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HomeMy WebLinkAbout14-2214 Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: Cumberland County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required hy law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition S ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff s Name: Bank of America, N.A., Lead Defendant's Name: Hank P. Donovan; Lori C successor by merger to BAC Home Loans Servicing, Donovan T LP f /k/a Countrywide Home Loans Servicing, LP I Dollar Amount Requested: El within arbitration limits Are money damages requested ?: ❑ Yes ® No Check one � ( ) ®outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: Christopher A. DeNardo, Esquire ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not ❑ Employment Dispute: include mass tort) Discrimination E ❑ Slander /Libel/Defamation ❑ Employment Dispute: Other C F Other: ❑Zoning Board T ❑ Other: I ❑ Other: O MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 1 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 I `; ?.` c`,'•' r �! . Ci.,; �,.._.• TELEPHONE: (610)278 -6800 S & D FILE NO. 14- 045463 Bank of America, N.A., successor by merger COURT OF COMMON PLEAS to BAC Home Loans Servicing, LP f/k/a CIVIL DIVISION Countrywide Home Loans Servicing, LP CUMBERLAND COUNTY PLAINTIFF 11 VS. Hank P. Donovan 58 Quarry Hill Road Newville, PA 17241 Lori Donovan 58 Quarry Hill Road Newville, PA 17241 DEFENDANTS COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Q Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 14- 045463 Bank of America, N.A., successor by merger COURT OF COMMON PLEAS to BAC Home Loans Servicing, LP f/k/a CIVIL DIVISION Countrywide Home Loans Servicing, LP CUMBERLAND COUNTY PLAINTIFF NO: VS. Hank P. Donovan 58 Quarry Hill Road Newville, PA 17241 Lori Donovan 58 Quarry Hill Road Newville, PA 17241 DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP, the address of which is, 400 Countrywide Way, Simi Valley, California 93065 -6298, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage Mortgagee Mortgage Electronic Registration Systems, Inc., as nominee for Countrywide Bank, FSB, its successors and assigns Mortgagor(s) Hank P. Donovan and Lori Donovan (b) Date of Mortgage July 11, 2008 (c) Place and Date of Record of Mortgage Recorder of Deeds Cumberland County Document ID# 200823818 Date: July 14, 2008 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments Assignor: Mortgage Electronic Registration Systems, Inc. Assignee: Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f /k/a Countrywide Home Loans Servicing, LP Date of Assignment: March 3, 2012 Recording Date: March 7, 2012 Instrument No.: 201206779 The Assignment(s) is /are a matter a matter of public record and are therefore incorporated herein as provided by Pa. R.C.P. No. 1019(g). 2. Plaintiff is either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by operation of law. 3. The real property that is subject to the Mortgage is generally known as 58 Quarry Hill Road, Newville, PA 17241 and is more specifically described as attached as part of Exhibit "A ". 4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by the Mortgage (the "Promissory Note "). The Plaintiff, directly or through an agent, has possession of the Promissory Note. The Promissory Note is either made payable to the Plaintiff or has been duly endorsed. A true and correct copy of the Promissory Note is attached and marked as Exhibit "B ". 5. The names and mailing addresses of the Defendants are: Hank P. Donovan, 58 Quarry Hill Road, Newville, PA 17241 and Lori Donovan, 58 Quarry Hill Road, Newville, PA 17241. 6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 7. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of March 1, 2013 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 8. The following amounts are due as of March 31, 2014: Principal Balance Due $178,531.89 Interest Currently Due and Owing at 6.5% $13,538.70 From February 1, 2013 through March 31, 2014 it Late Charges $480.34 Escrow Advances $3,095.45 Corporate Advances $94.10 Suspense/Unapplied Balance ($2.14) TAL $195,738.34 9. Interest continues to accrue for each month that the debt remains unpaid, and Plaintiff may incur other expenses, costs and charges collectible under the Note and Mortgage. 10. In addition to the above amounts, reasonably incurred attorney's fees and costs as well as proof of title in conformity with the mortgage documents and Pennsylvania law, shall be sought by Plaintiff and included in any request for judgment. 11. Notice of Intention to Foreclose with the information required pursuant to 41 P.S. § 403 commonly known as Act 6 and demand for payment was sent to each individual Defendant by Certified and Regular Mail. Copies of the Notice are attached as Exhibit "C ". 12. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. § 1707- 1715z -18). Accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & DeNARDO, LLC Date: l BY: Attorneys for Plaintiff S & D File No. 14- 045463 h ' �M v1 Prepared Sy; ROBERTA WEIDMAN COUNTRYWIDE BANK, F'SB 2512 EASTERN BOULEVARD #25 YORK PA 17402 After Recording Return To; COUN'T'RYWIDE BANK, FSB MS SV -79 DOCUMENT PROCESSING P.O.Box 10423 Van Nuys,, CA 91410 -0423 Parcel Number- 31-10-0618-005 Premises; 58 QUARRY HILL RD NEWVILLE PA 17241 -9403 [Space Above This Line For Recording Data] ase [Doc ID #] C0m i n on w e a lth of Pennsylvania MORTGAGE MIN THIS MORTGAGE ( "Security Instrument ") is given on JULY 11, 2008 FHA Pennsylvania Mortgage with MFRS - 4196 MERS FHA Mortgage-PA 1004N•PA (11l07)(dlf) Page 1 of 1 0 Amended 6102 h gib, '�►� CASE #: DOC ID #: . The Mortgagor is HAND P DONOVAN, AND LORI DONOVAN, HUSBAND AND WIFE ( "Borrower "). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. ( "MERS "), (solely as nominee for Lender, as hereinafter defined, and Lender's successors and assigns), as mortgagee. MERS is organized and existing under the laws of Delaware, and has an address and telephone n Box 2026, Flint, MI 98501 -2026, tel, (888) 679 -MERS, umber t P.O. e COUNTRYWIDE BANK, FSB ( "Lender. ") is organized and existing under the laws of THE UNITED STATES address of , and lips an 1199 North Fairfax St. Ste-500, Alexandria, VA 22314 Borrower owes Lender the principal sum of ONE HUNDRED EIGHTY NINE THOUSAND FIVE HUNDRED TWO and 00/100 Dollars (U.S. $ .169, 502 .0 0 • ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ( "Note "), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on AUGUST 01, 2038 This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with Interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and die Note, For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS, the following described property located in CUMBERLAND County, Pennsylvania; MERS FHA Mongrige•PA 1004N.PA (11107) Pago 2 of 10 CASE #s DOC ID #c SEE EXHIBIT "A" ATTACHED HERETO AND MADE A PART HEREOF. which has the address of 58 QUARRY HILL RD, NEWVILLE )Sheet, city) Pennsylvania 17241.9403 ("Property Address "); [Zip Code] TOGETHER WITH all the Improvements now or hereafter erected on the property,, and all easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shalt also be covered by this •Security Instrument. All of the foregoing iv referred to In this Security Instrument as the "Property," Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument; but, if necessary to comply with law or custom, MERS, (as nominee for Lender and Lender's successors and assigns), has the right; to exercise any or all of those interests. Including, but not IlMted to, the right to foreclose and sell tho Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower Is lawfully seized of the estate hereby conveyed and has the right to mortgage, 'grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record, THUS SECURITY INSTRUMENT combines uniform covenants for national use and non - uniform covenants with limited variations by Jurisdiction to constitute a uniform security instrument covering real property. Borrower and Lender covenant and agree as follows UNIFORM COVENANTS, 1. Payment of Principal, Interest and Late Charge, Borrower shall pay when due die principal of, and Interest on, the debt evidenced by the Note and late charges due under the Note, 2. Monthly Payment of Taxes, Insurance and Other Charges, Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph A. In any year In which the MFRS FHA Mortgage -PA 1004N -PA (11107) Page 3 of 10 CASE #: DOC YD #: _ Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development (Secretary "), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also Include either: (1) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (11) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, In a reasonable amount to be determined by the Secretary, Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds," Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 el seq. and implementing regulations, 24 CPR Part 3500, as they may be amended from time to time ( "RESPA "), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium, If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RE SPA, Lender shall account to Borrower for the excess funds as required by RESPA, if the amounts of funds held by Lender at any time are not sufficient to pay. the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The 'Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with