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HomeMy WebLinkAbout07-2865r' COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: U '1- ?2 y 6 y C-4. "74-- COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE SHAPIRO & KREISMAN, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 LAUREN R. TABAS, ESQ., ATTORNEY I.D. NO. 93337 ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF VS. Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 DEFENDANT(S) 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. 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1.4 SHAPIRO & KREISMAN, LLC BY: CHRISTOPER A. DENARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY I.D. NO. 81747 LAUREN R. TABAS, ESQ., ATTORNEY I.D. NO. 93337 ILANA ZION, ESQ., ATTORNEY I.D. NO. 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF VS. Mary M. Zayas-Bazar 154 Faith Circle Carlisle, PA 17013 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07- a$G,!? Qk =c COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Wells Fargo Bank, N.A., the address of which is, 1 Home Campus Drive, Des Moines, Iowa 50328, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mortgage: Mortgagee: Consumer First Mortgage, Inc. Mortgagor( s): Mary M. Zayas-Bazan (b) Date of Mortgage: January 5, 1996 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1298 Page 952 Date: January 10, 1996 The Mortgage is a matter of public record and is incorporated herein as provided by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached hereto and marked as Exhibit "A" and incorporated herein by reference. (d) Assignments: Assignor: Consumer First Mortgage, Inc. Assignee: Resource Bancshares Mortgage Group, Inc. Date of Assignment: January 5, 1996 Recording Date: January 10, 1996 Book: 511 Page: 835 Assignment Re-recorded: Assignor: Consumer First Mortgage, Inc. Assignee: Resource Bancshares Mortgage Group, Inc. Date of Assignment: January 5, 1996 Recording Date: August 13, 1996 Book: 527 Page: 762 Assignor: Resource Bancshares Mortgage Group, Inc. Assignee: HomeSide Lending, Inc. Date of Assignment: February 12, 1997 Recording Date: March 5, 1997 Book: 542 Page: 33 Assignor: Washington Mutual Bank f/k/a Washington Mutual Bank, FA successor in interest to HomeSide Lending, Inc. Assignee: Wells Fargo Bank, N.A. Date of Assignment: as recorded Recording Date: as recorded Book: as recorded Page: as recorded 2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal successor in interest to the original Mortgagee, or is the present holder of the mortgage by virtue of the above-described Assignment(s). 3. The real property which is subject to the Mortgage is generally known as 154 Faith Circle, Carlisle, Pa 17013 and is more specifically described as attached as part of Exhibit 4. The name and mailing address of each Defendant is: Mary M. Zayas-Bazan, 154 Faith Circle, Carlisle, PA 17013 5. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. 6. The Mortgage is in default because the monthly installments of principal and interest and other charges stated below, all as authorized by the Mortgage, are due as of January 1, 2007 and have not been paid, and upon failure to make such payments when due, the whole of the principal, together with charges specifically itemized below are immediately due and payable. 7. The following amounts are due as of April 30, 2007: Principal of Mortgage debt due and unpaid $56,845.98 Interest currently due and owing at 7.75% per annum calculated from December 1, 2006 at $12.07 each day $1,822.57 Late Charge of $26.13 per month assessed on the 16th of each month from January 16, 2007 to April 16, 2007, (4 Months) $104.52 Escrow Balance (Credit to Defendant) ($130.06) Property Inspection $45.00 Title Search/Report Fees $250.00 Attorneys' Fees and Costs $2,842.30 IMAL $61,780.31 8. Interest accrues at a per diem rate of 12.07 each day after April 30, 2007, that the debt remains unpaid, and Plaintiff may incur additional attorneys' fees, as well as other expenses, costs and charges collectible under the Note and Mortgage. 9. The attorneys' 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 attorneys' fees will be charged based on work actually performed. 10. The original principal balance of the Mortgage exceeds Fifty Thousand Dollars ($50,000.00). Accordingly, Notice of Intention to Foreclose pursuant to 41 P.S. § 403 is not required. 11. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. § 1707-1715z-18). Accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note and Mortgage and for the foreclosure and sale of the mortgaged premises. SHAPIRO & KREISMAN, LLC Date: 511 D-IM . ' l) BY: W v 4Attey's for Plai t f S & K File No. 07-29369 r 1-1 17p 74 tr :?=CQADCtc OF HE05 1.1LI1 MIS Coll ?-97)95 dflN 10 RM 9 03 ma zo, ms.wa deers M..w.ae, ta.. soar eNar. a-t n.N.. 29a 12me sote.ma. so 71043 1.9pm Alba 7slr Lt.. Yet neeuatlK bml - -- CRU Na 441-5]22394 raw AI! M050497 om mdrlv=o of Pt aseltaala MORT"GE 77419 MOR710AOE ("BAtmity tomuffic n is drat on r7A[170111Y 6SA, 1996 'Me Menpgor is Mm M. 1IMS-Now, [1MMIM ('Oorrooer ). 77th Saettriv tastremsnr b even to rtt7tat^ . ,INC. cmimm mm wblab b wpW Ad oW aiRillt, ond•r dw lute or TZ 8J9u8 cr ARRKt41ti1 and wbas: address is 8808 CWM 3810( V=, 3Fb AIlLr CIi84?1t MM TM 21045 i'L9odQ? 9atrewar owes I-der the prinelpal mm of $I= Ercar 2ELUSM ZMK taamm ANO W/100---- Dorn (U.& S 60, 400.00 ), 7'hb debt is arldmoed by Beim tY pate datad ft lame data as this bemdpr hisituaem PNatel wldeb Prmtdas IN mantMY Pnuw ta, with the InN debt It trot paid earlier. du and pupimc as PJ?il f , 2026 ?• BesnilW Ipswmeat swum to Leader: (a) the rep yawat rot the debt eYldeamd by the No?e, with iasgsst, told an tAawplti saaemslooot pml madlomtlepsi (b) t{ta laymmt di pll adios awns with idiered, adsuseed alder FA&Mpk 6 to Fuhm tlw Mo ik ar tlde Satur(ar teutumeati and (a) dw pcr m prm at limtav.et'c eorm um and alwAmam ender this Sceddq laslreoomt end the Nole. yvr sift parpo% Rommw does hereby manppq 6nvit and topvey to Loader the Wlloaattp dckribed propm ly Tamped In CMMMEM County, peansyi•adlu see VML aMCRDBM I BMW M MW A P11fs'1' ED= Alch hat the addntl ar 154 FAMI CIIY'IE utr. 11 ' CARLISLE It:I71 Potusyltanis 1701.3 ('PMpcM Addn:Wt, izir cmel TOOL-rKm wrr u all the Improvmraari low or hetepher "ecwd dA the proputy. and oil essamcml, tights. AppartWgpceF, two, rgaWes, mineral, 00 end ps right &a proljtt, water rights and stock ad all &daica Oaw or bcrufair a part or the peopaty. M repbCCmeats and addbims abatl aho be covatd by this Seewhy Instrument- All dIA `Proparry: of the hwegabty to mrerrad m In this Sawriry lnurummrt AS BORROWER COVSWAN'tS that Eatmwvar Is lawfully ached of the ants bombq saftwed and hu the right m mtetpt t, gnat avid calm the Prop sm red dw the Property Is unucmdbert4 eroupr ter enaumbraaem or mvnt Nmvo*er warrants And will defctt0 ga arally the title to the Property splau all claims and demaodt, into= to any enmo,bnnm or rceard. FeFMW - 0-d"241 Ion PapeI rd,.f Pot"Yee, i„e WK1298 PIUE 352 I„m,,,, ExHIe1T -a- r MW Mt =150407 1, PAyment of Principal,, Interest Bahr Lem amiqu. Borrwer Shan pay Wheo don the pdnciprl o(, and futarest no. the debt avidancod by rho Nola and lots charges dun umdd the Note z kronudy Pfpmeae d7asa, lamraahs, ass Athaaageti Bartmwernba8 include fa auk monthly wymoor. tayedn r with the prmdpal and lateral a act forth In rlw Note aqd any lain drergea, a sure for (a) farm and tpectal auctaaunt¦ le.ica or to he levied 40ntt the Ptapc:W, (b) laseh lid pWoc ua at ground reach an the Property, end (e) premiums Far Insurance inquired Parlor Pmftlmph 4. In nay year In whidt the Lauder round pay A mortgaaa instance pramldm to tits Sotretaty orNeadag and Urban a`ieteP+sa+s (%CM0041 or to nay year in w.hidt such promlua, W"M have bout required CIAWar Plat hcid tlto Soohrhy Inca unseal, tmdt esoathly payment slutl also faeiude either p) a win for the annual Omdop bwrmhm prmtlvin to be gold IW I cador to use seretay, or (9) a mwtwy elan,. haasd of a go to &a r m= premium If this Secalry fahmaust Is hold Pry the Scamterh fa a mee whit nowunr to be der mdad by the Staetay. Gaap< for the monthly Amp by the Saret>try, thou lom stn Wind -&cmw Item' and tho Puma paid in LwAr Are Ballad 'Sam POPW La dor may, at coy time, wl1w and hold an wata for EkWW Item in an o/e cgm amount oat m razed the maalmvm mount that may be required for 11whranos r tscrrev arsoum under tha jt%W Comte Sonbmwar Protmlmras Apr or tffra, to U= amt ri ma. and terpfaaustMg repaladom. 24 CFft pan S',{(p, 4 they ¦ay be emoaded hum time to theca C "A'), efapt fiat the amhtga ar raw.. petmltkd fy RWA for wmnudpsmd 4bbsnewom or dls==M=ta Wfore the Bnerawefs payments Big agflable In dw account Mo r not be hued to mutants doe for the matt" lasuama faemlmm. It Our smminn held by Locator flu Pacmw items oared Ilia --"in paamhtad to be IwW by RWA. Lenov shad deal with fpm a, I - funds as ft*[Md by RBSPA If the Bresnan of funds held by Leader at may rimc ore mat ref ;iaar to pay the riserow lama when duct Lahdtt may aodfy the eeaoamr Bad mqurrc Borrow in aahe up the ahw%vF at derldawy a pertahtad by RSWA. The EaoW ponds am oWgcd a sddldoaal security vet all am savored by dill Sasadty tatrumsnt. If Siotrowar taduh ro Leader the fall payment crag 14th mess, Saawwar's atsawa dog be cr allkd witif the baLsem remainfng for all hsm¢mear firma (a), (b), and (e) and any manpp insensate, premium IDmWneae rimc lender bee nor weama atdipted to pay to the Sew", and Lender"pmmpdy refunded any alias bode to narrower. immedfafdy prior to a brochure tale .ribs Property or Its wgokWm by pendtf, Ba ews amount thou be credited wlih any bnlmin renshhbe for all installations, far form (A}, (b), and (o). 3. Apptteh1l" err Nlymenta. All pgrama under paraarspha I amt 2 shell be applied by Lender as fdim.c rani to ter. monlisp Inso mpm p nnothms to be paid by L.on to the 5taetuy, or to the monthly charge by the Secretary 149ad of the mouldy Noon" lomanq pranduml S j an Alp rent, special aaopmeata, leas" payments or ground Tanta, and Bre, Quad and other, haaal insutrnra iaamhtms, u rarpskod; M ut Woman due under the MM Fourth, to amortisalap or do pdadpel of the Note; fem. W hue do %-= due under the Mom 4, 81% Mood 4134 Odw amid lows ace, BaHoWer shall (neuter all imp m=mu an the property, whether our is ttdsfmvo err aubaryt+eAty txeaad, aptad Bay h4mrds, rmddin. and mattermcle,3adudios lim. for wbfeb under nquhes Insurance. We Iwohaee owl bet maintained to"amauma and far the pdrbdr that Lmtw requires. Borrower chap also, IMUie All Impraremmn an the PMWW. whether now, to txbteaoe at mbaquantly credited; against rota by floods w the Want required by do Sodomy. AN (muaaaa atoll be cBMW with companies approved by Lz"w, no insurance polhda end any ranewab Phall be hdd by Leader add shell Induds tar Mice daurec In raver a(. and to a Iona Act"ble to, touch. In the czar of tots, fiorrover doll give Linda I mlralide notice by wit. tender may male proof of low B not made ptnspuy IW f lotrow. Gash Wooer wanMey coachrntd is be* aathaeirad add directed in metro payment for such Ion directly to Leader, fastmd m to Boresaer end to Leader Jointly. An or any part ar die laaun,ue promcch the sewemnWe applied by Lendny at lta option, olther, (a) W Ow reducaao or the tndelenchg o cinder the Maio and ry mane, rsssr w any dau opmert amoanta appfio0 In Ibe Order ht pltapaph 3, mad than W pngwomr of pride ^ or (b) to this MWAlla s at rope of die damaged pfoperp. Any UWI=be at the pru escds to the principal shall dot esmphd m puotpaan the dam data of the, man" peymtms w" am mrorno to In pare flrsph A ar change the