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Home My WebLink About14-3896 Supreme Court of Pennsylvania 4 , f f Pleas For Prothonotary Use Only: i FXV CU"BERl.'ANQ � CountyDocket No: 'The information collected on this fo rm is used solely for court administration purposes. This forin does not supplement or replace the filing and set-vice of pleadings or other papers as required by law or rules of court. PC] ment of Action: petition plaint ❑ Writ of Summons ❑ Ssfer from Another Jurisdiction ❑ Declaration of Taking E' fs Name: Bank of America,N.A.,Successor by Merger to BAC Lead Defendant's Name: Zachary J.Beide! e Servicing,LP Dollar Amount Requested: ._ within arbitration limits T Are money damages requested?: ❑Yes ® No (Check one) I x outside arbitration limits ' O 1 N Is this a Class Action Suit? ❑Yes ® No Is this an MDI Appeal? ❑Yes 0 No Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC A ❑ Check here if you have no attorney(are a Self-Represented[Pro Se]Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(donor include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS f ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance' ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other E ❑ Product Liability(does not include S mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: ❑ Asbestos Q ❑ Tobacco N ❑ Toxic Tort-DES ❑ Toxic Tort-Implant ❑ Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Other: ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus B ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ® Mortgage Foreclosure:Residential Restraining Order ❑ Dental ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Legal ❑ Partition ❑ Replevin 171 Medical ❑ Quiet Title ❑ Other: ❑ Other Professional: C1 Other: Updated 1!1/!201.7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BANK OF AMERICA, N.A.,SUCCESSOR BY CIVIL DIVISION Q , MERGER TO BAC HOME LOANS SERVICING, LP, NO.: Plaintiff, Vs. TYPE OF PLEADING Zachary J. Beidel; CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE Defendant. FILED ON BEHALF OF: TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE Bank of America. N.A.,Successor by Merger to ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS BAC Home Loans Servicing, LP FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: ZUCKER,GOLDBERG&ACKERMAN,LLC 400 National Way Simi Valley,CA 93065 Scott A. Dietterick, Esquire-Pa. I.D.#55650 AND THE DEFENDANT: Kimberly A. Bonner, Esquire-Pa. I.D.#89705 430 Shippensburg Road Joel A.Ackerman, Esquire-Pa I.D.#202729 Newville,PA 17241-9123 Ashleigh Levy Marin, Esquire-Pa I.D.#306799 Ralph M.Salvia, Esquire-Pa I.D.#202946 Jaime R.Ackerman, Esquire-Pa I.D.#311032 CERTIFICATE OF LOCATION Jana Fridfinnsdottir, Esquire-Pa I.D.#315944 I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS Brian Nicholas, Esquire-Pa I.D.#317240 6 Fairfield Street,Newville PA 17241 Denise Carlon, Esquire-Pa I.D.#317226 Municipality: Newville 200 Sheffield Street,Suite 101 Mountainside, N1 07092 ATTORNE - R PLAINTIFF (908) 233-8500 ATN FILE NO.:XCP 190239 (908)233-1390 FAX office@zuckergoldberg.com File No.:XCP-190239/rbo « MOD r"� � W CO CD MCS y T�C Rw 3n9?f 1 t IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY(30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR.RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A.,Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP Plaintiff, NO.: VS. Zachary J. Beidel; Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty(20)days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800)990-9108 Phone (800) 990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA- Bank of America, N.A.,Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP Plaintiff, NO.: vs. Zachary J. Beidel; Defendant. AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demands establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dial despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800)990-9108 Phone (800)990-9108 (717) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A.,Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP Plaintiff, NO.: vs. Zachary J. Beidel; Defendant. CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE And now comes Bank of America, N.A.,Successor by Merger to BAC Home Loans Servicing, LP, by its attorneys,Zucker,Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing,.LP, (hereinafter "plaintiff") having its principal place of business at 400 National Way, Simi Valley,CA 93065. 2. The Defendant, Zachary J. Beidel, is an individual whose last known address is 430 Shippensburg Road, Newville, PA 17241-9123. 3. Bank of America, N.A.,Successor by Merger to BAC Home Loans Servicing, LP,directly or through an agent, has possession of the Promissory Note. Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A,attached hereto and made a part hereof. 4. On or about August 29, 2011, Zachary J. Beidel made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Bank of America, N.A. a Mortgage in . the original principal amount of $113,350.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on September 1, 2011, Instrument #201124466. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. Zucker,Goldberg&Ackerman,LLC 5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded June 7, 2014 the mortgage was assigned to Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #201216907. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Zachary J. Beidel, single man is the record and real owner of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage for, inter glia, failure to pay the monthly installments of principal and interest due January 1, 2013. 8. As of 05/30/2014 the amount due and owing Plaintiff by Defendants) is as follows: Principal $110,944.11 Interest from 12/01/2012 to 05/30/2014 $7,054.44 Uncollected Late Charge $306.68 Other Amounts Due $282.88 Escrow Balance Due $2,566.86 Partial Payment Balance ($403.84) Total $120,751.13 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding,this action is in no way an attempt to re-establish such liability. Zucker,Goldberg&Ackerman,LLC WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $120,751.13 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER,GOLDBERG&ACKERMAN, LLC BY: N A Dated:, l Scott A. Diettenck, Esquire; PA .D.#55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XCP-190239/rbo 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500;(908) 233-1390 FAX Email: Office@zuckergoIdberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker,Goldberg&Ackerman, LLC EXHIBIT A Zucker,Goldberg&Ackerman,LLC urepared by; LEIRFSa_NE P. COLON - LOAD? # NATE -- - - _ - AUGUST 29, 2011 N-ErWVILLE F'kIJNSYLVs�,i3TA LDatr.] (Cuyl (state] 6 FAIRFIELD ST, NEW'V'ILLE, PA 27242-_306 LProperty Address] X. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $a 13,350.00 (this amount is called "Principal"). plus interest,to the order of the Lender.'rhe Lendur is BANK OF AMERICA, N.A. I will make all payments under this Note in the form of cash,check or money order. f I understand that the Lender may transfer this Note.The i_.ender or anyone who takes this Note by transfer and who is entitled to mc-eive payments under this Note is called the"Note Holder." 2. INI"EREST Interest will be charged on unpaid principal until the full amount of Principal has been paid.I will pay interest at a yearly rate Of 4.250 The interest rate required by this Section 2 is the rate.1 will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and V%ux of Payments I will pay principal and interest by making a payment every month. I Will make my monthly payment on the FIRST day of each month beginning on OCTOBER 01, 2011 I will make these paymeuts every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note.Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal.If,on SEPTEMBER O1, 2041 ,I still owe amounts under this Note.I will pay those amounts in full on that date,which is called the"Maturity Date." I will make my monthly payments at P.O. Box 650070, Dallas, TX 75265--0070 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly paymentwlll be in the amount of U.S.$557.671 4. BORROWER'S RIGHT TO PREPAY I have thtc right to make payments of Principal at. any time before they are due. A payment of Principal only is known as a "Prepayment."When I make a Prepayment.I will tell the Note Holder in writing that I am doing so.I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prupayrnm s to reduce the armurrl of Principal that I owe under tlds Note.However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, bcforr applying my Prepayment to reduce the Principal amount of the Mote-If I make a partial Prepayment,them will be no changes in the due date or in the amount of my monthly payment unless thr. Note Halder agrees in writing to those changes. 5. LOAN CHARGES If a law,which.applies to 1.his loan.and which sets maxirrlum loan charges,is!anally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, them (a) any such loan charge shall he reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to.me.The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me- If a refund reduces Principal, the reduction will be treated as a partial Prepayment_ 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments -If the Note Holder has not received the full amount of any monthly payment by the end of FIFTEEN calendar days after the date it is due, I will pay a late charge to the Note Bolder. The amount of the charge will be 5_^00 % of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the toll amount of each monthly payment on the date it is due,I will be in default MULTISTATE FIXED RATE NOTE--Single Family--Fannie MaelFrrddle Mxc UNIFORM INSTRUMENT Form 3200 1101 Fixed Rate Note 20o5N-XX(05/11)(d1y Page 1 of 3 2 3 9 9 1 " _ - --- -' I i (C) Notice of Default LO-MI If I arra in default,the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date,the Note Holder way require me to pay immediately the full amount of Principal which has not been paid and all the interest that i f owe on that amount. Tliat date must be. at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if,at a time when I am in default,the Note Holder does not require me to pay inunediately in full as described above,the Note Hulder will still have the right to do so if I am irr default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Molder has required me to pay inunediately in full as described above,the Note Holder will have the right to be paid back by me for all of its costs and expenses iu enforcing this Note to the extent not prohibited by applicable law. Those expenses includeJor example,reasonable attorneys'fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by fust class mail to me at the Property Address above or at a different address if I give the Now Holder a notice of my different address_ Arty notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A)above or at a different address if I am given a notice of that dirferent address. S_ OBLIGATIONS OF PERSONS UNDER THIS NO"T"E If more than one person signs this Notc, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any petson who is a guarantor, surety or endorser of this Note is also obligated to do these things.Any person who takes over these obligations,including the obligations of a guarantor,surety or endorser of this Note,is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together.This means that arty one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations'under ibis Note waive the rights of Presentment and Notice of Dishonor_ "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor"means the right to require the Note Holder to give notice to other persons that amounts due have not been paid_ 1t?. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Bolder under this Note,a Mortgage, Deed of'l est,or Security Deed (the"Security Instrument"), dated the same date as this Note, i protects are Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note.Some of those conditions are described as follows: I£all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower,is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of al i sums seared by this Security Instrument.However,this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. i I - j I MULTISTATE FIXED RATE NOTE--Single Family-Fannia Mae/Freddie Mac UNIFORM INSTRUMENT Form 3200 1101 Fixed Rate Note 2005N-XX(05111) Page 2 of i LOAN t' If Lender exercises dds upticm,Lender shall give Borrower notice of acceleration.The notice shall period of not less than 30 days from the date the notice is given in accordance with Section 15 within which. Bormwer must pay all sums secured by this Security Instrument. if.Porrower fails to pay these Sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand.on Borrower. i I 'WITNESS THE HAND(S)AND SEAL(S) OF THE UNDERSIGNED. (Seal) z V11iRy J. EMIDEL -Borrower -Borrower (Seal) Borrower I (Seal) -Borrower (Sign Urigina!Untyi i I i i MULTISTATE FIXED RATE NOTE--Single Family--Fannie MaelFreddic Mac UNIFORM INSTRUMENT Form 3200 1101 Fixed Rate Note 2005N-XX(05111) Page 3 of 3 i I EXHIBIT B Zucker,Goldberg&Ackerman, LLC ALL THAT CERTAIN house and Iot of ground situated on the Northwest corner of Fairfield Street and Rose Alley in the Borough of Newville, County of Cumberland and State of Pennsylvania bounded and described as follows: BEGINNING at a point, corner of Fairfield Street and Rose Alley;thence along the North side of Fairfield Street, 33 1/feet to a corner of property formerly of Ralph Lehman,now or formerly of Woodrow Miller;thence by said property of Woodrow Miller,North 6 %degrees East,60-feet to a post;thence by the same,North 16 1/2degrees East, 161 feet to a post; thence by property formerly of Harvey Heberlig,now or formerly of Elmer Kough,73 1/ degrees East,45 %z feet to said Rose Alley;thence along said Rose Alley,200 feet to the place of BEGINNING. i i i , VERIFICATION /1 hereby states that he sh is L�.rszrf//i� �of Bank of Ameri , NA, Plainti in this matter,that he she '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 his er nowledge,information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to unsworn falsification to authorities. Signature: J�O Print Name: Title: �Ss/fnf By: Bank of America, N.A. Date: S y� File No: 190239 Borrower Name: Zachary J. Beidel I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA i Bank of America,N.A.,Successor by Merger to BAC Home Loans CIVIL DIVISION - Servicing,LP Plaintiff, NO.. Zachary J.Beidel; � Defendant. 5 %> NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First,within twenty(20) days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you.Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date.During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint.If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty(60) days of the service upon you of the foreclosure complaint. if you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE.TIDS PROGRAM IS FREE. ZUCKER,GOLDBERG&ACKERMAN,LLC By. N M a q Dated: July 1,2014 Scott A.Dietterick,Esquire; A I.D.#556t() Kimberly A.Bonner,Esquire; PA I.D.#89705 Joel A.Ackerman,Esquire; PA I.D.#202729 Ashleigh L.Marin,Esquire; PA I.D.#306799 Ralph M.Salvia,Esquire;PA I.D.#202946 Jaime R.Ackerman,Esquire;PA I.D.#311032 Jana Fridfinnsdottir,Esquire;PA I.D.#315944 Brian Nicholas,Esquire; PA I.D.#317240 Denise Carlon,Esquire;PA I.D.#317226 Attorneys for Plaintiff XCP-190239/emed 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 (908)233-8500;(908)233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XCP-190239 Ill ij'; Cumberland County Residential Mortgage Foreclosure Diversion Program j� 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: CUSTOMER/PRI Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes& Insurance: Date of Last Payment: - Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number&attorney: Zucker,Goldberg&Ackerman,LLC XCP-190239 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: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ if yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): - Fax: Email: Zucker,Goldberg&Ackerman, LLC XCP-190239 ' 1 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? j Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for.delinquency and any supporting documentation (hardship letter) V Listing agreement(if property is currently on the market) Zucker,Goldberg&Ackerman, LLC XCP-190239 i I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A.,Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP Plaintiff, NO.: VS. Zachary J. Beidel; Defendant. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28,2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies a`s follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property,which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker,Goldberg&Ackerman, LLC XCP-190239 ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A.,Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP Plaintiff, NO.: VS. Zachary J. Beidel; Defendant. CASE MANAGEMENT ORDER AND NOW,this day of ,20 ,the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in at the Cumberland County Courthouse,Carlisle, Pennsylvania. 1. At least twenty-one(21) days prior to the date of the Conciliation Conference,the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2)which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference.The representative-of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker,Goldberg&Ackerman,LLC XCP-190239 � IIS resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference,the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 3. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure;entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker,Goldberg&Ackerman, LLC XCP-190239 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _ r LE :- ' .. V Sheriff �t; THE PROTi HONG IA, ': Jody S Smith Chief Deputy Richard W Stewart Solicitor ce0S..' of CH1116cr'a OFFICE OF THE SHERIFF 2:514 JUL I 1 IM10:20 CUMBERLAND COUNTY PENNSYLVANIA Bank of America, N.A. Successor by Merger to BAC vs. Zachary J Beidel Case Number 2014-3896 SHERIFF'S RETURN OF SERVICE 07/08/2014 12:45 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Zachary J Beidel at 6 Fairfield Street, Newville Borough, Newville, PA 17241 L A CLINE, DEPUTY SHERIFF COST: $51.56 SO ANSWERS, July 09, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RONNY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of AmericaN.A., Successor by Merger to BAC CIVIL DIVISION Home Loans Servicing, LP, No.: 14 -3896 -CIVIL Plaintiff, vs. ISSUE NUMBER: Zachary J. Beidel; TYPE OF PLEADING: Defendant. Mortgaged Premises: 6 Fairfield Street, Newville, PA 17241 PRAECIPE FOR ENTRY OF JUDGMENT BY/- DEFAULT (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKRMAN LLC Scott A. Dietterick, Esquire- Pa. I.D. #55650 Kimberly A. Bonner, Esquire- Pa. LD. #89705 Joel A. Ackerman, Esquire- Pa |.D.#2O%729 Ashleigh Levy Marin, Esquire- Pa}.D.#3O6799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R.Ackerman, Esquire- Pa|.D.#311O32 Jana pridfinnsdotdr,Esquire- Pa|.D.#315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa|.D.#317236 Roger Fay, Esquire; 9A|.D.#315987 200 Sheffield StreetSuite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XCP-190239 91x(4 ;Li/ 7g/ � _� k'n^ �� 14_ Praecipe c'ntryof,L4One(j/c/ Zucker, Goldberg & Ackerman, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., Successor by Merger to BAC CIVIL DIVISION Home Loans Servicing, LP, Plaintiff, No.: 14 -3896 -CIVIL vs. ISSUE NUMBER: Zachary J. Beidel; TYPE OF PLEADING: Defendant. Mortgaged Premises: 6 Fairfield Street, Newville, PA 17241 PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa. I.D. #55650 Kimberly A. Bonner, Esquire- Pa. I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh Levy Marin, Esquire- Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XCP-190239 Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XCP-190239 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP vs. Zachary J. Beidel; Plaintiff, Defendant. NO.: 14 -3896 -CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above -captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiffs damages as set forth in Complaint: Amount as set forth in Complaint $120,751.13 plus interest on the judgment amount ($120,751.13) from May 31, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 6 Fairfield Street. address is: Newville, PA 17241 BY: ❑ Scott A. Diet -rick, Esquire; PA. I.D. #55650 ❑ Kimberly A. Bonner, Esquire; PA. I.D. #89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 .-0--Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 ❑ Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XCP-190239 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com ZUCKER, GOLBERG : KE AN, LLC DAMAGES ARE HEREBY ASSESSED AS INDICATED Date lu'2`t 1 14 Prothonotary Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XCP-190239 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP vs. Zachary J. Beidel; • Plaintiff, Defendant. NO.: 14 -3896 -CIVIL AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true and correct to the best of my knowledge, information, and that: 1) The Defendant Zachary J. Beide) is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; Zucker, Goldberg & Ackerman, LLC XCP-190239 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. Dated: /1.2 2,7/y BY: ❑ Scott A. Dietterick, Esquire; PA. I.D. #55650 E Kimberly A. Bonner, Esquire; PA. I.D. #89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 ❑ Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 ❑ Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XCP-190239 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com ZUCKER, GOLBER CKERMAIy//LLC Sworn to and subscribed before me This 3 day of Cf Jek , 20 6c( C • /17AAT,,—__,----Th Notary ublic My Commission Expires: PAUL C. NADRATOWSKI Notary Public of New Jersey ID# 2407850 My Commission Expires 4/27/2016 Zucker, Goldberg & Ackerman, LLC XCP-190239 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: BEIDEL First Name: ZACHARY Middle Name: J Active Duty Status As Of: Oct -24-2014 Results as of : Oct -24.2014 11:27:00 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 D of Active Duty Status Date Active Duly Start Date Active Duty End Date Status . Service Component NA NA No NA 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 notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Yhaut 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/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date, . More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 4EKCZ5CDN055W40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP Plaintiff, vs. Zachary J. Beidel; Defendant. NO.: 14 -3896 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Zachary J. Beidel 6 Fairfield Street Newville, PA 17241 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order,ecree or Judgment was entered in the above captioned IN1DC1Jul proceeding on [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $120,751.13 Zucker, Goldberg & Ackerman, LLC XCP-190239 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP Plaintiff, vs. Zachary J. Beide) Defendant. TO: Zachary J. Beide) 6 Fairfield Street Newville, PA 17241 DATE OF NOTICE: 10/7/2014 CIVIL DIVISION NO.: 14 -3896 -CIVIL IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., Successor by Merger to BAC . Home Loans Servicing, LP Plaintiff, vs. Zachary J. Beide) Defendant. TO: Zachary J. Beide) 6 Fairfield Street Newville, PA 17241 CIVIL DIVISION NO.: 14 -3896 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:10/7/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERlDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS ILVIPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Scoff A. Di,aferi,ck, Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 190239 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY I tut!, f. OFFICE OF THE SHERIFF Bank of America, N.A. Successor by Merger to BAC vs. Zachary J Beidel Case Number 2014-3896 SHERIFF'S RETURN OF SERVICE 07/08/2014 12:45 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Zachary J Beidel at 6 Fairfield Street, Newville Borough, Newville, PA 17241 SHERIFF COST: $51.56 July 09, 2014 (c) CounlySulle Sherd(, Teleoso0 Inc. CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF 1902?9' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP, vs. Zachary J. Beidel; Plaintiff, Defendant. TO THE PROTHONOTARY OF THE SAID COURT: File No. 14 -3896 -CIVIL Amount Due $120,751.13 Interest from 06/01/2014 to date of sale ::$7,299,.77 Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens agains described in the attached exhibit. DATE: -\sc.SDX d o Sf eS6 GST 103_ 75 )1 .66 // ka 00.31 aA41ii349 434.sot-t - Signature: Print Name: iealz. .4//� Scott A. Di,: - , Esquire Kimberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh Levy Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, Esquire Roger Fay, Esquire f the defendant(s) Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650; 89705; 202729; 306799; 202946 311032; 315944; 317240; 317226; 315987 -zcf3/ inn aisial Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN house and lot of ground situated on the Northwest corner of Fairfield Street and Rose Alley in the Borough of Newville, County of Cumberland and State of Pennsylvania bounded and described as follows: BEGINNING at a point, corner of Fairfield Street and Rose Alley; thence along the North side of Fairfield Street, 33 1/4 feet to a corner of property formerly of Ralph Lehman, now or formerly of Woodrow Miller; thence by said property of Woodrow Miller, North 6 1/2 degrees East, 60 - feet to a post; thence by the same, North 16 1/2 degrees East, 161 feet to a post; thence by property formerly of Harvey Heberlig, now or formerly of Elmer Kough, 73 1/4 degrees East, 45 1/2 feet to said Rose Alley; thence along said Rose Alley, 200 feet to the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 6 Fairfield Street, Newville, PA, 17241. BEING the same premises which Raymond L. Green and Elsie G. Green, husband and wife, by Deed dated August 2, 2011 and recorded September 1, 2011 in and for Cumberland County, Pennsylvania, Instrument #201124465, granted and conveyed unto Zachary J. Beidel, single man. Tax Map No.: 28-20-1754-047. Zucker, Goldberg & Ackerman, LLC XCP-190239 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP, vs. Zachary J. Beidel; Plaintiff, Defendant. TO THE PROTHONOTARY OF THE SAID COURT: File No. 14 -3896 -CIVIL Amount Due $120,751.13 Interest from 06/01/2014 to date of sale $7,299.77 Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens agains described in the attached exhibit. DATE: Signature: �eal : •f the defendant(s) ."Ar Print Name: Scott A. 'i �'� Esquire Kimberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh Levy Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, Esquire Roger Fay, Esquire Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650; 89705; 202729; 306799; 202946 311032; 315944; 317240; 317226; 315987 r Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN house and lot of ground situated on the Northwest corner of Fairfield Street and Rose Alley in the Borough of Newville, County of Cumberland and State of Pennsylvania bounded and described as follows: BEGINNING at a point, corner of Fairfield Street and Rose Alley; thence along the North side of Fairfield Street, 33 1/4 feet to a corner of property formerly of Ralph Lehman, now or formerly of Woodrow Miller; thence by said property of Woodrow Miller, North 6 1/2 degrees East, 60= feet to a post; thence by the same, North 16 1/2 degrees East, 161 feet to a post; thence by property formerly of Harvey Heberlig, now or formerly of Elmer Kough, 73 1/4 degrees East, 45 1/2 feet to said Rose Alley; thence along said Rose Alley, 200 feet to the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 6 Fairfield Street, Newville, PA, 17241. BEING the same premises which Raymond L. Green and Elsie G. Green, husband and wife, by Deed dated August 2, 2011 and recorded September 1, 2011 in and for Cumberland County, Pennsylvania, Instrument #201124465, granted and conveyed unto Zachary J. Beidel, single man. Tax Map No.: 28-20-1754-047. Zucker, Goldberg & Ackerman, LLC XCP-190239 ',„tY:X. • w:. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • Bank of America, N.A., Successor by Merger to BAC CIVIL DIVISION Home Loans Servicing, LP, Plaintiff, vs. Zachary J. Seidel; Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 NO.: 14 -3896 -CIVIL Execution No.: Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP, Plaintiff in the above action, sets forth as of the date` the Praecipe for Writ of Execution was filed the following information concerning the real property located at 6 Fairfield Street, Newville, PA 17241. 1. Name and Address of Owner(s) or Reputed Owner(s): ZACHARY J. BEIDEL, SINGLE MAN 430 Shippensburg Road Newville, PA 17241-9123 2. Name and Address of Defendant(s) in the Judgment: ZACHARY J. BEIDEL 430 Shippensburg Road Newville, PA 17241-9123 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff 4. Name and Address of the last record holder of every mortgage of record: BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Plaintiff PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to aut - 'ties. Dated: BY: ZUCKER, GOLD6AN LLC Scott A. Die ten , squire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XCP-190239/pn 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XCP-190239 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN house and lot of ground situated on the Northwest corner of Fairfield Street and Rose Alley in the Borough of Newville, County of Cumberland and State of Pennsylvania bounded and described as follows: BEGINNING at a point, corner of Fairfield Street and Rose Alley; thence along the North side of Fairfield Street, 33 1/4 feet to a corner of property formerly of Ralph Lehman, now or formerly of Woodrow Miller; thence by said property of Woodrow Miller, North 6 1/2 degrees East, 60 - feet to a post; thence by the same, North 16 1/2 degrees East, 161 feet to a post; thence by property formerly of Harvey Heberlig, now or formerly of Elmer Kough, 73 1/4 degrees East, 45 1/2 feet to said Rose Alley; thence along said Rose Alley, 200 feet to the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 6 Fairfield Street, Newville, PA, 17241. BEING the same premises which Raymond L. Green and Elsie G. Green, husband and wife, by Deed dated August 2, 2011 and recorded September 1, 2011 in and for Cumberland County, Pennsylvania, Instrument #201124465, granted and conveyed unto Zachary J. Beidel, single man. Tax Map No.: 28-20-1754-047. Zucker, Goldberg & Ackerman, LLC XCP-190239 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bank of America, N.A., Successor by Merger to CIVIL DIVISION BAC Home Loans Servicing, LP vs. Zachary J. Beidel; Plaintiff, • Defendant. NO.: 14 -3896 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Zachary J. Beidel 430 Shippensburg Road Newville, PA 17241-9123 AND 6 Fairfield Street Newville, PA 17241 TAKE NOTICE: - That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on June 3, 2015 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 6 Fairfield Street, Newville, PA, 17241 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 14 -3896 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Zachary J. Beidel, single man Zucker, Goldberg & Ackerman, LLC XCP-190239 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. Zucker, Goldberg & Ackerman, LLC XCP-190239 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. Dated: 17z_a I ill BY: ZUCKER, GOLDBE 4irA Scott A. Die erl Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XCP-190239/pn 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com A LLC VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XCP-190239 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN house and lot of ground situated on the Northwest corner of Fairfield Street and Rose Alley in the Borough of Newville, County of Cumberland and State of Pennsylvania bounded and described as follows: BEGINNING at a point, corner of Fairfield Street and Rose Alley; thence along the North side of Fairfield Street, 33 1/4 feet to a corner of property formerly of Ralph Lehman, now or formerly of Woodrow Miller; thence by said property of Woodrow Miller, North 6 1/2 degrees East, 60= feet to a post; thence by the same, North 16 1/2 degrees East, 161 feet to a post; thence by property formerly of Harvey Heberlig, now or formerly of Elmer Kough, 73 1/4 degrees East, 45 1/2 feet to said Rose Alley; thence along said Rose Alley, 200 feet to the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 6 Fairfield Street, Newville, PA, 17241. BEING the same premises which Raymond L. Green and Elsie G. Green, husband and wife, by Deed dated August 2, 2011 and recorded September 1, 2011 in and for Cumberland County, Pennsylvania, Instrument #201124465, granted and conveyed unto Zachary J. Beidel, single man. Tax Map No.: 28-20-1754-047. Zucker, Goldberg & Ackerman, LLC XCP-190239 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 '(717) 240-6195 www.ccpa.net BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP Vs. NO 14-3896 Civil Term CIVIL ACTION — LAW ZACHARY J. BEIDEL WRIT OF EXECUTION 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:.$120,751.13 L.L.: $.50 Interest FROM 6/1/2014 TO DATE OF SALE - $7,299.77 Atty's Comm: Atty Paid: $200.31 Plaintiff Paid: Date: 12/3/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary B Deputy REQUESTING PARTY: Name: SCOTT A. DIETTERICK, ESQUIRE Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 55650