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HomeMy WebLinkAbout03-3743FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff WILLIAM P. GARRETT 14384 POLK STREET SYLMAR, CA 91342 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM No. - CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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. 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 File #: 77275 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. File #: 77275 Plaintiffis WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 The name(s) and last known address(es) of the Defendant(s) are: WILLIAM P. GARRETT 14384 POLK STREET SYLMAR, CA 91342 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 10/10/1996 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to SIGNET MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1346, Page 92. By Assignment of Mortgage recorded 9/24/01 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 681, Page 1166. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 77275 The following amounts are due on the mortgage: Principal Balance Interest 03/01/2003 through 08/01/2003 (Per Diem $12.96) Attorney's Fees Cumulative Late Charges 10/10/1996 to 08/01/2003 Cost of Suit and Title Search Subtotal $51,833.53 1,995.84 1,225.00 110.45 $ 550.00 $ 55,714.82 Escrow Credit - 649.22 Deficit 0.00 Subtotal $- 649.22 TOTAL $ 55,065.60 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. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. This action does not come under Act 91 of 1983 because the mortgage premises is not the principal residence of Defendant(s). WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 55,065.60, together with interest from 08/01/2003 at the rate of $12.96 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. By: FEDERMAN. AND PHELAN.~LI~/- FRANK FEDERMAN, ESQU1RE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE File #: 77275 B~ING ~0~ A~; 5~9 SO~ PITT S~ET. VERIFICATION JANICE BERGTHOILD hereby states that she is VICE PRESIDENT LOAN DOCUMENTATION of WELLS FARGO HOME MORTGAGE, 1NC. 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: Janice Bergthold,~ile President Loan Documentation RUSH! AFFIDAVIT OF ~ERVICE - CUMBERLAND (FHLMC) PLAINTIFF WELLS FARC-O HOME MORTGAGE, INC. NO. 03-3743-CIVIL TERM DEFENDANT SERVE AT: WILLIAM P. GARRETT 14384 POLK STREET SYLMAR, CA 91342 TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action SERVED Served and made kn~o,wn, to ~/,//~Y~ .~..~~__ . - , Defendant on then~%-~ day of ~,, 20~ at - ~ , Qi'~y in Uhe man~r de~c:fib~-be~ow( Defendang personal~y served. dul~ ~am~ly me.er with whom Befendang(s) Relationship is Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s) Agent or person in charge of Defendant's office or usual place of business. and officer of said defendant company. Other: I,~~t~,~ a competent adult, being' duly sworn accordl~ law, depose and state that I persona~ly, hande~ to ]~]~]/~ ~ed in the captioned case on the date and;at the address ~d~cate above. ::::,E? NOT SERVED On the day of , 20__, at o'clock .M., Defendant NOT PO~ because: -- Moved Unkno~ No ~swer Vacant Other: Sworn to and subscribed Before me the day Of , 20__. Notary: By: ATTORNEY OF PLAINTIFF FRANK FEDERMAN, ESQUIRE - I.D.~12248 Suite 1400 One Penn Center Plaza at Suburban Station Philadelphia, PA 19103-1799 (215) 563-7000 C'~ o O FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Idenfificafion No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff, WILLIAM P. GARRETT Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3743-CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiffand against WILLIAM P. GARRETT and, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 8/2/03-9/23/03 to 9/24/03 TOTAL $55,065.60 $686.88 $55,752.48 I hereby certify that (1) the addresses of the Plaintiffand Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. PRO PROTHY RUSH! AFFIDAVIT OF SERVICE - CUMBERLAND (FHLMC) PLAINTIFF WELLS FARGO HOME MORTGAGE, INC, NO. 03-3743-CIVIL TERM DEFENDANT SERVE AT: WILLIAM P. GARRETT 14384 POLK STREET SY'LMAR, CA 91342 TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action SERVED -- , City in the manner descfib~ below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s) __Agent or person in charge of Defendant's office or usual place of business. and officer of said defendant company. Other: I /~,/T~c4~' f~bC/~' a competent adult, being duly sworn accordlIkq law, depose and state that I personally handed to ~ i~////'~/)$ a true and correct copy of the /~/¢~ .