMOUNT DUE: $54,280.66 INTEREST: from 05/06/14 $1,891.04 at $8.92 ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 235 State Street, West Fairview, Pennsylvania 17025 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 1 t-1 1 McCABE, WEISBERG & CONWAY,%P.C. BY: c/ \ [ ] Terrence J.' McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff Marc S. Weisb6rg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. Address:123 S. Broad Street, Suite 1400 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. aaI ate-/ �� ' (9c- n SvH. d '3)9030 LEGAL DESCRIPTION It MAI CTAIC1 lot or tract of land sitnaato in tie Borough of*. e Vairsieu, aE r"7 d &State of Pennsylvania, .'fors particularly boon �' and destr. bt d as fellows, to tit d BtG ANG et a point on the northerly line of State Street Which point is feet eastwardly of the northeasterly corner. of Third and State Streets; thence North 23 degrees 59 minutes East 47.03 feet to a point OA the so theriy line of Clay Street; thence along sue North 75 degrees 45 minutes East 24 feet to a point-, thonse South 11 degrees 41 minutes East 21+47 fit to a point; thence. SSutb 3 degrees 34, minutes Nest 50,15 feet to a point on the n rtOerly line of State Street aforesaid; thence along S400 North 63 degrees West 4Qtw81 feet to a point the place of BEGINNING; MIK thereon erecta a, dwelling house known as and nus rered 23 :Skate Stet. BEING the same premises which Hilda M. Berry, Trustee for Robert A. Berry by deed dated December 23, 1987 and recorded December 29, 1987 in Deed Book 33-C, Page 899, granted and conveyed unto Deirdre A. Nowak. Premises: 235 State Street, West Fairview, Pennsylvania 17025. TAX MAP PARCEL NUMBER: 45-17-1044-204 McCABE, WEISBERG & CONWAY, P.C. . BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant °I;* F SyN� Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-981 AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 235 State Street, West Fairview, Pennsylvania 17025, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 2. Name and address of Defendant in the judgment: Name Address Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff Herein East Pennsboro Township 98 S. Edna Drive Enola, Pennsylvania 17025 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff Herein Federal Deposit Insurance Corp. Address 1776 F Street N.W. Washington, D.C. 20429 LaSalle Bank, N.A. 909 Hidden Ridge Drive Suite 200 Irving, Texas 75038 Alliance Funding 135 Chestnut Ridge Road Suite 200 Montvale, New Jersey 07645 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address NONE 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 235 State Street West Fairview, Pennsylvania 17025 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address NONE 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. DATE McCABE, WEISBERG & CONWAY, P.C. BY: A(f [ ] Terrence J. cCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff [ Marc Sr Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 v. Deirdre A. Nowak Cumberland County; Number: 14-981 LEGAL DESCRIPTION HAT CERTAIN lot or tract of land situate in the 8oro g1 of West Fairview, oUnty of atibeacind &State of Pennsylvania, nore particularly bounded and described as follows, to wit: BEGINNING at a point on the northerly line of State Street Which hint is 4.2:0 feet eastwardly of the northeasterly corner of Third and State Streets; thence North 23 degrees 50 minutes East 4`.03 feet to a point on the s0utierty line of Clay Street; thence along sane North 75 degrees 45 minutes East 24 feet to a point; thence South 11 degrees 41 minutes East 21,4' feet to a point; thence' South 3 degrees 34 minutes West 50.15 feet to a paint 04 the northerly line of State Street aforesaid; thence along saw North 63 degrees West 48.81 feet to a paint the place of BEGINNING. HAVING thereon erected a dwelling house known as and nunbered 235 State Street. BEING the same premises which Hilda M. Berry, Trustee for Robert A. Berry by deed dated December 23, 1987 and recorded December 29, 1987 in Deed Book 33-C, Page 899, granted and conveyed unto Deirdre A. Nowak. Premises: 235 State Street, West Fairview, Pennsylvania 17025. TAX MAP PARCEL NUMBER: 45-17-1044-204 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 v. Deirdre A. Nowak Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-981 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 Your house (real estate) at 235 State Street, West Fairview, Pennsylvania 17025 is scheduled to be sold at Sheriffs Sale on December 3, 2014.at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $54,280.66 obtained by U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 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 canceled if you pay to U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the 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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION All MAT CERTAIN lot or tract of land situate in the Borough of West Fairy ew, unty 5t cuftbeaand &State of Pennsylvania, snore particularly bounded and described 0 follows. to wit: BEGINNING at a point an, the northerly line of State Street which point is',Z0 feet eastwardly of the northeasterly corner of Third and State Streets, thence. North 23 degrees 50 minutes East 47.03 feet to a point on the southerly line of Clay Street; thence along sane Worth 75 degrees 45 minutes East 24 feet to a point thence South it degrees 41 *flutes East 2..41 feet to a point; theice. South 3 degrees 3 minutes West 50,15 feet to a paint on the northerly line of State Street aforesaid; thence along Forts; 63 degrees West 48+81 feet to a point the place of BEGINNING. HAYING thereon erected a dWelling haute known as and limbered 235 State Street. BEING the same premises which Hilda M. Berry, Trustee for Robert A. Berry by deed dated December 23, 1987 and recorded December 29, 1987 in Deed Book 33-C, Page 899, granted and conveyed unto Deirdre A. Nowak. Premises: 235 State Street, West Fairview, Pennsylvania 17025. TAX MAP PARCEL NUMBER: 45-17-1044-204 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net U. S. BANK NATIONAL ASSOCIATION, AS INDENTURE TRUSTEE, SUCCESSOR IN INTEREST TO BANK OF AMERICA, NATIONAL ASSOCIATION, AS INDENTURE TRUSTEE, SUCCESSOR BY MERGER TO LASALLE BANK NATIONAL ASSOCIATION, AS INDENTURE TRUSTEE FOR AFC TRUST SERIES 1999-2 Vs. NO 14-981 Civil Term CIVIL ACTION — LAW DEIRDRE A. NOWAK 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: $54,280.66 L.L.: $.50 Interest FROM 5/6/14 - $1,891.04 AT $8.92 Atty's Comm: Due Prothy: $2.25 Atty Paid: $232.12 Other Costs: Plaintiff Paid: Date: 7/25/14 (Seal) David D. Buell, Prothonotary REQUESTING PARTY: Name: MARC S. WEISBERG, ESQUIRE Address: MCCABE, WEISBERG & CONWAY, P.C. 123 S. BROAD STREET, SUITE 1400 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 'McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-981 AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 29th day of October, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129.1 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEF OF n -DAY 014 NOTARY PUB NO i REAL SEA BARBARA J. MOYER, Notary Public City of Philadelphia, Phila. County MComm�ssNr, c�.-012 2098 Y �. a�e►s.tsntu9fy �L 'r,.,'igsParw, McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Tefrence,McCabe, Esquire [ ] Edward 0. Conway, Esquire [ [ [ [ [ Attorneys for Plaintiff ] Andrew L. Markowitz, Esquire ] Marisa J. Cohen, Esquire ] Brian T. LaManna, Esquire ] Joseph F. Riga, Esquire ] Celine P. DerKrikorian, Esquire ] Carol A. DiPrinzio, Esquire [ ] Marc S. Weisberg, Esquire ..[—I"1Vlargaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-981 AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 235 State Street, West Fairview, Pennsylvania 17025, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 2. Name and address of Defendant in the judgment: Name Address Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address East Pennsboro Township 98 S. Edna Drive Enola, Pennsylvania 17025 Pennsylvania State Employees Credit One Credit Union Place Union Harrisburg, Pennsylvania 17110 Pennsylvania State Employees Credit Union c/o Matthes F. Stephenson, Esquire 224 Finance Building Harrisburg, Pennsylvania 17120-0001 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Federal Deposit Insurance Corp. !) LaSalle Bank, N.A. Alliance Funding Federal Deposit Insurance Corporation Address 1776 F Street N.W. Washington, D.C. 20429 909 Hidden Ridge Drive Suite 200 Irving, Texas 75038 135 Chestnut Ridge Road Suite 200 Montvale, New Jersey 07645 1776 F. Street, N.W. Washington, D.C. 20429 5. Name and address of every other person who has any record lien on the property: Name East Pennsboro Township Address 98 S Enola Drive Enola, Pennsylvania 17025 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name NONE Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 235 State Street West Fairview, Pennsylvania 17025 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name NONE Address 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. DATE McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Te ence J McCabe, Esq. [ ] Edward 1. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. "[-]'Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. Re: U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 v. Deirdre A. Nowak. et al. Cumberland County; Number: 14-981 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-981 DATE: October 29, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Deirdre A. Nowak PROPERTY: 235 State Street, West Fairview, Pennsylvania 17025 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $54,280.66 The above -captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on December 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 1400g Philadelphia,PA 9109 Attn: SETH HAMRICK ---- Check type of mail or service: 0 Certified ❑ Recorded Delivery (International) 0 COD 0 Registered 0 Delivery Confirmation 0 Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation ❑Insured Affix Stamp Her (if issued as a certificate of mai, or for additional 1 copies of this billi Postmark and i Date of Receipt , : -3,4 lo i+* .•t ;a.;s 1 ,,} , � !4+�'�. --n neatstered—Value '� '!• ' rti r1 U.S. POSTAGE»PITNEY ��. ZIP 19109 02 1Y�' � 0001377494 if COD— r��w Immo=w Fee $ 030.000 OCT_ Fee BOWES � 29. 201 ". SH Fee 9 !i � Line Article Number Addressee Name, Street and PO Address Postage Fee Handling..n.-:. Charge{- RD Fee RR Fee U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 v. Deirdre A. Nowak p,.10 Ti, Tb^.:,:,<;,,,; t o j 9 ? � .7n� i ' Z 1 East Pennsboro Township S. Edna Drive Enola, Pennsylvania 17025 `' 44. . PAt t 298 j 2 Pennsylvania State Employees Credit Union One Credit Union Place Harrisburg, Pennsylvania 17110 3 Pennsylvania State Employees Credit Union c/o Matthes F. Stephenson, Esquire 224 Finance Building Harrisburg, Pennsylvania 17120-0001 4 Federal Deposit Insurance Corp. 1776 F Street N.W. Washington, D.C. 20429 5 LaSalle Bank, N.A. 909 Hidden Ridge Drive Suite 200 Irving, Texas 75038 6 Alliance Funding 135 Chestnut Ridge Road Suite 200 Montvale, New Jersey 07645 7 Federal Deposit Insurance Corporation 1776 F. Street, N.W. Washington, D.C. 20429 8 East Pennsboro Township 98 S Enola Drive Enola, Pennsylvania 17025 9 . Tenants 235 State Street West Fairview, Pennsylvania 17025 10 • Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 11 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8th Street Suite #204 Philadelphia, PA 19107 12 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 13 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 14 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Harrisburg, _.- 15 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 16 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales 17 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 18 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 19 Tax Claim Bureau 1 Courthouse Square Carlise, PA 17013 20 Commonwealth of PA Department of Revenue Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales 21 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 22 United States of America c/o United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 23 United States of America c/o Atty General of the United States U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 24 United States of America c/o Atty General of the United States U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Total Number of Pieces Listed by Sender 24 Total Number of Pieces Received at Post Office Postmaster, Per (Name of receiving employee) The full decl ration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $500 per piece subject to additional limitations for multiple pieces lost or damages in a single catastrophic occurrence. The maximum indemnity payable on Express Mail merchandise insurance is $500, but optional Express Mail Service merchandise is available for up to $5,000 to some, but not all countries. The maximum indemnity payable is $25,000 for registered mail. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels. PS Form 3877, August 2000 Complete by Typewriter, Ink, or Ball Point Pen McCABE, WESIBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-981 Notice of the Date of Continued Sheriffs Sale The Sheriff's Sale scheduled for December 3, 2014 at 10:00 A.M. in the above -captioned matter has been continued until January 7, 2015 at 10:00 A.M. Certificate of Filing On this date, a Notice of the Date of Continued Sheriffs Sale in the above -captioned matter was sent for filing with the Prothonotary of CUMBERLAND County. Certification of Service On this date, a Notice of the Date of Continued Sheriff's Sale was served by first-class mail, postage prepaid upon the following: Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania, 17070 Date: 11 f McCABE, WEIS,:E' G & C BY: [ ] Terrence J. Mc a. e, [ ] Edward D. Conway, E drew L. Markowitz, [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff ] Marc S. Weisberg, Esq. ] Margaret Gairo, Esq. ] Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. ] Ann E. Swartz, Esq. ] Joseph I. Foley, Esq. ] Lena Kravets, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RICA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14-981 MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 1. Plaintiff attempted to personally serve a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Deirdre A. Nowak, at his/her last -known address of 531 Harding Street, New Cumberland, Pennsylvania 17070. The process server was not able to serve the Defendant because after several attempts they were unable to locate the defendant. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit "A". 2. Plaintiff attempted to serve a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant's mortgaged property of 235 State Street, West Fairview, Pennsylvania 17025. The process server was not able to serve the Defendant. True and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof, and marked as Exhibit "B". 3. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendant and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "C". 4. As a result of the investigation, a special Order of Court is required permitting service by regular and certified mail at the Defendant's last -known address and by posting a copy of the original process on the mortgaged premises. 5. No judge has ruled upon any other issue in this matter or in any related matter. 6. No attorney has entered an appearance in this matter on behalf of Defendant and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 7. If service cannot be made on the Defendant, Deirdre A. Nowak, the Plaintiff will be prejudiced. WHEREFORE, Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve the Notice of Sheriffs Sale of Real Property upon the Defendant, Deirdre A. Nowak, by regular mail; certified mail, return receipt requested, and by posting at the last -known address of Defendant and the mortgaged premises known in this herein action as 235 State Street, West Fairview, Pennsylvania 17025. McCABE EISBERG -C -ON W BY: �,� ‘,11111.---w- .---T'—'- [ ] Terrence J. McCabe, Esquire [ ` 1 arc S. Weisberg;, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14-981 MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. McCABE, WEISBERG : ND BY: ,Z" �' [ ] Terrence J. McCabe, Esquir e [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celi e -P. DerKrikorian, Esquire [ ro] A. DiPrinzio, Esquire Attorneys for Plaintiff , P.C. Marc -/ eisberg, Esquire Mar • aret Gairo, Esquire Heidi R. Spivak, Esquire Christine L. Graham, Esquire Ann E. Swartz, Esquire Joseph 1. Foley, Esquire Lena Kravets, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, .ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 14-981 CERTIFICATION OF SERVICE The undersigned attorney for the Plaintiff hereby certifies that he/she served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 8th day of December, 2014, upon the following: Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania 17070 McCABE, WEISBERG A1.D-CO BY: [ ] Terrace J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] CehkrerberKrikorian, Esquire [ro1 A. DiPrinzio, Esquire Attorneys for Plaintiff 1 Marc Se eisberg, Esquire ] Margaret Gairo, Esquire 1 Heidi R. Spivak, Esquire ] Christine L. Graham, Esquire ] Ann E. Swartz, Esquire 1 Joseph I. Foley, Esquire ] Lena Kravets, Esquire VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of this jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, WEISBERG BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. a, Esquire [ ] Cell' [ ]'Carol A. DiPrinzio, Esquire Attorneys for Plaintiff . DerKrikorian, Esquire [ ] Mar -.. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ 1 Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as .Indenture Trustee for AFC Trust Series 1999-2 v.Deirdre A. Nowak Cumberland County; CCP; Number 14-981 File Number: 75975 EXHIBIT A Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUN Q1 Crunkrit OFFICif,V" Tkr: Us Bank National Association vs. Deirdre A Nowak ase Number 2014-981 09/30/2014 SHERIFF'S RETURN OF SERVICE 04:12 PM - Deputy Shawn Harrison, being duly sworn according to law, states service posting a true copy of the requested Real Estate Writ, Notice and Description, and Sa above titled action, upon the property located at 235 State Street, East Pennsboro, We 17025, Cumberland County. 11/04/2014 Ronny R. Anderson, Sheriff, being duly swom according to law, states that he made a inquiry for the within named Defendant, to wit: Deirdre A. Nowak, but was unable to lo in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Descriptio titled action, as "Not Found" at 531 Harding Street, New Cumberland, PA 17070, defe located at address provided prior to expiration date, 9 service attempts were made. c SHERIFF COST: $983.19 SO ANSWERS, s performed by andbill in the airiiew, PA gent search and thd Defendant the above nt ci)uld not be November 04, 2014 RONtfr R ANDER EXHIBIT B Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUN NAV Ot +444 IV;E; 0.% nit S.!•.!:EPC4,, Us Bank National Association vs. Deirdre A Nowak ase Number 2014-981 SHERIFF'S RETURN OF SERVICE 09/30/2014 04:12 PM - Deputy Shawn Harrison, being duly sworn according to law, states service posting a true copy of the requested Real Estate Writ, Notice and Description, and Sal above titled action, upon the property located at 235 State Street, East Pennsboro, We 17025, Cumberland County. 11/04/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a inquiry for the within named Defendant, to wit: Deirdre A. Nowak, but was unable to lo in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Descriptio titled action, as "Not Found" at 531 Harding Street, New Cumberland, PA 17070, defe located at address provided prior to expiration date, 9 service attempts were made. c SHERIFF COST: $983.19 SO ANSWERS, s performed by andloill in the air+iew, PA gent search and thd Defendant thel above nt could not be November 04, 2014 RONNY R ANDER , SHERIFF EXHIBIT C AFFIDAVIT OF GOOD FAITH INVESTIGATION File 1111111 u 11111 imi um 11111 1111 1111 Subject: Deirdre A. Nowak Last -known Address: 531 Harding Street, New Cumberland, PA 17070 STATE OF NEW YORK COUNTY OF SUFFOLK ss.: Susan Farbizio, the undersigned, being duly sworn, deposes and says that I am over the age of eighteen and not a party to this action. I reside in the STATE OF NEW YORK. I conducted a good faith investigation into the whereabouts of the Deirdre A. Nowak at the last-known/property address indicated below and the extent of the investigation and the results are as follows: Date DueDiligence Remarks 11/20/2014 PROPERTY ADDRESS: 235 State Street, West Fairvi, PA 17025 11/20/2014 LAST -KNOWN ADDRESS: 531 Harding Street, New Cumberland, PA 17070 11/20/2014 INQUIRY OF LOCAL TELEPHONE COMPANY: Directory Assistance: Search was unable to locate a telephone listing for the subject, however results provide the last -known address associated with the subject. 11/20/2014 INTERNET SEARCH: Search results provided the last -known address as the most recent address for the subject. 11/20/2014 INTERNET SEARCH: Search results provided the property address and the last -known address as the most recent address for the subject. Results provide a telephone number of 717-732-1017 associated with the subject. 11/20/2014 DEATH RECORDS: Social Security Death Index Search was unable to locate a death record for the subject. 1 ]/20/2014 LOCAL TAX RECORD INQUIRY: Search was unable to confirm a mailing address for the above stated property address. 1, Susan Farbizio, reviewed and signed this affidavit on 11/20/2014. The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best of my knowledge, information and belief. Swornt and subscribed before me on 0 , 20 /� �&-.... ...... Notary Public, RITA MASTRANGELO Notary Public. State of NEW YORK 01MA6055607 Qualified in Nassau County Commission Expires, FEBRUARY 26, a d ! J X Susan Farbizio Attorney Outsourcing Support Services, Inc. Agency License #2004244 -DCA 1 Huntington Quadrangle, Suite 2SO4 Melville, NY 11747 (516) 284-5850 Firm Ref#: Free people search and contact Page 1 of 1 Advertisement: Need a way to save? Check out AT&T wireless discounts Deirdre A Nowak Age: =Sign kow Equi(ax.coinm Address 531 Harding StNew Cumberland, PA 17070-1237 People Deirdre may know James F Nichols Previous locations Enola, PA New Cumberland, PA Mechanicsburg, PA © 2014 Whitepages Inc. Site Map Print this page http://www.whitepages.com/name/Deirdre-A-Nowak/New-Cumberland-PA/4m5gnwn 11/20/2014 R3search Person Search Results Search Terms Used - SSN: All Full Name 1. DEIRDRE A NOWAK LexID: 1858541040 We Also Found: 2. 3. 4. 5. 6. 7. 8. ❑ Pho DEDE NOWAK Gender: Female LexID: 1858541040 DEIRDRE A MOWAK Page 1 of 3 Records: 1 to 18 of 18 Age/DOB Address Dates Phone Information LexID: 1858541040 DEIREDRE A NOWAK Gender: Female LexID: 1858541040 DEIRDRE A NOWAK Gender: Female LexID: 1858541040 DEDE NOWAK Gender: Female WPMM DEIDRA A NOWAK Gender: Female 531 HARDING ST Dec 1987 - Nov 2014 NEW CUMBERLAND PA 17070-1237 Probable current address ❑ Property Records ❑ Email Address 531 HARDING ST Jan 2008 - Sep 2014 NEW CUMBERLAND PA 17070-1237 Probable current address 531 HARDING ST Oct 2010 NEW CUMBERLAND PA 17070-1237 Probable current address 531 HARDING ST Oct 2010 NEW CUMBERLAND PA 17070.1237 Probable current address 235 STATE ST ENOLA PA 17025.3236 DEIREDRE A NOWAK Gender: Female 1.1111.11. 235 STATE ST ENOLA PA 17025-3236 235 STATE ST ENOLA PA 17025-3236 Feb 1989 - Mar 2011 Feb 1989 - May 2010 Nov 2005 235 STATE ST ENOLA PA 17025-3236 Jan 2003 774-3629 https://secure.accurint.com/app/bps/main 11/20/2014 19. 10. DEIRDRE A NOWAK Gender: Female LexID: 1858541040 DEIRORE A MOWAK Gender: Female LexID: 40 DEIDRE A NOWAK /13. DEIRORE A MOWAK Gender: Female DEtREDRE A NOWAK LexID: 1858541040 DEIDRE A NOWAK 235 STATE ST PHILADELPHIA PA 19147 235 STATE ST ENOLA PA 17025.3236 Apr 1993 Apr 2002.Oct 2002 235 STATE ST - •- ENOLA PA 17025-3236 Jan 1988 817 UPLAND ST MECHANICSBURG PA 17055.4356 505 GEARY AVE NEW CUMBERLAND PA 17070.1857 Aug 1986 Oct 1987 505 GEARY AVE NEW CUMBERLAND PA 17070.1857 Aug 1986 774.3629 774-3629 74-3629 , 505 GEARY AVE NEW CUMBERLAND PA 17070.1857 Apr 1986 18. x https://secure.accurint.com/a 05 GEARY AVE NEW CUMBERLAND PA 17070.1857 Feb 1885 -Apr 1986 317 UPLAN MECHANICSBURG PA 17055 317 UPLA MECHANICSBURG PA 17055 Feb 1982 774-3629 Feb 1982 7743629 Records: 1 to 18 of 18 11/20/2014 Page 2 of 3 Page 3 of 3 Your DPPA Permissible Use: Use in the Normal Course of Business Your GLBA Permissible Use: Authorized by Consumer Your DMF Permissible Use: No Permissible Purpose Iattps://secure.accurint.com/app/bps/main 11/20/2014 Tracers Information Specialists, Inc. - Premium People Search Page 1 of 3 12 Records NOWAK DEIRDRE A AKA: DE/RDRE NOWAK AKA: NOWAK DEIRDRE AKA: DEDE NOWAK AKA: DEIRDRE A NOWAK NOVVAK DEIRDRE AKA: DEDE NOWAK 531 HARDING ST 2x NEW CUMBERLAND https:// .tracersinfo.com/SearchCentral/viewreturnphp3? 