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Home My WebLink About14-4777 t For Prothonotary Use Only: u -reme Court,.of P"ennsyIvan1a .it 'fit. 'j Docket No. and County 1 \l ,. The inforrrtalion collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service of leadin s or other papers as required by law or rules of court. �^ Commencement of Action: I S S Complaint ❑ Writ of Summons ❑ Petition E ❑Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name:Bank of America,N.A. Lead Defendant's Name:Michael E.Skalka T 1 Are there money damages requested? ❑ Yes S No Dollar Amount Requested: ❑within arbitration limits r 0 (check one) ❑outside arbitration limits N Is this a Class Action Suit? ❑ Yes S No Is this an MDJAppeal? ❑ Yes S No A Name of Plaintiff/Appellant's Attorney:McCabe,Weisberp_&Conway,P.C. ❑ Check here if you have no attorney(a Self-Represented lPro Sel Litigant) L 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 ❑Department of Transportation ❑Premises Liability(does not include ❑ Statutory Appeal: Other S mass tort) E ❑Slander/Libel/Defamation ❑Employment Dispute: ❑Other: Discrimination C ❑Employment Dispute: Other ❑Zoning Board T ❑ Other I 0 ❑Other N MASS TORT ❑Asbestos ❑Tobacco 11 1 ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS B ❑Toxic Waste ❑Ejectment ❑Common Law/Statutory Arbitration ❑Other: ❑Eminent Domain/Condemnation ❑Declaratory Judgment ❑Ground Rent ❑Mandamus ❑Landlord/Tenant Dispute ❑Non-Domestic Relations S Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure:Commercial ❑Quo W arranto ❑Dental ❑Partition ❑Replevin ❑ Legal ❑Quiet Title ❑Other: ❑Medical ❑Other: ❑Other Professional: I L_�_._ Updated 1/1/2011 L � E h,IV S U"�T McCABE,WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE,ESQUIRE- ID# 16496 MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE-ID# 34687 MARGARET GAIRO,ESQUIRE- ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK, ESQUIRE- ID# 74770 MARISA J. COHEN,ESQUIRE-ID# 87830 CHRISTINE L. GRAHAM, ESQUIRE- ID# 309480 BRIAN T. LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID# 201926 JOSEPH F. RIGA,ESQUIRE- ID# 57716 JOSEPH I. FOLEY,ESQUIRE-ID# 314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID #313673 JENNIFER L. WUNDER,ESQUIRE- ID# 315954 LENA KRAVETS, ESQUIRE-ID# 316421 , CAROL A. DiPRINZIO,ESQUIRE-ID# 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 Bank of America,N.A. Cumberland County 1800 Tapo Canyon Road Court of Common Pleas Mail Stop#SV-103 Simi Valley, CA 93063 Number V. Michael E. Skalka 14732 Little Anne Drive Little Elm,TX 75068 and Paula M. Skalka 14732 Little Anne Drive Little Elm, TX 75068 COMPLAINT IN MORTGAGE FORECLOSURE \�S:7S tkile#78138 Page 1 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages,you must take action within ex-puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la Corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisiones de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO BELOW. THIS OFFICE CAN PROVIDE TIENE A UN ABOGADO, VA A O YOU WITH INFORMATION ABOUT TELEFONEA LA OFICINA EXPUSO HIRING A LAWYER. ABAJO. ESTA OFICINA LO PUEDE IF YOU CANNOT AFFORD TO PROPORCIONAR CON INFORMATION HIRE A LAWYER,THIS OFFICE MAY BE ACERCA DE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH Sl USTED N O PUEDE INFORMATION ABOUT AGENCIES PROPORCIONAR PARA EMPLEAR UN THAT MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990-9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 File#78138 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Please Note: (1) unless,within thirty (30) days after your receipt of this notice,you dispute the validity of the debt, or any portion of the debt,we will assume that the debt is valid; (2) if you notify us in writing within thirty (30) days of your receipt of this notice that the debt, or a portion of the debt, is disputed,we will cease collection of the debt until we obtain verification of the debt or a copy of the judgment against you and mail to you a copy of the verification or judgment that we obtain; (3) upon your written request to us within thirty (30) days of your receipt of this notice for the name and address of the original creditor of your debt,we will cease collection of the debt until we mail to you the name and address of the original creditor, if different from the current creditor. Case Name: Bank of America,N.A. v. Michael E. Skalka and Paula M. Skalka Cumberland County File#78138 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is Bank of America, N.A., duly organized and doing business at the above- captioned address. 2. The Defendant is Michael E. Skalka,who is a mortgagor and real owner of the mortgaged property hereinafter described,whose last-known address is 14732 Little Anne Drive,Little Elm,TX 75068. 