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