~ %~; //7 issued zn the captzoned case on the date an~ at the address ~d~ated above. Sworn to and subscribed ~ * '~'~ ' Bef_ore me this~g~^ day ~ .... ~i ,~04~,/ ~ //~ NOT SERVED On the day of , 20__, at o'clock .M., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed Before me the day Of 20__. Notary: By: ATTORNEY OF PLAINTIFF FPJ~NK FEDERMAN, ESQUIRE - I.D.#12248 Suite 1400 One Penn Center Plaza at Suburban Station Philadelp~a, PA 19103-1799 (215)563-7000 FEDERMAN AND PHELAN. LLP Fl;LANK FEDERMAN, ESQ, Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FKANCIS S. HALLINAN. ESQ.. Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (2Iq) $6~-7000 WELLS F,A~RGO HOME MORTAGE, INC. Plaintiff Vs. WILLIAM P. GARRETT Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COL2qTY NO. 03-3743 CIVIL TERM TO: WILLIAM P. GARRETT 14384 POLK STREET SYLMAR, CA 91342 DATE OF NOTICE: SEPTI~MBER 11. 200't THIS FII~M IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAIN'ST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A dUDGMENT 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 CUIVIBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 {,717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALL/NAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN. LLP FRANK FEDERMAN. ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19 103 (?!5) 563-7000 WELLS FARGO HOME MORTAGE, [NC. Plaintiff Vs. WILLIAM P. GARRETT Defendants ATTORNEY FOR PLAINTIFF COLrRT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 03-3743 CML TEI~M TO: WILLIAM P. GARRETT 519 S. PITT STREET CARLISLE, PA 17013 DATE OF NOTICE: SEPTEMBER 11. 2003 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE [NDEBTEDNESS REFERRED TO HEREIN, AND ANY INTORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PUq:~POSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BAN3CRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE C,M>,I,ISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE A~tomeys for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO HOME MORTGAGE, INC. : Plaintiff, : WILLIAM P. GARRETT : Defendant(s). : No. 03-3743-CIVIL TERM TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/24/03 to MARCH 3, 2004 (per diem -$9.16) TOTAL $55,752.48 $1,483.92 and Costs $57,236.40 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL those ~wo ccnain lots of groRigl sit. tie in the Third W'ard of th~ l~orotlgh of Carlisle, Cc~ltbcrlamt County, Pennsylvania, hounded and described as follows: TRACT NO. 1; BEGINNING at a point on the Eagero linc of sixty (60) feet ~de South Pi~t Stree~ at the Sout. hwesRm't corner of premises/mown as 517 South Piti Street now or formerly of Cc~il J, Z¢igler and wife, which point at the pla~ of becoming is 50.8 feet South of the eerier of lot now or formerly of Retold W. Weigle and wife, and which point at tl~ place of begimting ia 148.2 fe~t South of the Southern line of Willow Street: thence from said tack a~ the plane of beginning South 83 degrees 47 mLnutes East, a distance of 110 feet ~hrough the center of the partition w~l separating the houses known as Nos. 517 and 519 Sonth Pitt Sn~"t to the Western line of a ten (10) feet wide public alley; thert~ along the Western line of said ten (10) feet wide public alley, South 6 degrees i3 m irmteS West a distance of 16 fee~ to the No~qh~.~tora corner of loton which is ereo~l a house known as No, 521 South Piti StreeL thenc~ along the No.hera line Of said lot known a~ 521 South Pitt Sueel. North 83 degrees 47 minutes West, a dist~n~ of 110 feel through the center of the partition wall separating the tWO hOUSeS known as No~ 519 and 521 South Pitt Street to the sat6 Eastern line of sixty (6~) feet wide South Pitt Str~'-t; thenoe along ~he Ea~ra lim~ of said sixty (60) feet wide South PRt Street, North 6 degrees 13 minutes EasL a distance of 16 fee~ to a tack a~ the place of hegirmiag. CONTAINING 16 fee~ in front along the F.a~ern line of sixty (60) Irbet wide SoL, th Pi~t Slreet and extending Eastwardly tlmrcl¥om at an even width a distance of 110 feet ~o the Western line of ten (10) f~.4 wide public alley, and having thereon cre~ed a three-story attached frame dwelling boone known as 519 South Pitt $~'eet. TRACT NO. 2: BEGINNING at an iron pm on the .Eastern side of a ten (10) feet wide public alley wh~h exumd{ Southwaxdly from Willow Slreat, at the Southwestern comer of lot now or formerly of Cecil J. Zoigler and wife, which iron pin at the plac~ of bngJaning is 45 feet South of an iron pin on the same skle of said alley located a dist*m~ of I t3.g3 feet South of the Soothem line of Willow Street, and whiCh iron pin at tl~ place of beginning is 158.83 gaet Sonth of the Soufltern tine of Willow Sa'eel, (said point of heg~ing being also 120 fee~ Fast of Sooth Pin Str~), then~ fi.om said iron pin at the place of beginning, along the Southern line of ~ land now or formo'ly of Cecil I. Zeigler and wife, South 8~ degreea 47 minnies East., a diahnnee of 70 fe~ to an ira, pin in line of land fon'nerly of llemaan R. Meals, now or formerly of Robert L. Myers, theaee along said line of land now or formerly of Robert L. Myers, South 6 d~grees 13 minutes We. st, a dtstaxlce of 15 fee~ to a stake at the Northeasterll corner of lot now or formerly of Paul t2. Mellen; thence along the Northern line of said lot now or formerly of Paul C. Mellen; No~h 8:3 degrees 47 minet~ We~t, a distance of 70 feet to aa iron pin on the Eastern line of a ten (10) feet wide public all~y; thence along the F. astern lin~ of said ten (10) f~t wide public alley; North 6 degrees 13 minute~ Fast, a ~ of 15 fee~ to ea iron pin at the place of beginning. CONTAINING 15 feet ia fi'om along the ~ line ora ten (10) t~ wide public alley and exlendlag Eastwardly therefrom at art even widlh a diatance of 70 feet Io ~ now or formerly of Rohen L. Myers, said lot of gmond iying East of tl~ lot of ground descr~,ed as Tract No. I above. TOOETHER wi~h the rigl~t to use in common with the owners of 513,515, 517 and ~21 South Pitt Stre~ any comnmn pipe conn~cling said houses or any of them with the Bolough sewer as the same is now used. TITi~F~ TO SAID PREMISES IS VE..q']'ED IN William P. Oartett, ~ngleman by Deed from C -haxles R. Delp, singleman and Susan L. Delp, singlewoman, formerly husband and wife, dated 10/I0/1996 and recorded 10111/1996 in Deed Book 147, Page ~83. TAX PARCEL #04-22-04834)75 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-3743 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., Plaintiff (s) From WILLIAM P. GARRETT (1) You are directed to levy upon the prope~ oftha defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach tha property of tha defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. AmotmtDue $55,752.48 L.L. $.50 Interest FROM 9/24/03 TO 3/3/04 (PER DIEM - $9.16) - $1,483.92 AND COSTS Atty's Corem % Due Prothy $1.00 AttyPaid $151.56 Other Costs Plaintiff Paid Date: SEPTEMBER 26, 2003 (Sea~ CURTIS R. LONG Prothonotary ~/~.~e.},.~_~_.) Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563~7000 Supreme Court ID No, 12248 WELLS FARGO HOME MORTGAGE, INC. Plaintiff, WILLIAM P. GARRETT Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3743-CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3 ! 29 (Affidavit No. 1) WELLS FARGO HOME MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,519 S. PITT STREET, CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) WILLIAM P. GARRETT 14384 POLK STREET SYLMAR, CA 91342 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Sallle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Natne None Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: manle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Sallie Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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: Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 519 S. PITT STREET CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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. Sec. 4904 relating to unsworn falsification to authorities. September 23, 2003 DATE FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff WELLS FARGO HOME MORTGAGE, INC. Plaintiff, WILLIAM P. GARRETT De.adam(s). TO: WILLIAM P. GARRETT 14384 POLK STREET SYLMAR, CA 91342 CUMBERLAND COUNTY No. 03-3743-CIVIL TERM September 23, 2003 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 519 S. PITT STREET, CARLISLE, PA 17013, is scheduled to be sold at the Sheriff's Sale on MARCH 3, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $55,752.48 obtained by WELLS FARGO HOME MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 notice on page two 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 (215) 563-7000. 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 in the sale. To find out if this has happened, you may call (717) 240-6390. 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 the 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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 distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL those two certain lots of ground sinuae in the Third Ward of the Borough of Carlisle, Cumberland Count-y, Pennaylvania, bounded and described as follows: TRACT NO. 1: BEGINNING at a point on the Eastern line of sixty (60) l~,t wide South Pitt Street at tho Southweatem co~'~t et' premit~a lmown as 517 South Pitt Stre~l now or formerly of C~.il J. Zeigler and wife, which poim at the p~ace of beginninE is 50,8 feet South of the cotter of [0t now or font~tly of Karold W. Wetgle and wife, an~ which point a~ the place of begitthing is 148.2 fe~ Sooth of the Sou~a'lt lille of Willow S't£o.-'t: I]~nce ffo~ said tack at the place of bngJn~'ng Sooth 83 d~gtees 47 minutes East, a distance of 110 feet throagh the center of the partition wall separating ~ houses known as Non, 517 and 519 South P~ Smmt to the We~ern lit~ of a tea (90) feet wide pablic alley; then~ along the Western line of said t~ (10) feet wide public alle~, South 6 degrees t3 miaut~ West a distance of 16 feet to the Northea~etn coiner of loton which is erected a ho~se known a~ bfo. ~21 South Pitt Street, thence along the Noflh~rn line of said lot know~ as 521 South Pitt Street, North 83 degrees 47 rainut~ We~t, a di~.ance of Il0 feet through the center of the partition wall s~tmting the tWO housex ~n as No~. 519 and 521 South Pitt Strc~ to the sal~ F. aatern lin~ of sixty (60) feet wid~ South Pitt Stx~; the~'tce along the Easm~n line of said aLxty (60) tm wid~ South P~ Slrc'~L North § degrees 13 mimates Ea~, a di~nan~ of 16 feet to a ~sck at the place of beginning. CONTAINING 16 feet in front along the ~rn line of sixty (60) t~.t wMe South Pitt SIxeet and extending F~stwardly thereErom al an even width a distance of 110 feet to the Western lirm of ten (10) fe~t wide public alley, and having thereon ~vected a three-story attach~l frame dwelling house known as 519 South Pitt TRACT NO. 2: BEGINNING at au iron plo on the 'Eastern side of a tea (10) feet wide public alley which ex~ Southwnrdly from Willow StreW, ar the Soothwesttttn cortl~ of lot now oz formerly of CeOJ J. Zeigler and wife, which iron pin al the place of b~n$ ia 45 feet South of an iron pin on tile same side of said alley lee, areal a diatlm~ of 113.83 feet South of the Southern line of Willow Strec't, and whiCh iron pin al the place of beginning ia 158.$~ feet Sooth of the Southern tine of Willow Street, (said point of beginning being also 120 feet East of South Pitt S~eel), theme flora said iron pin at the place of hegMnin$, ninny the Southern line of said land now et formerly of Cecil J. Zeigler and wife, South 83 deg~es 47 minutes East, a distance of 70 feet to an iro~ pin in line of land fen'hotly of EL-tmon R, Meals, now or fot~a~fly of Ro~acrt L Myers, thence along said line of land now or formerly of Robert L. Myers, South 6 degrees 13 miattms We. st. a distance of t5 feet to a stake at the Northeastern corner of lot now or formerly of Paul C. Moilers; thence idong the Northern line of said tot now or formerly of Paul C. Mellon; North 83 degrees 47 minu~es West, a distance of 70 feel to aa hoe pin on the ,F.