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Home My WebLink About14-2781 Supreme Court,Of Pennsylvania ;. , Cour sof Come �n Pleas C3av1'i ` ` � For UseOnl vlif;Cove>r��heet '�' y: C1 iN11iER AND '^ COUnty Docket No: The information collected on this form is used solelyfor court administration put poses. This form does not supplement or replace the•fling and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Bank of America,N.A. Lead Defendant's Name: Mary E.Romito C T Are money damages requested?: ❑Yes ® No Dollar Amount Requested: — within arbitration limits I (Check one) X outside arbitration limits O N Is this a Class Action Suit? ❑Yes ® No Is this an MDI Appeal? ❑Yes ® No Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC A ❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability(does not include S mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT El Other: ❑ Asbestos 0 ❑ Tobacco N ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste El Other: C-1 Ejectment F1 Common Law/Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus B ❑ Landlordfrenant 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A., CIVIL DIVISION l / / -Z Plaintiff, NO.: VS. TYPE OF PLEADING Mary E. Romito; CIVIL ACTION -COMPLAINT Defendant. IN MORTGAGE FORECLOSURE TO: DEFENDANT FILED ON BEHALF OF: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS Bank of America, N.A. FROM SERVICE HEREOF ORA DEFAULT JUDGMENT MAYBE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: ZUCKER,GOLDBERG&ACKERMAN, LLC 400 National Way Simi Valley,CA 93065 Scott A. Dietterick, Esquire '. ANDTHE DEFENDANT: Pa. I.D.#55650 625 Woodland Avenue Kimberly A. Bonner, Esquire Mount Holly Springs,PA 17065 Pa. I.D.#89705 Joel A.Ackerman, Esquire r -t: Pa I.D.#202729 °<C3 i C..) x': C) CERTIFICATE OF LOCATION Ashleigh Levy Marin, Esquire F I HEREBY CERTIFY THAT THE LOCATION OF y ' f THE REAL ESTATE AFFECTED BY THIS LIEN IS Pa I.D.#306799 625 Woodland Avenue,Mount Holly Springs PA 17065 Ralph M. Salvia, Esquire Municipality: South Middleton Pa I.D.#202946 Jaime R.Ackerman, Esquire..— ATTORNEY ORP INTIFF� Pa I.D.#311032 ATTY FILE NO.:XRP 181229 200 Sheffield Street,Suite 101 Mountainside, N1 07092 (908) 233-8500 (908)233-1390 FAX office Pzuckergoldberg.com File No.:XRP-181229/tku owl plc* L4 bbl 26 � � s , r IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE,THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY(30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Mary E. Romito; Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty(20)days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800)990-9108 (717)249-3166 (717) 249-3166 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, NO.. vs. Mary E. Romito; Defendant. AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dial despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800)990-9108 Phone (800) 990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Mary E. Romito; Defendant. CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE And now comes Bank of America, N.A., by its attorneys,Zucker,Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Bank of America, N.A., (hereinafter "plaintiff") having its principal place of business at 400 National Way,Simi Valley,CA 93065. 2. The Defendant, Mary E. Romito, is an individual whose last known address is 625 Woodland Avenue, Mount Holly Springs, PA 17065. 3. Bank of America, N.A., directly or through an agent, has possession of the Promissory Note. Bank of America, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 4. On or about September 12, 2007, Guy A. Romito and Mary E. Romito made, executed, and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Countrywide Bank, FSB, its successors and assigns a Mortgage in the original principal amount of $131,750.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on September 18, 2007, Instrument #200736290. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded April 1, 2013,the mortgage was assigned to Bank of America, N.A. which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument#201310219. The Assignment is a Zucker,Goldberg&Ackerman, LLC XRP-181229 matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Defendants Mary E. Romito and Guy A. Romito,Jr.,as joint tenants with right of survivorship, are the last known record owners of the aforesaid mortgaged premises. Upon the death of Guy A. Romito,Jr.,all decedent's right,title and interest in the aforesaid mortgaged premises is vested to Mary E. Romito by operation of law as a joint tenant with right of survivorship. 7. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due September 1, 2012. 8. As of 05/09/2014 the amount due and owing Plaintiff by Defendants) is as follows: Principal $124,629.82 Interest from 08/01/2012 to 05/09/2014 $16,286.41 Late Charges $363.92 Escrow Advance $2,941.07 Property Inspection $701.30 Other Fees $56.95 Total $144,979.47 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding,this action is in no way an attempt to re-establish such liability. Zucker,Goldberg&Ackerman, LLC XRP-181229 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $144,979.47 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER,GOLDBERG 4ACKERM , LLC BY: Dated: Scott A. Diex{erick, Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032' Attorneys for Plaintiff XRP-181229/tku 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker,Goldberg&Ackerman,LLC XRP-181229 EXHIBIT A Zucker,Goldberg&Ackerman,LLC XRP-181229 I Prepared by,.GNA MOUS _ NOTE SEPTEMBER 12, 2007 HARRISBURG PENNSYLVANIA [Date] Icuyl [State] 625 WOODLAND AVE, MOUNT HOLLY SPRINGS, PA 170651937 [Property Add—s] 1, BQRROWER'S PROMISE TO PAY In return for a loan that I have received,I promise to pay U.S. S 131,750.00 (this amount is called "Principal'),plus interest,to the order of the Lender.The Lender is Countrywide Bank, FSB, I will make all payments under this Note in the form of cash,check or money order. I understand that the Lender may transfer this Note.The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the"Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid.I will pay interest at a yearly rate of 7.375 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A)Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the FIRST day of each month beginning on NOVEMBER 01, 2007 .I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note.Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal.if,on OCSOBER 01, 2037 ,1 still owe amounts under this Note,I will pay those amounts in full on that date,which is called the"Maturity Date." I will make my monthly payments at P.O. Box 660694, Dallas, TX 75266-0694 or at a different place ifreguired by the Note Holder. (B)Amoant of Monthly Payments My monthly payment will be in the amount of U.S.S 9 o 9.96 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due.A payment of Principal only is]mown as a "Prepayment"When I make a Prepayment,I will tell the Note Holder in writing that I am doing so.I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a frill Prepayment or partial Prepayments without paying a Prepayment charge.The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note.However,the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount,before applying my Prepayment to reduce the Principal amount of the Note.If I make a partial Prepayment,there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 5, LOAN CHARGES If a law,which applies to this loan and which sets maximum loan charges,is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits,then:(a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit;and(b)any sums already collected from me which exceeded permitted limits will be refunded to me.The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me.If a refund reduces Principal,the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A)Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of FIFTEEN calendar days after the date it is due,l will pay a late charge to the Note Holder.The amount of the charge will be 5.000 %ofany overdue payment of principal and interest. 1 will pay this late charge promptly but only once on each late payment. (B)Default If I do not pay the full amount of eaeb monthly payment on the date it is due,1 will be in default MULTISTATE FIXED RATE NOTESinde Family-Farmle Mae/Freddie Mac UNIFORM IMMUMENT tm7�air:= A-1 Page 1 or 40-GN(0207).01 CHL(010I04xd) VMP Mortgage Solatlm Inc.(800)521-7209 Form 32001/01 2 3 9 9 1 1 7 9 6 7 1 5 2 8 0 0 0 0 0 2 0 0 5 N (C)Notice of Default If I am in default,the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date,the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount.That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D)No Waiver By Note Holder Even if,at a time when I am in default,the Note Holder does not require me to pay immediately in full as desen-bed above, the Note Holder will still have the right to do so if I am in default at a later time. (E)Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above,the Note Helder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law.Those expenses include,for example,reasonable attomeys'fees. 7. GIVING OF NOTICES Unless applicable law requires a different method,any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A)above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER 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 who 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.The Note Holder may enforce its rights under this Note against each person individually or against all of us together,This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I 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 the Note Holder to demand payment of amounts due.'Notice of Dishonor"means the right to require the Note Holder to give notice to other persons that amounts dun have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions.In addition to the protections given to the Note Holder under this Note,a Mortgage,Deed of Trust,or Security Deed(the"Security Instrument"),dated the same date as this Note,protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note-That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts 1 owe under this Note.Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred(or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in fall of all sums secured by this Security Instrument. However,this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option,Lender shall give Borrower notice of acceleration.The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument.If Borrower fails to pay these sums prior to the expiration of this period,Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. f PAY TO M ORDER OF Countwide Homg LoanIRC•MOUTRECOURSEry -:>7 7-E =NT DE 7QMELryryANS,INC. 8Ya�td�z, WiRESAANDER seccheycEa ;kir D ECUTIVE VICE PRESIDENT WITNESS THE RAND(S)AND SEAL(S)OF THE UNDERSIGNEDD, (Seal) (Seal) GUY A. ROMIIJO -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower !Sign ottinat only] at-SN to2wpi CHL(1 QJod) page 2 of 2 Form 32001/04 EXHIBIT B Zucker,Goldberg&Ackerman, LLC XRP-181229 Schedule C Legal Description ALL the following described--real property situate in South Middletown Township,Cumberland County, Pennsylvania,bounded and described as follows: BEGINNING at a point on the Southern side of Woodland Avenue,said point being at the dividing line between Lot Nos.74 and 37 in the hereinafter Plan of Lots,and said point being 158.1 feet in an Easterly direction from the Eastern side of Highland Avenue;thence South 71 degrees 42 minutes East along the Southern side of said Woodland Avenue,a distance of 76.3 feet to an iron pin at the center line of Lot No. 73;thence South 00 degrees 19 minutes West along said center line of Lot No.73,a distance of 140 feet to an iron pin on the Northern line of Lots Nos. 67 and 68,a distance of 75 feet to an iron pin at the Eastern line of Lot No.36;thence North 1 degree West along the Western line of Lots Nos.36,35,34 and 33,a distance of 140 feet to a point on the Southern side of Woodland Avenue,the place of beginning. BEING Lot Nos.74 and the Western half of Lot No.73 in the Plan of Lots known as'Mountain View Addition",said plan being recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 3,Page 68. HAVING thereon erected a brick dwelling house. BEING Parcel No.40-30-2646-048 VERIFICATION Dodds F-hrmon, hereby states that henshe f, 19(efden of Bank of America, NA, Plaintiff in this matter,that he he)is authorized to make this Verification and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/6-e knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S.Sec.4904 relating to unsworn falsification to authorities. QVOf y123/1y Name: f Title: AUAhWPf/�e1r1 f By: Bank of America, NA File No: 181229 Borrower Name: Mary E. Romito IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION . Plaintiff VS. NO.. Mary E. Romito r' Defendant ',c`� y n �i L CD C-3 C- 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. Zucker, Goldberg&Ackerman, LLC XRP-181229 IF YOU WISH TO SAVE YOUR HOME; YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE.TIDS PROGRAM IS FREE. ZUCKER,GOLDBERG &.ACKERMAN, LLC By: Dated: Scott A. Dietterick, Esquire; PA I.D.#55650 S p`Z Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A. Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime`R.Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XRP-181229/jpa 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoIdberg.com Zucker,Goldberg&Ackerman, LLC XRP-181229 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: CLISTOMER/PRIAPPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes,provide names, location of court,case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Zucker,Goldberg&Ackerman, LLC XRP-181229 Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description(not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: 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? Zucker,Goldberg&Ackerman, LLC XRP-181229 Yes ❑ No ❑ If yes,please indicate the status of those negotiations: Please provide the following information,if known,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation(hardship letter) V Listing agreement(if property is currently on the market) Zucker,Goldberg&Ackerman, LLC XRP-181229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, vs. ' NO.: Mary E. Romito; Defendant. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker,Goldberg&Ackerman, LLC XRP-181229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff VS. NO.: Mary E. Romito Defendant 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. 1. At least twenty-one (21) days prior to the date of the Conciliation Conference,the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. 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 Zucker,Goldberg&Ackerman, LLC XRP-181229 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. 3. 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. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker,Goldberg&Ackerman, LLC XRP-181229 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F Sheriff HE PRQ ; HONd T Jody S Smith 201.11 : 1. Chief Deputy JUN _Li f' 3 Richard W Stewart Solicitor OFFICE OF THE, smERIF CUMBERLAND COUNTY PENNSYLVANIA Bank of America N.A. vs. Mary E Romito Case Number 2014-2781 SHERIFF'S RETURN OF SERVICE 05/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Mary E Romito, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 415 Chestnut Street, Floor 1, Mt. Holly Borough, Mt. Holly Springs, PA 17065. Residence is vacant. 05/23/2014 06:44 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: Mary E Romito at 415 Chestnut Street, Floor 1, Mt. Holly Borough, Mt. Holly Springs, PA 17065. DAWN KELL, DEPUTY SHERIFF COST: $35.91 May 27, 2014 (c) CoutySu!tc Sheriff, Te!eoscff, inc. SO ANSWERS, RONR ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, �> , vs. NO.: 2014-02781 ,., cel Mary E. Romito; y Defendant. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s),for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $144,979.47 plus interest on the judgment amount ($144,979.47)from May 10, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 415 Chestnut Street Fir 1 address is: Mount Holly Springs, PA 17065 ZUCKER, GOLBERG &ACKERMAN, LLC Dated:?/mss/�) BY:� C¢��Q I F] Joel A.Ackerman, Esquire; PA I.D.#202729 ❑ Ashleigh L. Marin, Esquire; PA I.D.#306799 ❑ Jaime R.Ackerman, Esquire; PA I.D.#311032 a Denise Carlon, Esquire; PA I.D. #317226 Brian Nicholas, Esquire; PA I.D.#317240 Roger Fay, Esquire; PA I.D.#315987 Attorneys for Plaintiff XRP-181229 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office@zuckergolcberg.com K DAMAGES ARE HEREBY SSESSED AS INDICATED ;,` Date �w � Prothonot lCr.so d � P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., CIVIL DIVISION Plaintiff No.: 2014-02781 VS. ISSUE NUMBER: Mary E. Romito; TYPE OF PLEADING: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) Mortgaged Premises: 625 Woodland Avenue, Mount Holly Springs, PA FILED ON BEHALF OF: 17065 Bank of America, N.A. Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa. I.D.#55650 Kimberly A. Bonner, Esquire- Pa. I.D.#89705 Joel A.Ackerman, Esquire- Pa I.D.#202729 Ashleigh Levy Marin, Esquire- Pa I.D.#306799 Ralph M. Salvia, Esquire- Pa I.D.#202946 Jaime R. Ackerman, Esquire- Pa I.D.#311032 Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 Brian Nicholas, Esquire- Pa I.D.#317240 Denise Carlon, Esquire-Pa I.D.#317226 Roger Fay, Esquire; PA I.D.#315987 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XRP-181229 Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC XRP-181229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2014-02781 Mary E. Romito; Defendant. AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ZUCKER,GOLBERG &ACKERMAN, LLC Dated: 7 lacy 1�.' BY� ,6 a , cla�pk ' J Joel A.Ackerman, Esquire; PA I.D.#202729 ❑ Ashleigh L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Denise Carlon, Esquire; PA I.D.#317226 Brian Nicholas, Esquire; PA I.D.#317240 Roger Fay, Esquire; PA I.D.#315987 Attorneys for Plaintiff XRP-181229 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Sworn to and subscribed before me This aJ day of Jct. (,� , 20 /y Notary Public Ch My Commission Expires: MyComm. rYYt Debeneadto Notary public Expires Oct 16, 2016 State of New 276 Jersey Zucker,Goldberg&Ackerman, LLC XRP-181229 Department of Defense Manpower Data Center Results as of:Jul-24-2014 07:46:34 AM SCRA 3.0 Status Riepott Pursuant to Servicemembers Civil Relief Act Last Name: ROMITO First Name: MARY Middle Name: E Active Duty Status As Of: Jul-24-2014 NA NA 'No NA This response reflects the Individuals'active duty status based on the Active Duty Status Date WWW loft= rra .. w r ,€ I 7 NA NA I No NA This response reflects where the individual left acti"duty.status within 367 days preceding the Active Duty Status Date NA NA No NA _R! This response reflects whether the Individual or his/her unit has recelved early notlflcatlon 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. iAr 4"4- 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 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.htmi. 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(NOAH 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: 9BT1 PEOCW055550 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2014-02781 Mary E.Romito Defendant. IMPORTANT NOTICE TO: Mary E. Romito 415 Chestnut Street Fir 1 Mount Holly Springs, PA 17065 DATE OF NOTICE: 6/20/2014 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 again you. Unless you act within Ten(10)days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S.Bedford Street 32 S.Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, Vs. NO.: 2014-02781 Mary E. Romito Defendant. AVISO IMPORTANTE TO: Mary E. Romito 415 Chestnut Street Fir 1 Mount Holly Springs, PA 17065 FECHA DEL AVISO:6/20/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CAB O UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS Ev2ORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INNIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S.Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER GOLDBERG&ACKERMAN BY: Sw*A. Di.P�" Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. #55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 181229 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson {{ ['+=;LL J014-CiH"(`�1110 t' p Sheriff Jody S Smith 20111 JUN —4 FM 3: 15 Chief Deputy � Richard W Stewart "° <?` CUMBERLAND cout v Solicitor OFFCEOFT"Et"r.Rw PENNSYLVANIA Bank of America N.A. vs. Case Number Mary E Romito 20142781 SHERIFF'S RETURN OF SERVICE 05/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Mary E Romito, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 415 Chestnut Street, Floor 1, Mt. Holly Borough,Mt. Holly Springs,PA 17065. Residence is vacant. 05/23/2014 06:44 PM.Deputy Dawn Keil,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:Mary E Romito at 415 Chestnut Street,Floor 1,Mt. Holly Borough,Mt. Holly Springs,PA 17065. E DAWN KELL, DEPU . SHERIFF COST:$35.91 SO ANSWERS, May 27,2014 RbNtn R ANDERSON,SHERIFF tc!00u lysw*shwlrt'rwecsor,irtc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A. CIVIL DIVISION Plaintiff, NO.: 2014-02781 VS. Mary E. Romito; Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Mary E. Romito 415 Chestnut Street Fir 1 Mount Holly Springs, PA 17065 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Ord Deeccre or Judgment was entered in the above captioned proceeding on I L ' [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $144,979.47 p costs Prothonotary Zucker,Goldberg&Ackerman, LLC XRP-181229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Bank of America, N.A., Plaintiff, vs. File No. 2014-02781 Amount Due $144,979.47 Interest from 05/11/2014 to date of sale at the Statutory Rate $7,087.29 Mary E. Romito; Costs Defendant. TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installmeht s 1'e, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): S` amksa8.S pd a ,z�S. k\ CC F 1 ID Pet See Exhibit "A" attached ADD ,as t.LeCiL4 -it/06 Com. Zucker, Goldberg & Ackerman, LLC /` U\)t i RP22it PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: Signature: Print Name: Sc•� . Diettsquire Ki • erly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh Levy Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, Esquire Roger Fay, Esquire Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650 89705 202567 201493 202946 315987 Zucker, Goldberg & Ackerman, LLC XRP-181229 Exhibit "A" LEGAL DESCRIPTION ALL the following described real property situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southern side of Woodland Avenue, said point being at the dividing line between Lots Nos. 74 and 37 in the hereinafter Plan of Lots, and said point being 158.1 feet in an Easterly direction from the Eastern side of Highland Avenue; thence South 71 degrees 42 minutes East along the Southern side of said Woodland Avenue, a distance of76.3 feet to an iron pin at the center line of Lot No. 73; thence South 00 degrees 19 minutes West along said center line of Lot No. 73, a distance of 140 feet to an iron pin on the Northern line of Lot No, 67; thence North 70 degrees 37 feet West along the Northern line of Lots Nos. 67 and 68, a distance of 75 feet to an iron pin at the Eastern line of Lot No, 36; thence North I degree West along the Western line of Lots Nos. 36, 35, 34 and 33, a distance of 140 feet to a point on the Southern side of Woodland Avenue, the place of BEGINNING. BEING Lots Nos. 74 and the Western half of Lot No. 73 in the Plan of Lots known as "Mountain View Addition"; said plan being recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book No.3, page 68. Having thereon erected a brick dwelling house. HAVING thereon erected a brick dwelling house being known and numbered as 625 Woodland Avenue, Mount Holly Springs, PA, 17065. BEING the same premises which Guy A. Romito and Mary E. Romito, his wife, as tenants by the entirety, where the aforementioned Guy A. Romito having died on June 24, 1998, thereby vesting full title unto Mary E. Romito„ by Deed dated October 16, 2008 and recorded October 31, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume , Page Instrument #: 200835621, granted and conveyed unto Mary E. Romito and Guy A. Romito, Jr., as joint tenants with right of survivorship. Tax Map No.: 40-30-2646-048. Zucker, Goldberg & Ackerman, LLC XRP-181229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., vs. Mary E. Romito; Plaintiff, Defendant(s). : CIVIL DIVISION NO.: 2014-02781 : Execution No.: AFFIDAVIT PURSUANT TO RULE 3129.1 C3 Bank of America, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 625 Woodland Avenue, Mount Holly Springs, PA 17065. 1. Name and Address of Owner(s) or Reputed Owner(s): MARY E. ROMITO AND GUY A. ROMITO, JR., AS JOINT TENANTS WITH RIGHT OF SURVIVORSHIP 415 Chestnut Street, Floor 1, Mount Holly Springs, PA 17065 2. Name and Address of Defendant(s) in the Judgment: MARY E. ROMITO 415 Chestnut Street, Floor 1, Mount Holly Springs, PA 17065 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: BANK OF AMERICA, N.A. Plaintiff Zucker, Goldberg & Ackerman, LLC XRP-18 1 229 WEST ASSET MANAGEMENT, INC. FOR BANK OF AMERICA 7171 Mercy Road PO Box 6183 Omaha Nebraska 68106-0183 4. Name and Address of the last record holder of every mortgage of record: BANK OF AMERICA, N.A. Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR COUNTRYWIDE BANK, FSB PO Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees Street, Suite C Danville, II 61834 AND 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 AND 1210 Northbrook Dr. #300 Trevose, PA 19053 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 SOUTH MIDDLETON TWP 520 Park Drive Boiling Springs, PA 17007 AND C/0 BOB CAIRNS 520 Park Drive PO Box 40, Boiling Springs, PA 17007 Zucker, Goldberg & Ackennan, LLC XRP-181229 SOUTH MIDDLETON SCHOOL DISTRICT 4 Forge Rd, B oiling Springs, PA 17007 AND C/O BOB CAIRNS 520 Park Drive PO Box 40, Boiling Springs, PA 17007 MOUNT HOLLY SPRINGS BORO AUTH 200 Harman Street Mt Holly Springs, PA 17065 SOUTH MIDDLETON TWP MUN AUTH PO Box 8 Boiling Springs, PA 17007 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 625 Woodland Avenue Mount HoIIy Springs, PA 17065 UNKNOWN SPOUSE 415 Chestnut Street, Floor 1, Mount HoIIy Springs, PA 17065 Zucker, Goldberg & Ackennan, LLC XRP-181229 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: 1-61 ZUCKER, GOLDBERG & ACKERMAN, LLC BY: / Scott A.5tterick, Esquire; PA I.D. #55650 Kimbe y A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XRP-181229/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackennan, LLC XRP-181229 Exhibit "A" LEGAL DESCRIPTION ALL the following described real property situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southern side of Woodland Avenue, said point being at the dividing line between Lots Nos. 74 and 37 in the hereinafter Plan of Lots, and said point being 158.1 feet in an Easterly direction from the Eastern side of Highland Avenue; thence South 71 degrees 42 minutes East along the Southern side of said Woodland Avenue, a distance of76.3 feet to an iron pin at the center line of Lot No. 73; thence South 00 degrees 19 minutes West along said center line of Lot No. 73, a distance of 140 feet to an iron pin on the Northern line of Lot No, 67; thence North 70 degrees 37 feet West along the Northern line of Lots Nos. 67 and 68, a distance of 75 feet to an iron pin at the Eastern line of Lot No, 36; thence North I degree West along the Western line of Lots Nos. 36, 35, 34 and 33, a distance of 140 feet to a point on the Southern side of Woodland Avenue, the place of BEGINNING. BEING Lots Nos. 74 and the Western half of Lot No. 73 in the Plan of Lots known as "Mountain View Addition"; said plan being recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book No.3, page 68. Having thereon erected a brick dwelling house. HAVING thereon erected a brick dwelling house being known and numbered as 625 Woodland Avenue, Mount Holly Springs, PA, 17065. BEING the same premises which Guy A. Romito and Mary E. Romito, his wife, as tenants by the entirety, where the aforementioned Guy A. Romito having died on June 24, 1998, thereby vesting full title unto Mary E. Romito„ by Deed dated October 16, 2008 and recorded October 31, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume , Page Instrument #: 200835621, granted and conveyed unto Mary E. Romito and Guy A. Romito, Jr., as joint tenants with right of survivorship. Tax Map No.: 40-30-2646-048. Zucker, Goldberg & Ackerman, LLC XRP-181229 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO.: 2014-02781 Bank of America, N.A. vs. Mary E. Romito; Plaintiff, Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 MARY E. ROMITO 625 Woodland Avenue Mount Holly Springs, PA 17065 AND 415 Chestnut Street, Floor 1, Mount Holly Springs, PA 17065 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on June 3, 2015 at 10:OOam prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 625 Woodland Avenue, Mount Holly Springs, PA, 17065 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2014-02781 Zucker, Goldbay & "kekcrrnan, XRP-131229 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Mary E. Romito and Guy A. Romito, Jr., as joint tenants with right of survivorship A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. Zucker, Goldberg & Ackerman, LLC XRP-181229 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. Dated: r-ak `7_, y ZUCKER, GOLDBERG & ACKERMAN, LLC BY: Scott A. rick, Esquire; PA I.D. #55650 Kimber A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XRP-181229/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackennan, LLC XRP-181229 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA '• 17013 (717) 240-6195 www.ccpa.net BANK OF AMERICA, N.A. Vs. MARY E. ROMITO WRIT OF EXECUTION NO 2014-02781 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $144,979.47 L.L.: $.50 Interest FROM 5/11/2014 TO DATE OF SALE AT THE STATUTORY RATE - $7,087.29 Atty's Comm: Atty Paid: $1.84.66 Plaintiff Paid: Date: 1/13/2015 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonota , AV Deputy REQUESTING PARTY: Name: ROGER FAY, ESQUIRE Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 315987