unman, or such payme" Any amen kow"M ptomrd. Oman amount regairad to pay au ona hoding indabatdenx under the Note ant fhb g®dqr huaameat dw8 be paid to the entity lepaAy notified thereto to duo crest or forednoure of pads SmwRry bmammf ae other taoslor ar dtha m tta Pmpcrtp that tdngulsbn the iadebudaasq all right, vale and m(/ Freer of Banower is and to ladm11eu poldt fn farce shall pass w tho purehow. S. Occupancy. Preservation, MaIB4"Ohno sad I'MUCom of the lwww awromes Uemn Ap d"doai iearchdda faarowst sbott aaaupy, eareNidh, and on rho property an Baleares principal resfdeme within ably days after the eaecutioa or fait Security hrdrumanf and shoe atnihuu M ocmpy the Proi s as Borrowers prhuipl mmorum for at Iert ana year and? the date of ampmcy, union rbc Secretary deteetnh m this tepilramet will dawn undue hardship for Barmwc, m.alas eatanuatirtt elfmmdaw d %SIP which am ihcya°rl Barmwda rdanol. Dorrowar shelf andry Lmace of any esrcouodng ctrmmsmaees Bmtawa' utcil ant inmmh waAe or tbdroy, dmaage or tubtgmiatly change der tropcrty err .Bow the Ptopetty to dmaiormq mahamble war add tent etcoptatL Leader may lugwxh flier property PArMra • Sgambrr w. MLI Paae201S 1w alit, rag he OWN no 053 haste ; SM4 IP) MW504137 If the INGW4' !r vemnt ere 4111MICIO A or the hum L in deholL Laadc seat tat. tamaalea aedm to partner and prermao coH wont err abmndmpl PMPa7• Borrower du11 alm be in d*ult If Boreftur. during the loge oporessind PtrrcP% Co materbdly alto Of loexareta Iarsmwtiaa or 34lanean to I ddcr (or Wild In p,twido Leader with any aatarial reinstalled) It canocoa s rdth the Iraq ardento by the Nesq indudiag, but not Houma ter, repremniaryau emurnidg florraweea occupancy of the hnpeety ox a principal reddoacr, It this Sararity Imtrumcal it an a lesrehotd. Borrower IRAN Comply Wish the provisions of the lease It BWPMa aegaing ran We to ON Properb, the Iesmehold and fns tide shall not be maargcd anlrss Lander agfma to eke tmrjer to ereitag. IL Charges a Bannerhmd ISukcdm of Landed RWa luUW Prbpoty, Con Hdermthnr Shall pqy ell gaveremenral or Pal charges, Ones Pad (mpmtiona IM no not btduded in paragraph I 8ottoenet Ling pat dneme obligaiions on time directly td the mthly rnku Is aped the ptymmt. If haUp to PRV Weld ftdyeedy alien Leedee. interest In she Propvy. upset Leader's ttiquest narrower *41 prmpdy tbratxh to Leader am1pts erddtedng most pymmta. If Borrowtr tads in seeks them paypneah or Nte Maltese reghlrad by pugmpb 4 a kill to perform any aamr emeeardo and agrarocaa owulacd In dill seeatky Inroumvelf. W than Is a kgal proceeding that my significantly . effect Ladies rights In the property (nods as a Proceeding In Nnbroptepr tae tAedcomadimr or to enrwea Imes or ? tMO)o lbea Lander rmy do sad pay W3atncr is aeaaety to "at she valuo or the Property aM Lettder4 the properOS kdudipg paymear of taxes, hessard hdurmam and other km m alloded In perapatph I Any snu meta cif barsad fry Leader War this pengeaph OW becmmm an wMdoagl 4abt of Borrmm and he xmwad 17 this Security Gmromont. 7b m ewsues slap beer Interest from the data of dbburssonwat, at the piton tote, Ind me theoption a(Lander, "beIte sdlatdydunandplyabla % Come! adorn Min proQedt ararry gwntd ar daim for damages, dlecat or nonsaquandalr in mogmkn with any cotdowataa or dtbor nkiap or may part of the I%.,- , ar fur hsmvMnce ht pl m of omdtmnethm. am bmdy assigned end rhdl be paw to radar to the soar ur rite (op Imomr of the fac eUtdae s that remain nopad under the xetc madd 4 thdata is ? lnmemctn. Leddar AIWI spay lads psommds to the reduction of the h dahrednal anda and (bete in pre bdtrnocK Hart m say donations! maaom spOW in cite order provided In pregraph 3. em ky %MA Aar an selected ? of Ise ro or damp al shot net of coteral Pat or fbtt lte, the data dear orhhs amore7 pey a t?I? 2. err eke amoPmat of Path oared ptecom ores an lataum tse aloes a pay an aatatamOrg inviviskstesut tadsr du Note and this seity Arty Integument. Short be paid to am me* legghy sa lga4 flown. A. Far, Leader may collect fees and charges autbarked fly the Setrsory. P. araaaat ForAadaal)ca orLctw (4 M&44 Lends may, snap! a Utnled by toguhdoaa (loran by the kcrehay in the Sue of Mascot dcfaallrr as(ahe hewedrate pipacat In 111 1191 It loos roeurod by this Smelly l atrurpmt III (1) Borrower dtalbita M laBing to pay In tap my nuaddy pgroeot required Icy this Security lmwdinedt print to, of an don duo due or the aesl pmtthly ptl'meat. a -?, an Bgtrowtr ciddiril by filing, fora period or thtry days, to perform any Ober abUgadons amumbed in side Sou rity iraryumest. (b) Sde Weal Crdn AppamL Lander Shall B peerdtted by appUmbk lay and adds the prior approve; or the Secretary, require humiliate peyragd In Lisp of an same .nested by dt6 Scosriy annaladt In (1) u or part of the ropy, err a b-dkw loom in ¦ feat unfag IN or pan of the Property. Is told or atherwde Irandmted (attar than tar deft or detamt) by the BotrowQ, and (t) Mw native Is nor occupied by the purchaser or amoma n We or her prlndpl rrsweacc, or dm pardatu or gtanue dose Co aeatpy tho Praporty but bid or her credit box net bun a ad it a®rdeum with sbm eequbaracts of the Baaemry. > (e) Iqn Walvoo it drrawlmoem oml Met would psmk Loodof to mgaim Immediate paygmt In tub. Iwt Lander does nor rgoir torah pgmm% Lander does sot Worse its data with nsped to subugdear evaha. Id! tLtgtattaam orntlb 8ccrataq'. br stagy dreumameaa msthl.rtotnn finned try Lira getretaywDl limit Lender's lights is the cos tr pgggent ftwIlc to tegeim Immediate pea t Id fog lad weeds. it not paid. Tbb Security Instrument epees nat mavemise scuderating or foreclosure if not pasettted by rephorans of the ages". (c) MoeTaago Net inland. Borrowor wets that dnooid dill Sacatlty Instrument add Inca Nom laeurud thereby not be 4MM. for insurance under the xniand HoodagAet suf ter SACL"d f60) DAn (span tree data haver, Leader may, ar ho apdon and nomidompolaa asydtle t in lemgmph i; roqulro Won akic o t"i Id fast or all matt ettared cry this Seeuthy inttrummn, A wham statement of ady aumorimd agaa ordt 5eaaeory dead submgoeat to S33d1'X (till) fAtYfl from the due hareaaL declining to learn this Som iy insknmq[r mad ohs Nino secured temabt teen In daemsd co dodve paoar rdsadr iudigibity. Naewitanandieg the Breyeiag, this opdae my am be t:erciead by trailer *ban as; hnarl0a6tUry of Insurance 4 solely dm to Iamdm% rapers to Yemen a morsels fraoesam premises to the Secretary. In. kdatekm= nemeses has ¦ eight to be reinstates B L --hw has regnbml homadlata payment In full bamase of bmowart Murat to Pay an marine dot under alto Nme or this See rby Inserument. This rlghr applies even attar rmudasure proceedings sea (nldddod Ta fotastam the Scoo ft Wnatamt, Berrmrcr slaU Lawlor In a hemp tam PA atrpants required to bring Barrawm4 aunt current Ioeludrag, to am Salem Obey are nbUpan" of Unmoor under thk Secsrly (Peramm6 fmatlevore wsPs and reate mable and ePemcnry IfioMWA feu and txpcaw laa}atly aneatatod with tho foredmota ptamaxd 4 Upaa retnIMMMCnt by Borrower, this Sacdrity lestruratnt and Mc obligations that it oaaaos [ball twain In .(real m It Leader has Pm "Plead iwwcdlgrs faywcnr In 1VU. liawevat, Lander is sna requlml to permb remst temeen Its (l) LendtrIm naspad rdmawnever Poor me towmsmm?mr or f daz•.rn p+vdodielp tvithla two Yuma kmmedb uty prc*IPA she temm occuitat of a currant foracknum r tvbaa _ &qeo. bw 136 ryes Pats 3 piS a.s r..p h'pc? we Moo 129,8 P4 854 awota T!]ItN M1 W60997 proceadin& (u7 refadinzam t will ptedude, forecklwre m dnfermt grounds in des future, or (4*11) rolanatemant Will edrersely n4M the priority of the Hen aeatal by this Security fasdumeat IL tiananor ft Adowll Frwtracandh III L401W NW • 7VdteL prdaosien of the time of pgaent ar Modification of aanotnmdoct of the sumo snouted IV ibis Seemlt/ hetinment granted y Lander to able waanor in larcrCir of ilatrowe shag not apeme tG rclisaa MslhnbBtq of rho hatginal Bacrdrsr ar Bartawers attaesem M InlarmL Ldadet shall net be ralabed to tLanmeon prtxvdinp sphuf soy socccesor to latercu or rerdro in adatd time for psyarcat or wharwlaa modify samctlmlka or the atpa aWaed by this Scauthy Excitement ter talon of aft demand made by Ills original Hartowor w Banawa''s anatones In fracrat Joy frahearanaa by Lcadcr in aotdslna say right or comedy short not be it wirer or cc phecindo the ahstd, of any clot or tcmafy. IL dacesraas eau ARkes uohmdi Jaiar sewn Savers! IIaLInGI tx Skttea hue vorenane and agraamem of mis Swrdty instrument shin bled and heard/ tit/ soo?mp and tmtges of L oula dad $arrafts. subject to the Provision, of pusanAh 9A Bottaeiet'a urnmsaa and agtu®mp sWg bt Jahn and IavetaL Aay Burrower who ca-dpd this Scantily rmbromeat but 4111101, oat etttatla the NOW (a) k eawrgaisg this SecuHry la17aaamn only an mhwives, grant and mavgy that Barteners IRVJM h the Frepatry amdar Ilia berms of 11111 Security iaatamoot', (b) Is not personally obligated to pay tho some lammed by this Security tostiamanir sad (e) Wed Mat Leader No any other Borrower may ales in edat4 modify. Awbar or mane ably ncmaimadadana with regard an tha farms of this Soearity Instrument a the Now whhoot that Dorrawa'a wmens. M 1110111- Any mrda to Boerawce proddsd let In this Seoudty fmtril moat limn he time by dafivadng k: or by oolong It by Bet dw and go = nppBglble law scaleless amt or avow Mdbo& Tae indet shelf be dircmesd to the Property AN= or any Giber addran Borrower ddaast l y aedee to Leaden Any trance to Larder shag be good by tint class will to EsisderY addRer anted Itordo or soy address lender cla+ileain by nodes m Boerowar. Any rud. provided for In thk Sects ty Instrument shad be dosmad to Marc bad Shpt in Barmwer or Leader when given as provided in des pamgral n, N. Corerming lArq 6ornifi gtp This 5cowlly iaarameor ling be riummed by Madrid saw amt rtes tow of the )urlanrtbm In which the property Is tamed to the event the any i swidon m those of title Security lostmotenr at the Lints haall" with appllahte kw, each melid shag not agar orhmm psoddos s of ibis Seanrfty Instrument or the Now which an be given agent without the twugfeckil prwirloo. 'tis this and the prorWana of this Secpol, Instrument ado die Nw qrc drstared is he smershis if. Ocoranees Capp .tiarrawr shall be girth ate codfarated copy of this Saouiry Lastru , lk Anlgomeer or Beats. Si tromw uaealdtdop lly Usilip and taaeofea to harder all the cape and mvenum of the Propt M Patin not eadmrhm Lmwtor at Lander n ageaa to m0a't the ran# and rmenues sad hefty dir= scab consist of the property to pay the rmrol in Landerac Latderas agent Haocver, prior in Larder's natlm to iltrtowes of Bareva's Wench of may cosecant of Mpusient In The Semdry lestraarrs4 Borrower shag cogea and reoaha all rants sod teseatta of tae properly as wastes for da bandit of Lander and Borrower. Y* mafgnment of rents anatnaret an abwi0an aniporricst and act aR sNgmmot fm =Will" xcewhy only, tIt herder gho codas or b mA to Btmpws (a) ail inAp tomb rd by eoeowcr shag be held by Burrower as truism far based or Leader mdy. la be apood to the amts soatied by The Seca lly inatumantt (b) Lander dmtl he adldd an mllea and remka ad of ran raft of des Prepelq and (a) eadt tenant at the Prapal, awl pay o0 rent, dad and unpaid m L.todat or Leaders River cm Lemicr•s written daaend ro tho Ia nni. Borrower has not Cd ovA ably prior xcslgnmeat of the rants and has not and will not perform nay an that would prevent Lander tram czaadaing its rights under t& pategmph 16 Lander shall am be reyalted to enter apoe, take mood arm aashuaEo dm property Ihdare or after givfag notice of breach to Bor nmec However, Lander or a f oilkally appointed ra