235 STATE ST ENOLA PA 17025- 1x E 3236 Reported: /1/17/2014 - 11/17/2014 County: Cumberland 235 STATE ST lx ENOLA PA 3236 17025- Reported: 11/17/2014 11/17/2014 County: Cumberland 531 HARDING ST 2x NEW CUMBERLAND PA 17070-1237 Reported: 11115/2014 11/15/2014 County: Cumberland 235 STATE ST 4x ENOLA PA 17025- 3236 Reported: 02/01/1989 - 09/01/2012 County: Cumberland 1/20/2014 Tracers Information Specialists, Inc. - Premium People Sear A: WAK IRDRE A: RDRE WAK DRE AK AK NO DE AK DE1 AN( AKA DEIR NOW NOWAK DE1REDRE A AKA: MOWAK DE/RORE A AKA: NOWAK DEIRDRE A AKA: NOWAK DEIRDRE https:// NOWAK DEIREDRE A AKA: MOWAK DEIRDRE A AKA: NOWAK DEIRDRE PA 17070-1237 Reported: 10/06/2010 - 0700/2012 County: Cumberland Page 2 of 3 531 HARDING ST 2x NEIN CUMBERLAND PA 17070-1237 Reported: 10/04/2010 10/04/2010 County: Cumberland 235 STATE ST Ix WEST FAIRVI PA /7025 Reported: - 03/10/200803/10/2008 County: Cumberland 317 UPLAND MECHANICSBURGST 3x PA 17055-4353 Reported: 11/13/2000 11/13/2000 County: Cumberland 317 UPLAN MEC 1HANICSBURG PAx 17055 Reported: 11/13/2000 11/13/2000 - County: Cumberland 235 STATE ST ENOLA PA /7025- 3236 Reported: 04/01/1993 - 04/01/1993 County: Cumberland .acersinfo.com/SearchCentral/viewreturn.plip3? 11/20/2014 Tracers Information Specialists, Inc. - Premium People Search Page 3 of 3 A AKA: NOWAK DEIRDRE Reports Name Address Maps SSN/DOB Phone MOWAK DEIRORE A 505 GEARY AVE lx NEW CUMBERLAND PA 17070-1857 Reported: 03/31/1993 - 03/31/1993 County: Cumberland Map It NOWAK DEIREDRE A AKA: MOWAK DEIRORE A 505 GEARY AV 4x NEW CUMBERLAND PA 17070-1857 Reported: 08/01/1986 - 08/01 /1986 County: Cumberland Map It https://www.tracersinfo.com/SearchCentral/viewreturn.php3?pargs=YToxOntpOj YyMj E... 11/20/2014 Social Security Death Index (SSDI) Records - Social Security Death Index SSDI Records ... 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MVO' AltiffillIMMISIMENEMPOMMAVEINIRCOMPIO. in the news 1 contact us 1 affiliates 1 privacy policy 1 terms of use 1 site map 1 blog http://www.genealogybank.condgbnk/ssdi/?lname=&filame=&minit=&birthy_0=&birthy... 11/20/2014 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant THE PRSCHONCI1--Cf' 2C1:11[nr 1.EC I PH 3: 26 CUMBERLAND COUNTY PENNSYLVANIA Cumberland County Court of Common Pleas Number 14-981 ORDER AND NOW, this Arday of cf-4-4 , 2014, the Plaintiff is granted leave to serve the Notice of Sheriffs Sale of Real Property upon the Defendant, Deirdre A. Nowak, by regular mail and by certified mail, return receipt requested, to his/her last -known address of 531 Harding Street, New Cumberland, Pennsylvania 17070, and by posting the mortgaged premises of 235 State Street, West Fairview, Pennsylvania 17025. P-2( c.afic.,M =/-1 McCABE, WESIBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 U.S. Bank National Association, as Indenture Trustee, successor in interest to Bank of America, National Association, as Indenture Trustee, successor by merger to LaSalle Bank National Association, as Indenture Trustee for AFC Trust Series 1999-2 Plaintiff v. Deirdre A. Nowak Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-981 Notice of the Date of Continued Sheriff's Sale The Sheriff's Sale scheduled for January 7, 2015 at 10:00 A.M. in the above -captioned matter has been continued until February 4, 2015 at 10:00 A.M. Certificate of Filing On this date, a Notice of the Date of Continued Sheriff's Sale in the above -captioned matter was sent for filing with the Prothonotary of CUMBERLAND County. Certification of Service On this date, a Notice of the Date of Continued Sheriff's Sale was served by first-class mail, postage prepaid upon the following: Deirdre A. Nowak 531 Harding Street New Cumberland, Pennsylvania, 17070 Date: l ! c) % ./t/ L( McCABEKBERG & CONWAY, P.C. BY:, T]errence J. McCabe, Esq. [ ] Marc S. Weisberg, Esq. Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq.[ 1 Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ 1 Christine L. Graham, Esq. [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. [ 1 Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq.[ 1 Lena Kravets, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff