The URL can be used to link to this page

Home My WebLink About01-03377 , . ... FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (71 'i) 'ifi,-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION WELLS FARGO HOME MORTGAGE, INC, FIK/A NORWEST MORTGAGE INC, 5024 P ARKW A Y PLAZA BOULEVARD, BUILDING 7 !FIC CHARLOTTE, NC 28217-2407 Plaintiff TERM NO. 01- .3J77 QI~\..C I~ v, CUMBERLAND COUNTY ROBERT J. WORMSER DOROTHY S. WORMSER 844 ANTHONY DRIVE MECHANICSBURG, P A. 17055 Defendant(s) CIVIl. ACTION - l.A W COMPT.A TNT TN MORTr.Ar.E FORECI .OSTlRE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #:9038140 >'\lj!I , ':". ,-. ",,,."'07'_,,""" '''~ ",_. "',, . - . -" . '"" .... "".., ,A,. --, ' IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. , ~.,. - ,-, _ .' or ~ 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC. F/KJA NORWEST MORTGAGE INC, 5024 P ARKW A Y PLAZA BOULEVARD, BUILDING 7 !FIC CHARLOTTE, NC 28217-2407 2, The name(s) and last known addressees) of the Defendant(s) are: ROBERT J. WORMSER DOROTHY S, WORMSER 844 ANTHONY DRIVE MECHANICSBURG, P A. 17055 who islare the mortgagor(s) and real owner(s) of the property hereinafter described, 3, On 4/8/88 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to THE PRUDENTIAL HOME MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 907, Page 899. By Assignment of Mortgage recorded 10/1/96 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No, 531, Page 444, 4, The premises subject to said mortgage is described as attached. 5, The mortgage is in default because monthly payments of principal and interest upon said mortgage due 2/1/01 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, '"" . -- ~ , --" ,- .,-, , " ,- 6, The following amounts are due on the mortgage: Principal Balance Interest 1/1/01 through 5/1/01 (per Diem $23.86) Attorney's Fees Cumulative Late Charges 4/8/88 to 5/1/01 Cost of Suit and Title Search Subtotal $91,638.55 2,887.06 4,000.00 107.13 .iiOJill $99,182.74 Escrow Credit Deficit Subtotal 0.00 D..llil S; 000 TOTAL $99,182.74 7, The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale, If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged, 8. The mortgaged premises is =ant and "h"nrlonerl, WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $99,182.74, together with interest from 5/1/01 at the rate of$23.86 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ?-4c:r~ Is/ Fnmk Pp.np.nn::m FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 'l~~~,c ,'..,~' .c. <_ ", , "r v" ',,< l '_.-.~..._-_.- ~ALL THAT CERTAIN ~~ac~ a~ parcel o~ ground wi~h 1m~rovem.n~. ~hereon .rec~ed s1~ua~e in ~he Township o~ Hampden. Coun~y o~ CUMberland end S~.tB o~ Pennsyl~.n1a. more par~icu'ar'y bounded and descr1ped as fo'10w$p ~o w1~: BEGINNING _t a point an the'sou~hern r1Qh~-o~-wOY '1"e of Anchony Or1ve (~o~~erly M.roare~ Road) a~ ~ne d1v1d1ng 11"0 between Lo~. NOSa 38 and 39 on ehe her81na~ter mentioned Plan of Lots; ~hence along said dividing line sou~h n1neceen (19) degrees twenty-one minute. (21) twen~y-Cwo seco~ds wes~ one hundred ninety and cweney-n1n_ one hundredths (190.29) ~ee~ to line o~ Lot No.6. Plan No.1, Pert of Section II. Daimler Monor; thence .long che same and a10nQ the line oT Lot No.7 on ehe said P'a~. nor~h e1Qh~y~~wo (82) degrees ~w.n~y-n1n. minu~.. ~~O (02) seconds ea.