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HomeMy WebLinkAbout14-4512 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet CUMBERLAND County Docket No: J 1 V The information collected on this form is used solelyfor court administration purposes. This form does not supplement or replace thefiling and service qfpleadings or other papers as required by law or rules of court. Commencement of Action: S O Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: BANK OF AMERICA,N.A. Lead Defendant's Name: DONNA L. MILES S/B/M TO BAC HOME LOANS SERVICING,LP F/K/A T COUNTRYWIDE HOME LOANS SERVICING, LP I Dollar Amount Requested: El within arbitration limits O Are money damages requested? El Yes M No (Check one) ❑x outside arbitration limits N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes ❑x No A Name of Plaintiff/Appellant's Attorney: Jonathan Lobb,Esq., Id.No.312174,Phelan Hallinan,LLP ❑ Check here if you have no attorney(are a Self.-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability(does not S include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other ❑Zoning Board C ❑Other: T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco — ❑ Toxic Tort- DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑Ejectment ❑ Common Law/Statutory Arbitration B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑Non-Domestic Relations Z Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Pa.R.C.P, 205.5 Updated 01/01/2011 FORM 1 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 947318 ?014 jtj L CU pBERL AND C411 v SYCVA jjA1jT., PI-IELAN HALLINAN,LLP Jonathan Lobb,Esq.,Id.No.312174 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia,PA 19103 Jonathan.Lobb@phelanhall inan.com 215-563-7000 BANK OF AMERICA,N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE COURT OF COMMON PLEAS HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE CIVIL DIVISION PLANO,TX 75024 TERM Plaintiff V, NO, DONNA L. MILES CUMBERLAND COUNTY 6811 SALEM PARK CIRCLE MECHANICSBURG, PA 17050-2847 TIMMY R. MILES 6811 SALEM PARK CIRCLE MECHANICSB-URG, PA 17050-2847 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE aMA a 113.75 Pd a File ti 947316 C�-11� i Uu a3s� ?CA a3 i. Plaintiff is BANK OF AMERICA,N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP 7105 CORPORATE DRIVE PLANO,TX 75024 2. The name(s)and last known address(es) of the Defendant(s)are: DONNA L.MILES 6811 SALEM PARK CIRCLE MECHANICSBURG,PA 17050-2847 TIMMY R. MILES 6811 SALEM PARK CIRCLE MECHANICSBURG,PA 17050-2847 who is/are the mortgagor(s) and/or real owner(s)of the property hereinafter described. 3. On 08/28/2009 DONNA L. MILES and TIMMY R. MILES made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR BANK OF AMERICA,N.A., which'mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200930492. By Assignment of Mortgage recorded 04/10/2012 the mortgage was assigned to PLAINTIFF,which Assignment is recorded in Assignment of Mortgage Instrument No. 201210199.The mortgage and assignment(s), if any,are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g);which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. BANK OF AMERICA,N.A. SB/M TO SAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP, directly or through an agent, has File N: 947318 possession of the promissory note. The promissory note is either made payable to BANK OF AMERICA,N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE. HOME LOANS SERVICING, LP or has been duly endorsed. 5. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01/01/2014 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor,the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage as of 05/13/2014; Principal Balance $111,856.92 Interest $2,167.20 12/01/2013 through 05/31/2014 Late Charges $149.45 Subtotal $114,173.57 Suspense Credit ($35.31) Escrow Credit LUZI.641 TOTAL $113,866.62 8. Plaintiff is not seeking a judgment of personal liability (or an in person am judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding,this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File a 947314 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) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured, WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $113,866.62, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: 14A __. Jona an Lobb, Esq., Id. No.312174 Attorney for Plaintiff File 4 947318 LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, lying and being in the Township of Hampden, County of Cumberland and State of Pennsylvania, more particularly described as follows: BEGINNING at the point of intersection of the northern line of a twenty (20) foot wide driveway and the line of adjoiner between Lots 130 and 131 on the hereinafter mentioned plan of lots, said point also being referenced along said northern line of driveway, South 69 degrees 35 minutes 1 I seconds West, a distance of 147.0 feet, more or less,from the western curve line of Park Circle; thence South 69 degrees 35 minutes 1 I seconds West along said northern line of driveway a distance of 20.0 feet to a point;thence North 20 degrees 24 minutes 49 seconds West along the eastern line of common lands now or formerly of EME Development Corporation a distance of 100.0 feet to a point on the southern line of a twenty (20) foot wide sanitary and storm sewer easement; thence North 69 degrees 35 minutes I I seconds East along said southern line of easement a distance of 20.0 feet to a point;thence South 20 degrees 24 minutes 49 seconds East along the line of adjoiner between Lots 130 and 131 on said plan a distance of 100.0 feet to a point on the northern line of a twenty (20) foot wide driveway,the point and place of BEGINNING. BEING Lot No. 130 on the Plan of Salem Park Land Development as recorded in the Cumberland County Recorder of Deeds in Plan Book 25, page 12. HAVING THEREON ERECTED a townhouse style dwelling known and numbered as 6811 Salem Park Circle. File N: 947318 PROPERTY ADDRESS: 6811 SALEM PARK CIRCLE, MECHANICSBURG,PA 17050- 2847 PARCEL #10-19-1606-087. File N: 947318 VERIFICATION hereby states that /she is ri` Pf _of BANK Ola AMERICA,N.A., Plaintiff in this matter, that&/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best oll his her 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. DATE: Name: 41 Ua,1 , . /1� 7 Title: _ 4,,,1 V�ce.l,'Es�Clt• BANK OF AMERICA,N.A. File#: 947318 Name: MILES File N: 947318 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson SheriffHE PRO THONCITAR Cir irit0)1%1, Jody S Smith Chief Deputy Y 2014 AUG 19 AM 16: 2 G Richard W Stewart Qf�QE�.ANQ COUNT �' t' Solicitor C1crF;; OF THE sN=FIEF ENNS i LVANIA Bank of America, N.A. vs. Donna L Miles (et al.) Case Number 2014-4512 SHERIFF'S RETURN OF SERVICE 08/12/2014 03:55 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Donna L Miles at 6811 Salem Park Circle, Hampden Township, Mechanicsburg, PA 17050. DE IS FRY, PUTY 08/12/2014 03:55 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Donna Miles, wife, who accepted as "Adult Person in Charge" for Timmy R Miles at 6811 Salem Park Circle, Hampden Township, Mechanicsburg, PA 17050. SHERIFF COST: $55.30 August 14, 2014 tc) County: uite Sheriff, Teleosoft, Inc. DE IS FRY, DE. SO ANSWERS, RONNS' R ANDERSON, SHERIFF PHELAN HALL1NAN, LLP Kenya Bates, Esq., Id. No.203664 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 kenya.bates@phelanhallinan.com 215-563-7000 r.iF THE PROTHONO TAW:" 20111 SEP 23 AMO: 34 CUMBERLAND COUNTY PENNSYLVANIA BANK OF AMERICA, N.A. S/B/NI TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP VS. DONNA L. MILES TIMMY R. MILES Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14-4512 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DONNA L. MILES and TIMMY R. MILES, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $113,866.62 TOTAL $113,866.62 I hereby certify that (1) the Defendants' last known address is 6811 SALEM PARK CIRCLE, MECHANICSBURG, PA 17050-2847, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date Kenya ates, Esq., Id. No.203664 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: C‘ oglo PH # 947318 PROTHONOTARY PHELAN HALLINAN, LLP Kenya Bates, Esq., Id. No.203664 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 kenya.bates@phelanhallinan.com 215-563-7000 BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP vs. DONNA L. MILES TIMMY R. MILES Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION : No. 14-4512 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) DONNA L. MILES and TIMMY R. MILES are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant DONNA L. MILES is over 18 years of age and resides at 6811 SALEM PARK CIRCLE, MECHANICSBURG, PA 17050-2847. (c) that defendant TIMMY R. MILES is over 18 years of age and resides at 6811 SALEM PARK CIRCLE, MECHANICSBURG, PA 17050-2847. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date Phelan Ilallinan, LLP Kenya Bates, Esq., Id. No.203664 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 947318 Department of Defense Manpower Data Center Status. Report Pursuant to SSI"viceinembers Civil. R, lief Act Last Name: MILES First Name: TIMMY Middle Name: R Active Duty Status As Of: Sep -22-2014 Results as of : Sep -22-2014 12:07:42 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duly End Date Status Service Component NA NA l' t ..-- -- -- No z NA This ' active d- r response reflects the Individuals my status based on the Active Duty Status Date fJ • Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA t NA _ ... _' - �. No ' NA This re ponse reflects where the individual leftactiveduty 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. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Status Report t to Senricemembers Civil Relief Act Last Name: MILES First Name: DONNA Middle Name: L Active Duty Status As Of: Sep -22-2014 Results as of : Sep -22-2014 12:07:34 AM SCRA 30 On Active Duty On Active Duty Status Date Active Duly Start Date Active Duty End Date Status Service Component NA NA ,- s'i. • 'is _. --iir- :- NC %., NA This response reflect;iheindkluals'active duty status based on The Active Dui), 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 This response reflects where the individual left active duly -Status within 367 'days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notiticatran 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 tor 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. ril Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff V. DONNA L. MILES TIMMY R. MILES Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO, 14-4512 CIVIL CUMBERLAND COUNTY TO: DONNA L. MILES 6811 SALEM PARK CIRCLE MECHANICSBURG, PA 17050-2847 DATE OF NOTICE: .1;14 I VI 11 THIS FIRM IS A DEBT COLLEL 1 OR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN Al 1EMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 947318 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 Michael Dingerdissen, Esq., Id. No.317124 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 BANK OF AMERICA, N.A. S/B/M TO BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS SERVICING, LP Plaintiff v. DONNA L. MILES TIMMY R. MILES Defendant(s) TO: TIMMY R. MILES 6811 SALEM PARK CIRCLE MECHANICSBURG .PA 17050-2847 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-4512 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WIT .1, BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AI 1EMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY A FI ORNEY 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 FI:E. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By:. PH # 947318 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 Mic iael . "rngerd ssen,'Esq., .[d: No.317124 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19 ] 03 (Rule of Civil Procedure No. 236) - Revised BANK OF AMERICA, N.A. S/B/M TO CUMBERLAND COUNTY BAC HOME LOANS SERVICING, LP F/K/A COUNTRYWIDE HOME LOANS COURT OF COMMON PLEAS SERVICING, LP vs. DONNA L. MILES TIMMY R. MILES against you on : CIVIL DIVISION : No. 14-4512 CIVIL Notice is given hat a Judgment in the above captioned matter has been entered. If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Kenya Bates, Esq., Id. No.203664 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 947318