3. The Defendant is Paula M. Skalka, who is a mortgagor and real owner of the mortgaged property hereinafter described,whose last-known address is 14732 Little Anne Drive,Little Elm,TX 75068. 4. On March 19, 2008,Michael E. Skalka and Paula M. Skalka,mortgagors, made, executed and delivered a Mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as Nominee for Countrywide Bank, FSB, its successors and assigns which Mortgage is recorded in the Office of the Recorder of Cumberland County as Instrument Number 200810224 (the "Mortgage"), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa. R. C. P. 5. On March 19,2008,Defendants,Michael E. Skalka and Paula M. Skalka, also executed a promissory note secured by the aforementioned Mortgage. Plaintiff, directly or through an agent, is in possession of the note and is the holder of the note with the right to enforce it;the note is either made payable to plaintiff or has been duly endorsed. 6. On August 19, 2010, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. to BAC Home Loans Servicing, L.P., by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201029213,such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. Mortgage Electronic Registration Systems,Inc.was acting in its capacity as Nominee for Countrywide Bank,FSB,its successors and assigns. 7. Subsequent thereto, BAC Home Loans Servicing, L.P. merged with and into Bank of America,N.A. and became known as Bank of America,N.A. File#78138 Page 4 8. On October 11, 2012, the Mortgage was assigned by Bank of America, N.A. to Federal National Mortgage Association, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201232360, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa. R. C. P. 9. On January 7,2014,the Mortgage was assigned by Bank ofAmerica,N.A.(BANA)Attorney in Fact (AIF) for Federal National Mortgage Association to Bank of America, N.A., Plaintiff herein, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201416499,such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g)Pa. R. C. P. 10. The premises subject to said Mortgage is described in the legal description attached as Exhibit "A" and is known as 1126 Fairfield Street,Mechanicsburg,Pennsylvania 17050. 11. The Mortgage is in default because monthly payments of principal and interest upon said Mortgage due July 1,2012 and each month thereafter are due and unpaid,and by the terms of said Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. File#78138 Page 5 12. The following amounts are due on the Mortgage as of August 15, 2014: Principal Balance $ 197,114.61 Interest from June 1, 2012 through August 15, 2014 $ 20,102.14 (Plus $24:9768 per diem thereafter) Late Charges $ 500.94 Escrow Advance $ 3,882.07 Property Inspections $ 285.00 Return Payment Fee $ 20.00 Title Fees $ 285.00 Court Costs $ (135.00) GRAND TOTAL $ 222,054.76 r 13. Plaintiff complied with all notice requirements as prescribed by 41 P.S. §101, et seq. (Act 6), and 35 P.S. 1680.401c, et seq. (Act 91), as applicable. WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of $222,054.76,together with interest at the rate of$24.9768 per diem and other costs and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged property. McCABE,WEISBERG& CONWAY,P.C. BY: [ ] Terrence J.McCabe,Esquire [ arc T.Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ] Marisa J.Cohen,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ] Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,Esquire [ ]Jennifer L. Wunder,Esquire [ ]Lena Kravets,Esquire [ ] Carol A.DiPrinzio,Esquire Attorneys for Plaintiff File#78138 Page 6 VERIFICATION PCllnn"I Mo.Aup a anti,_hereby states that he/Oh is&t;c-Idly ide,,+ ofBank of America, N.A.,Plaintiff in this matter,that he/VV'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 hi er knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. By: a.660 Cc. Printed Name: 0.".ami Title: ksI?. gict. nos"dfMt Bank of America,N.A. Date: &Au"'&-�_4, Bank of America,N.A.v.Michael E.Skalka and Paula M.Skalka File#78138 Page 7 a� EXHIBIT "A" 1 1 ALL THAT CERTAIN LOT of ground situate in the Township of Hampden, County of Cumberland and State of Pennsylvania,bounded and described as follows,to wit; BEGINNING at a point in the eastern line of Fairfield Street,which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mention PIan of Lots;thence along the eastern line of Fairfield Street,North 23 degrees west,one hundred(100)feet to a point in.the division line between Lots Nos. 13 and 14 on said Plan;thence along the division line between Lots Nos. 13 and 14 on said Plan;thence along the division line between Lots Nos. 13 and 14,North 67 degrees east,one hundred fifty(150)feet to a point in the division line between Lots Nos. 10 and 13 on said Plan; thence along the division Iine between Lots Nos. 10 and 13, South 23 degrees east, one hundred(100)feet to a point in the division line between Lots Nos. 12 and 13 on said Plan, aforesaid;thence along the division line between Lots Nos. 12 and 13, South 67 degrees west,one hundred fifty(150)feet to a point in the eastern line of Fairfield Street,aforesaid, at the point and place of BEGINNING. BEING Lot No. 13 in the Plan of Lots known as Glennwood and Farm Estates,which said Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County,Pennsylvania in Plan Book 10,at Page 3. UNDER AND SUBJECT,Nevertheless,to certain restrictions and conditions as set forth by Instrument in Writing and Recorded with said Plan of Lot. There is reserved over the rear of the above described Lot, a ten(10)foot utility easement. Said easement parallels Fairfield Street. FORM I Bank of America,N.A. IN THE COtJR`I'OF COMMON PLEAS OF Plaintiff CIJMBERLAND COIJNTY, PENNSYLV'QNIA r vs. • 5 Michael E. Skalka and Paula M. Skalka Civil _ Defendants 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. THIS PROGRAM IS FREE. Respectfully submitted: Date [Signature of Counsel for Pla ntiffJ 78138 Page 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM ER/1"RI MARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑No ❑ Listing date: Price$ Realtor Name: Realtor Phone: Borrower Occupied? Yes❑No❑ Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? CO-BORROWER Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? FINANCIAL O' First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount$ Included Taxes& Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes 0 No 0 If yes, provide names, location of court, case number&attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation(automobiles boats motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description(not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d 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 Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes O No❑ If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)assistance? Yes ❑No❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes 0No❑ 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: 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 obiligation 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: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days f Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement(if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY RonnyRAnderson FI[., D- F ICE Sheriff CT HE PROTHONOTARY Jody S Smith LQ�i(tttt at cumber. Chief Deputy <c i H SEP —2 PM 3. 57 Richard W Stewart " CUMBERLAND COUNTY Solicitor OFFlec OF T. $NERIFF P E NN S Y LVA N I A Bank of America N.A. vs. Michael Skalka (et al.) Case Number 2014-4777 SHERIFF'S RETURN OF SERVICE 08/25/2014 04:20 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Rob Cohut, who accepted as "Adult Person in Charge" for Occupant at 1126 Fairfield Street, Hampden Township, Mechanicsburg, PA 17050. .SON KINSLER, DEPUTY 08/26/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Paula Skalka, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 1126 Fairfield Street, Hampden Township, Mechanicsburg, PA 17050. Current occupant Rob Cohut informed deputies that the defendant has moved to Texas and he was unable to provide a forwarding address for the defendant. 08/26/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael Skalka, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 1126 Fairfield Street, Hampden Township, Mechanicsburg, PA 17050. Current occupant Rob Cohut informed deputies that the defendant has moved to Texas and he was unable to provide a forwarding address for the defendant. SHERIFF COST: $65.30 SO ANSWERS, August 26, 2014 RONNY R ANDERSON, SHERIFF (c) ountySuite Sheriff, Teleosoft. Inc. 1 COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY BANK OF AMERICA, N.A., Plaintiff(s), Index No.: 14-4777 CIVIL Date Issued: 08/12/2014 vs. MICHAEL E. SKALKA, et al., AFFIDAVIT OF SERVICE Defendant(s). STATE OF \ a. e•3 County of mss,. Q rt)r av1. jaHkow1% ss: , the undersigned being duly sworn, deposes and says that I was at the time of service over the age of eighteen and not a party to this action. On 2104 cDoI l( at 129 AM / let) served the within NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRA ; COMPLAINT IN MORTGAGE FORECLOSURE; VERIFICATION on MICHAEL E. SKALKA at 14732 LITTLE ANNE DRIVE, LITTLE ELM, TX 75068 , in the manner indicated below: PERSONAL SERVICE: By delivering thereat a true copy of the aforementioned documents to said recipient personally; deponent knew the person so served to be the person described herein by deponent asking if he or she is the named Recipient and the person responding that he or she is in fact the person named in this action as the Recipient. SUITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of suitable age and discretion at the above address which is MICHAEL E. SKALKA's usual place of residence/place of abode/place of business, with: 1 Recipient's Name: C�,O'c M. Cs ] a_ Relationship: k—c' , a family member or otherP erson at said address. PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on , at AM / PM, on , at AM / PM, and on , at AM / PM. Additional Comments: Description of person process was left with: Sex: �' Skin/Race: Approx. Age: 41 Hair Color: r Height: l0 Weight:1to Other: Is defendant in the military? YES n NO Signed and sworn jq before me on {,p this a -Q day of ?iib , 20 19) . Notary Public 1 ;.;P::4,,,,, BELINDA MAYE BLACK ^ Notary Public, State of Texas •y= My Commission Expires ,„vr:A P�` July 02. 2018 Xe & t t Wit NkD �):. t r,'7 r� C_ (Print Name)::--- `= 11 f I-11 ?% rri co ClientRef#: 234-10167PA� LawFirmRef#: 234-10167PA --< > "`”" CD McCabe, Weisberg & Conway, P.CI #28 --- 123 S. Broad Street Aa. 7; �' -y' -,Philadelphia, PA 19109 c-) —, > cO c T -t o- .:-.7.- COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY BANK OF AMERICA, N.A., Plaintiff(s), Index No.: 14-4777 CIVIL vs. Date Issued: 08/12/2014 MICHAEL E. SKALKA, et al., AFFIDAVIT OF SERVICE Defendant(s). STATE OF County of obi 11111111111111111 J15111 J1.111 11111 1111 1111 ss: , the undersigned being duly sworn, deposes and says that I was at the time of 5erviee Over the agc ofvightm and not a party t� this action. On 21 4.t4uA- 2c:.14 at 1 23 AM served the within NOTICE OF RESIDENTIAL MORTGAGE FOREC SURE DIVERSION PROGRXWICOMPLAINT IN MORTGAGE FORECLOSURE; VERIFICATION on PAULA M. SKALKA at 14732 LITTLE ANNE DRIVE, LITTLE ELM, TX 75068 , in the manner indicated below: PERSONAL SERVICE: By delivering thereat a true copy of the aforementioned documents to said recipient personally; deponent knew the person so served to be the person described herein by deponent asking if he or she is the named Recipient and the person responding that he or she is in fact the person named in this action as the Recipient. SUITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of suitable age and discretion at the above address which is PAULA M. SKALKA's usual place of residence/place of abode/place of business, with: Recipient's Name: Relationship: a family member or other person at said address. 7 PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on , at AM / PM, on , at AM / PM, and on , at AM / PM. Additional Comments: Description of person process was left with: Sex: V Skin/Race: 1,1 Weight: to Other: Is defendant in the military? YES 0 NO Yi Signed and sworn to before me on this day of QA.A.Ptuvb , 20 IV. . Notary Public BELINDA MAYE BLACK Notary Public, State of Texas My Commission Expires July 02, 2018 Approx. Age: Hair Color: IA Height: 1-1 1 0 (Print Name) ClientRef#: 234-10167PA LawFirmRef#: 234-10167PA McCabe, Weisberg & Conway, 123 S. Broad Street Philadelphia, PA 19109 cp ,->c cz P.C. CI128 • McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH 1. FOLEY, ESQUIRE - ID # 314675 CELJNE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bank of America, N.A. Plaintiff v. Michael E. Skalka and Paula M. Skalka Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-4777 Civil n C -�3 mW ern cnr- -<x <U c, zG7 ---4 t —4 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants, Michael E. Skalka and Paula M. Skalka, in the above -captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Amount due Interest from 08/16/14 to 10/08/14 Total Date: 10/8/2014 McCABE, WEISBERG BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph . Riga, Esq. [ ] C e P. DerKrikorian, Esq. [ Carol A. DiPrinzio, Esq. Attorneys for Plaintiff $ 222,054.76 $ 1,348.75 $ 223,403.51 ONWAY, P.C. 4/6. 5-a ed eisberg, Esq. ,e 31,2212 Margaret Gairo, Esq. ] Heidi R. Spivak, Esq. 4011 e ;�alZPl ] Christine L. Graham, Esq. ] Ann E. Swartz, Esq. ] Joseph I. Foley, Esq. ] Lena Kravets, Esq. AND NOW, this /3/4day of Oe T , 2014, Judgment is entered in favor of Plaintiff, Bank of America, N.A., and against Defendants, Michael E. Skalka and Paula M. Skalka, in rem only and not in personam, and damages are assessed in the amount of $223,403.51, plus intermit and costs. BY THE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bank of America, N.A. Plaintiff v. Michael E. Skalka and Paula M. Skalka Defendants Attorne s for Plaintiff Affidavit submitted to the Court for filing on CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-4777 Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants, Michael E. Skalka and Paula M. Skalka, 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, 50 U.S.C. App. §501, et seq.; and that the Defendants, Michael E. Skalka and Paula M. Skalka, are over eighteen (18) years of age, and reside as follows: Michael E. Skalka 14732 Little Anne Drive Little Elm, TX 75068 SWORN AND SUBSCRIBED Date: 10/8/2014 Paula M. Skalka 14732 Little Anne Drive Little Elm, TX 75068 BEFORE ME THIS 8 DAY McCABE, WEISBE ' ' C I WAY, P.C. OF C)t iD'9 .41— , 2014 NOT COMMON LTH PUB OF PENNSYLyga NOTARIAL SEAL BRI -ANNE H. GLADD . Notary City of Philadelphia, Phil .C unty My Commission Expires July 242 17 IA BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Jose . Riga, Esq. [ ] C ne P. DerKrikorian, Esq. arol A. DiPrinzio, Esq. Attorneys for Plaintiff [ j }arc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. Department of Defense Manpower Data Center Status Report Pursuant to Sery cernembeas Civil Relief Act Last Name: SKALKA First Name: MICHAEL Middle Name: E. Active Duty Status As Of: Oct -08-2014 Results as of : Oct -08-2014 11:26:03 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NAie.', ,--A.... ` ...,. ----::,..,L1 No~ .. NA This response reflects the iridivlduals' active dub; status based n the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA %' . - NA '.:` . r iv Note I NA This response reflects vmere the Individual left active duty status within 367 days precedirip the3Active 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 '4:.. NA N. .. ... r iv Note I NA This response reflects whether the individual or his/her unit has received early notllcation 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 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: 5E2A43C3V05EW30 Department of Defense Manpower Data Center Status Report Pursuant to Servicerneembers Civil Relief Act Last Name: SKALKA First Name: PAULA Middle Name: M. Active Duty Status As Of: Oct -08-2014 Results as of : Oct -08-2014 11:27:18 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 n /.-'� - '- r 1;1-O7,%.NA NA This response reflects the' Individuals' active duty status based on the Active Duty Status Date Left Active Duty WIthin 367 Dr of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA t NA . =1 i .,,;r - ;r"No-7 1,- 't NA This response reflects where the Indmdual left-atti a duty status In 367 days preceding the Active Duty Status Date J. 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 Notification End Date Status Service Component NA L. NA u , - ' ., .Nor t NA This response reflects whether the individual di 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. Y� 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 Soldiersand Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty' responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOM 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: XEV3W3E3405FT80 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bank of America, N.A. Plaintiff v. Michael E. Skalka and Paula M. Skalka Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-4777 Civil AFFIDAVIT OF LAST -KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last -known mailing addresses of the Defendants are: Michael E. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 SWORN AND SUBSCRIBED BEFORE ME THIS t DAY OF ,2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL BRI -ANNE H. GLADD,. Notary Public City ofphiladelphia, Phila. County My Cotrnhssion Expires July 24, 2017 SS. Paula M. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 Date: 10/8/2014 McCABE, WEISBERG BY: OIYW.AY, P.C. [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph iga, Esq. [ ] Ce . DerKrikorian, Esq. [ arol A. DiPrinzio, Esq. Attorneys for Plaintiff [ ] Mar Weisberg, Esq. [ ] Mar ret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bank of America, N.A. Plaintiff v. Michael E. Skalka and Paula M. Skalka Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-4777 Civil CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendants that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF QC7fDb-?f ' , 2014 COMM9NWEALTH OF PENNSYLVANIA NOTARIAL SEAL BRI -ANNE H. GLADD, Notary Pubtic City of Philadelphia, Phila. County My Comn*sion Expires July 24, 2017 Date: 10/8/2014 McCABE, WEISBERG,&-CO BY: / [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph . ig Esq. [ ] C e P. DerKrikorian, Esq. [ L arol A. DiPrinzio, Esq. Attorneys for Plaintiff Y, P.C. [ ] Marc S. eisberg, Esq. [ ] Marg et Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE. WEISBERG BY: [ ] Terrence J. McCabe, Esq [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph .Riga Esq. [ ] C e P. DerKrikorian, Esq. [ Carol A. DiPrinzio, Esq. Attorneys for Plaintiff CONWAY, P.C. Bank of America, N.A. v. Michael E. Skalka and Paula M. Skalka Cumberland County; Number: 14-4777 Civil ] Marc S. eisberg,Esq ] Margaret Gairo, Esq. ] Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. ] Ann E. Swartz, Esq. ] Joseph I. Foley, Esq. ] Lena Kravets, Esq. • OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland_County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary September 17, 2014 To: Michael E. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 Bank of America, N.A. vs. Michael E. Skalka Paula M. Skalka Cumberland County Court of Common Pleas Number 14-4777 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUTA 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS I MPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire eline P. DerKrikorian, Esquire Carol A. DiPrinzio, Esquire Attorneys for Plaintiff Jixhihi i' ] Marc S. Weisberg, Esquire 1 Margaret Gairo, Esquire ] Heidi R. Spivak, Esquire ] Christine L. Graham, Esquire ] Ann E. Swartz, Esquire 1 Joseph I. Foley, Esquire ] Lena Kravets, Esquire 78138 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary September 17, 2014 To: Paula M. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 Bank of America, N.A. vs. Michael E. Skalka Paula M. Skalka Cumberland County Court of Common Pleas Number 14-4777 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT 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 (1 0) 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE, SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECERLOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE,,,/WEISBERGiAND CONWAY, P.C. BY: C/V ,l /jt.�C// [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ 1 Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] seph F. Riga, Esquire ine elP. DerKrikorian, [ �Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff ] Marc S. Weisberg, Esquire ] Margaret Gairo, Esquire ] Heidi R. Spivak, Esquire ] Christine L. Graham, Esquire ] Ann E. Swartz, Esquire 1 Joseph I. Foley, Esquire ] Lena Kravets, Esquire 78138 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonota ry To: Michael E. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 Bank of America, N.A. Plaintiff v. Michael E. Skalka and Paula M. Skalka Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-4777 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Paula M. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 Banlc of America, N.A. Plaintiff v. Michael E. Skalka and Paula M. Skalka Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-4777 Civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin 323 Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Bank of America, N.A. FILE NO.: 14-4777 Civil Civil Term C) v. AMOUNT DUE: $223,403.51 cI- y c Paula M. Skalka and Michael E. Skalka INTEREST: from 10/09/14 $5,397.84 at $36.72 ATTY'S COMM.: COSTS: n) TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or 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 or 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) 1126 Fairfield Street, Mechanicsburg, Pennsylvania 17050 (More fully described as 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 personalty list) and all other property ofthe defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the described in the attached exhibit. DATE: 11 (If amishee(s) as a lis pendens against real estate of the defendant(s) MCCAB BY: [ ] Terrence J. ab sq. [ ] Edward D ' onway, Esq. [ ] Andrew . Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ Brian. T. LaManna, Esq. [ Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff ;[ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. 51) Pal �s 30 4. 2.2c ZCo Ls), co G C Address:123 S. Broad Street, Suite 1400 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone:{215) 790 1010 Supreme Court ID No. e#.2010/ Aek- 3! qa7 # eg, W(17Eex ISSuPa/ THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net Bank of America, N.A. Vs. NO 14-4777 Civil Term CIVIL ACTION — LAW Paula M. Skalka and Michael E. Skalka 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: $223,403.51 L.L.: $.50 Interest from 10/09/14 - $5,397.84 at $36.72 Atty's Comm: Due Prothy: $2.25 Atty Paid: $226.05 Other Costs: Plaintiff Paid: Date: 11/26/14 //1g,41/ David. D. Buleillit 41Irnota , (Seal) By: Deputy REQUESTING PARTY: Name: Joseph F. Riga, Esq. Address: 123 S. Broad Street, Suite 1400 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: 215-790-1010 Supreme Court ID No. 57716 McCABE; WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Bank of America, N.A. Plaintiff v. Paula M. Skalka and Michael E. Skalka Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-4777 Civil AFFIDAVIT PURSUANT TO RULE 3129.1. C-) r., C D r`) —a C) The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1126 Fairfield Street, Mechanicsburg, Pennsylvania 17050, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Paula M. Skalka Michael E. Skalka 2. Name and address of Defendants in the judgment: 14732 Little Anne Drive Little Elm, Texas 75068 14732 Little Anne Drive Little Elm, Texas 75068 Name Address Paula M. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 Michael E. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Hampden Township Address 230 South Sporting Hill Road Mechanicsburg, Pennsylvania 17050 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Address 1126 Fairfield Street Mechanicsburg, Pennsylvania 17050 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 86 Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America do Atty General of the United States United States of America c/o Atty General of the United States PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name None Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 0 I ( (41 DATE BY: [ ] Terrence cCaie, Esq. [ . ] Marc S. Weisberg, Esq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. VI, Joseph F. Riga, Esq. [ ] Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff Bank of America, N.A. v. Paula M. Skalka and Michael E. Skalka Cumberland County; Number: 14-4777 Civil LEGAL DESCRIPTION ALL THAT CERTAIN LOT of ground situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the eastern line of Fairfield Street, which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mention Plan of Lots; thence along the eastern line of Fairfield Street, North 23 degrees West, one hundred (100) feet to a point in the division line between Lots Nos. 13 and 14 on said Plan; thence along the division line between Lots Nos. 13 and 14, North 67 degrees East, one hundred fifty (150) feet to a point in. the division line between Lots Nos. 10 and 13 on said Plan; thence along the division line between Lots Nos. 10 and 13, South 23 degrees East, one hundred (100) feet to a point in the division line between Lots Nos. 12 and 13 on said Plan, aforesaid; thence along the division line between Lots Nos. 12 and 13, South 67 degrees West, one hundred fifty (150) feet to a point in. the eastern line of Fairfield Street, aforesaid, at the point and place of BEGINNING. BEING Lot No. 13 in the Plan of Lots known as Glennwood Faris Estates, which said Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 10, at Page 3. UNDER AND SUBJECT, NEVERTHELESS, to certain restrictions and conditions as set forth by Instrument in Writing and Recorded with said Plan of Lot. There is reserved over the rear of the above described Lot, a ten (10) foot utility easement. Said easement parallels Fairfield Street. Premises: 1126 Fairfield Street, Mechanicsburg, Pennsylvania 17050. BEING the same premises which Dennis G. Jaster, married man, and Stephen H. Ritter, married man by deed dated February 28, 2005 and recorded February 28, 2005 in Deed Book 267, page3567, granted and conveyed unto Paula M. Skalka and Michael E. Skalka. TAX MAP PARCEL NUMBER: 10-17-1029-050 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Bank of America, N.A. v. Paula M. Skalka and Michael E. Skalka Paula M. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-4777 Civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Michael E. Skalka 14732 Little Anne Drive Little Elm, Texas 75068 r Your house (real estate) at 1126 Fairfield Street, Mechanicsburg, Pennsylvania 17050 is scheduled to be sold at Sheriffs Sale on March 4, 2015 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $223,403.51 obtained by Bank of America, N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Bank of America, N.A. the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE • PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN LOT of ground situate in the Township of Hampden, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the eastern line of Fairfield Street, which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mention Plan of Lots; thence along the eastern line of Fairfield Street, North 23 degrees West, one hundred (100) feet to a point in, the division line between Lots Nos. 13 and 14 on said Plan; thence along the division line between Lots Nos. 13 and 14, North 67 degrees East, one hundred fifty (150) feet to a point -in the division line between Lots Nos. 10 and 13 on said Plan; thence along the division line between Lots Nos. 10 and 13, South 23 degrees East, one hundred (100) feet to a point in the division line between Lots Nos. 12 and 13 on said Plan, aforesaid; thence along the division line between Lots Nos. 12 and 13, South 67 degrees West, one hundred fifty (150) feet to a point in the eastern line of Fairfield Street, aforesaid, at the point and place of BEGINNING. BEING Lot No.13 in the Plan of Lots known as Glennwood Farm Estates, which said Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 10, at Page 1 UNDER AND SUBJECT, NEVERTHELESS, to certain restrictions and conditions as set forth by Instrument in Writing and Recorded with said Plan of Lot. There is reserved over the rear of the above described Lot, a ten (10) foot utility easement. Said easement parallels Fairfield Street. Premises: 1126 Fairfield Street, Mechanicsburg, Pennsylvania 17050. BEING the same premises which Dennis G. Jaster, married man, and Stephen H. Ritter, married man by deed dated February 28, 2005 and recorded February 28, 2005 in Deed Book 267, page3567, granted and conveyed unto Paula M. Skalka and Michael E. Skalka. TAX MAP PARCEL NUMBER: 10-17-1029-050 COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY BANK OF AMERICA, N.A., Plaintiff(s), Index No.: 14-4777 CIVIL vs. Sale Date: 03/04/2015 PAULA M. SKALKA, et al., AFFIDAVIT OF SERVICE Defendant(s). STATE OF Ve� County of Q.tti-f -itv.- ss: 11 e. �C.lj j i t k- , the undersigned being duly sworn, deposes and says that I was at the time of serve over the age of eighteen and not a party to this action. On 12.-17-70f at Z.'1.5 A*f /' served the within NOTICE OF SHERIFF'S SALE OF REAL PROPERTY on MICHAEL E. SKALKA a 4732 LITTLE ANNE DRIVE, LITTLE ELM, TX 75068 , in the manner indicated below: ERSONAL SERVICE: By delivering thereat a true copy of the aforementioned documents to said recipient personally; deponent knew the person so served to be the person described herein by deponent asking if he or she is the named Recipient and the person responding that he or she is in fact the person named in this action as the Recipient. n SUITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of suitable age and discretion at the above address which is MICHAEL E. SKALKA's usual place of residence/place of abode/place of business, with: Recipient's Name: Relationship: , a family member or other person at said address. ❑ PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on , at AM / PM, on , at AM / PM, and on , at AM / PM, Additional Comments: Description of person process was left with: Sex:_ / Skin/Race: W�'t ! T_ Approx. Age:9V �5 Hair Color: 4 Height: S %) Weight: (CJ Other: ,.,/ Is defendant in the military? YES n NO I� Signesworn t efore me on this K day of Q , 20/ 1 ry Publi SUNNY S. BUSKIRK My Commission Expires March 24, 2016 ............ ClientRef#:234-10167PA , LawFirmRef#: 234-10167PA McCabe, Weisberg & Conway, P.C. CID #28 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 y r 47, y COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY BANK OF AMERICA, N.A., " . Plaintiff(s), vs. PAULA M. SKALKA, et al., Defendant(s). STATE OF-"f'_fitg County of p rtr01- ss: Index No.: 14-4777 CIVIL Sale Date: 03/04/2015 AFFIDAVIT OF SERVICE 1111111 i 11111111111111111111111 CrAfjii k g u5K1 , the undersigned being duly sworn, deposes and says that I was at the time of servYce over the age of eighteen and not a party to this action. On (2-1 Y 7o/ at 2 c 15 .AGI' I served the within NOTICE OF SHERIFF'S SALE OF REAL PROPERTY on PAULA M. SKALKA at 32 LITTLE ANNE DRIVE, LITTLE ELM, TX 75068 , in the manner indicated below: U PERSONAL SERVICE: By delivering thereat a true copy of the aforementioned documents to said recipient personally; deponent knew the person so served to be the person described herein by deponent asking if he or she is the named Recipient and the person responding that he or she is in fact the person named in this action as the vSecipient. UITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of suitable age and discretion at the above address which is PAULA M. SKALKA's usual place of residence/place of abode/place of business, with: �/ /jam Recipient's Name: '�I I eh4 ( 8, 51'�al/ J , Relationship: tL(.L5ba4 , a family member or other person at said address. II PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on , at AM / PM. AM / PM, on , at AM / PM, and on , at Additional Comments: Description of person process w s left with: Sex: / ' 1 Skin/Race: iii f e-- Approx. Ager(Hair Color: EOM Weight: 2Q 0 Other: Is defendant in the military? YES ❑ NO UJ Height: Sign this 01,6 �• _i/ otary Public sworn t• before me on y of 20/1 SUN!!Y S. BUSKIRK My Commission Expires {Bare:+ 24, 2016 ................ (I 7,-,1 ha,c,sectort (Print Name) ClientRef#: 234-10167PA LawFirmRef#: 234-10167PA McCabe, Weisberg & Conway, P.C. CID '#28 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109