~tera line of a ten (tO) feet wide publk alley; thence along the Eastern line of said ten (IO) f~al wide public alley; North 6 degre~ 13 minutes East, a ~ of 15 feet to an iron at the place of heginning. CONTAIN[NO 15 feat in from along the Eastern [me of a ten (10) feet wide public alley and exeendtng F. astwardly therefr~,,n at an even width a distance of 70 feet to land now or formerly of Rohett L. Myers, aaid lot of gnmnd lying, Eaal of the lot of groand described as Tract No, I above. TOOETHER with the right to rue in common with the owgrs of 513, 315, 517 and ~21 South Pitt Streol any comnwn pipe connoting said hou~ or a~y of them with the Borough sewer as the same is now TITLE TO SAID PREMISES IS VE,.RTED IN William P. Oanett, aingleman by Df. ed from Cla~les R. Delp, singknum and Susan L. Dell), sin$1ewoman, formerly husbaud and wife, dated 1011011996 and recorded 10/1111996 in Deed Book 147, Page 4-83. TAX PARCEL #04-22-0483~075 Request for Military Status Page I of I Department of Defense Manpower Data Center OMilitary Status Report Pursuant to the Soldmrs and Sailors Civil Relief Act of 1940 ~(Last Nanle [ First Imiddle IBegin Date {Active Duty Status GARRETT [ WILLIAM Cttrrently not on Active Military Duty, based on the Social Security Number and last name provided. SEP-23-2003 11:34:56 Service/Agency Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the cun'ent status of the Defendant(s), per the Information provided, as to all branches of the Military. Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail to sscra.helpdesk~osd.pentagon.mii. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owaJsscra.prc_Select 9/23/2003 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 f215} 563-7000 WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD P~imiff, V. W/LLIAM P. GARRETT Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3743-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant WILLIAM P. GARRETT is over 18 years of age and resides at, 14384 POLK STREET, SYLMAR, CA 91342. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff C) c'.2~ FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PItlLADELPHIA, PA 19103-1814 (215) 563~7000 WELLS FARGO HOME MORTGAGE, INC. Plaintiff, WILLIAM P. GARRETT Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3743-CIVIL TERM CERTIF/CATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: 0 an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff SHERIFF'S RETURN CASE NO: 2003-03743 P COMMONWEALTH OF PE~SYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS GARRETT WILLIAM P OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT GARRETT WILLID~4 P but was unable to locate Him deputized the sheriff of YORK , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: in his bailiwick. County, serve the within COMPLAINT - MORT FORE He therefore Pennsylvania, to On September 23rd , 2003 attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York County 32.56 .00 69.56 09/23/2003 FEDERMAN & PHELAN Sworn and subscribed to before me this 2~x_ day of ~ ~#~-3 A.D. this office was in receipt of the Sheriff of Cumberland County 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF R~,TURN PLF. A~E TYPE ONLY UNE I THRU 22 DO NOT DETACH ANY COPIES 1. PLAINTIFF/S/ 2. CQURTNUMB~ER Wells Fargo Hcrne Mortgage Inc 03-3743 czvil 4 TYPE OF WRIT OR COMPL~INq' 3. DEFENDANT/S/ Notice & Complaint in William P. Garrett . Mortqaqe Foreclosure SERVE ~' 5. NAME OF INDIVIDUAL, DOMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. William P. Garrett '' 6 ADDRESS (STREET OR RFC WITH BOX NUMBER, APT NO., CITY,, BORO, TWR, STATE AND ZiP COJ~_ ~ AT 409 ROSS Avenue Apt 4 New Cc~nberland, PA 17070 ~/~~ 7. INDICATE SERVICE: L~ PERSONAL F.J PERSON IN CHARGE ~DEPUTIZE ~..CEI~TM/~L J 1 ST CLASS MAIL LJ POSTED [~ OTHER NOW August 12 ,20 03 I, SHERIFFO~5'~]NTY, PA, do_hereby deputize tJ%e sheriff of York COUNTY to execute thi..~.i~r~d.~l~e return t~,~. cording to law. This deputization being made at the request and risk of the plaintiff. /~.~ ~..~r;. t,,.~, ~_~___.,,.4r,~_ · - / ~. - SHERIFF OF~rCOUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: CL~nberlan~ Send return of service to Cumberland County Sheriff OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY ATTY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any properly under within wdt may leave same without ~ watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the pad of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any properly before sheriff's sale thereof. 9. TYPE NAME andADDRESSofATTORNEY/ORIGINATORandSIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED FRANK FEDERMAN 1617 JFK BLVD. PHIL:A, PA 19103 215-563-7000 8-4-03 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if ¢otice is to be mailed)· CUMBERLAND CO SHERIFF SPACE BELOW FOR USE OF THE SHERIFF -- DO NOT WRITE BELOW THIS LINE 13. I acknowledge receipt of the wdt 14. DATE RECEIVED 15. Expiration/Hearing Date or c~nplaint as indicated above. R. AHR EN S 8- 13- 03 9- 3- 03 16. H(~NSERVED: PERSONAL( ) RESIDENCE( ) POSTED( ) POE( ) SHERIFF'SOFEICE( ) OTHER( ) SEE REMARKS BELOW l~a' ~ hereby cerbfy and return a NOT FOUND because I am unable to I~c<3t e the individual, company, etc. name above, (See remarks below.) 18~VlE AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20. ]~me of Service 22.21 A~'EMPTS~I~i~~l DateREMARKS: ~me Miles Ira. J DateIT]me Miles Int. I Date ~fime Miles Int. IDate Time Miles Iht I Date ~me Miles Int. PER DIANNA GARRETT, N~E,R/LIVED AT THIS ADDRESS 25. N/F 26. Mileage .30. 56 23. Advance Costs Postage 28. Sub Total 29. 41.AFFIRMEDandsubscrib~¢lg~; f~r~ t i~ /J' 42, day of OF Al RESIDENT, WM. IS HER SOON-TO-BE EX-FATHER-IN LAW AND HE 38. Mileage/Posted/Not Found "~ ~T '~'AR~-^' -~,'r 4~k Signature of '~ I~, P' NO ep Sheriff · ' ' ' ur~ Signature of York City of YorK, York County _~,~.~ . My Commissiof~ E~r~s ApHI 20 20U'6-T~ County Sheriff ~ ~ ~ -WILLIAM M. HOSE 1. WHITE - Issuing Autbo~ity 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's Office 47. DATE 49. DATE 51 DATE RECEIVED AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO HOME MORTGAGE, INC. DEFENDANT(S) WILLIAM P. GARRETT SERVE WILLIAM P. GARRETT AT 14384 POLK STREET SYLMAR, CA 91342 CUMBERLAND COUNTY PJT No. 03-3743-CIVIL TERM ACCT. g4133346 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 3, 2004 Served and made know~ to WILl, IAM P. GARRETT at 5:25 ,o,clock__P.m.,at 14384 POLK STREET, o~6~,~n the manner described below: SERVED ,De~ndant, onthe. 25th SYLMAR, CA 91342 dayofOctober ,200~ xxx Defendant personally served. -- Adult family member with whom Defendant(s) reside(s). Relationship is -- Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendam(s)'s office or usual place of business. an officer of smd Defendant(s) s compa y. Other: Description: Age 60 Height6' Weighil85 RaceCaUCsex MaleotherGrey/brn hair __ - ~ear-d~ustache, glasses. I, Ch r i s Hut ch i n s on , a competent adult, being duly sworn according to law, depose and state that I personally handed a ~me and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. STATE OF CALIFORNIA, COUNTY OF LOS ANGELES) Swom to and subscribed i/\ I~/- I / bef~reme~his~2~ day /'¥, 1/' ~. [-ff",~lJ . . /~ On the . day of ,200__, at Moved __ Unknown__ No Answer Ist Attempt: / / Time: : NOT SERVED o'clock __.m., Defendant NOT FOUND because: Vacant 2nd Attempt: / / Time: 3rd Attempt: / / Time: : Swom to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 Wells Fargo Home Mortgage Inc. VS William P. Garrett In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3743 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Poundage 3.18 Advertising 30.00 Certified Mail 8.15 Levy 30.00 Surcharge 30.00 Law Library .50 Prothonotary 1.00 Share of Bills 29.08 $161.91 paid by attorney 01/13/04 Sworn and subscribed to before me This IY ~ day of Prothonotary FEDERMAN AND PHELAN By: DANIEL SCHMIEG IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 ~215) 563-70~0 WELLS FARGO HOME MORTGAGE, INC. Plaintiff VS, WILLIAM P. GARRETT Defendant(s) ATTORNEY FOR PLAINTIFF : County : Court of Common Pleas : CIVIL, DIVISION : NO. 03-3743ClVlLTERM PRAE~IPE TO RATIRFY JUD(.~MEN'T WITHOUT pREJUDICE TO THE PROTHONOTARY: Kindly satisfy the Judgment which was entered on 9~26~03 against WILLIAM P. GARRETT, Defendant(s), in the amount of $ 55,752.48 relative to the instant matter and mark this case satisfied, without prejudice, upon payment of your costs only. Dated: July 29, 2004