~ one hundred seven~y-eigh~ ond ~1ve-~enths (178.5) ~..e ~o 11n_ o~ Lot No. 40 on ~he he~.1~a~~.r men~1oned P1an; ~h.nc. along tn_ sam. nor~h seven (07) de9rees f1f~y-one (51) m1nuees ~h1r~y-.ou~ (34) seconds wes~. one hundred ~or~y-e1ghe and f1#eeen" one-hundradt::.bc (148.15) 'f'.'et; e-o 1:he $ouehern righe-of-wa',y Oof Anochony Orive-. 1:henc:e along ~he same 1" a wesr:e,..1y di,rect1on around a cu~v. to the right h~v1"Q a radius o~ ~~o.hundred (200) feet. an arC distance o~ ninety-five (95) feee. ~o_ the 11na of Lot No. 38, ~hv place o~ BEGINNING. BEING ell c~ Lo~ No. 39, on en. ~1nal Plan No. 2, Par~ .o~ S.c~1on 2. Daimler Manor. recorded at ~lan Soak 33. POQ8 10. Cumberland Ccun~v Records. HAVING THEREON erected a two story brick and ~rem. dwelling house No. 844 An~hony Or1vQ. Mechan1c~b~rg, Pennsylvania. UND~~ ANO SUBJECT ~o cond1eions. rign~s-of-way and resCr1c~ions o~ record, including w1~hOU~ l1miea~1on~ a drainaQe easement as shown on the said P'an across the southern portion o~ the premis... ~eING th_ same premises which ja~es w. Gr8gor~ and Ma~y R. Gregory, his wife. by ~he1r deed da~ed Sep~ember 19, 1986. and r.co~ded in the Office o'f' the Recorder a~ Deeds in and for Cumber'an~ Count~. in Deed Sook E-32. PaQG 713. o~an~.d and conveyed uneo Oav1d ~. P8nw~1Qht and Jc~n M. P.nwr1gh~. h1S w1~.. Grantors herein. PRElIU!SES ON :844 ANTIIOI!JY DRIVE -'~J"$~ , -- -~,~~. VERIFICATION TAMMY JOHNSON hereby states that she is ASSISTANT VICE PRESIDENT of WELLS FARGO HOME MORTGAGE, INe. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her 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, ~ DATE: 5/r9q/()( '-, ~ ".' , .~-"" ~, '''n.'' '.. ,__, -c ',," '" "."",,,",' '. _ ,-,'0' -~-~4----~' ,"' " ,- ,'., -,.,),. -'. '_"""_"'_-~'" '_"'-~".fr ". ,~-"^-"'''''~-, ~.. ,,"'. 0"'" . ''"~--- 8- & 0 t 0 c> ~ t ~ ~ c s: c-. --, ~ ~ "'Ow c: .fiip2 ~ ~ ~r" :;z: ::0 -- , ~~ I --y',;rn Uv 8 B "l ::::Cl(J ........ ~ ~~ ...... 0 ,<0 "'10 t: ..0 ~8 :Jr ~1(") f' ( I r:~ orn 5>c f'- ~ ~ ~ ~ ~" :;;t 0 f'v ~ 7- ) ""'~ . i<I. . , l_!lJJr,~_'lltiw",,,)q,R:m'''~'''''-,--'f<''''~''Vi''''i'\'-O:-O.R'jt"~'W~~~!l'!-,lI~.#ijI~_~~~ SHERIFF'S RETURN - NOT FOUND t , CASE NO: 2001-03377 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS WORMSER ROBERT J ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT WORMSER ROBERT J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , WORMSER ROBERT J MOVED, LEFT NO FORWARDING ADDRESS Sheriff's Costs: Docketing Service Not Found surcharge 18.00 6.20 5.00 10.00 .00 39.20 County FEDE 06/2 PHELAN Sworn and subscribed to before me ----- this day of ~J~i { ''':Wi,rr SHERIFF'S RETURN - REGULAR ! CASE NO: 2001-03377 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS WORMSER ROBERT J ET AL CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WORMSER DOROTHY S the DEFENDANT , at 1330:00 HOURS, on the 5th day of June 2001 at 844 ANTHONY DRIVE MECHANICSBURG, PA 17055 by handing to KEVIN WORMSER, ADULT SON a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~L~':~ R. Thomas Kline 06/26/2001 FEDERMAN & PHELAN iff Sworn and Subscribed to before By: me this I r--J{ day of A.D. / 41 -",.,,^c", .......~~. 'I "li!l1I'. ~ ~_. " ~! - _0. ~ " FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF.KENNEDYBOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (? 