die balance remaining for all installment items (a), (b), and (c) and any mortgage Insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrowers account shall be credited with any balance remaining for all installments for items (a), (b), and Q. 3, Application of Payments, All payments under paragraphs I and 2 shall be applied by Lender as follows: 119, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage Insurance premium; "con , to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Thj, d, to interest due under the Note; Fourth, to amortization of the principal of the Note; and Fif 11h, to late charges due under the Note. 4. Fire, Flood. and Other )hazard insurance, Borrower shall insure all improvements on the Property, whether now In existence or subsequently erected, against any hazards, casualties, and'contingencles, Including fire, for which Lender requires Insurance: This Insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure ail improvements on the Property, whether now In existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include. loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each Insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may he applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied In the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application MERS FHA Mongage•PA 1004N.PA (11107) Page 4 of 10 CASE #: DOC ID #: _ of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments, Any excess Insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extingulshes the indebtedness, all right, title and Interest of Borrower In and to Insurance policies in force shall pass to the purchaser. 5, Occupancy, Preservation, Maintenance and Protection of the Properly; Borrower's Loan Application; Leaseholds, Borrower shall occupy, establish, and use the Property w Borrowers principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted, Lender may inspect the Property if the Property is vacant or.abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default If Borrower, during the loan application process, gave materially false or inaccurate Information or statements to Lender (or failed to provide Lender with any material Information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument Is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires fee tide to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger In writing. 6. Coudemnation. The proceeds of any award or claim for damages, direct or consequential, In connection will► any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the Indebtedness under the Note and this Security instrument, first to any delinquent amounts applied-in the order provided In paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone die due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments, Any excess proceeds over an amount.required to pay all outstanding Indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in tbe-Property. Borrower shall pay-all governmental arzmunicipal charges, fines and impesttlons that are not included in paragraph 2. Borrower shall pay these obligations on Ume directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements• contained in Oils Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard Insurance and other items mentioned In paragraph 2, MFRS FHA Mortgage-PA 1004N -PA (11 /07) Page 5 of 10 • CASE #; DOC ID W: Any amounts disbursed by Lender wider this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument, These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees In wrlUng to the payment of the obligation secured by the lien In it manner acceptable to Lender; (b) contests In good faith the lien by, or defends against enforcement of the lien in, -legal proceedings which in the Lender's opinion operate to prevent the enforcement of the hen; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the property Is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien, Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary, 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations Issued by the Secretary, In the case of payment defaults, require Immediate payment in full of all sums secured by this Security Instrument (1) Borrower defaults by failing to pay In full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment, or (if) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument, (b) Sale Without Credit Approval, Lender shall, if permitted by applicable law (including Section 341(d) of the Gam -St. Germain Depositary Institutions Act of 1982, 12 U,S.C. 1701] -3(d)) an Security Instrument If: d with the prior approval of the Secretary, require immediate payment in full of all sums secured by this (1) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved In accordance with the requirements of the Secretary. (e) No Waiver. If circumstances occur that would permit Lender to require Immediate payment.In fu U, but Lender does not require such payments, Lender does not waive Its rights with respect to subsequent events. (d) Regulations of HUD Secretary. In many circumstances regulations Issued by the Secretary will limit Lender's rights, In the case of payment defaults, to requite immediate payment bi full and foreclose if not paid. This Security Instrument does not authDrize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured, Borrower agrees that if this Security :Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at Its option, require Immediate payment in full of all sums secured by this Security Instrument.. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be, deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of Insurance is solely due to Lenders failure to remit a mortgage.insurance premium to the Secretary, MERS FHA Mortgage -PA 1004N.PA (11107) Page 6 of 10 CASE #: DOC ID # 10. Reinstatement. Borrower has a right to be reinstated If Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are Instituted. To reinstate the Security Instrument, Borrower shall tender In a lump sum all amounts required to bring Borrower's account current Including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that It secures shall remain in effect as If Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement IP (1) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (Ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in Interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor In interest. Lender shall not be required to commence proceedings against any successor In interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors In interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy, 12. Successors and- Assigns Bound; Joint and Several Liability; Co- Signers. The covenants and agreements of tilts Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be Joint and several, Any Borrower who co -signs this Security Instrument but does not execute the Note; (a) Is co- signtng this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under die terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; m and accommodations with regard to the t tee e rms of this cur ty In Instrument t or d Vi m Note without that Borrowers consent. 13. Notleca, Any notice it) Borrower provided for in this Security Instrument shall be given by delivering it or by .mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any ocher address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mall io Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given-to Borrower or Lender when given as provided in this paragraph, 14. Governing Law; Severablllty. This Security Instrument shall be governed by Federal law and the law of the Jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable, IS, Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument, 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or ire the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law, The preceding two sentences shall MFRS FHA Mortgage -PA 1004N -PA (11107) Page 7 of 10 CASE #: DOC ID #: not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residentlal.uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediadon of any Hazardous Substances affecting (he Property Is necessary, Borrower shall promptly take all necessary remedial actions In accordance with Environmental Law. As used In this paragraph 16, "Hazardous Substances" are Orose substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON- UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. To the extent permitted by applicable law, Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property, Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents, However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under Oils paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property befbre or after giving notice of breach to Borrower. However, Lender or a Judicially appointed receiver may do so at any time there.is a breach, Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of die Property shall terminate when the debt secured. by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instniment by judicial proceeding and Invoke- any other remedies permitted by applicable law. -Lender shall be entitled to collect all expenses incurred in pursuing the remedies -provided in this paragraph 18, including, but sot limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the- Secretary requires Immediate payment in full under Paragraph 9, the Secretary may Invoke the no"Judleia) power of sale provided is the Slugle Family Mortgage Foreclosure Act of 1994 ( "Act ") (12 U.S.C. 3751 el seq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing In the preceding sentence sball deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law, MGRS FHA Mortgage -PA 1004N -PA (11107) Page a of 10 CASE # ■ -- DOC ID )) : ■ 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instnument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs, 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future Iaws providing for -stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 2I. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 22, Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, Otis Security Instrument shall be a purchase money mortgage. 23. Interest Rate After Judgment, Borrower agrees that the interest rate payable after a Judgment is entered on the Note or In an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated Into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part df this Security Instrument, (Check applicable box(es)). ❑ Condominium Rifler ❑ Growing Equity Rider ❑ Planned Unit Development Rider ❑ Graduated Payment Rider ❑ Other (specify] BY SIGNING BELOW, Borrowet accepts and agrees to the terms contained In this Security Instrument and In any rider(s) executed by Borrower and recorded with it. HANK P . DONOVAN (Seal) Borrower Z LORI DONOVAN - - Borrower (Seal) - 'Borrower (Seal) Borrower MFRS FHA Monoage•PA 1004N -PA (11107) Page 9 of 10 , CASE DOC ID #; COMMONWEALTH OF PENNSYLVANIA, ����° County ss; On thls, _ ll day of 0 ( , before me, the undersigned officer. personally appeared known to me (or satisfactorily proven) to be the person(s) whose name(s) Is/are subscribed to the wlthtn instrument and ucknowledged that he /shelthey executed the same for the purposes herein contained, IN WITNESS WHEREOF, I hereunto set my ban and official seal. My Commission Expires! Krlaten 0. Shiva, Not zA�C�Yi, Notaripl eal J ..�. ; ..� f ,•`^ Notary Publio Camp HM 6oro, Dumhartand County Title f Officer I MUMM412" Ire J n 20 8 Certiflca ,pf �slil e I ', '� U ,-(, do hereby certify that the correct address of the with named Mortgagee is RO. 0ox 2026, Flint, MI 48501- 2020.. Witness my hand thi day of Agent of Mortgagee ME RS FHA Mongaaa -PA 104N. PA (11/07) Page 10 of 10 ALL THAT FOLLOWING DESCRIBED REAL ESTATE LYING AND BEING SITUATE IN PENN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING AND INTENDED TO BE ALL, OF THE LANDS OF THE GRANTORS OTHER THAN LOT 3A AND BEING THE REMAINDER AFTER PRIOR CONVEYANCE OF LOT 3A ALL AS IN SHOWN ON SURVEY PLAN ENTITLED "FINAL SUBDIVISION PLAN FOR LEE D. KEESEMAN" PREPARED BY ERIC L. DIFFENBAUGH, PROFESSIONAL LAND SURVEYOR, WHICH SUBDIVISION PLAN WAS APPROVED BY THE APPROPRIATE MUNICIPAL AUTHORITIES AS AND FOR A SUBDIVISION PLAN, UNDER WHICH PLAN IS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 76, PAGE 58, MORE PARTICULARLY DESCRIBED AS FOLLOWS; BEGINNING AT A POINT IN THE CENTERLINE OF PUBLIC ROAD T -3'66 (ALSO KNOWN AS QUARRY HILL ROAD), WHICH POINT IS A COMMON CORNER OF THE WITHIN DESCRIBED PARCEL OF LANDS NOW OR FORMERLY OF THOMAS R, AND CONNIE A. MCCARTY (WHICH LANDS OF MCCARTY IS ALSO LOT 4 ON PLAN RECORDED IN CUMBERLAND COUNTY PLAN BOOK 48, PAGE 98), THENCE ALONG CENTERLINE OF QUARRY HILL ROAD, SOUTH THIRTY -SIX (36) DEGREES THIRTY (30) MINUTES ZERO (0) SECONDS EAST, ONE HUNDRED FIFTY AND ZERO HUNDREDTHS (150.00) FEET TO A POINT AT COMMON CORNER OF THE WITHIN DESCRIBED PARCEL AND LANDS NOW OR FORMERLY OF SHIRLEY BISCUIT; THENCE ALONG COMMON BOUNDARY LINE OF THE WITHIN DESCRIBED PARCEL AND LANDS NOW OR FORMERLY OF SHIRLEY BISCUIT, SOUTH FIFTY -THREE (53) DEGREES THIRTY (30) MINUTES ZERO (0) SECONDS WEST, TWO HUNDRED TWENTY -FIVE (225.00) FEET TO AN EXISTING IRON PIN; THENCE CONTINUING BY THE SAME SOUTH FIFTY -FOUR (54) DEGREES EIGHTEEN (I8) MINUTES ZERO (0) SECONDS WEST, TWO HUNDRED FIVE AND FIFTY -TWO HUNDREDTHS (205.52) FEET TO A SET IRON PIN, AT COMMON CORNER OF TIME WITHIN DESCRIBED LOT AND LANDS NOW OR FORMERLY OF RICHARD J. AND DIANA M. TONKIN (WHICH TONKIN LANDS ARE DESIGNATED AS LOT 3A ON THE HEREIN REFERRED TO SUBDIVISION PLAN); THENCE ALONG COMMON BOUNDARY LINE OF LANDS OF TONKIN, NORTH TWENTY -FOUR (24) DEGREES FIFTY -TWO (52) MINUTES TWENTY -TWO (22) SECONDS EAST, ONE HUNDRED FIFTY -TWO AND EIGHTY -FOUR HUNDREDTHS (152.84) TO A SET IRON PIN; THENCE CON'T'INUING ALONG SAME, NORTH FIFTY-FOUR (54) DEGREES SEVENTEEN (17) MINUTES ZERO (0) SECONDS EAST, ONE HUNDRED SEVENTY -FIVE AND SIXTEEN HUNDREDTHS (175.16) FEET TO AN EXISTING IRON PIN AT COMMON CORNER OF THE WI'T'HIN DESCRIBED PARCEL AND LANDS NOW OR FORMERLY OF THOMAS R. AND CONNIE A. MCCARTHY; THENCE ALONG LINE OF LANDS NOW OR FORMERLY OF MCCARTHY, NORTH FIFTY -THREE (53) DEGREES THIRTY (30) MINUTES ZERO (0) SECONDS EAST, TWO HUNDRED TWENTY -FIVE AND ZERO HUNDREDTHS (225,00) FEET TO THE POINT AND PLACE OF BEGINNING. Y ROBERT P. ZIEG•LER RECORDER Or DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE - =� CARLISLE, PA 17013 71.7.240.6370 z � ° Instrument Number - 200823818 Recorded On 7/14/2008 At 10;31:56 AM * Total Pages - 12 * Instrument Type - MORTGAGE Invoice Number - 25023 User ID - RAK * Mortgagor - DONOVAN, HANK P Mortgagee - MORTGAGE ELECTRONIC REGISTIRATION SYSTEMS INC * Customer - 1ST ADVANTAGE * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $10.00 JUSTICE DO NOT DETACH RECORDING FEES — $25.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 This page is now part C OUNTY ARCHIVES FEE $2.00 of this legal document. ROD ARCHIVES FEE $3.00 TOTAL PAID $52.50 I Certify this to be recorded in Cumberland County PA RECORDER O A DS irno * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page, OOOW9D If III�II��IIIIIiDIi�I�IIN CRPRDNRBS46a 3/13/2012 1:20:39 PM PAGE 34/089 888 - 294 -5658 Prepared by: ROBERTA WEIDMAN multistate NOTE JULY 11, 2008 [Datni 58 QUARRY HILL RD, NEWILLE, PA 17241 -9403 (Prop -y Addressj i. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns- "Lender" means COUNTRYWTDE BANK, FSS and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, lormwer p romise& to p the p rincipal sum of ONE HUNDRED EIGHTY NI %E THOUSAND FIVE HUNDRED TWO and 00/100 Dollars (U.S. Si as, 502. oo ) plus interest, to the order of Lender. Interestwill be charged on unpaid principal, from the date of dLsbursement of the loan proceeds by Lender, at the rate of six & ONE -HALF percent ( 6.500 95) per year until the full amount of principal has been paid, 3. PROMISE TO PAY SECURED Borrowers promise to pay is secured by a Mortgage, Deed of Trust or similar security Instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from lasses which might result If Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on SEPTEIsMER 01, 2008 Any principal and interest remaining on the first day of AUGUST, 2038 will be due an that date, which Is called the "Maturity Date.' (13) Place Payment shall be made at P.O. Box 560694, Dallas, TX 75266 - 0694 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and Interest will be in the amount of U.S. $1, 197.78 This amount will be part of a larger monthly payment requlred by the Securlty InsWment, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) AtIonge to this Note for payment adjustments If an allonge providing for payment adjustments Is executed by Borrower together with this Note, the covenants of the allonge shall he incorporated Into and shall amend and supplement the covenants of this Note as If the allonge were a part of this Note, [Check applicable box) ❑ Graduated Payment Allonge ❑ Growing Equity Allonge ❑ Other [specify] S. Y30PXOWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays Interest on the amount prepaid for the remainder of the month to the extent required by Lender and perruitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes, 6. BORROWER'S FAILURE TO PAY (A) Late Chime for Overdue P"ents If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due. Lender may collect a late charge in the amount of FOUR percent ( 4. 000%) of the overdue amount of each payment . (B) Did'ault If Borrower defaults by falling to pay In full any monthly payment, then Lender may, except as limited by regulations of die Secretary in the case of payment defaults, require immediate payment in 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 arty subsequent default. In marry circumstances regulations issued by the Secretary will limit Lender's tights to require immediate payment in full in the case o€ F Fixed Rate Note 20018 -M 104!07) (0) Pagel of 2 FHA Mattistate Fixed Rate Nota - 10195 1� P� CRPRDNRBS46a 3/13/2012 1:20:39 PM PAGE 35/089 888- 294 -5658 CRPRDNRBS46a 3/13/2012 1:20:39 PM PAGE 36/089 888- 294 -5658 } CASE ii • LOAN 4: - payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If lender has required immediate payment in full, as described above, Tender may require Borrower to pay costs and expenses Including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable late. Such fees and costs shall bear Interest from the date of disbursement at the same rate as the principal of this Note. 7. WAVERS 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. S. GIVING OFNOTiCES Unless applicable law requires a different method, any notice that must be given to Borrower under this Nate will he given by delivering It or by mailing It by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mall to lender at the address stated In Paragraph 4(8) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS MER THIS NOTE If more than one person signs this Note, each person Is fully and personally obligated to keep all of the promises made In this Note, including the promise to pay the full amount owed. Any person wbo is a guarantor, surety or 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 made in this Note. Lender may enforce its rights under this Note against each person Individually or against all signatories together. Any one person signing this Mote may be required to pay all of the amounts owed under this Note. BY SfGNING, BELOW, Borrower accepts and agrees to the terms and covenants contained in this Nole. (Seat) tiAP73C P . AONOVRN - Borrower (Seal) L R1 DO VAN Borrower F l To 71!g URGER OF � + rCOum (Seal) Cm1wavi'DE - Borrower BY lAl,'.ni'f nMrC¢R - Borrower SEMOR NICEPzaDga F Fixed Rats NotO 2001 R -XX (04107) Page 2 or 2 FHA Muttirlate Fixed Rate Note - t0t98 PRESORT PO Box 9048 First -Class Mail Temecula, CA 92589 -9048 U.S. PoFees stage and 2269589932 WSO 20130118 -7 HANK P DONOVAN 58 Quarry Hill Rd Newville, PA 17241 -9403 C3_1445 BLQPA2 14091 08/24/2011 W ' January 18, 2013 Account No.: HANK P DONOVAN 58 Quarry Hill Rd Newville, PA 17241 -9403 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear HANK P DONOVAN, The MORTGAGE held by BANK OF AMERICA, N.A. and serviced by Bank of America, N.A. (hereinafterwe, us or ours) on your property located at 58 Quarry Hill Rd Newville, PA 17241, IS IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts shown below for the months of 11/01/2012 - 01131/2013. Monthly Charges: 11/01/2012 - 11/30/2012 @ $1560.83 $1,560.83 12/01/2012 - 01/3112013 @ $1562.97 $3,125.94 Late Charges: 11/01/2012 - 11/30/2012 @ $62.43 $62.43 12/01/2012 - 01/31/2013 @ $62.52 $125.04 Other Charges: Additional Uncollected Late Charges: $230.38 Uncollected Costs: $79.10 Partial Payment Balance: 0.00 TOTAL DUE: $5,183.72 Late charges and other charges have also accrued to this date in the amount of $496.95. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $5,183.72. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $5,183.72, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at Bank of America, N.A.at P.O. Box 15222, Wilmington, DE 19886 -5222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property, if the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day period, you will not be required to pay attorney's fees. 2269569932 We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1- 800 - 669.4578. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. if you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year." C3_3222_BRECDISC 15352 09/24112 IMPORTANT DISCLOSURES If you are currently in a bankruptcy proceeding, or have previously obtained a discharge of this debt under applicable bankruptcy law, this notice is for information only and is not an attempt to collect the debt, a demand for payment, or an attempt to impose personal liability for that debt. You are not obligated to discuss your home loan with us or enter into a loan modification or other loan- assistance program. You should consult with your bankruptcy attorney or other advisor about your legal rights and options. Bank of America, N.A., the servicer of your home loan, is required by law to inform you that this communication is from a debt collector. There has been a payment default or other default on your loan that could result in acceleration of all sums due under the Note. As a result, Bank of America, N.A. will use companies, including its affiliates LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, N.A., and LandSafe Appraisal Services, Inc., to provide services required to protect the Noteholder's interest and rights in the property and under the note and security instrument, including any remedies thereunder (the "Default Related Services "). Bank of America, N.A. will assess fees to your loan account for the Default Related Services, including those provided by its affiliates. A schedule of fees that may be charged to your account for Default Related Services is available at the following web address: htto://www.bankofamerica.com/defaultfees If you do not have internet access, please contact us at 1- 800 - 669 -6607, Monday through Thursday 8 a.m. - 11 p.m. Eastern, Friday 8 a.m. - 9 p.m. Eastern, Saturday 9 a.m. - 3 p.m. Eastern, to have a fee schedule mailed to you. The fee schedule contains a complete list of the default - related services you could be charged, but does not include a complete list of all fees or charges that could be assessed on your loan account. MILITARY PERSONNEL /SERVICEMEMBERS If you or your spouse is a member of the military, please contact us immediately. The federal Servicemembers Civil Relief Act and comparable state laws afford significant protections and benefits to eligible military service personnel, including protections from foreclosure as well as interest rate relief. For additional information and to determine eligibility please contact our Military Assistance Team toll free at 1- 877 - 430 -5434. If you are calling from outside the U.S. please contact us at 1 -817- 685 -6491. L YM E 2269589932 ° DIVULGACIONES IMPORTANTES Si usted se encuentra actualmente en un procedimiento de quiebra, o ha obtenido previamente una exoneraci6n de esta deuda bajo la ley aplicable sobre quiebra, este no es un intento de recaudaci6n, una demanda de pago o un intento de imponer una responsabilidad personal por esa deuda. Usted no este obligado(a) a hablar de su prestamo para vivienda con nosotros ni a participar en un programa de modificaci6n de prestamos u otro programa de asistencia para prestamos. Usted debe consultar con su abogado especializado en quiebras u otro asesor acerca de sus opciones y derechos legales. Bank of America, N.A., el administrador de su prestamo para vivienda esta obligado por ley a informarle a usted que esta comunicaci6n proviene de un cobrador de deudas. Ha ocurrido un incumplimiento de pago u otro tipo de incumplimiento con su prestamo que podria resultar en la aceleraci6n de todas las cantidades adeudadas bajo el Pagare. Como resultado, Bank of America N.A. utilizare companias, incluyendo sus afiliados LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, NA, y Landsafe Appraisal Services, Inc., para proporcionar servicios necesarios pars proteger los intereses del Titular en la propiedad y sus derechos bajo el instrumento de seguridad y el pagare, incluyendo cualquiera de sus recursos (los " Servicios relacionados a un incumplimiento "). Bank of America, N.A. aplicare cargos a la cuenta de su prestamo por los servicios relacionados a un incumplimiento, incluyendo los servicios proporcionados por sus afiliados, Una lists de los cargos que podrian cobrarse a su cuenta por servicios relacionados a un incumplimiento esta disponible en el sitio de Internet: [ hftr)://www.bankofamerica.com/defaultfees ]. Si usted no tiene acceso a internet, por favor comuniquese con nosotros al 1- 800 - 669 -6607 de lunes a jueves de 8 a. m. a 11 p. m. hora del este, viernes de 8 a. m. a 9 p. m. hora del este, sebados de 9 a. m. a 3 p. m. hora del este. para pedir que se le envie una lists de cargos por correo. La lista de cargos contiene una lists completa de los servicios relacionados por incumplimiento que le podian cobrar, pero no incluye una lists completa de todos los costos y cargos que podrian ser aplicados a la cuenta de su prestamo. PERSONAL MILITAR/ MIEMBROS DE LAS FUERZAS ARMADAS: Si usted o su c6nyuge es un miembro del servicio militar, por favor comuniquese con nosotros inmediatamente. La Ley federal de Ayuda Civil para Miembros de las Fuerzas Armadas y las ]eyes estatales comparables otorgan protecciones y beneficios significativos al personal del servicio militar que califique inc]uidas protecciones contra la ejecuci6n hipotecaria asi como tambien ayuda en la tasa de interes. Para obtener mss informaci6n y determinar su calificaci6n por favor Ilame sin costo a nuestro Equipo de Asistencia para el Servicio Militar al 1- 877 - 430 -5434. Si usted llama desde fuera de los Estados Unidos por favor comuniquese con nosotros al 1 -817- 685 -6491. 2269569932 C3_5088 OPTAVDFC 15319 09/2412012 Options are Available to'Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. +j Options to consider if your goal is to stay in your home .... :: :......:.::....... ::: :::: . Home Affordable A federal government program that allows you to repay the loan on newly agreed upon terms, Modification which may include lowering the interest rate, placing past due amounts at the end of the loan, Program (RAMP) and/or extending the term of the loan. You may be eligible for this program if you meet the following requirements: • The amount you owe on the first mortgage is equal to or less than $729,750 for a single - family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have documented a financial hardship and represented that you do not have sufficient liquid assets to make the monthly mortgage payments. • Your mortgage was obtained before Jan. 1, 2009. • The property securing the mortgage loan has not been condemned or is not in such poor physical condition that it is not habitable even if not condemned • The mortgage is secured by a one to four unit property Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the Reinstatement loan up to date until the day of your foreclosure sale. Repayment Plan A repayment plan allows you to make your regularly scheduled mortgage payments, plus pay off a portion of the past due amounts over time. This may include principal, interest, fees, and /or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and /or collection of payments Forbearance for a period of time, to allow you to re- establish your ability to make the required payments. Agreement Loan Modification A loan modification is a change to the original terms of your loan. Loan modifications could (non -RAMP) include lowering your interest rate, extending the term or maturity date of the loan, moving from an adjustable to a fixed -rate loan, deferring some portion of the unpaid principal balance to the end of the loan, and /or forgiving some portion of the unpaid principal balance. Partial Claim (FHA If you have a Federal Housing Administration (FHA) loan and your payments are past due but loans only) you are now able to make your regular monthly mortgage payment, this program is designed to bring your loan up to date by creating a second mortgage /lien on your property for the amount that is past due. p Options to consider if you cannot or do not wish to stay in your home Home Affordable Designed to help borrowers who are eligible for the Home Affordable Modification Program Foreclosure (HAMP) but were unsuccessful in securing a permanent modification through the program. Alternatives HAFA provides the option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A Program (HAFA) short sale is a transaction in which you sell your property for less than the total amount owed on the loan (subject to agreement by your servicer /lender /investor), resulting in the release of our lien on your home and avoidance of foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ If you can no longer afford to make your mortgage payments and your home is worth less than Pre - foreclosure you owe, a short sale may allow you to sell your home to pay off the mortgage. In a short sale, Sale (non -HAFA) the lender agrees to accept an amount less than what is actually owed on the loan. Offered to borrowers who are not eligible for HAMP or other home retention alternatives. Deed in Lieu of Used as an alternative to foreclosure, with a deed in lieu of foreclosure, you transfer ownership Foreclosure of your house and all property secured by your mortgage loan. This may satisfy the total (non -HAFA) amount due on that mortgage. Offered to borrowers not eligible for HAMP or other home ?! retention alternatives, and who were not able to sell the property through a short sale. t' We are here to help you. Please call us today. 2269589932 Hay opciones disponibles para ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notificacion adjunta para obtener mas informacion Cuando Ilame, por favor tenga a la mano la informacion de sus ingresos y gastos para que podamos discutir cuales opciones podrian funcionar para usted. Opciones a considerar si su objetivo es permanecer en su casa p. P. ?: :•i: J': i::::;:::::: ii: ?::::::i iii:: \::::ti:::::::::i:::i : i::i ::i:i:::: ?: • ::: :.i� Home Affordable Es un programa del gobierno federal que le permite pagar el prestamo bajo los nuevos Modification terminos acordados, que pueden incluir la reduccibn de la tasa de interes, agregar Program (RAMP) cantidades vencidas al final del prestamo, y/o extender el plazo del prestamo. Usted puede calificar pars este programa si cumple con los siguientes requisitos: • La cantidad que usted adeuda de su primera hipoteca es igual o menor que $729,750 dolares para una vivienda unifamiliar, $934,200 dolares para una propiedad de 2 unidades, $1,129,250 dolares pars una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades • Usted ha documentado que atraviesa por una dificultad financiera y declarado que no tiene suficiente liquidez pars hacer los pagos mensuales de la hipoteca. • Obtuvo su hipoteca antes del 1 de enero de 2009. • La propiedad que garantiza el prestamo hipotecario no ha sido condenada o no este en malas condiciones fisicas como para no poder habitarse incluso si no este condenada. • La hipoteca esta garantizada por una propiedad de una a cuatro unidades. Restablecimient Si usted puede poner al dia los pagos de su prestamo, aceptaremos los fondos necesarios o del Prestamo para que el prestamo este al dia hasta la fecha de la venta por ejecucidn hipotecaria. Plan de Pago Un plan de pago le permite a usted hacer sus pagos hipotecarios regulares, ademes de pagar una porcion de los montos vencidos a traves del tiempo. Esto puede incluir capital, interes, cargos o costos aplicados a su prestamo. Acuerdo Es un acuerdo en el cual aceptamos no proceder con la ejecucion hipotecaria y/o el cobro Temporal de de los pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia por hater los pagos requeridos. incumplimiento Modificacion de Una modificacibn del prestamo es un cambio en los terminos originales de su prestamo, Prdstamo Las modificaciones podrian incluir reducir su tasa de interes, extender el termino o la fecha (no por medio de pago del prestamo, cambiar de un prestamo de tasa de interes ajustable a uno de tasa de HAMP) de interes fija, diferir una parte del saldo del capital impagado al final del prestamo, y/o condonar una parte del saldo de capital impagado. Reclamo Parcial Si usted tiene un prestamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos (solamente estan vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, prestamos de la este programa este disenado para que su prestamo este al dia mediante la creacibn de FHA) una segunda hipoteca / gravamen sobre su propiedad por el monto que esta vencido. 2269589932 • Y Opciones a considerar si no puede o no desea quedarse en su casa Home Affordable Disenado para ayudar a los prestatarios que califican para el Programa de Home Foreclosure Affordable Modification (RAMP), pero no consiguieron obtener una modificacion Alternatives permanente a traves del programa. HAFA ofrece la posibilidad de una vents en Program (HAFA) descubierto y, si no tiene exito, una escritura de traspaso voluntario de propiedad en lugar de la ejecuci6n hipotecaria. Una venta en descubierto es una transaccibn en la que usted vende su propiedad por menos de la cantidad adeudada en el prestamo (sujeto a previo acuerdo de su administrador / prestamista / inversionista), resultando en la liberacion de nuestro derecho de retencion sobre su propiedad y evitar la ejecuci6n hipotecaria, Una escritura de traspaso voluntario de propiedad en lugar de la ejecuci6n hipotecaria es una transaccibn en la que usted este de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. Venta en Si usted ya no puede hacer sus pagos hipotecarios y su vivienda vale menos de to que descubierto/ usted adeuda, una vents en descubierto le podria permitir vender su vivienda para pagar Venta previa a la la hipoteca. En una vents en descubierto, el prestamista acepta recibir una monto menor ejecuci6n de to que actualmente se adeuda en el prestamo. Se ofrece a los prestatarios que no hipotecaria (no por califican para HAMP o para otras alternativas de retencion de la vivienda. medio de HAFA) Escritura de Se usa Como una alternativa de la ejecuci6n hipotecaria. Con una escritura de traspaso traspaso de voluntario de propiedad en lugar de la ejecuci6n hipotecaria, usted transfiere la titularidad propiedad en lugar de su vivienda y toda la propiedad que garantiza su prestamo hipotecario. Esto puede de la ejecuci6n hater que el monto total vencido de esa hipoteca se considere como pagado. Se ofrece a hipotecaria (no por prestatarios que no califican para HAMP u otras opciones de retencibn de vivienda, y que medio de HAFA) no pudieron vender la propiedad a traves de una yenta en descubierto. Estamos aqui para ayudarle. Por favor Ilamenos hoy. PRESORT PO Box 9048 First -Class Mail Temecula, CA 92589 -9048 U.S. Postage and Fees Paid 2269589931 WSO 20130118 -7 �Illl�lll�llllll�lllll�l�ll Illll�l�lll�ll�l�l Ilnll�ll�nllll�l�� LORI DONOVAN 58 Quarry Hill Rd Newville, PA 17241 -9403 lUlty: C3_1445 BLQPA2 14091 08/24/2011 January 18, 2013 Account No.: LORI DONOVAN 58 Quarry Hill Rd Newville, PA 17241 -9403 NOTICE OF INTENTION TO FORECLOSE MORTGAGE Dear LORI DONOVAN, The MORTGAGE held by BANK OF AMERICA, N.A. and serviced by Bank of America, N.A. (hereinafter we, us or ours) on your property located at 58 Quarry Hill Rd Newville, PA 17241, IS IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts shown below for the months of 11/01/2012 - 01/3112013. Monthly Charges: 11/01/2012 - 11/30/2012 @ $1560.83 $1,560.83 12/01/2012 - 01/31/2013 @ $1562.97 $3,125.94 Late Charges: 11/01/2012 - 11/30/2012 @ $62.43 $62.43 12/01/2012 - 01/31/2013 @ $62.52 $125.04 Other Charges: Additional Uncollected Late Charges: $230.38 Uncollected Costs: $79.10 Partial Payment Balance: 0.00 TOTAL DUE: $5,183.72 Late charges and other charges have also accrued to this date in the amount of $496.95. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $5,183.72. You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount of $5,183.72, plus any additional monthly payments and late charge which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at Bank of America, N.A.at P.O. Box 15222, Wilmington, DE 19886 -5222. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property, if the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. if you cure the default within the thirty day period, you will not be required to pay attorney's fees. 2269589931 We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges Dien due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale [and perform any other requirements under the mortgage]. It is estimated that the earliest date that such a Sheriffs sale could be held would be approximately six (6) months from the date of this Notice. A notice of the date of the Sheriff sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1- 800 - 669 -4578. This payment must be in cash, cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that a Sheriffs sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, [AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED]. CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST]. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year." / r C3_3222_BRECDISC 15352 09/24/12 IMPORTANT DISCLOSURES If you are currently in a bankruptcy proceeding, or have previously obtained a discharge of this debt under applicable bankruptcy law, this notice is for information only and is not an attempt to collect the debt, a demand for payment, or an attempt to impose personal liability for that debt. You are not obligated to discuss your home loan with us or enter into a loan modification or other loan- assistance program. You should consult with your bankruptcy attorney or other advisor about your legal rights and options. Bank of America, N,A., the servicer of your home loan, is required by law to inform you that this communication is from a debt'collector. There has been a payment default or other default on your loan that could result in acceleration of all sums due under the Note. As a result, Bank of America, N.A. will use companies, including its affiliates LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc,, LandSafe Title of Texas, Inc,, ReconTrust Company, N.A., and LandSafe Appraisal Services, Inc., to provide services required to protect the Noteholder's interest and rights in the property and under the note and security instrument, including any remedies thereunder (the "Default Related Services "). Bank of America, N.A. will assess fees to your loan account for the Default Related Services, including those provided by its affiliates. A schedule of fees that may be charged to your account for Default Related Services is available at the following web address: httr)://www.bankofamerica.com/defauItfees - If you do not have internet access, please contact us at 1- 800 - 669 -6607, Monday through Thursday 8 a.m. - 11 p.m. Eastern, Friday 8 a.m. - 9 p.m. Eastern, Saturday 9 a.m. - 3 p.m. Eastern, to have a fee schedule mailed to you. The fee schedule contains a complete list of the default - related services you could be charged, but does not include a complete list of all fees or charges that could be assessed on your loan account. MILITARY PERSONNELISERVICEMEMBERS If you or your spouse is a member of the military, please contact us immediately. The federal Servicemembers Civil Relief Act and comparable state laws afford significant protections and benefits to eligible military service personnel, including protections from foreclosure as well as interest rate relief. For additional information and to determine eligibility please contact our Military Assistance Team toll free at 1- 877 - 430 -5434. If you are calling from outside the U.S. please contact us at 1 -817- 685 -6491. 2269589931 ` DIVULGACIONES IMPORTANTES Si usted se encuentra actualmente en un procedimiento de quiebra, o ha obtenido previamente una exoneraci6n de esta deuda bajo la ley aplicable sobre quiebra, este no es un intento de recaudaci6n, una demanda de pago o un intento de imponer una responsabilidad personal por esa deuda. Usted no est6 obligado(a) a hablar de su pr6stamo para vivienda con nosotros ni a participar en un programa de modificaci6n de prestamos u otro programa de asistencia para pr6stamos. Usted debe consultar con su abogado especializado en quiebras u otro asesor acerca de sus opciones y derechos legales. Bank of America, N.A., el administrador de su pr6stamo para vivienda estt obligado por ley a informarle a usted que esta comunicaci6n proviene de un cobrador de deudas. Ha ocurrido un incumplimiento de pago u otro tipo de incumplimiento con su pr6stamo que podria resultar en la aceleraci6n de todas las cantidades adeudadas bajo el Pagare. Como resultado, Bank of America N.A. utilizar6 comp&ilas, incluyendo sus afiliados LandSafe Default, Inc., LandSafe Services, LLC., LandSafe Title of California, Inc., LandSafe Title of Washington, Inc., LandSafe Title of Florida, Inc., LandSafe Services of Alabama, Inc., LandSafe Title of Texas, Inc., ReconTrust Company, NA, y LandSafe Appraisal Services, Inc., para proporcionar servicios necesarios para proteger los intereses del Titular en la propiedad y sus derechos bajo el instrumento de seguridad y el pagar6, incluyendo cualquiera de sus recursos (los "Servicios relacionados a un incumplimiento "). Bank of America, N.A. aplicar6 cargos a la cuenta de su pr6stamo por los servicios relacionados a un incumplimiento, incluyendo los servicios proporcionados por sus afiliados. Una lists de los cargos que podrian cobrarse a su cuenta por servicios relacionados a un incumplimiento esttl disponible en el sitio de Internet: [ hftp:// www. bankofamerica.com /defaultfees Si usted no tiene acceso a internet, por favor comuniquese con nosotros al 1- 800 - 669 -6607 de lunes a jueves de 8 a. m. a 11 p. m. hora del este, viernes de 8 a. m. a 9 p. m. hora del este, sE%bados de 9 a. m. a 3 p. m. hora del este. pars pedir que se le envie una lists de cargos por correo. La lista de cargos contiene una lista complete de los servicios relacionados por incumplimiento que le podian cobrar, pero no incluye una lists completa de todos los costos y cargos que podrian ser aplicados a la cuenta de su pr6stamo. PERSONAL MILITAR/ MIEMBROS DE LAS FUERZAS ARMADAS: Si usted o su c6nyuge es un miembro del servicio militar, por favor comuniquese con nosotros inmediatamente. La Ley federal de Ayuda Civil para Miembros de las Fuerzas Armadas y las leyes estatales comparables otorgan protecciones y beneficios significativos al personal del servicio militar gue califioue incluidas protecciones contra la ejecuci6n hipotecaria asi Como tambi6n ayuda en la tasa de inter6s. Para obtener mss informaci6n y determinar su calificaci6n por favor Ilame sin costo a nuestro Equipo de Asistencia para el Servicio Militar al 1- 877 - 430 -5434. Si usted llama desde fuera de los Estados Unidos por favor comuniquese con nosotros al 1- 817 -685 -6491. 2269589931 C3_5088 OPTAVDFC 15319 09/24/2012 Options are Available to Help You Avoid Foreclosure Call the number on the enclosed notice to learn more. When you call, please have your income and expense information available so we can discuss which option(s) could work for you. Options to consider if your goal is to stay in your home re m ....................::::::::::.:._::.::::::::::<:::>::. ion................ ................... Home Affordable A federal government program that allows you to repay the loan on newly agreed upon terms, Modification which may include lowering the interest rate, placing past due amounts at the end of the loan, Program (RAMP) and /or extending the term of the loan. You may be eligible for this program if you meet the following requirements: • The amount you owe on the first mortgage is equal to or less than $729,750 for a single - family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or $1,403,400 for a 4 unit property • You have documented a financial hardship and represented that you do not have sufficient liquid assets to make the monthly mortgage payments. • Your mortgage was obtained before Jan. 1, 2009. • The property securing the mortgage loan has not been condemned or is not in such poor physical condition that it is not habitable even if not condemned • The mortgage is secured by a one to four unit property Loan If you can bring your loan payments up to date, we will accept the funds needed to bring the Reinstatement loan up to date until the day of your foreclosure sale. Repayment Plan A repayment plan allows you to make your regularly scheduled mortgage payments, plus pay off a portion of the past due amounts over time. This may include principal, interest, fees, and/or costs assessed to your loan. Temporary An agreement whereby we agree not to proceed with foreclosure and /or collection of payments Forbearance for a period of time, to allow you to re- establish your ability to make the required payments. Agreement Loan Modification A loan modification is a change to the original terms of your loan, Loan modifications could (non -HAMP) include lowering your interest rate, extending the term or maturity date of the loan, moving from an adjustable to a fixed -rate loan, deferring some portion of the unpaid principal balance to the end of the loan, and /or forgiving some portion of the unpaid principal balance. Partial Claim (FHA If