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HomeMy WebLinkAbout14-2046 a • t Supreme Court of Pennsylvania Court of h; Pleas `' For Prothonota 1 Use Onl �vil.Cover Sheet � y: CUMBERLAND; County Docket No: Ov 4 The information collected 011 this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Bank of America, N.A., successor by merger Lead Defendant's Name: Doris Delp a/k/a Doris M. Delp C to BAC Home Loan Servicing, LP fka Countrywide Home Loans T Servicing, LP Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) — X outside arbitration limits O — N Is this a Class Action Suit? ❑ Yes ® No Is this an MDI Appeal? ❑ Yes ® No Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC A ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S F Product Liability (does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste F1 Other: [:1 Ejectment ❑Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus B ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1//2011 t z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., SUCCESSOR BY CIVIL DIVISION MERGER TO BAC HOME LOAN SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING, NO.: LP, TYPE OF PLEADING Plaintiff, vs. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE Doris Delp a /k /a Doris M. Delp; Michael A. Weltmer; FILED ON BEHALF OF: Bank of America, N.A., successor by merger to Defendants. BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS COUNSEL OF RECORD FOR THIS PARTY: FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. ZUCKER GOLDBERG & ACKERMAN, LLC I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: Scott A. Dletterick Esquire- Pa. I.D. #55650 400 National Way Kimberly A. Bonner, Esquire- Pa. I.D. #89705 Simi Valley CA 93065 Joel A. Ackerman, Esquire- Pa I.D. #202729 AND THE DEFENDANT: Ashleigh Levy Marin, Esquire- Pa I.D. #306799 37 Highland Drive Ralph M. Salvia, Esquire- Pa I.D. #202946 Camp Hill PA 17011 Jaime R. Ackerman, Esquire- Pa I.D. #311032 ^ . Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 CERTIFICATE OF LOCATION Denise Carlon, Esquire- Pa I.D. #317226 1 HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 37 Highland Drive, Camp Hill PA 17011 200 Sheffield Street Suite 101 Municipality: Lower Allen Mountainside, NJ 07092 ' (908) 233 -8500 (908) 233 -1390 FAX r ATTORNEY FO N office@zuckergoldberg.com ATTY FILE N .: XFP 185388 File No.: XFP- 185388/mme ojk Vda l C IL bj .� 33935 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to CIVIL DIVISION BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP NO.: Plaintiff, vs. Doris Delp a /k /a Doris M. Delp; Michael A. Weltmer; Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to CIVIL DIVISION BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP NO.: Plaintiff, VS. Doris Delp a /k /a Doris M. Delp; Michael A. Weltmer; Defendants. AVISO LISTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacidn de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGAR UNO, LLAME O VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to CIVIL DIVISION BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP NO.: Plaintiff, vs. Doris Delp a /k /a Doris M. Delp; Michael A. Weltmer; Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP, (hereinafter "plaintiff') having its principal place of business at 400 National Way, Simi Valley, CA 93065. 2. The Defendant, Doris Delp a /k /a Doris M. Delp, is an individual whose last known address is 37 Highland Drive, Camp Hill, PA 17011. 3. The Defendant, Michael A. Weltmer, is an individual whose last known address is 37 Highland Drive, Camp Hill, PA 17011. 4. Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP, directly or through an agent, has possession of the Promissory Note. Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 5. On or about March 30, 2010, Michael A. Weltmer and Doris Delp made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for NFM, Inc. d /b /a NFM Consultants, Inc. a Mortgage in the original principal amount of $151,505.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on April 5, Zucker, Goldberg & Ackerman, LLC 2010, Instrument #201008310. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded May 31, 2012, the mortgage was assigned to Bank of America, NA, successor by merger to BAC Home Loans Servicing, LP fka Countrywide Home Loans Servicing, LP which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #201216141. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 7. Michael A. Weltmer and Doris Delp, both single people, as Joint Tenants with Right of Survivorship and not at Tenants in Common are record and real owners of the aforesaid mortgaged premises. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due May 1, 2013. 9. As of 03/17/2014 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $144,745.10 Interest from 04/01/2013 to 3/31/2014 $7,599.12 Late Charges $ 315.63 Escrow $1,326.12 Property Inspection $ 15.00 Total $154,000.97 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Zucker, Goldberg & Ackerman, LLC Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 11. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendants) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $154,000.97 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & A MAN, BY: Dated: 'J Scott A. Dietterick squire; PA I.D. #55650 J Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP- 185388/mme 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC e � EXHIBIT A Zucker, Goldberg & Ackerman, LLC CftPRDNRBS,43b 12/13/2012 12:24:39 PM PAGE 36/097 888 - 294 -5658 LOAN A . 23210010408 FHA Case No, NOTE 446- 0058100 -703 i - Mulf sut@ NARYI+ADII !!ABCs 30, 2910 IzlCfiY7�' [9tate] [Date] 37 Highland Drive, Camp Hill, PA 17011 [property Address] 1. PARTIES • Borroower means each person signing atthe end of this Note, and the person's successors and assigns. "Lander means Xm, INC. d /b /a » CONSMTAN", INC. A MARYLAND CORPORATION. and its suecessois and assigns. 2. BORROWER'S PROMISE TO PAY; INTER EST P prine at sum of * * * *s *ONE MMDRED In return for a loan received from Lender, Borrower promises to pay the Dollars VE HUNDRED FIVE W SOf100* sxxxt +kir +r +ttxxs +rtxaxxxcxr * * +t +aa FIFTY ONE TS0uSA3AD t'I (U.S. $151, 505.09 }, Plus Interest to tyre order of Lender. Interest will be charged on unpaid principal, from ent `ate ofdisb of he loan proceeds my� of pr incip al , atthrate o been sad rre- FOVR2ti 3� 3, PROMISE TO PAY SECURED Instrument that is dated the Borrower's promise to Pay is secured bye mortgage, Th S c�ia� y Instrument rotects the Lender from losses same date as this Note and called the "Security Ins which might result it Borrower defaults under this Note. 4. MANNER OF PAYMENT (A} Tune lsx day of each month Boonower shall mak0 a payment of principal and interest to Lander on the Y Y da DI beginning on XAT 1, 2010- Any principal and interest remaining on the IST APRIL, 2040 will be due on ttia# date, which is taped the "l+naturity Date." (B) Plane Payment shall be made at 505 PROGRESS DRIVE LITRICOM, MD 21090 or at such place as Lender may designate in writing by notice to Borrower. (0) Attrount Each monthly payment of principal and interest will be In the amount of U.S. $836. b2. This amour will be part of a larger monthly payment required by the Security Instrument. that shall be applied top rincipal, interest and other Items in the order described in the Security Instrument. (D) Allonge to this Note for paymern.ad}uatrnents djustments Is executed by together Borrower f ether with this Note, the covenants of If an allonge providing for payment a ttra allong a shall be incorporated into and shall amend an d supplement the covenants of this Note as'rf the aHonga were a part of this Note. (Check applicable box] =1 Graduated Payment Allonge OGrowing Equity ADonge =Other [specify) S. BORROWER'S RIGHT TO PREPAY orpenatty,onthe Borrower has the right to gay the debt evidenced by this Note, in hull i pout charge ereston the amount first day ofany month. Lendershall accept prepayment on odrer days provided that bonowe Yr rot or of the Secretary. prepaid for the remainder the month to the extentrequired by Lender and permitted by rJ it Borrower makes a partial prepayment, therevviil be no changes in the due date or in the amount of them onthly payment unless Lender agrees in writing to those changes. 6. SORROWEWS FAILURE TO PAY (A) Late Charge for Overdue Payments IfLenderhisnotreceivedthefulimonthly payment required bythe Security Instrument asd scribed a��groeinthe of dnts NDts, by the and of is calendar days after payment is 4. Doe Le nder oY the overdue amount of each amount of Four payment. (t3) Default then Lender may, except as limited by regulations of if Borrower defaults by fajE ng to pay in full any monthly payment, the Secretary in the case of payment defaults, regvire immediate payment it full of the principal balance remaining due and all accrued interest Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default In manyclrcumslances regulations Not does rat auth acceleration when 9 of }rere mitted by HUDregulations in full in the rase of payment of FiDUSin and Urban iDeveiopm nt or hs or her designee_ As used in this Note. Secretary" means the Secretary g W Initials: FHA Muhratata Frxad Rare ND" • IWQ5 Page I of 2 V Online Dcc=antr. lnc. CAPRDNRBS,43b 12/13/2012 12:24:39 PM PAGE 38/097 888- 294 -5658 LOAN 11 23210010496 (C) Payment of Costs and Expenses If Lander has required immediate payment in full, as described abova, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' tees for enforcing this Note to the extent not prohibited byapplicable law. Suchfees and costs shag bearinterestfrom the dats of disbursement atthesame rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means. the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOT#CES Unless applicable law requires a different method, any notice that must be given. to Borrower under this Note will be given by defiverfng It or by malfing it by first class mail to Borrower at the property address above or at a different address it Borrower has given Lender a nonce of Borrower's different address. Any notice that must be given to Lender under this mote will be given by first class mad to Lender at the address stated In Paragraph 4(5) or at a different address il Borrower is given a notice of that different address. 9. 051-€GA71014S OF PERSONS UNDER THIS NOTE It more then one person signs this Note, each person Is fully and personally obligated to keep all of the promises made in this Note, including the prom iaeto paythefull amountowed. Anypersonwho is aguarantor, suretyor endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises mach in this Note. Lender may enforce its rlgbl,% Noteagainsteachperson individ oragainstall signatories together, Anyone person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the ter I r1� tars Note. (seal.} KICHAEL A. 1WCE 1ER /r / (Seal) DORIS t>BZ,e PAYTOTHEOMMOF ISTRSE BAWOFAMMIGAMA j' rr� N PAY TO THE ORDER OFD'"" A • BY , M���R . WITHOUT RECOURSE SENN AVMPRIES1DEW urm, iNc. d /b /a VFK CONS= ANTS, INC., A XARYLADtD CORPORATION FHA Multrstaia Faced R ate Ncta - i oies Online Downtem. Ine. Page 2 of 2 PaT00Np7 D" EXHIBIT B Zucker, Goldberg & Ackerman, LLC EXHIBIT A ALL THAT CERTAIN piece or _parcel of land, situate in the x'ownship of LOWCT Aflen, County of Cumberland and State ofTennsylvania, more particularly bounddd and described as follows. to wit: BEGINNING at a point, the northeast corner of 'pillage Road and Highland Drive; thence in an easterIv direction along Highland Drive 60 feet to Lot No. 18 on the hereinafter mentioned Plan of Lots; thence in a northerly direction along said Lot No. 18, 120 feet to Lot No. 40 on said PIan; thence in a westerly direction along Lot No. 40, 80.8 feet to Village Road; thence in a southerly direction along Village Road, 121.96 feet to the place of BEGINNING- BEING Lot No. 19 in the Plan of Highland village as recorded in The Cumberland County Recorder's Office in Plan Book No. 3, Page 98. HAVING THEREON erected a single brick dwelling house being , mow -n and numbexcd as 37 Highland Drive, Camp Hill, Permsylvania. VERIFICATION Mc i Do he ` Ehmon, hereby states that he is N( ' fIJr ' f ' S'I'dF-rJ4 of Bank of America, NA, Plaintiff in this matter, that he/ he is authorized to make this Verification and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his e knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. all 3J I Name: Doddf Title: ASST - YIaP&iJ'de- W By: Bank of America, N.A. File No: 185388 Borrower Name: Doris Delp a /k /a Doris M. Delp Rpr.04 2014 7:36AM ZGR 9086547861 p.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to CIVIL DIVISION BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing LP NO,. f)L41Q O -.� Plaintiff vs. a t ?'� Doris Delp a /k /a Doris M. Delp; Michael A. Weltmer Defendants ' NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live In the residential property which Is the subject of this foreclosure action, you may be able to participate In a court - supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible For a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MldPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet In the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It Is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal.can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit, proceeds forward. Zucker, Goldberg & Ackerman, LLC XFP- 185388 ,Rpr.04 2014 7:36RM ZGR 9086547861 p.2 IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & AC 4,AN, LL r B Dated: Scott A. Dietter , Esquire; PA I.D. #55650 6 Kimberly A. BoArier, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvla, Esquire; PA I.D, #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 r Jana Fridfinnsdottlr, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP- 185388/jpa 200 Sheffield Street, Suite 101 Mountainside, N1 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoIdberg.com Zucker, Goldberg & Ackerman, LLC XFP- 185366 Rpr.004 2014 7:36RM ZGR 9086547861 p.3 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete- your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM .. I MARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupled? Yes ❑ No ❑ Mailing Address .(If different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people In household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Horne: Office: Cell: Other: Email: # of people In household: How long? INFORMATION FINANCIAL First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Zucker, Goldberg & Ackerman, LLC XFP- 185388 Apr 0 04 2014 7:368M ZGR 9086547861 p,4 sets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ S Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ AAuti omoblle #1 ; Model: Year: Amount owed: Value: Automobile #2 ; Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2 • Monthly amount: Borrower Pay Days: Co- Borrower Pay Days; Monthly Expenses (Please only Include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT 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/AIIm. I Spending Money Da /Child Care/Tuit. I Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Tucker, Goldberg & Ackerman, LLC XFP- 185388 s Rpr.404 2014 7:36AM. 2GR 8086547861 p.5 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes [] No ❑ If yes, please Indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please Indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name); Contact: Phone: AUTHORIZATION 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: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Llsting agreement (If property Is currently on the market) Zucker, Goldberg & Ackerman, LLC XFP- 185388 r Rpr_,04 2014 7:36AM ZGR 9086547861 P.6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to CIVIL DIVISION BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP NO.; Plaintiff,. vs. Doris Delp a /k /a Doris M. Delp; Michael A. Weltmer; Defendants, REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court - supervised conciliation conference, The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa-C.S. § 4904 relating to unworn falsification to authorities, Signature of Defendant's Counsel /Appolnted Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker, Goldberg & Ackerman, LLC XFP- 185388 Apre,04 2014 7:36AM ZGR 9086547861 p,7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to CIVIL DIVISION SAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP NO.: Plaintiff, VS. Doris Delp a /k /a Doris M. Delp; Michael A. Weltmer, Defendants. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,the defendant /borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court - supervised conciliation Conference on at .M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant /borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Concillatlon Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Concillatlon Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Zucker, Goldberg & Ackerman, LLC XFP- 185388 r , Rpr+ - 04 2014 7:36AM ZGR 9086547861 p'8 Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative In advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender Is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. nce, the parties and their counsel shall be prepared to discuss and 4. At the Conciliation Confere explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate In the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the Institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, I J. 1 Zucker, Goldberg & Ackerman, LLC XFP- 185388 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY TI1E PROT OP 20111 APR R Ali 10: CUMBERLAND COUNTY PENNSYLVANIA ot Ciraribt,,4 OFF FCE OF ilFE ERFP Bank of America N.A. vs. Doris Delp (et al.) Case Number 2014-2046 SHERIFF'S RETURN OF SERVICE 04/07/2014 06:29 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Doris Delp at 37 Highland Drive, Lower Allen Township, Camp Hill, PA 17011. NOAH CLINE, DEPUTY 04/07/2014 06:29 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Doris Delp, girlfriend, who accepted as "Adult Person in Charge" for Michael A Weltmer at 37 Highland Drive, Lower Allen Township, Camp Hill, PA 17011. SHERIFF COST: $60.95 April 08, 2014 (C) CountySehe Sheriff: Theosoh, NOAH CLINE, DEPUTY SO ANSWERS, RONI4 R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP, Plaintiff, vs. Doris Delp a/k/a Doris M. Delp; Michael A. Weltmer; Defendants. Mortgaged Premises: 37 Highland Drive, Camp Hill, PA 17011 CIVIL DIVISION No.: 14 -2046 -CIVIL ISSUE NUMBER: TYPE OF PLEADING: ....,fir, PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa. I.D. #55650 Kimberly A. Bonner, Esquire- Pa. I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh Levy Marin, Esquire- Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-185388 03,4 .SOPci rji 7357`I #31av9E Praecipe for Entry of Judgment Zucker Goldbgrg & Ackerman, LLC X 85388 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp; Michael A. Weltmer; Defendants. CIVIL DIVISION NO.: 14 -2046 -CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above -captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiffs Complaint within the appropriate time limits from service thereof, and assess Plaintiffs damages as set forth in Complaint: Amount as set forth in Complaint $154,000.97 plus interest on the judgment amount ($154,000.97) from April 1, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 37 Highland Drive address is: Camp Hill, PA 17011 Dated: L j BY: 0 1:A & CKERMAN, LLC Scott A. Dietterick, Esquire; PA. I.D. #55650 Kimberly A. Bonner, Esquire; PA. I.D. #89705 Ralph M. Salvia, Esquire; PA I.D. #202946 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Denise Carlon, Esquire; PA I.D. #317226 Brian Nicholas, Esquire; PA I.D. #317240 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-185388 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com DAMAGES ARE HEREBY SSESSED AS INDICATED Date Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XFP-185388 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp; Michael A. Weltmer; Defendants. CIVIL DIVISION NO.: 14 -2046 -CIVIL AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true and correct to the best of my knowledge, information, and that: 1) The Defendants Doris Delp a/k/a Doris M. Delp, Michael A. Weltmer are not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; Zucker, Goldberg & Ackerman, LLC XFP-185388 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. Dated: i D i r! tp, ( y Sworn to and subscribed before me This f(p day of CZ -0304 , 20 /4 fa c, Notary Public My Commission Expires: BY: ❑ Scott A. Dietterick, Esquire; PA. I.D. #55650 0 Kimberly A. Bonner, Esquire; PA. I.D. #89705 Ralph M. Salvia, Esquire; PA I.D. #202946 Joel A. Ackerman, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 ❑ Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 O Brian Nicholas, Esquire; PA I.D. #317240 O Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-185388 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com & ACKERMAN, LLC PAUL C. NADRATOWSKI Notary Public of New Jersey ID# 2407850 My Commission Expires 4/27/2016 Zucker, Goldberg & Ackerman, LLC XFP-185388 Department of Defense Manpower Data Center tus Report want to Sery ceme nbers Civil Relief Act. Last Name: DELP First Name: DORIS Middle Name: M Active Duty Status As Of: Oct -15-2014 Results as of : Oct -15-2014 06:23:25 AM SCRA 3.0 • On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status - Service Component NA NA No NA This response reflects the Individuals' active duty status based on the Ave Duty Status Date Left Actltie'Duty Within 367 Days "of Active Duty Status Date Active Duty Start Date ' Active Duty End Date Status Service Conponent NA NA No NA This response reflects where the Individual left active duty status within 367 dayspreceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future CaIFUp to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date ' Status Service Component NA NA No - - NA This response reflects whether the individual or his/her unit has received early notificationtoreport 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(0 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: VET2ID56V0B2BBO 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: ZE047D16F0B3M20 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp; Michael A. Weltmer; Defendants. CIVIL DIVISION NO.: 14 -2046 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Doris Delp a/k/a Doris M. Delp 37 Highland Drive Camp Hill, PA 17011 [ ] Plaintiff [V] Defendant [ ] Additional Defendant � 1 You are hereby notified that an rder, Decree or Judgment was entered in the above captioned proceeding on [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $154,000.97 Prothonotary Zucker, Goldberg & Ackerman, LLC XFP-185388 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp; Michael A. Weltmer; Defendants. CIVIL DIVISION NO.: 14 -2046 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Michael A. Weltmer 37 Highland Drive Camp Hill, PA 17011 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on SCOL \I‘i [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $154,000.97 plus costs. ems., ,�is) Prothonotary Zucker, Goldberg & Ackerman, LLC XFP-185388 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp Michael A. Weltmer Defendant. TO: Michael A. Weltmer 37 Highland Drive Camp Hill, PA 17011 DATE OF NOTICE: 10/1/2014 CIVIL DIVISION NO.: 14 -2046 -CIVIL 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 again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp Michael A. Weltmer Defendant. TO: Michael A. Weltmer 37 Highland Drive Camp Hill, PA 17011 CIVIL DIVISION NO.: 14 -2046 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:10/1/2014 USTED ESTA EN REBELDL4 PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SINLLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICft A ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Scoff- A. DU.tte rL4 k. Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 185388 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp Michael A. Weltmer Defendant. TO: Doris Delp a/k/a Doris M. Delp 37 Highland Drive Camp Hill, PA 17011 DATE OF NOTICE: 10/1/2014 CIVIL DIVISION NO.: 14 -2046 -CIVIL 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 again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., successor by merger to BAC . Home Loan Servicing, LP fka Countrywide Home Loans Servicing, LP Plaintiff, vs. Doris Delp a/k/a Doris M. Delp Michael A. Weltmer Defendant. TO: Doris Delp a/k/a Doris M. Delp 37 Highland Drive Camp Hill, PA 17011 CIVIL DIVISION NO.: 14 -2046 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:10/1/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABG UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS ] PORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICU A ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Sco-H- A. D i.e ferix4c, Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 185388 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Bank of America N.A. vs. Doris Delp (et al.) Case Number 2014-2046 SHERIFF'S RETURN OF SERVICE 04/07/2014 06:29 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Doris Delp at 37 Highland Drive, Lower Allen Township, Camp Hill, PA 17011. NOAH CLINE, DEPUTY 04/07/2014 06:29 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Doris Delp, girlfriend, who accepted as "Adult Person in Charge" for Michael A Weltmer at 37 Highland Drive, Lower Allen Township, Camp Hill, PA 17011. SHERIFF COST: $60.95 April 08, 2014 µt) CountySuite Shontt. TolcosoIt Inc NOAH CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF