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HomeMy WebLinkAbout14-3142 Supreme Co , ' e�nnsylvania Cour sof Co1nnio , leas For Prothonotary Use Only. d � Docket No: Cul erland Countyl The information collected on this form is used solely for court administration purposes. This farm does not supplement or replace the filing and service ofpleadings or otherpapers as required by law or rules of court. (� Commencement of Action: S El Complaint © Writ of Summons © Petition ® Transfer from Another Jurisdiction ® Declaration of Taking iE C Lead Plaintiff's Name: Lead Defendant's Name: Sank Of America, N.A. Amanda E Bressler T Dollar Amount Requested: ®within arbitration limits I Are money damages requested? ®Yes 0 No (check one) outside arbitration limits O N Is this a Class Action Suit? [3 Yes No Is this an MDJAppeal? (:1 Yes 0 No A Name of Plaintiff/Appellant's Attorney: Elizabeth Wassell Esquire J EA Check here if you have no attorney(are a Self-Represented [Pro Sel Litigant) r 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 M Malicious Prosecution ❑ Debt Collection: Credit Card n Board of Assessment Motor Vehicle Debt Collection:Other D Board of Elections Nuisance O Dept.of Transportation [3Premises Liability Statutory Appeal: Other j S [3Product Liability(does not include E mass tort) Employment Dispute: © Slander/Libel/Defamation Discrimination j C Other: n Employment Dispute:Other El Zoning Board ,r 0 Other: I Q Other: O MASS TORT Asbestos N ® Tobacco ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste Other: ®Ejectment Common Law/Statutory Arbitration Eminent Domain/Condemnation ® Declaratory Judgment 0 Ground Rent ®Mandamus E3Landlord/Tenant Dispute [3 Non-Domestic Relations a Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ®Mortgage Foreclosure:Commercial ®Quo Warranto ® Dental ❑ Partition D Replevin Legal ® Quiet Title ®Other: Medical Other: i Other Professional: Updated 1/112011 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF BY: MARK J.UDREN,ESQUIRE - ID#04302 STUART WINNEG,ESQUIRE -ID#45362 LORRAINE GAZZARA DOYLE,ESQUIRE - ID#34576 SHERRI J.BRAUNSTEIN,ESQUIRE -ID#90675 SALVATORE CAROLLO,ESQUIRE-ID#311050 ' =� ELIZABETH L.WASSALL,ESQUIRE- ID#77788 JOHN ERIC KISHBAUGH,ESQUIRE -ID#33078 NICOLE B.LABLETTA,ESQUIRE -ID#202194 DAVID NEEREN,ESQUIRE-ID#204252 AMANDA RAVER,ESQUIRE -ID#307028 WOODCREST CORPORATE CENTER -� 111 WOODCREST ROAD,SUITE 200 x' CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America,NA COURT OF COMMON PLEAS C/O Bank of America,N.A.,as successor CIVIL DIVISION by merger to BAC Home Loans Servicing, CUMBERLAND County LP 16001 North Dallas Parkway Addison,TX 75006 NO Plaintiff V. AMANDA E BRESSLER 3 SOUTH RD MECHANICSBURG,PA 17050 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. S LAWYERS REFERRAL SERVICE „ 'n,,� lb&. 7S IJY�_) '/ atl, Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a 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 dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, 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 Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800) 990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period,we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt,and any information obtained will be used for that purpose. UDREN LAW OFFICES,P.C. /s/Mark J.Udren,Esquire Woodcrest Corporate Center 111 Woodcrest Road,Suite 200 Cherry Hill,NJ 08003-3620 (856) 669-5400 1. Plaintiff is Bank of America,NA. Plaintiff is the legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the current mortgagee of record, is the legal holder of the Mortgage by virtue of being successor in interest to the current mortgagee of record, or is the legal holder of the Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of Mortgage, all of which have either been recorded or Plaintiff is in the process of formalizing the actual Assignment of Mortgage in Plaintiff s favor: Assignor:Mortgage Electronic Registration Systems,Inc.as nominee for Fulton Bank,NA Assignee: Bank of America,N.A. Date of Assignment: 03/19/2014 Recorded Date: 03/20/2014 Book/Instrument#: Inst#201405671 Page: n/a The promissory note is endorsed by Plaintiff,or endorsed in blank and Plaintiff or its agent has possession of the note. 2. Upon information and belief Defendant(s)and/or their predecessor: Amanda E Bressler (hereinafter"Defendants"),are the owners of property located at 3 SOUTH ROAD, MECHANICSBURG,PA 17050,by virtue of Deed dated 02/17/2011 and recorded 02/18/2011 in Official Records Book Inst#201105992 at Page n/a of the Public Records of Cumberland County, Pennsylvania(hereinafter the 'Property"). 3. On 02/17/2011 ,Defendant(s) and/or their predecessor: AMANDA E BRESSLER promised to pay to the order of Fulton Bank NA ,the principal sum of $ 115,008.00 payable with interest thereon provided in the Note. 4. By Mortgage dated 02/17/2011 ,Defendant(s)and/or their predecessor: AMANDA E BRESSLER to secure the Note,mortgaged to Mortgage Electronic Registration Systems,Inc. as nominee for Fulton Bank,NA , the Property which is the subject of this action. The Mortgage was recorded on 02/18/2011 in Official Records Book Inst# 201105993 at Page n/a. Said Mortgage is incorporated herein by referenced in accordance with Pa.R.C.P 1019(g). A legal description of the mortgage premises is attached hereto and made a part hereof. 5. Said mortgage is in default in that the payment due 10/01/2013, and all subsequent payments have not been made, and by its terms,upon breach and failure to cure said breach after notice, all sums secured by said Mortgage,together with the other charges authorized by said Mortgage and itemized below, shall be immediately due. 6. After demand,the Defendant(s)continues to fail or refused to comply with the terms of the Mortgage as follows: (a) By failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) By failing or refusing to pay other charges,if any,indicated below. The following amounts are due on the said Mortgage or modification agreement as of the date stated below Unpaid Principal Balance $110,105.97 Accumulated Interest (from 09/01/2013 to 05/31/2014) $3,922.56 Accumulated Late charges $69.90 Escrow Deficit/(Reserve) $1,253.46 Property Inspection Fees $411.60 Grand Total $115,763.49 The above figures are calculated as of 05/30/2014: The interest rate is subject to adjustment if more fully described as such in the note and mortgage. The interest rate on the subject note is at 4.75000 %. The current monthly accrual of interest on this loan is $435.83 and that sum will be added every month hereafter. 7. Breach letters have been sent to Defendant(s)in accordance with the requirements of the subject mortgage and/or The Pennsylvania Act 6 of 1974 of the Commonwealth of Pennsylvania and, if applicable, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit "A" WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of$115,763.49 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged premises. UDREN LAW OFFIMS, P.C. BY: ELIZABETH L WASSALL, ESQ PA ID 77788 UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America,NA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION CUMBERLAND County V. AMANDA E BRESSLER NO. 3 SOUTH RD MECHANICSBURG,PA 17050 Defendant(s) • - VERIFICATION 1 hereby states that h /she is Ami �QQcam of Bank of America, NA, Plaintiff in this matter, that he/hJ s 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 hie knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Name: Title: , Company: ����`A��.c��.� N •�' MJU#: 14040409 CASE#: 14040409-1 First American Title Insurance Co. Commitment Number: 11018 EXHIBIT A PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL those two(2)certain tracts or parcels of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania,being more particularly bounded and described in accordance with a survey by Louis J. Harford, P.L.S., dated August 31,2010, as follows,to wit: TRACT 1 BEGINNING at a point on the easterly line of South Road, at the corner of lands now or formerly of Arlene E. Byers;thence along the line of said lands now or formerly of Arlene E. Byers North 67 degrees 8 minutes 43 seconds East,a distance of one hundred sixty and eighty-seven one-hundredths(160.87)feet to a point on the line of Tract No.2, below;thence along the line of Tract No.2 below,South 56 degrees 45 minutes 0 seconds East,a distance of eighty-four and sixty-five one-hundredths(84.65)feet to a point on the line of lands now or formerly of Sue A. Harley; thence along the line of said lands now or formerly of Sue A. Harley South 26 degrees 6 minutes 0 seconds West, a distance of one hundred two and sixty-eight one-hundredths(102.68)feet to a point on the line of lands now or formerly of Barbara E. Hake;thence along the line of said lands now or formerly of Barbara F. Hake North 84 degrees 5 minutes 32 seconds West, a distance of one hundred sixty-seven and twenty-five one-hundredths(167.25)feet to an iron pin on the easterly line of South Road;thence along the easterly line of South Road by an arc or curve to the left having a radius of one hundred twenty-two and ninety-six one-hundredths(122.96)feet, an arc distance of fifty-nine and forty-one one-hundredths(59.41)feet to an iron pin at the corner of lands now or formerly of Arlene E. Byers, the point and Place of BEGINNING. BEING Lot No. 52 on the Plan of Lots for Northfield Farms,said Plan being recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book 8 Page 22. HAVING THEREON ERECTED a one-story residential dwelling house with attached carport, being known and numbered as 3 South Road. BEING the same premises which Albert C.Troutman and Mary Lee Troutman, his wife, by their deed dated February 23, 1959 and recorded in the Recorder's Office aforesaid in Deed Book"Y",Volume 18, Page 186, granted and conveyed unto Paul William Karns and Goldie Arlene Karns, his wife. TRACT NO.2 BEGINNING at a point in the center line of the public road or street known as York Circle, at the corner of lands now or formerly of Suzanne E. Morse;thence along the center line of York Circle North 56 degrees 43 minutes 52 seconds East, a distance of seventy-four and ninety-eight one-hundredths(74.98)feet to a point at the corner of lands now or formerly of Donald C. Fisher and Karen L. Fisher;thence along the line of said lands now or formerly of Donald C. Fisher and Karen L. Fisher South 33 degrees 15 minutes 0 seconds West, a distance of one hundred sixty-six and fifty one-hundredths(166.50)feet to a point on the line of lands now or formerly of Arlene E. Byers;thence along the line of said lands now or formerly of Arlene E. Byers and continuing along the line of Tract No. 1, above, South 56 degrees 45 minutes 0 seconds East,a distance of ninety-five and eighty-six one-hundredths(95.86)feet to a point on the line of lands now or formerly of Sue A. Harley;thence along the line of said lands now or formerly of Sue A. Harley and continuing along the line of lands now or formerly of Suzanne E. Morse North 26 degrees 6 minutes 0 seconds East, a distance of one hundred sixty-seven and seventy-eight one-hundredths(167.78)feet to a point in the center line of York Circle, the point and Place of BEGINNING. ALTA Commitment Exhibit A (11018111018112) EXHIBIT A (Continued) Commitment Number: 11018 BEING Lot No.56 on the Plan of Lots for Northfield Farms,said Plan being recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book 8, Page 22. UNDER AND SUBJECT, NEVERTHELESS,to public rights of passage over and across the public roads or streets known as York Circle and Hogestown Road,to the extend of their respective legal widths. BEING the same premises which Albert C.Troutman and Mary Lee Troutman, his wife, by their deed dated February 23, 1959 and recorded in the Recorder's Office aforesaid in Deed Book"E',Volume 17, Page 298, granted and conveyed unto Paul William Karns and Goldie Arlene Karns, his wife. ALTA Commitment Exhibit A (11018f11018112) BaakofAmerica 401. Home Loans PRESORT First-Class Mail PO Box 9048 Temecula,CA 92589-9048 U.SFPeeestag nand W SO 2279©83357 Send Payments to. PO Box 15222 Wilmington,DE 19886-5222 Send Correspondence to: 20131202-213 PO Box 5170 Simi Valley,CA 93062-5170 liltl„i,t11mill litit11 AMANDA E BRESSLER 3 SOUTH ROAD MECHANICSBURG. PA 17050-3153 BREACHPA{FC} Exhibit A December 2,2013 Account No.: AMANDA E BRESSLER 3 SOUTH ROAD MECHANICSBURG, PA 17050-3153 NOTICE OF INTENT TO FORECLOSE MORTGAGE Dear AMANDA E BRESSLER, 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 3 SOUTH ROAD MECHANICSBURG, PA 17050 IS IN SERIOUS DEFAULT because you have not made the monthly payments in the amounts shown below for the months of October 1, 2013 - December 1, 2013, Monthly Charges: Month Due Principal& Interest Escrow Amount Optional Products Total Monthly Charge Amount Amount 10/0112013 $599.94 $273.87 $0.00 $873.81 11/0112013 $599.94 $273.87 $0.00 $873.81 12/01/2013 $599.94 $282.23 $0.00 $882.17 Late Changes: Month Amount 10/01/2013 $34.95 11101/2013 $34.95 Total Monthly Charges: $2,629,79 Current Late Charges: $69.90 Prior Unpaid Late Charges: $0.00 Total Other Charges/Fees: $15.00 Partial Payment Balance: ($0.00) TOTAL DUE $2,714.69 Late charges and other charges have also accrued to this date in the amount of$84.90.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$2,714.69. You may cure this default within THIRTY(30) DAYS of the date of this letter, by paying to us the above amount of $2,714.69,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. PO 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 attorneys fees will be added to whatever you owe us,which may also include our reasonable costs. If you cure the 2279083357 default within the thirty day period,you will not be required to pay attorney's fees. 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 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 Sheriff's sale could be held would be approximately six (6) monfs 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: 1-800-668-1904. 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 Sheriff's 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. 2279083357 C3 3222 BRECDISC 15353 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: hfp://www.bankofamerira.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 PERSON NEL/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. Er�$L 2279083357 C3 3222 BRECDISC 15353 09/24/12 DIVUL GACIONES 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 legates. Bank of America, N.A., el administrador de su prestamo para vivienda esti 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 para proteger los intereses del Titular en la propiedad y sus derechos bajo el instrumento de seguridad y el pagan§, incluyendo cualquiera de sus recursos(los"Servicios relacionados a un incumplimiento"). Bank of America, N.A. aplicara cargos a la cuenta de su prestamo par los servicios relacionados a un incumplimiento, incluyendo los servicios proporcionados por sus afiliados. Una lista de los cargos que podrian cobrarse a su cuenta por servicios relacionados a un incumplimiento este disponible en el sitio de Internet: fhttp://vwwv.bankofamerica.com/defaultfeesl. 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, viemes de 8 a. m.a 9 p. m. hora del este, sabados de 9 a, m. a 3 p. m. hors del este. para pedir que se le envie una lista de cargos por correo. La lista de cargos contiene una lista completa de los servicios relacionados par incumplimiento que le podian cobrar, pero no incluye una lista 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 leyes estatales comparables otorgan protecciones y beneficios significativos al personal del servicio militar Que califiaue, incluidas protecciones contra la ejecuci6n hipotecaria asi como tambien ayuda en la tasa de interes. Para obtener mas informaci6n y determiner 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. 2279083357 C35088 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 infonnation available so we can discuss which option(s)could work for you. Options to consider if your goal is to stay in your home fl•� jg ' R ° 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 3 following requirements: • The amount you owe on the first mortgage is equal to or less than$729,750 for a j single-family home, $934,200 for a 2 unit property, $1,129,250 for a 3 unit property or 1 $1,403,400 for a 4 unit property ' • You have documented a financial hardship and represented that you do not have sufficient j 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 mage is secured aone to_f_our unit eeqy_ -- —_—_ _ j 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. 1 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 I 3 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 1. loans only) you are now able to make your regular monthly mortgage payment, this program is designed to' I 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 11 r i" C11.2 yH 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 1 i 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 iNI 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. _ j Deed in Lieu of Used as an alternative to foreclosure,with a deed in lieu of foreclosure, you transfer ownership i Foreclosure of your house and all property secured by your mortgage loan.This may satisfy the total i (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. — We are here to help you. Please call us today. 2279063357 C35088 OPTAVWFC 15319 09/24/2012 Hay opciones disponibles para ayudarle a Evitar la Ejecucion Hipotecaria Llame al numero que aparece en la notification adjunta para obtener mas informaci6n Cuando (lame, 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 ..: .._..__ ...._.... ........�..�_...__�_ .a y .. prrgtatescrlpcicr 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 (RAMP) cantidades vencidas al final del pr6stamo,y/o extender el plazo del pr6stamo. Usted puede caiificar para este programa si cumple con los siguientes requisitos: f La cantidad que usted adeuda de su primera hipoteca es igual o menor que I $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 f $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 hater 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 tomo para no poder habitarse incluso si no est6 condenada. • La hipoteca est6 garantizada por una propiedad de una a cuatro unidades. Restablecimiento Si usted puede poner al dia los pagos de su pr6stamo, aceptaremos los fondos del Pr6stamo necesanos 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 hacer sus pagos hipotecarios reguiares,adem6s de pagar una porci6n de los montos vencidos a trav6s del tiempo. Esto puede incluir capital, inter6s, cargos o costos aplicados a su pr6stamo. 'Acuerdo Temporal Es un acuerdo en el cual aceptamos no proceder con la ejecuci6n hipotecaria y/o el de Tolerancia por cobro de los pagos por un periodo de tiempo, para permitirle que restablezca su incumplimiento habilidad de hacer los pagos requeridos. Modificaci6n de Una modificaci6n del pr6stamo es un cambio en los t6rminos originales de su pr6stamo, I Prestamo Las modificaciones podrian incluir reducir su tasa de inter6s, extender el t6rmino o la (no par medio de fecha de pago del pr6stamo, cambiar de un pr6stamo de tasa de inter6s ajustable a uno RAMP) de tasa de inter6s fija, diferir una parte del saido del capital impagado al final del pr6stamo, y/o condonar una parte del saido de capital impagado. Reclamo Parcial Si usted tiene un pr6stamo de la Administraci6n Federal de Vivienda (FHA)y sus pagos j(solamente est6n vencidos, pero ahora puede hacer sus pagos regulares mensuales de la hipoteca, { prestamos de la este programa est6 diseflado 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. 22?906335? C35088 OPTAVDFC 15319 09124/2012 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 (HAMP), pero no consiguieron obtener una modificaci6n Alternatives Program permanente a trav6s del programa. HAFA ofrece la posibilidad de una vents en j(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 transacci6n 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 liberaci6n de nuestro derecho de retenci6n sobre su propiedad y evitar la ejecuci6n hipotecaria. Una escritura de traspaso voluntario de propiedad en lugar de la ejecuci6n hipotecaria es una transacci6n en la que usted esta de acuerdo de transferir voluntariamente las escrituras de su propiedad a nosotros con el fin de evitar la ejecuci6n hipotecaria. j yenta en descubierto Si usted ya no puede hacer sus pagos hipotecarios y su vivienda vale menos de to que /yenta previa a la usted adeuda, una vents en descubierto le podria permitir vender su vivienda para pagar ejecuci6n hipotecaria la hipoteca. En una venta en descubierto, el prestamista acepta recibir una monto (no por medio de menor de to que actualmente se adeuda en el prestamo. Se ofrece a los prestatarios que HAFA) no califican para HAMP o para otras alternativas de retenci6n de la vivienda. Escritura de traspaso Se usa Como una alternativa de la ejecuci6n hipotecaria. Con una escritura de traspaso de propiedad en voluntario de propiedad en lugar de la ejecuci6n hipotecaria, usted transfiere la 3 lugar de la ejecucl6n titularidad de su vivienda y toda la propiedad que garantiza su prostamo hipotecario. hipotecaria(no por Esto puede hacer que el month total vencido de esa hipoteca se considere Como medio de HAFA) pagado. Se ofrece a prestatarios que no califican para HAMP u otras opciones de retenci6n de vivienda, y que no pudieron vender la propiedad a travos de una venta en j descubierto. Estamos aqui para ayudarle. Por favor Ilamenos hoy. 2279083357 FORM 1 ` ITS,THE COURT OF COMMON PLEAS OF r. CUMBERLAND COUNTY, PENNSYLVANIA, -� Plaintiff(s) vs. LP Defendant(s) NOTICE OF RESIDENTIAL MORTGAGE FORECLOE : 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.bereto,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 conciliatiou:conferenee.. 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 worksbeet 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 ROME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED.BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date [Sijfiiature of Co&Eff�tt-PAaLn f,SSALL, ES PA ID 77788 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: CUSTOMERIPRIMARY APPLICANT 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? 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: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation(automobiles, boats,motorccles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. 2 Additional Income Description(not wages): 1. monthly amount: 2. montlily 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 Pa ent s CandolNei h. Fees Auto Insurance Med.(not covered) Auto ftiel/re. airs Other prop.payment Install.Loan Payment Cable TV Child Support/Alien. Spending Mone Da !Child Care/Tuft. Other Expenses i Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes � No Q If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 i _..................._...._.............._................................._......._........._.__� 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: 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 Past 2 bank statements Proof of any expected income for the last 45 days V 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) FORM 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs) vs. 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 Prograrn"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 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY. MARK J. UDREN, ESQUIRE -ID #04302 STUART WINNEGS ESQUIRE -ID#45362 LORRAINE GAZZARA DOYLE,ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN,ESQUIRE -ID#90675 ELIZABETH L.WASSALL, ESQUIRE-ID#77788 , JOHN ERIC KISHBAUGH, ESQUIRE -ID#33078 �1- NICOLE B. LABLETTA, ESQUIRE -ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 �-_ AMANDA RAVER,ESQUIRE - ID#307028 p�- WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 - CHERRY HILL,NJ 08003-3620 � 856-669-5400 Pleadings*udren.com Bank of America,NA COURT OF COMMON PLEAS 16001 North Dallas Parkway,Addison,TX 75006 CIVIL DIVISION Plaintiff CUMBERLAND County V. ) H - Amanda E Bressler NO. 3 SOUTH RD MECHANICSBURG,PA 17050 Defendant(s) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the following counsel: Mark J.Udren,Esquire; Stuart Winneg,Esquire; Lorraine Gazzara Doyle,Esquire; Sherri J.Braunstein,Esquire; Harry B.Reese,Esquire; Salvatore Carollo,Esquire; Elizabeth L.Wassall,Esquire;John Eric Yishbaugh,Esquire;Nicole B.LaBletta,Esquire;David Neeren,Esquire, and Amanda Rauer,Esquire on behalf of the Plaintiff, in the above-captioned matter. UDREN LA FIC S, P.C.. BY: ' ELIZABETH L WA SALL, ESC; PA ID 71788 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ' THE PROff O Olrii 2314JUN 17 PH 3 06 CUMBERLAND] COUNTY PENNSYLVANIA OFFICE or THE ,SHERIFF Bank of America N.A. vs. Amanda E Bressler Case Number 2014-3142 SHERIFF'S RETURN OF SERVICE 05/28/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Amanda E Bressler, 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 3 South Road, Silver Spring, Mechanicsburg, PA 17050. Residence is vacant and per the Mechanicsburg Postmaster the defendant now resides at 959 Lake Drive, Dunedin, Florida 34698. SHERIFF COST: $39.30 SO ANSWERS, June 12, 2014 RONaR ANDERSON, SHERIFF (c) CountySuite Sheriff, Te!eosof UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America,NA (, COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County V. AMANDA E BRESSLER NO. 14-3142 Civil Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE C7 TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: 2 j rt UDREN LAW OFFICES,P.C. BY: Attorne foXlaintfirr AMANDA L. RAUER, ESQUIRE PA. I.D. # 307028 Service of Process by Bank of America,NA,et.al.,Plaintiff(s) APS International, Ltd. VS. Amanda E.Bressler,et.al.,Defendant(s) 1-800-328-7171 APS II IFY—NAT(QNAL APS International Plaza 7800 Glenroy Rd. Minneapolis,MN 55439-3122 APS File#: 129685-0001 AFFIDAVIT OF SERVICE -- Individual Service of Process on: UDREN LAW OFFICES --Amanda E.Bressler Ms.Laura Dolly Court Case No.Cumberland Co 14-3142-Civil 111 Woodcrest Rd.,Ste.200 Cherry Hill,NJ 08003-3620 State of: F Incl d G )ss. County of:P i o d 1 n�J } Name of Server: aV ,undersigned, being duly sworn, deposes and says that at th time of service, s/he was of legal age and was not a party to this action; nn Date/Time of Service: that on the iU day of J U� ,20 I, at Q�o'clock LM Place of Service: at 959 Lake Drive s in Dunedin,FL 34698. Documents Served: the undersigned served the documents described as: Complaint in Mortgage Foreclosure w/Notice of Residential Mortgage Foreclosure Diversion Program Service of Process on: A true and correct copy of the aforesaid document(s)was served on: Amanda E.Bressler Person Served,and Method of Service: 11 By personally delivering them into the hands of the person to be served. _ pp�..-- / By delivering them into the hands of 0�Wefsdn D_Y- of suitable age,who verified,or who upon q estioning stated,that he/she resides with Amanda E.Bressler at the place of service,and whose relationship to the person is: Description of Person The person receiving documents is described as follows: t Receiving Documents: Sex ffl_; Skin Color } }' ,— ; Hair Color !0VV n —; Facial Hair n 15� Approx. Age 5 5 ; Approx. Height 5 1 9 " ; Approx. Weight -'z�C70 L. To the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury Subscribed and s rn to before in this that the fore ing is true and corre 2 Signature f Server Notary Publi (Co sion''Expires) APS International, Ltd. " SEAN SEGEL Notary Public-State of Florida my Comm.Expires dun 1,1011 Commission N EE 684170 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHF,RRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Bank of America, NA E) r-.., -r, ' ---4 V. rn AMANDA E BRESSLER, = = -tg Defendant(s) r''-' NI ;19 ) NO. 14-3142 Civil -<- ---. --+ cr I-- z AFFIDAVIT OF NON-MILITARY SERVICE =a) -- c) • • UNDER Pa.R.C.P 76 — ".... ...--t • - — TI -IE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), AMANDA E BRESSLER, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". Plaintiff MORTGAGE FORECLOSURE The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. • This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: June 26, 2014 M.111#: 14040409 CASE#.: 14040409-1 Aalfcci. Nicole LaBletta, Esquire PAiD 202194 ,.w The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on -the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: HA8OCEBDGO8BZOO Department of Defense Manpower Data Center Results as of : Jun -26-2014 08:17:25 AM SCRA 3.0 Status Rept Pursuant to Seiviceinembers Civil Relief Act. Last Name: BRESSLER First Name: AMANDA Middle Name: E Active Duty Status As Of: Jun -26-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA' No S. NA This response reflects' the individuals' active duty status based on the Active Duty Status Date r;•' Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA I NA b.. No NA This response reflects where the individual left active duty' status within 367 days preceding theActive Duty Status Date The Member or HisfHer 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 (Army, Navy, Marine Corps, Air Force, NOM, 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 EXHIBIT A UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings ' udren.com Bank of America, NA 16001 North Dallas Parkway Addison, TX 75006 Plaintiff v. Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: R.� C')7'1 rrT ivy -71 CD "r'2 f') s/G, 544 dde(op 3/64760 Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), AMANDA E BRESSLER; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Escrow Per Complaint Property Inspection Fees Grand Total FROM TO 05/31/2014 08/30/2014 $110,105.97 $3,922.56 $1,307.49 $69.90 $1,253.46 $411.60 $117,070.98 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: 772/ / MJU#: 14040409 CASE#: 14040409-1 UDREN LAW OFFICES, P.C. t 1 Attorney t Attorney for P LIOurg'k49 C 4oLts UDREN LAW ONVICES, P.C. BY: MARK J. UDREN, ESQUIRE -II) #04302 STUART WINNEG, ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 SALVATORE CAROLLO, ESQUIRE - ID#311050 ELIZABETH L. WASSAIL, ESQUIRE - ID#77788 JOHN ERIC ICISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 AMANDA RAUER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America, NA CIO Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff V. AMANDA E BRESSLER 3 SOUTH RD MECHANICSBURG, PA 17050 Defendant(s) ATTORNEY FOR PLAIN& • ., COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County ,1L NO. j6/.3/1/ COMPLAINT IN MORTGAGE FORECLOSURE 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIa THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYERS REFERRAL SERVICE Bank of America, NA, et. al., Plaintiff(s) vs. Amanda E. Bressler, et. al., Defendant(s) UDREN LAW OFFICES Ms. Laura Dolly 111 Woodcrest Rd., Ste. 200 Cherry Hill, NJ 08003-3620 State of: F 1%)11 l; ) ss. itis County of: girl Name of Server: Service of Process by APS International, Ltd. 1-800-328-7171 APS International Plaza 7800 Glenroy Rd. Minneapolis, MN 55439-3122 APS File #: 129685-0001 AFFIDAVIT OF SERVICE -- Individual nice of Process on: —Amanda E. Bressler Court Case No. Cumberland Co 14 -3142 -Civil undersigned, being duly sworn, deposes and says that at thetime of""service, s/he was of legal age and was not a party to this action; Date/Time of Service: that on the 1 LP day of J U Imo, , 20 114 , at 3 .00 o'clock LM Place of Service: at 959 Lake Drive Documents Served: the undersigned served the documents described as: in Dunedin, FL 34698 Complaint in Mortgage Foreclosure w/ Notice of Residential Mortgage oreclosure Diversion Program Service of Process on: A true and correct copy of the aforesaid documents) was served on: Amanda E. Bressler ❑ By personally delivering them into the hands of the person to be served. Fp By delivering them into the hands of i2l� and n25 1 Jx 1 " of suitable age, who verified, or who upon Oiestioning stated, that he/she Amanda E. Bressler Person Served, and Method of Service: FCy{-\p olnC°1256I resides with at the place of service, and whose relationship to the person is: Description of Person The person receiving documents is described as follows: Receiving Documents: Signature of Server: Sex (Y1 ; Skin Color White— ; Hair Color &DIN n ; Facial Hair Approx. Age 5 5 ; Approx. Height 9 61" ; Approx. Weight aC0 n la /ElTo the best of my knowledge and belief, said person was not engaged in the US Military at the time of service. Undersigned declares under penalty of perjury Subscribed and s that the fore mg is true and r Signattue 6f Server Notary Publi APS International, Ltd. ion Expires) SEAN SEGEL Notary Public • Stow of FIotIAa My Comm. Wino Jon II, CM Commission N EE 854170 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com Bank of America, NA Plaintiff v. AMANDA E BRESSLER, Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil EXHIBIT A AFFIDAVIT OF NON-MILITARY SERVICE UNDER Pa.R.C.P 76 THE UNDERSIGNED states based upon a search of the Department of Defense Manpower Data Center for the Defendant(s), that the Defendant(s), AMANDA E BRESSLER, who/each of whom is over 18 years of age is/are not in active military service as defined in the Servicemembers' Civil Relief Act. The Military Status Report(s) is/are attached hereto as Exhibit "A". The Affiant lacks sufficient information to be able to determine whether any other Defendants in this action are in active military service because Plaintiff cannot provide date(s) of birth and/or Social Security number(s) for said Defendant(s) to enable a search. This statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: August 28, 2014 MJU#: 14040409 CASE#: 14040409-1 Atto y for Plaintiff Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act. Last Name: BRESSLER First Name: AMANDA Middle Name: E Active Duty Status As Of: Aug -28-2014 Results as of : Aug -28-2014 07:03:09 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 Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA _ No . NA 1. This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA 'No• NA This response reflects whether the.individual or his/her unit has received early not cation 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. yA. Mary. M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: HC11651 DKOF4F80 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Bank of America, NA Plaintiff v. Amanda E Bressler Defendant(s) TO: Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 Date of Notice: August 19, 2014 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0 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, 0 SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 6 t 2.. rt4,,-f ,ter 11 oo crest Road, Suite 200 Cherry Hill, New Jersey 08003-3620 MJ11#: 14040409 CASE#: 14040409-1 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin ' s ' udren.com Bank of America, NA Plaintiff v. AMANDA E BRESSLER Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil TO : Amanda E Bressler 959 Lake Drive, Dunedin, FL 34698 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. ❑❑❑❑❑❑E Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CONTACT: Attorney for Plaintiff Udren Law Offices, P.C. Woodcrest Corporate Center 111 Woodcrest Road, Suite 200, Cherry Hill, NJ 08003-3620 Phone: (856) 669-5400 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin . s ' udren.com Bank of America, NA 16001 North Dallas Parkway Addison, TX 75006 Plaintiff v. Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s), AMANDA E BRESSLER; for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: Unpaid Principal Balance Interest Per Complaint Additional Interest Late Charges Per Complaint Escrow Per Complaint Property Inspection Fees Grand Total FROM TO 05/31/2014 08/30/2014 $110,105.97 $3,922.56 $1,307.49 $69.90 $1,253.46 $411.60 $117,070.98 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. UDREN LAW OFFICES, P.C. BY: )!j DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: 97,2//Y MJU#: 14040409 CASE#: 14040409-1 Attorney for P PRO PROTHY +�. r" UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America, NA Plaintiff v. Amanda E Bressler ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil PRAECIPE TO ISSUE WRIT OF EXECUTION Defendant(s) TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $ 117,070.98 Interest From 08/31/2014 to Date of Sale 03/04/2015 Ongoing Monthly Interest of $435.83 to actual date of sale including if sale is held at a later date (Costs to be added) MJU#: 14040409 CASE#: 14040409-1 03xlc 0,4t,\ eier toe . -)S `` " \(t)So«« 'WV 'OS $ UDREN $ 3,050.81 G P1 r f'7 -max rn CD r—M —lC <o -1-1 Xlm CD o-7 E a..... O = _._. C7; -o CD OFFICES, P.0 BY: Ata eren, Esquire FA ID 2Q4252 MO' Co. .a o C,ICA 16.) Pt LEGAL DESCRIPTION All that certain lot or parcel of land situate in the borough of Camp Hill, County of Cumberland and State of Pennsylvania, more particularly bounded and described, as follows, to wit: BEGINNING AT A POINT at the easterly side of Runson Road, which point is two hundred thirty-eight and eighty-five one -hundredths (238.85) feet southwardly from the southeasterly corner of the intersection of Runson road and Logan Street; and which point is also at the dividing line between Lots No. 49 and 50 on the hereinafter mentioned plat of lots; thence along the last said dividing line north seventy-seven (77) degrees thirty-two (32) minutes east one hundred three and twenty-four one -hundredths (103.24) feet to a point; thence south twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point at the dividing line between lots No. 48 and 49 feet thence south seventy-seven (77) degrees thirty-two (32) minutes west one hundred three and twenty-four one -hundredths (103.24) feet to a point at the easterly side of Runson Road; thence along the easterly side of Runson Road north twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point, the place of beginning. BEING Lot No. 49 on the Revised Plan of Part of Hollywood Development, which plan is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, page 14. TITLE TO SAID PREMISES IS VESTED IN Susan E. Myers, by Deed from William C. Myers and Susan E. Myers, h/w, dated 08/19/2003, recorded 09/05/2003 in Book 259, Page 619. PREMISES BEING: 111 Runson Road, Camp Hill, PA 17011-2739 PARCEL NO. 01-21-0273-167 UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 leadin s ' udren.com Bank of America, NA Plaintiff v. Amanda E Bressler Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 c • rn 2J ^i3ri Cr; fir_c CrN CD �cD xr, Cs '11 CD of ryl Bank of America, NA, Plaintiff in the above action, by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 3 SOUTH ROAD, MECHANICSBURG, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 2. Name and address of Defendant(s) in the judgment: Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders - None 4. Name and address of the last recorded holder of every mortgage of record: Bank of America, NA 16001 North Dallas Parkway Addison, TX 75006 Sr Mortgage Holders - None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Sr lien Holders - None 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: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Tenants/Occupants 3 South Road Mechanicsburg, PA 17050 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA, Department of Revenue Bureau of Compliance PO Box 281230 Harrisburg, PA 17128-1230 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: Federal Tax Lien Holders - None Condo/Homeowners Association - None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: 61101 MJU#: 14040409 CASE#: 14040409-1 6ett'f6n, Es u PA ID 204252 LEGAL DESCRIPTION ALL THOSE TWO (2) CERTAIN TRACTS OR PARCELS OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OFPENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED INACCORDANCE WITH A SURVEY BY LOUIS J. HARFORD, P.L.S., DATED AUGUST 31, 2010, AS FOLLOWS, TO WIT: TRACT 1 BEGINNING AT A POINT ON THE EASTERLY LINE OF SOUTH ROAD, AT THE CORNER OF LANDS NOW OR FORMERLY OF ARLENE E. BYERS; THENCE ALONG THE LINE OF SAID LANDS NOW OR FORMERLY OF ARLENE E. BYERS NORTH 67 DEGREES 8 MINUTES 43 SECONDS EAST, A DISTANCE OF ONE HUNDRED SIXTY AND EIGHTY-SEVEN ONE -HUNDREDTHS (160.87) FEET TO A POINT ON THE LINE OF TRACT NO.2, BELOW; THENCE ALONG THE LINE OF TRACT NO.2 BELOW, SOUTH 56 DEGREES 45 MINUTES 0 SECONDS EAST, A DISTANCE OF EIGHTY-FOUR AND SIXTY-FIVE ONE -HUNDREDTHS (84.65) FEET TO A POINT ON THE LINE OF LANDS NOW OR FORMERLY OF SUE A. HARLEY; THENCE ALONG THE LINE OF SAID LANDS NOW OR FORMERLY OF SUE A. HARLEY SOUTH 26 DEGREES 6 MINUTES 0 SECONDS WEST, A DISTANCE OF ONE HUNDRED TWO AND SIXTY-EIGHT ONE -HUNDREDTHS (102.68) FEET TO A POINT ON THE LINE OF LANDS NOW OR FORMERLY OF BARBARA E. HAKE; THENCE ALONG THE LINE OF SAID LANDS NOW OR FORMERLY OF BARBARA F. HAKE NORTH 84 DEGREES 5 MINUTES 32 SECONDS WEST, A DISTANCE OF ONE HUNDRED SIXTY-SEVEN AND TWENTY-FIVE ONE - HUNDREDTHS (167.25) FEET TO AN IRON PIN ON THE, EASTERLY LINE OF SOUTH ROAD; THENCE ALONG THE EASTERLY LINE OF SOUTH ROAD BY AN ARC OR CURVE TO THELEFT HAVING A RADIUS OF ONE HUNDRED TWENTY-TWO AND NINETY-SIX ONE -HUNDREDTHS (122.96) FEET, AN ARC DISTANCE OF FIFTY-NINE ANDFORTY-ONE ONE -HUNDREDTHS (59.41) FEET TO AN IRON PIN AT THE CORNER OF LANDS NOW OR FORMERLY OF ARLENE E. BYERS, THE POINT AND PLACE OF BEGINNING.BEING LOT NO.52 ON THE PLAN OF LOTS FOR NORTHFIELD FARMS, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 8 PAGE 22. HAVING THEREON ERECTED A ONE-STORY RESIDENTIAL DWELLING HOUSE WITH ATTACHED CARPORT, BEING KNOWN AND NUMBERED AS 3 SOUTH ROAD. TRACT NO.2 BEGINNING AT A POINT IN THE CENTER LINE OF THE PUBLIC ROAD ORSTREET KNOWN AS YORK CIRCLE, AT THE CORNER OF LANDS NOW ORFORMERLY OF SUZANNE E. MORSE; THENCE ALONG THE CENTER LINE OF YORK CIRCLE NORTH 56 DEGREES 43 MINUTES 52 SECONDS EAST, ADISTANCE OF SEVENTY-FOUR AND NINETY-EIGHT ONE -HUNDREDTHS (74.98) FEET TO A POINT AT THE CORNER OF LANDS NOW OR FORMERLY OFDONALD C. FISHER AND KAREN L. FISHER; THENCE ALONG THE LINE OF SAID LANDS NOW OR FORMERLY OF DONALD C. FISHER AND KAREN L. FISHER SOUTH 33 DEGREES 15 MINUTES 0 SECONDS WEST, A DISTANCE OFONE HUNDRED SIXTY-SIX AND FIFTY ONE -HUNDREDTHS (166.50) FEET TO A POINT ON THE LINE OF LANDS NOW OR FORMERLY OF ARLENE E. BYERS; THENCE ALONG THE LINE OF SAID LANDS NOW OR FORMERLY OF ARLENE E. BYERS AND CONTINUING ALONG THE LINE OF TRACT NO. 1, ABOVE, SOUTH 56 DEGREES 45 MINUTES 0 SECONDS EAST, A DISTANCE OF NINETY-FIVE AND EIGHTY-SIX ONE -HUNDREDTHS (95.86) FEET TO A POINT ON THE LINE OF LANDS NOW OR FORMERLY OF SUE A. HARLEY; THENCE ALONG THE LINE OF SAID LANDS NOW OR FORMERLY OF SUE A. HARLEY AND CONTINUING ALONG THE LINE OF LANDS NOW OR FORMERLY OF SUZANNE E. MORSE NORTH 26 DEGREES 6 MINUTES 0 SECONDS EAST, A DISTANCE OF ONE HUNDRED SIXTY-SEVEN AND SEVENTY-EIGHT ONE - HUNDREDTHS (167.78) FEET TO A POINT IN THE CENTER LINE OF YORK CIRCLE, THE POINT AND PLACE OF BEGINNING. BEING LOT NO.56 ON THF PLAN OF LOTS FOR NORTHFIELD FARMS, SAIDPLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OFCUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 8, PAGE 22.UNDER AND SUBJECT, NEVERTHELESS, TO PUBLIC RIGHTS OF PASSAGE OVER AND ACROSS THE PUBLIC ROADS OR STREETS KNOWN AS YORK CIRCLE AND HOGESTOWN ROAD, TO THE EXTEND OF THEIR RESPECTIVE LEGAL WIDTHS. AS DESCRIBED IN MORTGAGE INSTRUMENT NUMBER 201105993 BEING KNOWN AS: 3 SOUTH ROAD, MECHANICSBURG, PA 17050 PROPERTY ID NO.: 38-22-0144-043 TITLE TO SAID PREMISES IS VESTED IN AMANDA E. BRESSLER BY DEED FROM ROBERT A. KARNS AND RONALD L. KARNS, CO-EXECUTORS UNDER THE LAST WILL AND TESTAMENT AND CODICIL OF GOLDIE A. KARNS, ALSO KNOWN AS GOLDIE ARLENE KARNS DATED 02/17/2011 RECORDED 02/18/2011 IN DEED BOOK Inst# 201105992 PAGE n/a. UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Pleadings@udren.com Bank of America, NA Plaintiff v. AMANDA E BRESSLER Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 14-3142 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 Your house (real estate) at 3 SOUTH ROAD,_MECHANICSBURG, PA 17050 is scheduled to be sold at the Sheriffs Sale`on 03/0471015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013, to enforce the court judgment of $117,070.98, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to.petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the heriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 ASSOCIATION DE LICENCLDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 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, NA Vs. AMANDA E. BRESSLER WRIT OF EXECUTION NO 14-3142 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: $117,070.98 L.L.: $.50 Interest FROM 8/31/2014 TO DATE OF SALE 3/4/2015 - Ongoing Monthly Interest of $435.83 to actual date of sale including if sale is held at a later date - $3,050.81 Atty's Comm: Due Prothy: $2.25 Atty Paid: $188.05 Other Costs: Dateff P :9/16/14 -1C/ . David D. Buell, Prothonotary G (Seal) ` Y _424" . lec22e.Ler— Deputy REQUESTING PARTY: Name: DAVID NEEREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 204252 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America,NA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County AMANDA E BRESSLER, 'r MORTGAGE FORECLOSURE _. Defendant(s) Ci NO. 14-3142 Civil AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 c 7 C-1 Plaintiff,by its/his/her Attorney hereby verifies that: 1. A copy of the Notice of Sheriffs Sale,a true and correct copy of which is attached hereto as Exhibit "A",was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution,on the date(s)appearing on the attached Certificates of Mailing. 2. A Notice of Sheriffs Sale was sent to Defendant(s)by regular mail and certified mail on the date appearing on the attached Return Receipt,which was signed for by Defendant(s)on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit"B". 3. If a Return Receipt is not attached hereto,then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court,then proof of compliance with said Order is attached hereto as Exhibit"B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.sec.4904 relating to unsworn falsification to authorities. Dated: / UDREN LAW OFFIC/EJS,P.C. BY: ,� ��1��/�K Attorneys for Plaintiff PeAlk ID 2 MN#: 14040409 CASE#: 14040409-1 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 leadin s udren.com Bank of America,NA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County Amanda E Bressler MORTGAGE FORECLOSURE Defendant(s) NO. 14-3142 Civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 AND RULE 76 Bank of America,NA, Plaintiff in the above action,by its undersigned attorney, upon information and belief, Udren Law Offices, P.C., sets forth, as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at: 3 SOUTH ROAD, MECHANICSBURG, PA 17050 1. Name and address of Owner(s) or reputed Owner(s): Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 Amanda E. Bressler c/o 1St United Methodist Church Clearwater (POE) 411 Turner Street Clearwater, FL 33756 2. Name and address of Defendant(s) in the judgment: Amanda E Bressler 959 Lake Drive Dunedin, FL 34698 Amanda E. Bressler c/o 1St United Methodist Church Clearwater(POE) 411 Turner Street Clearwater, FL 33756 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Jr Lien Holders-None 4. Name and address of the last recorded holder of every mortgage of record: Bank of America,NA 16001 North Dallas Parkway Addison,TX 75006 Sr Mortgage Holders -None Jr Mortgage Holders - None 5. Name and address of every other person who has any record lien on the property: Silver Spring Township Authority 5 Willow Mill Park Road, Suite#3 Mechanicsburg, PA 17050 Pennsylvania Power& Light Company 2 North 9th Street Allentown, PA 18101 Pennsylvania Power& Light Company 827 Hausman Road Allentown, PA 18104 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: Cumberland County Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Tenants/Occupants 3 South Road Mechanicsburg, PA 17050 Cumberland County Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Commonwealth of PA,Department of Revenue Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 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: Federal Tax Lien Holders -None Condo/Homeowners Association-None I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: UDREN LAW OFFICES, P.C. BY: O� AA A Attorney or Plainti f MJU#: 14040409 CASE#: 14040409-1 ua%i..'v✓W e i \✓ PA ID 2021 04 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Bank of America,NA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County AMANDA E BRESSLER; Defendant(s) MORTGAGE FORECLOSURE NO. 14-3142 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): AMANDA E BRESSLER; PROPERTY: 3 SOUTH ROAD, MECHANICSBURG, PA 17050 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on 03/04/2015 at 10:00 AM, at the Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013. Our records indicate that you may hold a mortgage or judgment on the property, which will be extinguished by the sale. You may wish to attend the sale to protect your interests. The Sheriff will file a Schedule of Distribution on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. MJU#: 14040409 CASE#: 14040409-1 EXHIBIT A wcn o �__--- — --- 00 41 m CD A� pp A w Z W 0 bd � _ ►D _ f T--- 01V>- .0 1V>-w �, a � o � ►�s ° a N b www�S a •SDs p Z �• M' o 5a CD � I I ry W CD O 5 a � � d �* ❑❑❑❑I e^macCD n n o o r ti "►3 "p ,n I ' i I I o a �'❑❑ ❑ NCD o �4 m o m � •t 8 d ti ;'Y U.S.POSTAGE>>PITNEY BOWES o ZIP 08003p0354° " a ❑❑I py o k � � ti e- 02 1 VY . ID a o o 00 870 EP 23 2014 ° w O — b° c y C HSo`<ao ! I C5 co ;i IV It ID �c d m y f NS. iii G c 375'Q �. fD m I o � I mQ waw F. ° cod$ — CA M .m� '...sn o o• I Z7 m'� G ° �o� al j DC7 M cam$ tioo 9 rn tryug f .r f3 q p C v�o eH,y e ^ m � FLo� � i w d 7 A+ 00 a a e �l b O �-. ° nCD w I I ►� C �' O z R's r re 0 � o � �rA oo �i> eoOKaC ID rye ° I'3 A a It I I I I I a CD y - -'-- - -- - n z C b a CD `° Cl U.S.POSTAGE>Y PITNEY aowE 4�1 ss Tfuw� ZIP 08003 $ 00ElaOZ 1WIa o 'I 00013870900CT 07X CID im ty q DR 3� a I ao� pa � p no a 0.�g rn IN ry b aaj (p r49C a` ° • �ert o� VJ O m b p N „ 1131, (r�Q O-' p d a�y a- w r•'1 (p UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 Bank of America,NA COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Cumberland County V. AMANDA E BRESSLER; et al i NO. 14-3142 Civil Defendant(s) PRAECIPE TO FILE PROOF OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Proofs of Service with regard to the captioned matter. Date: � (���� UDREN LAW OFFICES, P.C. BY: 4" 16do 4 for Plaintiff If tj Grp � � 2�94 EXHIBIT B Service of Process by Bank of America.NA.et.al..PlaintlMs) APS International, Ltd. �x. Amanda E.Bressler.et.al..Defendants) �__ — 1-$00-328-7171 APS 04T"tt�Ttt)YAL APS International Plaza 78M Glenroy Rd. Minneapolts,NIN 55439-3122 APS FII*N: 13151$4Ml AFFIDAVIT OF SERVICE -- Individual Service of Process on: l UDR£N LAW OFFICES —Amanda E Dressler his.Henni Crommarty Court Case No.Cumberland Co 14.3142 Civil I I t Woodcrest Rd-Ste.200 Cherry Hill.KJ OM3-3620 State of: UY I A a County of: Pjnj1 Name of Server: .undersigned,being duly sworn,deposes and says that at Ille time of service,s/he was of legal ago and was not a party to this action: Datelrime or Service: that on the day of �+ Q V.20 Lam,at „o'clock—M Place of Service: at POE-Ist United hlethodist Cburch Clearwater • in Clearwater.FL 33.756 411 Turner Street Documents Served: the undersigned served the documents described as: Notice of Sherlft's Sale of Real Property Service of Process on: A true and correct copy of the aforesaid documents)was served on: Amanda E.Bressler Person Served.and --"- — � — Method of Service: Lj By personally delivering them into the hands of the person to be served. m By delivering them into the hands of A I h Y a yir f.1, hftt is ,e Kon of suitable age,who verified:or wbo upon questioning stated,that he/she resides-M* IS Q uiAlm Q (o�A 0 Amanda E.Bressler 6(CC k F+ VY at the place of service.and whose relationship to the person is: ti Descripon`or Person The person receiving documents is described as follows: Receiving Documents: Sex F'--, Sian ColorQ(,hIL : Hair Color RIMA Facial Hairn�.�_ Approx.Age 1- I : Approx.Height '� Approx.Weight_, To the best of my knowledge and belief.said person was not engaged in the US Military at the time of service. Signature of Server: Undersigned declares under penalty of perjury Subscribed w m to before ale t that the foregoing is tru nd correct. da C j 0 1 SiSnorure of Server lie (Commission Expires) APS International,Ltd. F -4WftCHEW3Wy0N en►oLErzttaQ Z. E> i Ayult 1�26115 EXHIBIT B UDREN LAW OFFICES,P.C. ATTORNEY FOR PLAINTIFF WOODCREST CORPORATE CENTER 111 WOODCREST ROAD,SUITE 200 CHERRY HILL,NJ 08003-3620 856-669-5400 pleadings@udren.com Bank of America,NA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Cumberland County AMANDA E BRESSLER MORTGAGE FORECLOSURE Defendant(s) NO. 14-3142 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Amanda E Bressler First United Methodist Church Clearwater(POE/Youth Director) 411 Turner Street Clearwater, FL 33756 Your house (real estate) at 3 SOUTH ROAD,MECHANICSBURG,PA 17050 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 A.M. at the Cumberland County Courthouse, Commissioners Hearing Room,2nd Floor, Carlisle,PA 17013, to enforce the court judgment of$117,070.98, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment,late charges,costs and reasonable attorney's fees. To find out how much you must pay,you may call: (856)669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) EXHIBIT 13 YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 856-669-5400. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call 856-669-5400. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after Schedule of Distribution is filed. 7. You may also have other rights and defenses,or ways of getting your home back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 (800)990-9108 EXHIBIT B UDREN LAW OFFICES, P.C. BY: MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG; ESQUIRE - ID#45362 LORRAINE GAZZARA DOYLE, ESQUIRE - ID#34576 SHERRI J. BRAUNSTEIN, ESQUIRE - ID#90675 ELIZABETH L. WASSALL, ESQUIRE - ID#77788 JOHN ERIC KISHBAUGH, ESQUIRE - ID#33078 NICOLE B. LABLETTA, ESQUIRE - ID#202194 DAVID NEEREN, ESQUIRE - ID#204252 AMANDA RAUER, ESQUIRE - ID#307028 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ' leadin s ' udren.com Bank of America, NA C/O Bank of America, N.A., as successor by merger to BAC Home Loans Servicing, LP 16001 North Dallas Parkway Addison, TX 75006 Plaintiff v. AMANDA E BRESSLER, 3 SOUTH ROAD MECHANICSBURG, PA 17050 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 14-3142 Civil SUBSTITUTION OF ATTORNEY -. TO THE PROTHONOTARY: Kindly substitute the appearance of Phelan Hallinan, LLP for the following counsel: Mark J. Udren, Esquire; Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Sherri J. Braunstein, David Neeren, Esquire; Nicole Labletta, Esquire; John Eric Kishbaugh, Esquire; and Amanda Rauer, Esquire for Udren Law Offices, P.C. as counsel of record for Plaintiff, Bank of America, NA in the above -captioned matter. 14040409-1 UDREN LAW 0 Withdra. Atto By: Dated: David Neeren, Esquire /Awl PA ID 204252 14040409-1 • PHELAN HALLINAN, LLP Superseding Attorney _ By: —Se--otilel Loth) Cst .1.31/75/ Date: