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