1 'i) 'i1>,-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION WELLS FARGO HOME MORTGAGE, INC. F/KIA NORWEST MORTGAGE INC. 5024 P ARKW A Y PLAZA BOULEVARD, BUILDING 7/F/C CHARLOTTE, NC 28217-2407 TERM Plaintiff NO,OI- 2317 8o~ll~ v. - CUMBERLAND COUNTY ROBERT J. WORMSER DOROTHYS.WORMSER 844 ANTHONY DRNE MECHANICSBURG, P A. 17055 Defendant( s) CTVTT, ACTTON _ T,AW COMPT,A TNT TN MORTr.Ar.E FORECT ,OSTTRF, NOTTCF, **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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. Y ouare wamedthat 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Loan #:9038140 CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2LlBERTY AVENUE CARLISLE, P A 17013 (717)249-3166 TRUE COpy FROM RECORD In T~~ \vfl3f~l, i tkJra unto SlOt my hand 1!!WJ tme _ of saKI Coon at Cao""l" ..... T~ ~ "-. nl. "- ;, ~~ of. :;;.:: I; ~/ Pmtttonota;.~:- We hereby certify t~e 'thin to be a true "Jld W! ."',,, correct copy or ,I", original mectAofNrDe<;"ol;~LAN FEDERMAN ,"1", i<J;,,, ,,",,,,,~,,,,11!~" ,-, , - '; -~ ~-, ._. ,~"M,~~<, " , .Mr-"~ ~_ IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; ~ - .'., . - . OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) I)AYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. , '..., . , .'~ - ~,~","",~f ,^ 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC. F!K/A NORWEST MORTGAGE INe. 5024 P ARKW A Y PLAZA BOULEVARD, BUILDING 7/F/C CHARLOTTE, NC 28217-2407 2, The name(s) and last known addressees) of the Defendant(s) are: -- ROBERT J, WORMSER DOROTHY S. WORMSER 844 ANTHONY DRNE MECHANICSBURG, P A, 17055 who is/are the mortgagor( s) and real owner( s) of the property hereinafter described, 3, On 4/8/88 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to THE PRUDENTIAL HOME MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No, 907, Page 899. By Assignment of Mortgage recorded 10/1196 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 531, Page 444, 4. The premises subject to said mortgage is described as attached, 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 2/1101 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, ,,"- ..."y - r.., ~., - AA' 6. The following amounts are due on the mortgage: Principal Balance Interest 1/1/01 through 5/1/01 (Per Diem $23,86) Attorney's Fees Cumulative Late Charges 4/8/88 to 5/110 I Cost of Suit and Title Search Subtotal $91,638.55 2,887.06 4,000.00 107.13 55ll.illl $99,182.74 Escrow ~ Credit Deficit Subtotal 0,00 llJlll !I; 000 TOTAL $99,182,74 7, The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged, 8, The mortgaged premises is =ant and "h"nr1nn~r1, WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $99,182.74, together with interest from 5/1/01 at the rate of$23.86 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property, /~/ Fnmk Fp.c1f':rm::ln FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff --'f'._ ~,~ ',. " - - ~ . '~.-.~".. ~.~.- --ALL THAT CERTAIN ~rec~ O~ ~a~ce' o~ ground with 1mp~ovem.n~. ~hereon .~ec~ed s1~Ua~. in ~he Township c~ Hampden. Coun~y o~ Cumbe~land and S~a~e o~ Pennsylvania. more par~1cular'y bounded end described as ~O"OW$~ to w1~: BEGINNING at a po1n~ on ~he'sou~he~" r1Qh~-o~-wey .11ne o~ An~hony Or1ve (~orm.r'y Margor.~ Road) at ehe div1d1nO 11ne be~ween Lot. NOSa 38 and 39 en ene here1na~CQ~ mentioned Plan o~ Lots; thence .'on9 said dividing line south nineteen (1$) degrees twenty-one minut.. (21) ~wen~y-~wo seconds west one hundred ninecy and e~.nty-n1ne one hundredths (19Qa29) ~eec ~o line o~ LoC NOa 6. Pl.n NOa 1. Part of Section II. Oaim'er Manor; chenee a10ng eh. ..m. and along ~he line o~ Lot NOa 7 on ~he said Plan~ nor~h ei9hty-~wo (82) degrees twenty-nine m1n~~e. e.o (D2) seconds ...~ one hund~.d ..v.n~y-e1gn~ and ~1vo-~enehs (178.5) ~..e ~o 11n_ of Lot No. 40 on ~h. he~.in.~~.~ men~ignad Plan. ~he"c. alono en_ .a~ north seven (07) degr.es f1f~y-one (51) m1nuces ~k1rtv-.our (34) seconds wes~_ one hundred for~y-eight and f1f~een' on'!t-hundredt:BF (-148. '15) .teet 1:,0 th. sou~.he..n ;ri9.he-of.-w<l:i.y of- Anthony Or1"e. thenee ..long the .am. in. a w~:!"c.rly d1rec:t:10n around a curve co t:he "'i9h~ hav1nQ a radius of 'CWO hundred (200) ~eec. an ore d1s~once o~ n1neev-f1v& (95) ~eee. to ~he 11n8 of Lot No. 38. ehe place o~ eEGINNING. BEING ." of Loc No. 39. on ~h. Fina' Plan No.2. Pare -of Section 2. Oe1mler Manor. recorded at Plan Sook 33. Pace 10. Cumber' and Coul"lcy Rec::ords. H~VING THEREON .reeted e cwo SCOry brick and ~ram_ dwel11ng house No. 844 An~hony Drive. Meehanicsburg. Pennsylvania. UNDE~ ANO SUSJECT to conditions. rign~$-o~-way and restric~1ons 01 reco~d. including without: l1m1taCion~. a c:Ira1na~e easemef't'= 41$ snown on ~he said Plan aCross ~he sout:h.~n portion o~ ~h. premise.. aeING the same pr.m1se~ which James w. G~.go~y and Mary R. Gregory a hi9 wife. by their deed dated Sep~.mber 19. 1986. and recorded in the Office o~ the Recorder o~ Ceeds in and for Cumber' and County. in Deed Soak E-32. PDQ. 713. oran~ed and convey.d uneo Oavid W. P.nwr1Qh~ and Joan M. P.nwrfght. his wife. Grant:or$ herein. PREMISES ON: 844 ANTHONY DRIVE 'Tl" ~ "."--'''''''"'7'''''' ., CO.' ,.. > ,- , VERIFICATION TAMMY JOHNSON hereby states that she is ASSISTANT VICE PRESIDENT of WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, - that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are tnle and correct to the best of her knowledge, infonnation 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, cfi}J DATE: 6JJq/()! , ' eo" t, "Y~ ,'".-_1 - - 'f'" I ." ~"""~_"""':"~ ~:~1~~flliM.~~1j.'Mkl<~""--~-~"'lJ;:k!A""";;K~""'1'Ii'1;:1,:;-;-,!,ih'~;b',HA-; " i':'[~"iol't""';;'l,q,<K@d.'djllf"'!'.-"'r1#~i~ijiJill-;l~mi!il!!1Iii!l_~~~"' ~~ '~1l -f"'C C'i:::z.'\'.'" .(.if. \ ';\ (hr' ,v~r -', ." CI)\'l,( q(\\11'1' '::~!'''IV( j\l~ \ e,,' 0(\\ 1.\ usn\ \J' '-..J,:'\C: p t. H :;\) ;'j ..~ ,." , . ", I \ i \J p.N d" '- ' , I f. , i,! f:' I I: I:: i' , ~,~ ,. ~,. -~ FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. I.D, No,: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, INC., F/KIA NORWEST MORTGAGE INC. Plaintiff Court of Common Pleas CUMBERLAND County No. 01-3377 vs. ROBERT J. WORMSER DOROTHY S.WORMSER Defendant( s) PRAECIPE TO WITHDRAW COMPLAINT WITHOUT PREJUDICE, AND SETTLE. DISCONTINUE AND END TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, and mark this matter settled, discontinued and ended, upon payment of your costs only. f ~/1~(J1 w)~ Frank Federman Attorney for Plaintiff Date ,'Z~ y- ".'. ~"U ,""0 .,,"---- -'. -', ':-:'1 -.~ , ." ~, -' - ~ i I :i , ..1'm!i1'Il'fillf:i I' ,. -~, "~ ~- r~ 0 C) "'--) r- -, 7, ~- ~: ~: uC[' LT1rr ."0.; .2:::--, /: C- ;'-.,J (,0 ~~: c.::' -< 1--:-..: C. -1:) ::;;; ~ -- - :~ C:" j-; ~ ,"\ :.,-; C -~ ~ UT''>, - ":r:; en -< 'I!IJ!'l\UIl~~ll..1 < """"'~,_ __'",""' ,...-,w.,_ JJf.'Hl!!!;'Ji.1)ij)l:tc""'''''F7_''<i'''f?F!",~-"li\'':'-i_''';+-~'j,,""-((''Ki-~'lf;;;j;;"~1fflI'j;,\jf'l~"1?'\l[lIj1.1!-1!~j!t~"!!'#'Jll1l!"'~~i!];.'!Wj~~:I!B~