you have a Federal Housing Administration (FHA) loan and your payments are past due but loans only) you are now able to make your regular monthly mortgage payment, this program is designed to bring your loan up to date by creating a second mortgage /lien on your property for the amount that is past due. Options to consider if you cannot or do not wish to stay in your home 0 , ...... Home Affordable Designed to help borrowers who are eligible for the Home Affordable Modification Program Foreclosure (HAMP) but were unsuccessful in securing a permanent modification through the program. Alternatives HAFA provides the option of a short sale and, if unsuccessful, a deed in lieu of foreclosure. A Program (HAFA) short sale is a transaction in which you sell your property for less than the total amount owed on the loan (subject to agreement by your service r /lender /investor), resulting in the release of our lien on your home and avoidance of foreclosure. A deed in lieu of foreclosure is a transaction in which you agree to voluntarily transfer ownership of your property to us in order to avoid foreclosure. Short Sale/ If you can no longer afford to make your mortgage payments and your home is worth less than Pre - foreclosure you owe, a short sale may allow you to sell your home to pay off the mortgage. In a short sale, Sale (non -HAFA) the lender agrees to accept an amount less than what is actually owed on the loan. Offered to borrowers who are not eligible for HAMP or other home retention alternatives. Deed in Lieu of Used as an alternative to foreclosure, with a deed in lieu of foreclosure, you transfer ownership Foreclosure of your house and all property secured by your mortgage loan. This may satisfy the total (non -HAFA) amount due on that mortgage, Offered to borrowers not eligible for HAMP or other home retention alternatives, and who were not able to sell the property through a short sale. V �1C We are here to help you. Please call us today. 2269589931 M Hay opciones disponibles para ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notification adjunta para obtener mas information Cuando Ilame, por favor tenga a la mano la informaci6n de sus ingresos y gastos para que podamos discutir cuales opciones podrian funcionar para usted. Opciones a considerar si su objetivo es permanecer en su casa cad»::.:.:...........:.:::. �::::. � ::::............ ........ :::::::.:::.........:.. .......... .... . Home Affordable Es un programa del gobierno federal que le permite pagar el pr6stamo bajo los nuevos Modification t6rminos acordados, que pueden incluir la reducci6n de la tasa de inter6s, agregar Program (HAMP) cantidades vencidas al final del pr6stamo, y/o extender el plazo del pr6stamo. Usted puede calificar para este programa si cumple con los siguientes requisitos: • La cantidad que usted adeuda de su primera hipoteca es igual o menor que $729,750 d6lares para una vivienda unifamiliar, $934,200 d6lares para una propiedad de 2 unidades, $1,129,250 d6lares para una propiedad de 3 unidades o $1,403,400 para una propiedad de 4 unidades • Usted ha documentado que atraviesa por una dificultad financiera y declarado que no tiene suficiente liquidez para hacer los pagos mensuales de la hipoteca. • Obtuvo su hipoteca antes del 1 de enero de 2009. • La propiedad que garantiza el pr6stamo hipotecario no ha sido condenada o no est6 en malas condiciones fisicas como para no poder habitarse incluso si no est6 condenada. • La hipoteca est6 garantizada por una propiedad de una a cuatro unidades. Restablecimient Si usted puede poner al dia los pagos de su pr6stamo, aceptaremos los fondos necesarios o del Prestamo para que el pr6stamo est6 al dia hasta la fecha de la venta por ejecuci6n hipotecaria. Plan de Pago Un plan de pago le permite a usted hater sus pagos hipotecarios regulares, adem6s de pagar una porci6n de los montos vencidos a trav6s del tiempo. Esto puede incluir capital, inter6s, cargos o costos aplicadcs a su pr6stamo. Acuerdo Es un acuerdo en el cual aceptamos no proceder con la ejecuci6n hipotecaria y/o el cobro Temporal de de los pagos por un periodo de tiempo, para permitirle que restablezca su habilidad de Tolerancia por hater los pagos requeridos. incumplimiento Modificaci6n de Una modificaci6n del pr6stamo es un cambio en los t6rminos originales de su pr6stamo, Prdstamo Las modificaciones podrian incluir reducir su tasa de inter6s, extender el t6rmino o la fecha (no por medio de pago del pr6stamo, cambiar de un pr6stamo de tasa de inter6s ajustable a uno de tasa de HAMP) de inter6s fija, diferir una parte del saldo del capital impagado al final del pr6stamo, y/o condonar una parte del saldo de capital impagado. Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA) y sus pagos (solamente est6n vencidos, pero ahora puede hater sus pagos regulares mensuales de la hipoteca, prbstamos de la este programa est6 disenado para que su pr6stamo este al dia mediante la creaci6n de FHA) una segunda hipoteca / gravamen sobre su propiedad por el monto que est6 vencido. 2269589931 Opciones a considerar si no puede o no desea quedarse en su casa Home Affordable Disenado pars ayudar a los prestatarios que califican para el Programa de Home Foreclosure Affordable Modification (HAMP), pero no consiguieron obtener una modificacibn Alternatives permanente a traves del programa. HAFA ofrece la posibilidad de una venta en Program (HAFA) descubierto y, si no tiene exito, una escritura de traspaso voluntario de propiedad en lugar de la ejecucion hipotecaria. Una venta en descubierto es una transaccibn en la que usted vende su propiedad por menos de la cantidad adeudada en el prestamo (sujeto a previo acuerdo de su administrador / prestamista / inversionista), resultando en la liberacibn de nuestro derecho de retencibn sobre su propiedad y evitar la ejecucion hipotecaria. Una escritura de traspaso voluntario de propiedad en lugar de la ejecucion hipotecaria es una transaccibn en la que usted esta de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de.evitar la ejecucion hipotecaria. Venta en Si usted ya no puede hacer sus pagos hipotecarios y su vivienda vale menos de to que descubierto/ usted adeuda, una venta en descubierto le podria permitir vender su vivienda para pagar Venta previa a la la hipoteca. En una vents en descubierto, el prestamista acepta recibir una monto menor ejecucion de to que actualmente se adeuda en el prestamo. Se ofrece a los prestatarios que no hipotecaria (no por califican para HAMP o pars otras alternativas de retencibn de la vivienda. medio de HAFA) Escritura de Se usa Como una alternativa de la ejecucion hipotecaria. Con una escritura de traspaso traspaso de voluntario de propiedad en lugar de la ejecucion hipotecaria, usted transfiere la titularidad propiedad en lugar de su vivienda y toda la propiedad que garantiza su prestamo hipotecario. Esto puede de la ejecucion hater que el monto total vencido de esa hipoteca se considere Como pagado. Se ofrece a hipotecaria (no por prestatarios que no califican para HAMP u otras opciones de retencibn de vivienda, y que medio de HAFA) no pudieron vender la propiedad a traves de una venta en descubierto. Estarnos aqui para ayudarle. Por favor Iliamenos hoy. P �-- ,� / VERIFICATION `✓�e111 ` hereby states that hel�is of Bank of America, N.A., Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of NO 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. ame y�e,•��' /�� DATE: .F�!// /� �� Title: X9,-0 Company: Bank of America, N.A. S & D FILE NO: 14- 045463 Hank P. Donovan and Lori Donovan 4 B G • f { ' T x - FORM 1 : IN THE COURT OF COMMON PLEAS OF Bank of America, N.A., successor by merger to BAC ; CUMBERLAND COUNTY, Home Loans Servicing, LP f/k/a Countrywide Home PENNSYLVANIA ra Loans Servicing, LP Plaintiff(s)" Vs. Hank P. Donovan 58 Quarry Hill Road Newville, PA 17241. � Lori Donovan 58 Quarry Hill Road Newville, PA 17241 DEFENDANTS Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: SHAPIRO & DeNARDO, LLC qkliq - eL- Date Attorneys for Plaintiff ` b ? FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUST Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes 0 No ❑ Listing Date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes 0 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: Home: Office: Cell: Other: Email: # of people in household How Long? FINANCIAL INF ORMATIO N 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 0 No 0 If yes, provide names, location of court, case number & attorney Assets Amount Owed Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount Owed: Value: Automobile #2: Model: Year: Amount Owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount Owed: Value: Monthly Income: Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthl�Expenses•(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortage Food T 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 Su ort/Alim. Spending Money Day /Child Care /Tuft. I Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No 0 If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 r Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTH ORIZATIO N I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating m financial situation for possible mortgage options. I /We understand that I /We am /are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) r FORM 3 IN THE COURT OF COMMON PLEAS OF Bank of America, N.A., successor by merger to BAC CUMBERLAND COUNTY, PENNSYLVANIA Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP Plaintiff(s) vs. Hank P. Donovan 58 Quarry Hill Road Newville, PA 17241 Lori Donovan 58 Quarry Hill Road Newville, PA 17241 DEFENDANTS Defendant(s) Civil REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date i n FORM 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vS. Defendant(s) Civil CASE MANAGEMENT ORDER AND NOW, this day of , 20, the defendant/borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (2 1) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. z_ r. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT J. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY t1Fr;CF (F TPE S 6FIFF J-vh' RG ,QTHONO FAR,, MAY 23 Mi 10: 18 CUMBERLANDCOUNTY PENNSYLVANIA Bank of America vs. Hank P Donovan (et al.) Case Number 2014-2214 SHERIFF'S RETURN OF SERVICE 04/29/2014 07:51 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Hank P Donovan at 58 Quarry Hill Road, Penn Township, Newville, PA 17241. RYAN BURGETT, DEPI�T� 04/30/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupant, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 58 Quarry Hill Road, Penn Township, Newville, PA 17241. There are no other occupants other than the defendant, Hank P. Donovan. 05/14/2014 05:57 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Lori D. Donovan at 623 West Penn Street, Carlisle, PA 17013. DAWN KELL, DEP SHERIFF COST: $93.90 SO ANSWERS, May 14, 2014 (c) CeuntySu!te Sheriff, Te!eosoft, Inc. RONR ANDERSON, SHERIFF SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045463 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP PLAINTIFF VS. Hank P. Donovan and Lori Donovan DEFENDANTS fr i?°71-140 141? COIVS EN,r� A ND ° " COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:14-2214 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $202,354.59 in favor of the Plaintiff and against the Defendants, jointly and severally, for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of Mortgage Debt Due and Unpaid Interest Accrued Late Charges Escrow Advances Property Inspection Suspense/Unapplied Balance Attorney Fees & Costs of Foreclosure TOTAL BY: bssxtt AND NOW, judgment is entered in favor of damages are assessed as above in the sum of $2b 14-045463 $178,531.89 $17,406.90 $480.34 $4,608.85 $30.00 ($2.14) $1,298.75 $202,354.59 "} 5 tlo. S5 a a +ti IU� ')%? fl 30q ��Cu1Q4 �d�c�e SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045463 Bank of America, N.A., successor by merger COURT OF COMMON PLEAS to BAC Home Loans Servicing, LP f/k/a CUMBERLAND COUNTY Countrywide Home Loans Servicing, LP 400 Countrywide Way 14-2214 Civil Simi Valley, CA 93065 PLAINTIFF VS. Hank P. Donovan and Lori Donovan DEFENDANT(S) STATE OF: Pennsylvania COUNTY OF: Montgomery AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Date: �lj� BY.: Sworn to and subscribed before me this ( day , 2014. Not•. y Public SHAPIRO & DeNARDO, LLC ArAt a eys, ffor Plaintiff isQualu i COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Sharkey, Notary Public Upper Merlon Twp., Montgomery County My Commission Expires Oct. 19, 2014 - Member. Pennsylvania Association of Notaries Department of Defense Manpower Data Center Status Report Pursuant to Servicemem!bers Civil Relief Act. Last Name: DONOVAN First Name: HANK Middle Name: P. Active Duty Status As Of: Aug -01-2014 Results as of : Aug -01-2014 05:0217 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 Active Duty Status Date Left Active Duly Within 307 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ' - NA .Na - F 1 NA This response reflects where the individual left active duty status within 387 Gays preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA ' -No' NA This response reflects whether the individual or his/her unit has received' early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Arrriy, 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 Soldiersand Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above; or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: RCDFCAB110F4E80 Department of Defense Manpower Data Center Status Report Pursuant t©'Servicemembers Civil Relief Act Last Name: DONOVAN First Name: LORI Middle Name: Active Duty Status As Of: Aug -01-2014 Results as of : Aug -01-2014 05:02:18 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 onthe Active Duty Status Date Left Active Duly Within 367 Days of Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA NA .— - u: . No ` NA This response reflects where the individual left active duty status within 307 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No 1 NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. y)t. 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 Soldiersand 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)1Nhether 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 (NOM 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: 2CCFHAE1B0F4890 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY T.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045463 Bank of America, N.A., successor by merger COURT OF COMMON PLEAS to BAC Home Loans Servicing, LP f/k/a CIVIL DIVISION Countrywide Home Loans Servicing, LP CUMBERLAND COUNTY PLAINTIFF NO: 14-2214 Civil VS. Hank P. Donovan and Lori Donovan DEFENDANTS CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, July 15, 2014 to the following Defendants: Hank P. Donovan, 58 Quarry Hill Road, Newville, PA 17241 Lori Donovan, 623 West Penn Street, Carlisle, PA 17013 Meghan Williams, Legal Assistant to Bradley J Osborne for Shapiro & DeNardo, LLC SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045463 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP PLAINTIFF VS. Hank P. Donovan and Lori Donovan DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 14-2214 Civil NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Hank P. Donovan DATE OF NOTICE: July 17, 2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra, Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o Si no tiene dinero suficiente para tal servicio, vaya en persona o Ilame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32, South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Hank P. Donovan, 58 Quarry Hill Road, Newville, PA 17241 Lori Donovan, 623 West Penn Street, Carlisle, PA 17013 Date: SI PIRO & DeNARDO, LLC BY: A o ey r Plaintif (AlM. DONNELLY, SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045463 Bank of America, N.A., successor by merger COURT OF COMMON PLEAS to BAC Home Loans Servicing, LP f/k/a CIVIL DIVISION Countrywide Home Loans Servicing, LP CUMBERLAND COUNTY PLAINTIFF NO: 14-2214 Civil VS. Hank P. Donovan and Lori Donovan DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Lori Donovan DATE OF NOTICE: July 17, 2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o flame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Hank P. Donovan, 58 Quarry Hill Road, Newville, PA 17241 Lori Donovan, 623 West Penn Street, Carlisle, PA 17013 Date: BY: SHA'RO & DeNARDO, LLC A orneys for Plaintiff CAITi SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045463 Bank of America, N.A., successor by merger COURT OF COMMON PLEAS to BAC Home Loans Servicing, LP f/k/a CIVIL DIVISION Countrywide Home Loans Servicing, LP CUMBERLAND COUNTY PLAINTIFF VS. NO:14-2214 Civil Hank P. Donovan and Lori Donovan DEFENDANTS CERTIFICATE OF SERVICE I, Bradley J Osborne, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person(s) or their attorney of record: Hank P. Donovan, 58 Quarry Hill Road, Newville, PA 17241 Lori Donovan, 623 West Penn Street, Carlisle, PA 17013 Date Mailed: Date: BY: SHAPIRO & DeNARDO, LLC or Plaintiff ANT. ESQUIRE SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 14-045463 Bank of America, N.A., successor by merger COURT OF COMMON PLEAS to BAC Home Loans Servicing, LP f/k/a CIVIL DIVISION Countrywide Home Loans Servicing, LP CUMBERLAND COUNTY PLAINTIFF VS. NO:14-2214 Civil Hank P. Donovan and Lori Donovan DEFENDANTS CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Bank of America, N.A,, successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP 400 Countrywide Way Simi Valley, CA 93065 and that the last known addresses of the judgment debtors (Defendants) are: Hank P. Donovan 58 Quarry Hill Road Newville, PA 17241 Lori Donovan 623 West Penn Street Carlisle, PA 17013 Date: 14-045463 BY: SHAPIRO & DeNARDO, LLC 0a:30.in:tiff voz14,404,4 ESQUIRB OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Hank P. Donovan 58 Quarry Hill Road Newville, PA 17241 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP PLAINTIFF VS. Hank P. Donovan and Lori Donovan DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-2214 Civil NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE AT (610)278-6800. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 David D. Buell Prothonotary TO: Lori Donovan 623 West Penn Street Carlisle, PA 17013 Bank of America, N.A., successor by merger to BAC Home Loans Servicing, LP f/k/a Countrywide Home Loans Servicing, LP PLAINTIFF VS. Hank P. Donovan and Lori Donovan DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY CASE NO. 14-2214 Civil NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [] Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE AT (610)278-6800. 1 11