ciLw Gpy do so or any rime theta is a brain. Any apfdieadm at teats "not am or emlva cry ddwh as lamilostn any saver Halt or comedy of Lander Thls msipment or rode ofibe Property span lamlaate When the debt seahred by this swmdry itwrnmaac Is paid la run. NOIN MPOlttd COYMANT5, Bsnower and Lander fariber eeramar aid agree a fallewr; 17. Paredesrra Prsradam Irlasder roNlrec Immediate Fgmvtt In M undo pmpNph 9. Lender may cocaine: this Stymy fxcuPortat by imdtdd poaad(gf. Laadxc shall be enaam to cannot an espPtaas L,mrret In pw In f me rinudles prarided In tide parugaph 17, tkdd hry, bal not gmEkd ah altnraeye no sad aaq or don aid®ee. III, notate. Upon paymed at at wads saatrad by fhb Seoariry Instrument, thrs Searfty rnarumtat most me ante con"d shag teianhnta and become old. Mot NM Gxtnc m Lender shelf rlbdmrgo and mdsry nab Security ladramanr whitest *Arjp If Bomrsar_ Borrower shall pay any meeMmloe east 17. wrltet. Borrevar, to the ascent paudaed by nPddlmlds law, wafvm and r4cesm my trot or doleos In pm=dlap to ago= Ibis Security loftun mc. and hercb/ walm ft benefit of say present or ratnft Is" providing tort, atry or aecetlaa, entendon or durst a ampNom from ¦mcbaear, kvy and nir;, and homestead mizarrpriom m Itdoslrlmwne Ptalad, Bmrow.r's time to rclxcola provided in pnmgmph 10 del atcad to one hour prior Cu its: commonOCmaar of bidding at a "ft nM ar silver We ponbaa W this Seearlty Instrument. at. ParoGasw Murry ?tmgppe trany of tho debt stated by ibis Seenrity Instrument is lent to uarKmar to acquire Moto the Propetry, die Security Imwumem dug be a purtbua mency mortgage. = Isturest Bate After )udp=L Bdttower crate Char the Interest rue pryahta altar a )udgnmr Is entered an the Hong at in as attiah of mmripp foreclmum dwn by the Mte pWb1c, dram dme to time under ttu Nma. PAperrC . E".Ww q brat Pale s q fs use prep t7a Is. 6a U129$ PACE 055 tval.ta !It '-a. kldm to tide Be-IV twnautml. Tf odo or MM.M. and tor=md kr potr,hrar mild r?daa tgtr wVlp this Security tfttromtmt, the ettnmmah at tvah sad, ridcr dwil M 1-MQM%d Into mad ahab amend and suppldmrnt ntc cnrcatak and larcumtegts of ddr smult) ttouumcols a, $ the rrdar[m) weft a PUT Of Chia SeayAtr rnt wh=L [Check applicable trot(.)[ Condotoialum Rider ? Graduated Paymw Aida Phwed Unit Onclopmenr Rkkr U Growing Equity Rider IMIti, Ad[ueurbie [taro Rida ®YSIGNING DELOW. borrower al cMu and ulna to the tcrnw ronminod ro this Socarky Inarrumenr arer rn atty f(dar(I) -M Vent by Borrower and recorded with it. Wltaeircn % ? 1?R1f f. t?1gL4 ! ? ?-( ) -Bnnvwcr (Semi) -borrower q •be+reNar -bareohar Cerdbak K ItetHmre 4 wirhut named tsaaar it 9e0e c9 gyp( nFyg, do heroby mn[rr That the LCMM PM x1104 ar tlu M' =Mr ?IRYIAhID 11045 Wkaota my hand ihla S1'B dq or .Attitbm, 1995 COMMOMMALTII OF PENCYWANIA. Ap"t ai Lender CUMMM On ihb, lba 91RI day or .9bII M, 1496 . boa" mq Ceumv an dta nwlq*faad M-, Paeanlby appeared known m me (or fatNtltceriy prom] to he lb. P -A *he. anA1e is butrumant Ind ackNomedged that SIM ascuad ttm smwte for the pa rpm to the trlthbe rPote becalm mamined, IN WITNESS WHEREOF, I haeuno, rot my hmad and aw w meat. MS commlodan ttplrc t? IKwaal . 00o G?hp? bmmMdmt . rMr' yxa tR t 'r r rMl h i-OFU29$ OAE D5F VAFMC - Je.q tr, Iemi pws00 a.c"pi.% t.c Mart RM that certain tract of tend with tit. imp=@msnta !bacon oz9wta4 4mmta Ln potbh Mddlaton Township, combarlane county, 980asylvanla, b34nded a'd daanabod as follow, OEt80 Lot f(0. 29 04 the P1Md dg Kingsbraake Soudan 130e 44 MOrdad In the 09fAm of the 34koozdar m! Dorado tow gbaboamd county, is PAaa E4ok 27, pans 3) contti.a;pq 30 tent alOAf' Wa asst atatp ratth Ctmtat containing 200 toot sung t5a AMM atdng Lot No. 30 an Bald Flan; ee blUnq 50 gear slang tho west 4 =lr land now or fcrosv%r of smoker rubs a Book, end containinf 900 Coot slonq the aqwth a;ogy Lot tb.+zq on sate Plan and coetalalnq Ia.ma.0a agauo toot. xmcr impro9ad wlth aJ=Lck and'81' 1m6aI?;wteipagc badreem dapUX known as U4 rstth Ptrrlpr carllsla. . -tn cf PonnOM1116 1 SS •-wmM of tdadmer nd the roeoldlnq Ossd+ WOO {naa[t? ? ,fw cc In and ntY V? ? ui h Ze„??? • 1?rt1 . » ?: 'tlk a. . d EOOXJ298 PAGE 957 1 4 VL nrrCAILON Ilan Zion, Esquire hereby s action, that she is ues that she is the Attorney for the Plaintiff in this authorized to make this Verification as the Plaintiff is jurisdiction of the Court and plaintiff's verification outside the could not be obtained within the time necessary to file this pleading and that the statements m Mortgage Foreclosure are true and made in the f°regoing complaint in correct to the best of her ?owledge, ?formatio The undersigned understands that this stateme n and belief. Of 18 Pa. C. S: nt herein Sec. 4904 is made subject to the penalties relating to unsworn falsification to authorities. SHAPIRo & KREISMAN BY: Attoe Aqainntjiffff ' Dated: 4 ?r r- r ?J } F r ` i J n. y „Yl ?* .dk" SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. 1 Home Campus Drive Des Moines, IA 50328 PLAINTIFF VS. Mary M. Zayas-Bazan DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO:07-2865 CIVIL TEAM PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to the Complaint in the above-captioned civil action. Respectfully Submitted, SHAPIRO & KREISMAN BY: ",a,Ilana Zion, Es ui Attorneys for Plaintiff v Wells Fargo Bank, N.A. v. Mary M. Zayas-Bazan VERIFICATION The undersigned is Supervisor of Fidelity National Foreclosure Solutions, as attorney in fact for Wells Fargo Bank, N.A. and as such is familiar with the records of said corporation, and being authorized to make this verification on behalf of Plaintiff an officer of the corporation and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Mortgage held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Fidelity National Foreclosure Solutions, as attorney in fact for Wells Fargo Bank, N.A. Date: [() W(3 N Name: U fj0.j ?C,{?t Title: Supervisor Company: Loan: 8447427165 07-29369 C? 1 SHERIFF'S RETURN - REGULAR CASE NO: 2007-02865 P COMMONWEALTH OF PENNSYLVANIA: -^!"- COUNTY OF CUMBERLAND ,.. WELLS FARGO BANK N A VS ZAYAS-BAZAN MARY M RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ZAYAS-BAZAN MARY M the >. DEFENDANT at 2044:00 HOURS, on the 23rd day of May 2007 at 154 FAITH CIRCLE CARLISLE, PA 17013 MARY ZAYAS BAZAN by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 .00 T37.60 Sworn and Subscibed to before me this day of , So Answers; t'K f R. Thomas Kline 05/24/2007 SHAPIRO & KREISMAN By. D puty Sheriff A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-02865 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK N A VS ZAYAS-BAZAN MARY M ..a. 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 OCCUPANTS but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT 154 FAITH CIRCLE I OCCUPANTS CARLISLE, PA 17013 THERE WERE NO OTHER OCCUPANTS. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 00 Sf 3i?0? ? 21.00 So an?sw?e' R. Thom Kline Sheriff of Cumberland County SHAPIRO & KREISMAN 05/24/2007 Sworn and Subscribed to before me this day of A. D. Z SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. COURT OF COMMON PLEAS PLAINTIFF ; CIVIL DIVISION VS. CUMBERLAND COUNTY Mary M. Zayas-Bazan DEFENDANT NO:07-2865 CIVIL TERM PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $62,546.18 in favor of the Plaintiff and against the defendant for failure to file an answer to Plaintiffs Complaint in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as stated in the Complaint: Principal of mortgage debt due and unpaid $56,845.98 Interest at 7.75% from December 1, 2006 to June 26, 2007 (208 days @ $12.07 per diem) $2,510.56 Late charges (for certain months prior to default and every month after at a rate of $26.13 per month) $156.78 Escrow Balance ($82.98) Mortgage Insurance Premium $23.54 Title Search Report Fees $250.00 Attorneys Fees $2,842.30 TOTAL AMOUNT DUE Ei? ,i $62,546.18 B: ?7 auren R. abas, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant and damages are assessed as above in the sum of $62,546.18. 07-29369 t--p Al. X Pro thy. SHAPIRO & KREISMAN, LLC BY: DANIELLE BOYLE-EBERSOLE, ESQ. LAUREN R. TABAS, ESQ., AND ILANA ZION, ESQ. ATTORNEY I.D. NOS. 81747, 93337 & 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF VS. Mary M. Zayas-Bazan DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: STATE OF: tr A) COUNTY OF: h'G` AFFIDAVIT OF NON-MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon investigations made and records maintained either as Plaintiff or servicing agent of the Plaintiff and that the above-captioned Defendants' last known address is as set forth in the caption and they are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Fidelity National F By: NAME: j p5kv U TITLE: Supervisor Sworn to and subscribed before me this as attorney in fact for Wells Fargo Bank, N.A. 2007. Notary Public 07-29369 9 s =JAN?30 PUBLIC A SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Mary M. Zayas-Bazan DEFENDANTS NO: 07-2865 CIVIL TEAM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Mary M. Zayas-Bazan DATE OF NOTICE: June 13, 2007 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 without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de la fecha de esta notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe llevar esta notificacion a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente para tal servicio, vaya en persona o llame por telefono a la oficina cuya direccion se encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 Ilana Zion, Esq r Shapiro & Kreis an, LLC Attorney for Plaintiff SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF VS. Mary M. Zayas-Bazar DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-2865 CIVIL TEAM CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, June 13, 2007 to the following Defendants: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 Angela D'Antonio, Legal Assistant to Ilana Zion, Esquire for Shapiro & Kreisman, LLC SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF VS. Mary M. Zayas-Bazan DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:07-2865 CIVIL TERM CERTIFICATE OF SERVICE I, Lauren R. Tabas, Esquire, Attorney for the Plaintiff, hereby certify that I have served by first class mail, postage prepaid, true and correct copies of the attached papers upon the following person or their attorney of record: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 Date mailed: --15 BY Lauren R. Tabas, Esquire Attorney for Plaintiff 07-29369 SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF VS. Mary M. Zayas-Bazan DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:07-2865 CIVIL TERM CERTIFICATION OF ADDRESS I hereby certify that the correct address of the judgment creditor (Plaintiff) is: Wells Fargo Bank, N.A. 1 Home Campus Drive Des Moines, IA 50328 and that the last known address of the judgment debtor (Defendant) is: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 O & KREISMAN, LLC Lauren R. Tabas, Esquire Attorney for Plaintiff 07-29369 T"' ?_ w? "C !ai ? t ?? ?SS ?`+C L C d ?" ct"a o - ? ?°. ?_ r?= ?- n . . .? "? ! 7L ?. ? ..,a ni ? ! ?? ?...:' ? ? ? . ? r.._? - 'S yy i " y ? ? ?+ y « ?? ^ ??y ..?+. .?: ?.... OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Curtis R. Long Prothonotary TO: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 Wells Fargo Bank, N.A. PLAINTIFF VS. Mary M. Zayas-Bazan DEFENDANT COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:07-2865 CIVIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. [XX] Judgment by Default [ ] Judgment for Possession ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings Curtis R. Long Prothonotary /s/ (?. 1, /x? /o 7 IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY LAUREN R. TABAS, ESQUIRE AT (610) 278-6800. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Wells Fargo Bank, N.A. PLAINTIFF () Confessed Judgment () Other File No. 07-2865 Civil Term Amount Due $62,546.18 Interest June 27, 2007 to December 5, 2007 is $2,151.36 vs. Atty's Comm Costs Mary M. Zayas-Bazan DEFENDANT(S) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment safe, 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. Issue writ of 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) See attached Legal Description PRAECIPE FOR ATTACHEMENT 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 of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the gamishee(s) as lis defendant(s) described in the attached exhibit. Date: of the Signatu e: Print Na 'Lauren R. Tabas, Esquire Address: 3600 Horizon Drive, Ste. 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 93337 V C V 91 V v \VY ---? --T",?1 r 4....' wee 4@1'1 ' ?S ? J ? w '1p 1 ? ? Y ?"' 1 • 1 rw 1 _ ? ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-2865 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From MARY M. ZAYAS-BAZAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the 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) If property 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. Amount Due $62,546.18 Interest 6/27/07 TO 12/5/07 IS $2,151.36 Atty's Comm % Atty Paid $177.60 Plaintiff Paid Date: JUNE 27, 2007 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs iiepury REQUESTING PARTY: Name LAUREN R. TABAS, ESQUIRE Address: 3600 HORIZON DRIVE, STE. 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 93337 IF SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF vs. Mary M. Zayas-Bazan DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-2865 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 154 Faith Circle, Carlisle, PA 17013. Name and address of Owner or Reputed Owner Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 2. Name and address of Defendant in the judgment: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Wells Fargo Bank, N.A. 1 Home Campus Drive Des Moines, IA 50328 4. Name and address of the last recorded holder of every mortgage of record: Wells Fargo Bank, N.A., Plaintiff 1 Home Campus Drive Des Moines, IA 50328 l ` Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 154 Faith Circle Carlisle, PA 17013 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. & KREISMAN, LLC Lauren R. Tabas, Esquire 07-29369 } cz: T-n 2 r 4 .-' SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY vs. Mary M. Zayas-Bazar NO: 07-2865 CIVIL TERM DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 Your house (real estate) at: 154 Faith Circle, Carlisle, PA 17013 29-14-0868-070 is scheduled to be sold at Sheriffs Sale on December 5, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at I0:00am, to enforce the court judgment of $62,546.18 obtained by Wells Fargo Bank, 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 cancelled if you pay back to Wells Fargo Bank, N.A. the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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 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 of 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. ,+51 4. 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 (610) 278-6800. 5. 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. 6. 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. 7. 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. 8. 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. 9. 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 no later than thirty (30) days from the date of the sale. This schedule will state who will be receiving the 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 Sheriff within ten (10) days after the date of filing of said schedule. 10. You may also have other rights and defenses or ways of getting your house 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 07-29369 or ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 29 on the Plan of Kingsbrook, Section "3", as recorded in the Office of the Recorder of Deeds for Cumberland County, in Plan Book 27, Page 3; containing 50 feet along the East along Faith Circle; containing 200 feet along the North along Lot No. 30 on said Plan; containing 50 feet along the West along land now or formerly of Hooke, Lebo & Hooke and containing 200 feet along the South along Lot No. 28 on said Plan and containing 10,000.00 square feet. BEING the same premises which Jay F. Vogel and Kathryn A. Vogel, his wife, by Deed dated January 5, 1996 and recorded in the Cumberland County Recorder of Deeds Office on January 10, 1996 in Deed Book 133, page 892, granted and conveyed unto Mary M. Zayas-Bazan, single woman. ` .? Q -?ra ?- - -C3 i`% ? mom'--- ?c-r .T' '? j;?? ?,, --? '?a. S,t't' ?' ?, L._a',' x'? ?..r ? C?. • { ];r .G? ?, ? .? Wells Fargo Bank, NA In The Court of Common Pleas of VS Cumberland County, Pennsylvania Mary M. Zayas-Bazan Writ No. 2007-2865 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states he made a diligent search and inquiry for the within named defendant, to wit: Mary M. Zayas-Bazan, but was unable to locate her in his bailiwick. He therefore returns the Real Estate Writ, Notice of Sale and Description, in the above entitled action as NOT FOUND, as to the defendant, Mary M. Zayas- Bazan. Several attempts at service were made, but no one answered the door. Cumberland County Sheriffs Deputies confirmed with a neighbor that the defendant still resides at 154 Faith Circle, Carlisle, Cumberland County, Pennsylvania. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 0942 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Mary M. Zayas-Bazan located at 154 Faith Circle, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Lauren Tabas. Sheriff s Costs: Docketing 30.00 Poundage 14.97 Advertising 15.00 Posting Handbills 15.00 Mileage 9.20 Levy 15.00 Surcharge 20.00 Law Library .50 Prothonotary 2.00 Postpone Sale 20.00 Law Journal 355.00 Patriot News 251.66 Share of Bills 14.92 $763.25 f 3l?y?u? So Answers: ?• R. Thomas Kline, Sheriff Real Estate S rgeant Ga4/7 SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF vs. Mary M. Zayas-Bazan DEFENDANT COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-2865 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth, as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 154 Faith Circle, Carlisle, PA 17013. 1. Name and address of Owner or Reputed Owner Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 2. Name and address of Defendant in the judgment: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Wells Fargo Bank, N.A. 1 Home Campus Drive Des Moines, IA 50328 4. Name and address of the last recorded holder of every mortgage of record: Wells Fargo Bank, N.A., Plaintiff 1 Home Campus Drive Des Moines, IA 50328 5. Name and address of every other person who has any record lien on the property: 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: Cumberland County Domestic Relations 13 North Hanover Street Carlisle, PA 17013 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: TENANT OR OCCUPANT 154 Faith Circle Carlisle, PA 17013 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 unworn falsification to authorities. B tO & KREISMAN, LLC 07-29369 - Lauren R. Tabas, Esquire SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY VS. Mary M. Zayas-Bazan NO: 07-2865 CIVIL TERM DEFENDANT NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 Your house (real estate) at: 154 Faith Circle, Carlisle, PA 17013 29-14-0868-070 is scheduled to be sold at Sheriffs Sale on December 5, 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00am, to enforce the court judgment of $62,546.18 obtained by Wells Fargo Bank, 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 cancelled if you pay back to Wells Fargo Bank, N.A. the amount of the judgment plus costs or the back payments, late charges, costs, and reasonable attorneys fees due. To find out how much you must pay, you may call: (610) 278-6800. 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. You may 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 of 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. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-2865 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From MARY M. ZAYAS-BAZAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the 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) If property 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. Amount Due $62,546.18 Interest 6/27/07 TO 12/5/07 IS $2,151.36 Atty's Comm % Atty Paid $177.60 Plaintiff Paid Date: JUNE 27, 2007 (Seal) REQUESTING PARTY: Name LAUREN R. TABAS, ESQUIRE Address: 3600 HORIZON DRIVE, STE. 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 L.L. $.50 Due Prothy $2.00 Other Costs . F-Y Supreme Court ID No. 93337 A W Real Estate Sale # 41 On August 17, 2007 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA Known and numbered as 154 Faith Circle, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 17, 2007 By: Real Estate Sergeant PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9, 2007 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 9 day of November, 2007 C z? r?z ?-? Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY MY Commission Expires Apr 28, 2010 FAAL MATS &WA NO. 41 Writ No. 2007-2865 Civil Wells Fargo Bank, NA VS. Mary M. Zayas-Bazar Atty.: Lauren Tabas DESCRIPTION ALL that certain tract of land with the improvements thereon erected situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEING Lot No. 29 on the Plan of Kingsbrook, Section "3", as recorded in the Office of the Recorder of Deeds for Cumberland County, in Plan Hook 27, Page 3; containing 50 feet along the East along Faith Circle; contain- ing 200 feet along the North along Lot No. 30 on said Plan; containing 50 feet along the West along land now or formerly of Hooke, Lebo & Hooke and containing 200 feet along the South along Lot No. 28 on said Plan and containing 10,000.00 square feet. BEING the same premises which Jay F. Vogel and Kathryn A. Vogel, his wife, by Deed dated January 5, 1996 and recorded in the Cumber- land County Recorder of Deeds Office on January 10, 1996 in Deed Book 133, page 892, granted and conveyed unto Mary M. Zayas-Bazan, single woman. The Patriot-News Co. f 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE t4A Patti* ot Nevus Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/24/07 10/31/07 11/07/07 Sworn to me this 30 day of November, 2007 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal James L. Clark. Notary Public City Of Hamsbu Harrisburg. Dauphin County My Canmiasio i Expires June 2, 2008 Member, Pennsylvania Association of Notaries ?, ?. r ? ? V ,? ?. *a SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29369 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Mary M. Zayas-Bazan DEFENDANTS NO: 07-2865 CIVIL TERM PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment entered on June 27, 2007 in the above entitled action vacated without prejudice to Plaintiff. BY: & KREISMAN, LLC R. Tabas, Esquire CERTIFICATE OF SERVICE I, LAUREN R. TABAS, ESQUIRE, hereby certify that on I served a true and correct copy of the within Praecipe to Vacate Mortgage Fo eclosure Judgment upon the following parties via first class mail, postage prepaid: Mary M. Zayas-Bazan 154 Faith Circle Carlisle, PA 17013 SHAPIRO & KREISMAN, LLC BY: K'-s? UREN R. TABAS, ESQUIRE Attorney for the Plaintiff HIM w ?