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Home My WebLink About07-3150SHAPIRO & 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF VS. Tina Coyle 153 Valley Drive Carlisle, PA 17013 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: O'ff' 3l S'6 I U (, ! fr1L..?'n, COMPLAINT - CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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. 11 NOTICIA LE RAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES, USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Tina Coyle 153 Valley Drive Carlisle, PA 17013 DEFENDANT(S) NO: 6 ' 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: Mortgage Electronic Registration Systems, Inc. as nominee for Waypoint Bank Mortgagor(s): Tina Coyle (b) Date of Mortgage: March 19, 2004 (c) Place and Date of Record of Mortgage: Recorder of Deeds Cumberland County Mortgage Book 1857 Page 4503 Date: March 23, 2004 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: Mortgage Electronic Registration Systems, Inc. as nominee for Waypoint Bank Assignee: Washington Mutual Bank, FA Date of Assignment: May 24, 2006 Recording Date: July 24, 2006 Book: 728 Page: 986 Assignor: Washington Mutual Bank fka Washington Mutual Bank, FA 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 153 Valley Drive, Carlisle, Pa 17013 and is more specifically described as attached as part of Exhibit 4. The name and mailing address of each Defendant is: Tina Coyle, 153 Valley Drive, 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 February 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 May 16, 2007: Principal of Mortgage debt due and unpaid Interest currently due and owing at 5.75% per annum calculated from January 1, 2007 at $7.49 each day Late Charge of $14.59 per month assessed on the 16th of each month from February 16, 2007 to May 16, 2007, (4 Months) Escrow Balance (Credit to Defendant) Property Inspection Title Search/Report Fees Attorneys' Fees and Costs $47,542.32 $1,018.64 $58.36 ($328.13) $15.00 $250.00 $2,377.12 $50,933.31 8. Interest accrues at a per diem rate of 7.49 each day after May 16, 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 Sheriff s sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 10. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S. § 1680.402c, et seq., was sent to each individual Mortgagor at their mailing address and/or the mortgaged property address by first-class mail and certified mail. Pursuant to the act of December 21, 1998 (P.L. 1248, No. 160) (Act 160), this Notice contains the information required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. Section 403 et seq., and separate Notice of Intention to Foreclose is not required. Copies of the Notice are attached hereto as Exhibit "B". 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: cJ o?3 BY: 1 Attorneys for Plat ff S & K File No. 07-29392 LOo /7 A?? FrT P. "ZIEGLER uCiy 'EDEED" i 7 23 FI,9 1103 Prepared By: Return To: Lori Whitehead 101 S. George Street WAYPOINT BANK York, PA 17401 966-929-7646 101 S. George Street York, PA 17401 . 866-929-7646 Parcel NuMS>aer: 21181363014 )Spucc Above Thh Ilan For &=r& q Aaial MORTGAGE MIN 100249600400019808 DZrF[ MONS Words used ut multiple sections of this document are drained below and other words ate defined m Sections 3. 11, 13. 18.20 and 21. Corwin tales regarding ft 119AF of words used in this document ere also provided in Seeded 16. (A) aSectwltY1ns`b=1ftte means this 1100 Meat, which is dated March 19th, 2004 togcther with all Riders to this document. (It)'930M VI is Tina Coyle Harrower is the mortgagor under this Security hwument. (C) "MBRS" is Martgage litectronic Regiattatiov Systems. Inc. MERS is a separate eorporadon that is under tWS SSeeulrity instrument. MFRS is o LAader's Successors and amigns. I is the mortgagee address and telephone ? and Misting under the laws of Delaware, and has an number of P.O. Box 2026. Pliat MI 48501-2026, tel. (888) 679 MERS. PENNSYLVANIA - Single Family - FahWM Matftedlse Mac UNIFORM INSTAUM&NT yy MEAS Fom13n89 7107 (W.,6AWAI M2061 pop 1 of 18 VMP MORTGAGE F13WS -190)621-7791 BK 1857PG45O3 ?CH151T 'A' M) "Lender" is WAYPDTNT BANK Lander is a Federal. Savings Bank mr$anized W mhtiogWider the laws of the United States of America I4dder's adtiross is 101 S. George Street, York, PA 17901 M) "Note" means the pramissmty note signed by Bovower and dated March 19th, 2004 Tbt: Note states that Borrower owes Lender Fifty Thousand and no/100- (U.S. S 50,000.00 ) plus interest. Borrower has promised to pay this debt in re DoAtus Paymeal9 and to pay the debt in full not later tbaan Apri,1 1$t, 2034 Baler periodic, M "Property" means the property titer is described below Propf;M. 11 under the heading "Transfer of Rights in the (Q) "140n" means the debt evidenced by the Note, plus interest, any pre payment charges and late: charges due under the Note, and all sutras due wader this Security Instrument, plus interest. M 'iders" means all Riders to this Security Instrument drat an executed by Borrower, The following Riders are to be executed by Borrower [check box as applicabla), Cl Adjustable Rare Rider ? Condominium Rider Second Home Rider 0 Balloon Rider Planned Unit Dovelopmem Rider 1-1 Family bier d VA Rider ? Biweddy Payer Rider Other(s) [specify] Rider to Paragraph 19 (1) Applicable Law" means all eogtrolling appHuble federal, state and local statutes, regulations, ordinances and administrative toles and orders (that have the affect of law) as well as alt applieable final, non-appealable iadi opinions. (.I) "Commoat yt As uchadon Vuest )~ees$ and Agents" sqearts all dries, fm, assessments and other charges that are imposed on Borrower or the property by a condomittium association, homeowners association mr similar organization. check. " del tom le Funds ?9fer" r any transfer of funds, other than a trausaction originated by c instrument couiputer, heck. dra.. or sun ai nnier arpaper instramem, which is initiated through an clecttotdo lariniuat. telephonic *do or credit an 4ccouni. Suchhterm in des, but is no'limited to or poauthorb4 f-s a financral tnsntum at to debit machine aausacdons, transfers initiated by telephone, wire 'traansf rss, and t automated eleauinghaaso transfers. (L) 'crow Items" means those it= That arc described in Section 3. M "Miseeltancovs proceeds" means any vou, settlement, award of damages, or proceeds paid by any third party (other than hisura u c 9 paid under the coverages described in Section 5) for: (i) datnage to, or destruction of, the Property., (H) condemnation or oiber taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. ? oAgage Sze" Nett- insurance protecting fonder against the nonpayment of, or default on, than. (O) "PeriaMe Payment" means the regularly soheduled amaunt due for (i) principal and interest under the Note, plus u) any amounts under Section 3 of this Security ap=t. ?b peg* 2 of in Prom 3039 1101 6K 1857PG4504 (P) "RESPA" mom the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 at seg.) and its implementing re?u1anon, Regulation X (24 C.F.R. Part 3500), as they might be m=ded from time to time, or nay AddideaaI ar successor legislation or roguWon that governs the same subject utmer. As used in this Secirrity Instrument. "ROSPA" refers to all requirements and tesoc;ogOns that are imposed in regard loan" "federally federally related mortgagt loan" even if the Loan does not qualify as a "federally related mortgage . (0) "Successor In Intemst of Sarroger" moms any party that has taken title to the property, whether or sat that Party has assumed Borrower's obligations under the Note attdlor this Seondry Insmuttcttt. TRANSFER OP RIGHTS IN THE PROPERTY This Security l'st'rttmeat yew to Lender: (t) the repayment of the Loan, and all renewals, extensions and modifications of rite Note; mad (li) the performance of Borrower's covenants and agreeme= under rhis Security lnstraum and the Note. For this purpose, Borxower dots havby mortgage, grant and convey to MFRS (solely as aomigce for Lender and Lender's successors od assigns) and to the successors and assigns of MFRS, Cumberland Ebe described property tocmted in the County mpc of R=nHaa 7utismedo»1 of tNuae of Acconft )urWic&zQ: Which 0%1=Uy has the address of Carlisle 153 valley Drive U l ('Pmpetry Address I?Y1 , Pemasylvaaia 17013 Iz;p cane TO r-TETHER WPrH III the 4WMVIOMME9 now Or hereafter easements621 [en , and fixtures now or on. the Property, and all additions atm bee covered by t'is Secud here a P= of the fmpwrty. ,vt replacemems and SO= Instrument as the ?' Iastntmwmt• All of the ore oing is rimed to in this to the iatem?'•" Howes understands and agt holds only legal title ted by Borrower is th and is Secu Lander rit s custom. MFRS Y Instru ment, but, if wry to ^IY with law or asnotmfinee for Leader or all of those interests, laelttdlt , but not limited m, th ? co and fonl igoosse ) anhas the ri &-: d sell the Prompexercise any take any action required of Lander lnCltttIing, but not limited to, rel ; and to Instrument. casing and can 1,08 this Security -6AlPAl rosos? >nm"a?? roe s a rs Form 3039 t/o7 81K 18 57RG4505 BORROWER COVENANTS that Borrower is lawfully soloed of the estate hereby conveyed and bas the right to mortgage, grant and convey the Property and that the Pro encurabrances of record. BOxmwcr watrAnls and will defend generally the title 10 the Property except for claims and demands, subject to any encumbrances of record. ?o?m' against all THIS SECURITY INSTRUMENT combines uniform 00v= = for national use and non-uniform covenants with Bruited variations by jadsdicdon to constitute a uniform security insttwmrut covering real pzopeny. UNIFORM COVENANTS. Borrower and Lender caveat= and agree, as follows. I. Payment or princippl, ltttaut, Zwm r )plena, ftgn)mtutt Ch arg Borrower shall pay when due the principal of, and interest on, the debt evidencees, d Late nes. d by NntEOa y prepayment charges and late charges due under the Nora. Borrower shall also pay fiords for Escrow Items pursuant to Section 3. Payments due under the Note ad tills S=Wty Instrument spell be made in U.S. Currency. However, if any Cootie or other Ins[mawt received by tender as payment tender the Nora or this Security Inmumei t is r turned to Lender unpaid Lender may require that any or all snbsegoent payments due under the Note and Na Secruity Instrument be made in one or more of the following forms, as selected by Leader; (a) cash; (b) motley order; (c) eectied oheck, bank check, treasurer's check or cashier's ehaclr, provided any such Check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic FYtnds Transfer, Payments are doomed received by Leader when received at the location designated in the Note or at such other location as may be designated by Lender in aecardanee with the notice provisions in Section 15, Leader may rebtm 4n y paynat at penal paw if the payment or partial payments are insufficient to bring the Lean our aL Lender may RoMpt arty payment or pa W payment insufficient to bring tau Loan eunent. without waives of any tights hereunder or ptuejudice to its rigbts to refuse such payment or partial payments in the future, but Lender is act obligatEd to apply such payments at the time such payments are accepted. If each Periodic Payment Is applied as of its schedulai due date, then Lender need nor pay interest on unappIied funds. Lender spay hold such unapplied finds until Borrower makes payment to bring the Loam oumant. If Borrower does nor do so within a mascrosrblc period of time, Lender Aball elther apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to forcclosare. No offset or claim which Borrower aright have now or is do funue against Lender shall ralleve Borrowers from making payments due under the Note and this 9ecatrity Instrument or perfin4ag the covenaam and agreements secured by this Security Instrument, 2. APplicatien of Phymeuts or Procae& Ewept as othmwise desombed in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of prlofity. (a) interest due under the Note; (b) principal &a under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in the order In which it became due. Any remaining amounts s mcredapplied= the m to late charges, occond to any other amounts due under this Security hatrament. and principal balance of the Note. If Lender receives a paymeat from Borrower for a delinquent Periodic Payment which includes a sufflelot amount to pay any he charge due, the payment may be applied to the delinquent payment and the laic charge. If more than one Periodic Payment Is out Eom borrower to the repayment ,of the Periodic Payments if, if, , and to and to meY apply any at received the extent that, ea each payment Pipe 4 of 76 Form 3039 1/01 BK 1857PG4506 can be paid in full. To the extent that any excess exists after the payment is applied pnepsymenrs to the full payment of one or mom Periodic payments, Such excess may be applied to any late charges dice. Voluntary shall bo applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscalaneow Proceeds to principal due under the Note shall not emend or postpone the due date, or change the amount, of the Periodic payments. 3- ids for kserow Jame. BorMwer shall pay to Lender on the day Periodic payments are due under the Note, until the Note is paid in full, a sum (the •gundsN) to provide for payment of amounts due fo r. (a) taxes and assessments and other items which can attain priority over this Security Instrument as a Ran or p??enfor cumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) any and all insurance requimd by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Leader in lieu of the payment of Mortgage Insurance premiums in accordance with the pravi3ioma of Section 10. These items are called "Escrow Items." At origination or at any time during the term of the Loan, Lender may require that Community Association ]fires, Fees, and Assessments, if any, be escrowed by Bozmwer, and such dues, fees and assessments shall be an Escrow Item. Borrower shall promptly furnish to Lender all aotieea of amounts to be paid under this Section. Borrower ahall pay header the goods for brow hems unless Lender waives Borrower's obligation to pay the Funds, for any or all &orow Items. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of each waiver, Borrower shall pay directly. when and where payable, rile amounts due for any Emow Items for which payment of Ponds has boon waived by Leander and, if Leader requires, shall famish to ].,ender to ceipts evidetx* such payer within such time period as Lender may require, Borrower's obligation to make such payments zd to provide rec*ts shall for all purposes be deemed to be a covenant and agreement contained In this Security Instrument, as the phrase "covenant and areemant" is used in Sec don 9. If Brrttiwer is obligated to pay Escrow items directly, pursuant to a waiver, and Borrower fails to pay the amount tun for sn Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated wider Section 9 to repay, to Lender any such amount, Lender may revolve the waiver a to any or all lrSUM Items at any time by a notice given in accordance with Section 15 and, upon such revocation, Borrower shall pay to Leader all Funds, and in such amounts, that are then requited under this Section 3. Lcndcr may, at any time, collect and hold Funds in an amount (a) sufficient to permit Leader to apply the Funds at the time specified under RESPA, and (b) not to exceed the ma4mum amount a loader can require under RESPA. Lender shall estimate the amount of Ponds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law_ The Funds shall bo held in art institution whose deposits are insured by a federal ages imtrumrptality, or entity (including Lender, if Linder is as institution whose d cy, eposi any Federal Home Loup Bank. Loader shall apply tie Ftnwds to m Am ser than ithan d) or in specified under REVA. Fender 9W not chargo Borrower for holdthe io and w Items t later the tally analyzing the escrow 40counk or ved4ring the Escrow Itetus Wilms g Lender page IY1a8 o e r inter n atonally FtmdS and Applicable Law such a , Borrower est on the or Applicable Law requires Interest tLender paid oke the Funds, urge. Unlem au agreement Is made in writing any interest or earnings on the Funds. BomYwer and Ixeder Leader ?iAw- ing however, interest -8A(PA) tuo61 tnwr., tea S of 10 FMM 3099 1109 _._.?...._ ......__?___ aK l S 5 7 PG 4 5 0 7 Shall paid red the by Ram. Lender shall givo to Ftitads a as require Borrower, without charge, an annual accounting of the If there is a surplus of Funds bold is escrow. as defined under RESPA, L'.emdor shall account to Borrower for the exoess fimds in accordance with RESPA. If the:rc is a sbort9ge of pymds held in escrow, as defIW under RESPA, Lender shall notify Borrower as required by RMPA, and Borrower shall pay to Leader ttrc amount necessary to malts tip the shortage in accordant with RESPA, but in uo more than 12 monthly payments. If them is a deficiency of Ponds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RBSPA, and Borrower shall pay to Lender the amount necessary to matte up the deficiency in accordance With RESPA, but in no more than 12 monthly payments. Upon Payment In fill of all sums =wed by this Security Instrumeat, Leader shall promptly refund ro Borrower any Funds held by Leader. 4. Chat8es; ><Aans. Borrower shell pay all taxes, amessmeam, charges, fines, and impositions at tributable to the Pwperty which can attain priority over this Security Instrument. leasehold payments or ground rcrus on the the enteric that Propetty, if any, and Coutmuniry Association Dues, Poes, and Assessments, if any. To Bent that Borrower extent item am Escrow Items, Borrower sball pay them in the mower provided in Section 3 _ Borrower: (a) agrees Inow?thtg to th?pasty lien mt af th?iWhas n priority soma-ad b the lip my ?tr1> arc ptable to Lender, but only so long as Borrower performing such agreement; (b i re i manner acceptable by, or defends b) oxrntests the lien is goad faith prevent the odotuust enforcement of the Ilea in, legal proceedings whieb in Lender's opinion operate to p memeut of the lien While those procoodho ate pending, but only until such proceedings am concluded; or (c) segos frpta the holder of the lien an agreement sati*ctory to Leader subordinating the Ilan to this Security Irstrumm If Lender determines that my pal of the Property which can attain priority over this Security L=amw? Leaner nay give Borrower a saend to a like lien. Within 14 daye of do dare on which that notice is given. Borrower shat] axtisfy the he notice lir ea id or take s t*e ng the more of oho actions set forts above in this our or Swtitut 4. Leader may require Borrower to pay a sun-time charge for a red estate tarn ve i union and/or reporting service used by header in connection with this Loan, S, Proptaty ice. Borrower aball keep the improvements now existing or hereafter erected on the Property insured against toss by fire, hazards included within the term 'extended Coverage,' and any other hazards including, but not limited to, earthgW= and floods, for which Lender mqW= Insurance. .This Inmrance shall be stained in the amour (itiftling deductible levels) and for this Lender requires. What Lender roquim p? to the p?ed?g sentences can pe to that the Loan. The insurance rattler the insurance during providing shall be chosen by Borrower subject ro Leader's right to disapprove Borrower's choice, which right shad not be exesroised unreasonably. Leader may require Borrower to pay, in connection with this lam, either: (a) it one-timc charge for flood zone detenninatimr, certitludon and tracking services- or (h) a one-time charge for flood zone determination and certification services and a reaso nd tebly might affect sa d es each time remappings or similar changes occur which payment of may fins 3 certification. Borrower shall also he responsible for the Payinc of of f fie mpaged by the Pederal Emergency Mattagemeat Agency, is Connection With the mview any zone determlastioa resulting from an abjection by Borrower. BAIPAI romei IMQee J P¦p.aoe in Form 3039 9/ol BKI857PG4508 1f Borrower fails to maintain any of the covegges described above. Lender may obtain inshmnce coverage, at Leader's option and Borrower's c pem. Lender is under no obligation to purchase any Particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might 1141 protect Borrower, Borrower's equity in the p'mperty, or the contents of the prope rty h27ard or liability and might provide greater or lesser coverage than was 'against any risk, acknowledges that the cost of the lumraaee cove g 6previously 1e ceedt. the Borrower Insurance that Borrower could have obtained. An amounts obtained iW& si?? cost l become additional debt of Borrower secured th s a by Th under this d? S shall by Seoutity Instrument. Those amounts shall bear interest at rho Note rate from the date of disbursement and shat! be payable, with such interest, upon notice from Lender to Borrower requesting payment. All lnsurauce policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as Inortgagce and/or as an additional toss payee, Lender aball have. the right to hold the policies nud renewal certificates. If Lender requires, Borrower shall promptly Five to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance ooverage, not otherwise required by Leader, for damage to, or destruction oL the Property, such Policy shall include a standard mortgage clause and shall acme Lender as mortgagee and/or as an additional loss payee. In the event of loss, 'Borrower aball give prompt notice to the instumce carrier and Lander. Tender in wridn make proof of loss if not made promptly by Dornvwer. Unless bender and Botmwer otherwise agree g, MY lnsuraoce Mcceds, whether or not the Underlying insurance was required by Leader, shalt be applied to teswratlon or TV* of the property. if the restoration or repair is eea11omieatly feasible and h such insurat" t d6 not lessened. During such repair and restoration period, Lender shall have the tight to proceeds until Leader has had an opponunity to inspect such property to ensure the work has been completed to Lender's saftiction, provided that such Inspection hall s be promptly. Lendeo may disburse proceeds for the zepaim undOrtaken == Is in a single paym or in a seri as of pto,ress payments as the wart is feted. Q aw wrestmtion requires interest to be aid on such is made in writing FirentApplicable Law P Insurance pMCmds, lender shall not be required to pay $curower any Interest or earnings on such proceeda. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out Of the insurance proceeds and shall be the sole obligaticm of go. weY. If the reswra ' or repair b not economically feasible Or Leader`s security would be lessened, the inc??rancr Proceeds shall be applied to the suits secured by this Sec ur* humnnent, whether or not then due, with the Excess, if any, paid to Borrowet. Such iustumm proceeds shall be applied in the Section 2 order provided for in . If Borrower abandocts 'be properly, bender may file, negotiate and settle any available insurance claim and relnmd miners. If Borrower does not respond wld& 30 days to a notice from Leader that the in pcded surance curler has offered to settle a claim, rhea leader may negotiate and settle the claim. The 30-day Section 221 orotherwwhen ft ise, Borrower k?eby given. assigns 10 event, or if Lender requires the uer gns tO Lender (a) Borrowers rights to gamey is rrance proceeds in an amount not to exceed the amounts Unpaid under dte Note or this Security hiop menc, and (b) arty Other of Borrower's rights (other than the right to any refund of cmearned premiums paid by torrower) Under all insurance policies covering the PMPorcy, iWfar as such rights are applicable to the coverage of the property. Lender Atay use the imurance proceeds either to repair or restore the pro or to pay amounts tmpaid under the Note or U3 Security Insmunent, whether or not then due, perty -BA{PA) Mme, 4 dOw Fp.7 of 1a -te Faro 3039 1101 OK I 857PG4509 " ?pamr-y• Borrower shalt OccUpY, establisb, and use 1ba Property as Borrower's principal residency within 60 days after the execution of this Security Instrument And shall cotutwe to occupy the 1?toperry as Borrower's principal =side= for at least one year after the date of occupancy, unless Lender Grhemise agrees in writing, Wllit;h WAS= shall not be umasooably withheld, or unless extenuating eircamUmcm exist which are beyond Borrowers control. 7. Preservation, Maintenance and Protuffou of the Iftperty, 0 destroy, damggo or impair the ? 1?• Borrower shad not p'r'operty, allow the property to deteriorate or commit waste on the Property. Whtiher or not Borrower is raiding in the property. Borrower shall maintain the Property in order to pnevm the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pnrattaot to Section 5 that repair or restoration is not economically feasible, Borrower shall promPtiy repair the Property if damaged to NOW further deterioration or damage. If insurance or condemnation proceeds art paid in connection with damage to. or the w4ag of, the property, Barrower shall be responsible for repairing or restorittg the property only if Lender has released proceeds for such purposes. Lender =y disburse Procetds for the NPairs and restoMon m a single payment or in a series of progress payments as the work Is Meted. If the insurance or eondemnatiaA proceeds are not sufficient to repair or restore 010 Property, Borrower is not relieved of Borrower's obligation for the completion of such mpair or restoration. Leader reasonable =Or its R der may ? reasonable entries upon and Inspec icM of the Property. If it has Be, may Inspect rho interior of the improvements on the Property- Lender shall give Borrower notice at the time of or prior to such an interior kRxmuOn VW*Jng such 8. BOMWer?'s Lome Application. Borrower shall be in defimh if, ale cause. process, Bwtmwer or any Persons of entities acting at the direction of Bomwar or with Borrower ,s (knowledge or conmt gave Miedally false, misleadiag, or inaccurate W01104011 or sratenmts to Lender (or failed to provide Lender with material itdotmatioa) in Mcaction with the Loan. Material representations include, but are not limited to. representations concerning Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of header's hared in the PMperty and Rigbts Under thb Becwdty hatrnment if is alegal wer #ails to pedf rrm the coveaanta and agreements contained in this S,,?ry ms??? (b) there proecaft that might sl8W&andy aftect Imldzes Interest in the this Security r w=wnt (such as a proceeding in. b Property and/or rights under enforoement of a lien which an?ptC3'+ Probe. for cotlde?mnation or forfeitnrc, for 'W W du 006' over this tY but or to enforce laws or regulations), or (c) Borrower has abandoned the Property, then Lander tray do and reasonable or appropriate to protect Leader's interest in the pay for whatever y Instrument, rnclndin Property and rights under this Security g protecting and/or assessing the value of the Prvperry, and securing and/or repairing the Property. Lenders actions can includc, but ate not limited to: (a) paying any sums secured by a lien which bas priority over this aanrneys' fees to protect its inlet Scow* p??' ro) aping in Mn., and (C) PaYI?g reasonable party and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Socuiag the Property includes, but hs not limited to enteriug the property to make repairs, Change IWO, replace or board up doors and windows, drain water bone pipes, eliminate building or Giber code violations or dangerous conditions, and have utilities tnraed on or off, although Lender may take action under this Section 9. Lender dGes not }igye to do so and is not under any duty or obligation to do so. It is agreed that jactus no Mf? for not taking any or all actions authorized under this Section 9. 4m 6Att"At awaaet wuru P.w a of to Form 3039 11117 81f 1857PG45I0 Ally amounts disbwaed by Lender under this Section 9 shall booomc additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at ibe Note rite from the date of disbursement and shalt be payable, with such interest, upon notice from Lander to Borrower requesting Payment. If this Security Instrument is on a leasehold. Dorrower shall comply with all the provisions of the ]ease. If Borrower acquires fcc title TO the Property, the leasehold mad the fee title shall not merge unless Lender agrees to Om merga in writing. 10. Boer aSe Insurance. If Leader required Mortgage Insurance as a condition of making the Loan, shall the Mort pay tiro preantow required to mahttain the Mortgage Insurance7in effect. If, for any reason, Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such inswum and Bormwer was required to Make separately de?gnar;? payments s toward the premiums for Mortgage I,asutaace, Bomower shall pay the premiums requited to obtain cove a sabstamiaily equivalent to the Mortgage layura m Previously in effect, at a cost substantially vgtteat to tho cost to Borrower of the Mortgage Inmrarce previously in effect, from an alternate mortgage insurer selected by Lender. if substantially egwvaW Mortgage Insurance coverage is not available. Borrower shall continue to gay to Lender the amatmt of the separately designated payments that were due when the lnaurame coverage ceased to be in effect. Treader will accept, usn and retain these payments as a non-ale loss reserve in lien of Mortgage hmnamx. Such loss reserve shtdl be nova-refundable, notwithstanding the fact thnt the Lam is ul ' required to pay Borrower any interest or paid in full, and Lender shall not loss reserve, payments if Mortgage Insurance coverage: (ion such n ft ? fo t? 4o no longer require loss q i ra3 P vby an insurer selected by Lender egsir becomes ava6abic, is obtained, and >? der remm) separately designated Payments toward the premiums far Mortgage Insurance. if Lender r ate as a condition of malting the Lou and Borrower was Mortgage payments toward the premium for Mortgage kmratice, Borrow ? to the remiumsy designated r aintain e hnaranae in effect, or to pmv]dc a non-refaadablc reserve, autcl Leader's rement Mortgage Insurance ends in accordance with any written agreement between Borrower and Leader providing for such termination or until termination is required by Applicable Law. Nothing iR this Section 10 Wects Borrower's obligation to pay hunter at the rate provided in the Now. Mortgage Insurance reimburses Lender (or my entity that pumbasm the Nate) for cartab losses it may incur if Bomwer does nut repay the Loan as agreed. Borrower is not it party to the Mortgage Insurance. MattgMe insurers evalUM their total sink on all Such insurance in force from time to time, and way enter into Agreements With other parties that share or modity their risk, or reduce losses. These agreements ar c on terms and conditions than are satisfactory to the mortgage insurer and the other party (or parries) to flime of finds ts. The" its may U quire the mortgage lasuter to make yments using any source that Insurance P). mortgage insurer may have available (which may include obtained from Mortgage As a result of these agreements, bender, any purr of the Nate, another insurer, any reinsurer, any other entity, or any affiliate of any of the for+egohtg, may receive (directly or indirmtly) mounts that derive from (or might be characterized as) a portion of Borrower's exchange for sharing or modifying the rnwSage P for Mortggage lasagne e, in provides that an affiliate of Lander tafts a share of the s urrisk, s reducing ? in ]os a if such s a of t ha premiums paid to the insurer the sutrr s an e for :share of the (s) Any such a a?ttgeme°t is often orated "captive teinscrramae." urther: erib will not of ed the Amounts that Borrower has agreW to pay for Boor awaere hmmaime, win ow ,off other tours of the loan. Such agreements wm not fua=% the amount rtgage Ifasttraaee, stud they will not awde Borrower to any refund.. (k SAWA) tosoin WO -JL rw"tldte Fotat3n39 1 /py BK f 857PG451 1 (b) Any nwh agreements will not AWMCt the rights Borzo er has - If any - with respect to the Mortgage de tthe ri mrder the l omeotrriera Prnteeft Act of 1998 or any her low, Th may a rights int lade the right to receive certain dlsclasu,,es, to request and obtain catteellation of the rr.timtd of any lu1?nCi ao have ?the3 prtgage7nstumee terminated sutomatt,eally, and/or to receive a termiuadon. ptvroaiums that were uneanted at the time of such cancellation or 11• Asslpnmeut of MLscCIlaneous proceeds; Forfeitum All Miscellaneous proceeds are hereby assigned to and shall be paid to Leader. If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property. if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Leader shall have the right to hold such Miscaaneo,rs proceeds until Lender has had an Opportunity to inspect such to Cesare the work has been completed to Lender's satlefaetion, provided that such inspection shaU?yundcrtekca promptly. Trader may pay for the repairs and restoration in a sfngie dlsburstmeat or in a aeries of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires lutetcst to be paid on such Miscelhsneouz Proceeds. Lender shall not be reguirW to pay Borrower any Totem or emnings on such Miscellaneous Proceeds. If the rokw don or repair is not econamitslly feasible or tender's security would be lessened. the MkWlancous Proceeds shall be applied to the sums secured by this Sxa ft Instrument, whether or not then due, with the acess, if any, paid to Borrower. Such Miscellaneous proceeds shall be applied in the order provided for in Section 2. pads et Mat of a total taking, desaoetfan, or loss in value of the Property, the Miscellaneous this excess, l applW to the sums secured by this SemdW Fostrumeat, whether or not then due, with any, paid to Borrower. In the event of a partial taking, destruction, or loss in value of the to value of the Property immediately before the property which the fair market greater than the amount of the stuns p? fig' destruction, or loss iu value 19 equal to or aeouted by this Security Instrument immcd tel be ore artial taking. you, or I= in value, unless Bartowenr and Leader otltstwin agree is writing,ththe sums secured I lied thin Sty following Ynat ft'ar=rot shall be reduced by the amount of the Miscellaneous proceeds partial b ioac a the total amount of the sums secured imtnexliately before the P iffimed artial tak b, defore: rho e?y r Iris in value divided by (b) the fair nta<iret value of the property In the avert e a an • ?ror°?or toss in value. Any balance shall be paid to Borrower. partial EWdng,dostrnetiop or loss in value of the 1' valve of the toperty in which the fair et mark amount t the a the ? ?q, deKmion, or loss in value is less than the Borrower and Leader 0urediin lY W= the partial taking. destruction, or loss in value, unless Wri b(ISOC UIncous secured by this St U*Y I»suvment whe therr Orrnno?t the SUM are then d?? shall be applied to the sums If the Ptnperty Is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing party (as defined in the eau aeOtenCa) offers to males as award to settles a claim for dames, Borrower fails to respond to Lender within 30 days after the date the nodce is given, Lender is authorized to collect and apply the Misceilaaeona prods either to restoration or repair of the sums secured by this Security instrument, whether of not then due. " o 'g Patty" r ?oP rte t3thitrd to the chat owes Borrower Miscellaneous Proceeds or the pony Wim whom Bawer has s a parry regard to h(iscellaneons Proceeds, orrower has a right of action in Borrower shall be in default if any action or proceeding. whetter civil or criminal is b egan that, in Gender's judgment, could result in forfeiture of a. , or other itucrest in the Property or tights ender this ?, Prope;ity materiel impairment of Lender's hucretatlon the ocwt o Security W==E- Borrower can cure such a default and, if reinstate as provided in Section 19, by causing the action or proceeding to be 4A(PA1,a2a41 ? L? gage to 41 1 E Farm 3038 7101 8K1857PG4512 d impahment of WWssed with a rplipg ft, in Lender's judgment: Ludes forfeiture of the Property of other material any award or claim for sdainterest in ft nrages thptt are attributor I= under this able to the itapairment of?I a dInswment. en's laicise[ in G tbe pr ocw& of Property are hereby assigucd and shall be paid to Lender, All Misccllaneovs Ibotxeds that are not applied to restoration or repair of the Property shO be applied in the order provided for in Section 2. 12, Borrrowee Not Released; Forbearaace By Leader Not a Waiver. Extension of the time for payment or modi5catim of amortizatia of the slims scarred by this Security Instrument &maw by lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Leader sball not be required to commence proceedings against any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the suns smaed by this Security Iastrnmeat by reason of any demand mate by the original Borrower or any Successors in Interest of Borrower. Any fOrbearom by herder in exercising any tight or remedy Mfg, without limitadon, Leader's acceptaocc of payments from third persons, entities or Successors In Interest of Borrower or in amounts less than the amount then due, sball not be a waiver of or preclude the exetrAse of any right or remedy, 13. Joint and Several Liability; Co-signets; Successors and Assigns Bowed. Borrower covenants and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who Do-signs this Security 1nsWuncat but does not execute the Note (a "co-stgocr"): (a) is co-signing this Swarity Instrument only to mortgage, grant and convey the co-signer's irrrerast in the Property under the terms of this Sec dry instrltmenr (b) is riot personally obligated to pay the sums secured by this Security rasment; and (c) agnses that Leader and any other Borrower can agree to extend, modify, forbear or wb dory a0contawdadans with regard to the terms of this Seeeary Instrument or the Now without the ao•slgncr's consent. Subject to the provisions of Sudan 18, any Successor in Interest of Borrower who asa mes Borrower's obligations under this Setattity boisWunent In writing, and is approved by Leader, shell obtain all of Borrower's rights and benefits under this Secudty Instr memL Borrower shall not be r;eleased from Barrawer's obligations and liability umdar ft Security Instntweat unless Lender agrees to such encase in writing. The coven curs and amts of this Seandty Instrument 40 bind (except as provided in Section 20) and benefit the successors and assigns of Leader. 14. Loan Cbequ. Lender may charge Borrower foes for services performed in connection with Borrower's defame, for the purpose of protecting I ad 's intrnat in the Property and rights under this Security Insuuukm hmluding, but not limited to, attorneys' fees, property Inspection and valuation ides. lit itgard to any other lees, the abime of expresso autbotity in this Security Instrument to charge a specific: fee to Borrower shall not be construed as a prohibition on the charging of such fee. Linder may not charge fees tbat are expressly prohibited by this Security Instnu rot or by Applicable Law. If the Lomm is udbjeet to a law which no maximum loan charges, and that law is filly interpreted so that the interest or other loan charges collecied or to be collected in cozinection with the Loan exceed the permitted limits, then: (a) any such loan Aid V shall be reduced by the mount necessary to reduce the charge to the permitted Malt; and (b) any soma aire* colleW from Borrower which exceeded permitted Iiitliis will be refunded to Bonower. Lender may choose to make this refund by reducing the Papal owed Under the Note or by making a direct Paymant to Borrower. If a, refund reduces pr' pal, the rciuction will be treated as a partial prepaymi. without any prepaymeat charge (whether or not a prcpaymtatt charge is provided r nailer the Note). Rbrrower's wAmptaace of any such refired made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 15. Noticua. All notlces given by borrower or tender in connection with this S=Wty Intrument must be in writing. Any Aodec to Borrower in connection with this Security Instrument aball be deemed to ?SAIPAI mael MAN. V -.1 wp, rr or to Form 3039 1M BKI857PG4513 agreements; (c) pays all expenses incurred in caforclug this Security Iastrutnent, including, but not limited 0. reasonable attorneys fees, property inspection and valuation fees, and 00W fees incurred for the purpose of protecting Loader's interest in the Property 011 rights tinder this Security Instrument; and (d) calms such notion as Lender may reasonably require to assure that Leader's interest in the Property and rights under this Security Insttu=t. and Borrower's obligation to pay the suers secured by this Security Instrumem, shall cootdaue unchanged, Lender may require that Borrower pay sorb Xeinstatement sums and expenses in one err mom Of the following forms, as selected by Lender: (a) cash; (b) money order; (c) emmed chicle, bank check, treasurer's check or cashier's check, provided any such check is drawn open an institution whose deposits are insured by a federal agency. insttnmenrality or entity; or (d) Electronic Punch Transfer. Upon reinstatement by Bovowor, this Security Insrument and obligations secured hereby shall remain fully effecdve as if no acceleration bad occurred. However, this right to reinstate shalt not apply in the case of ac dcmdou tinder Section 18. 20. Sale of Nate; Change of Una Services; Notice of Grieva nca The Note or a partial interest in the Note (together with this Security Instrument) can be sold one or more times wid out prior notice to borrower- A sale might tomtit its a change in the entity (known as the "Loan Servicar") that collects Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan, servicing obligations under the Note, this Security Insw=nt, and Applicable Law. There also might be one or more chanson of the Lon SeMcer unrelated to a sale of the Now. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other- information RESPA requires in connection whh a notice of transfer of servicing. If the Note is sold and ther+Cafter the Loan is serviced by a Loan $crY cw other than flay purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan 5ervicer or be transferred to a sumnsor bout Servlcor and are not assumed by the Note pumbnser natess otherwise provided by the Note purchaser. Neither Borrower nor Tender may commepee, join, or bo joined to any judicial action (as either an 3 gant or the member of a class) that trrhm from the other party's actions pursuant to this exority hauument or that alleges that the other patty has breached my provision of or any dory owed by reason of, this Security Insromont, until such Borrower or Leader has norMed the other notice given In tmmplis= with the parry (with such requirements of Section IS) of such alleged breach and afforded the other party hereto a reasonable period after the gluing of stun notice to take corrective action. If Applicable I.aw provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleradon and opportan* to cure given to ft7ower pursuant to Section 22 and the notice of acceleration givers to Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. xi. 1MIzardoos Snbstahces. As used In Us Section 21: (a) 'Hazardous Substances' are those substances defined as tmlc or hazardous substances, poll[umab, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic peuoleuat products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or fommldeltyde, and radioactive materials; ( relate b) "Eaivironmental Law" means federal laws and laws of the jurisdiction where the property is located that action, to heft, safety or envirenntental Pro??; (G) 'Environmenid t'_leannp" includes any response Condition" me= a co dition that can cause, contributo to, nor otherwise higger an nvironm?ents] clemtup. MUM "k"IPA) (913 of t6 Farm 3039 7fot BK i 857PG4515 Borrower shall not cause or permit the presence, use, disposai, storage, or release of any Hazardous Substances. or threaten to release awry Hazardous substann on or is the l?roppeernryy Harrower shall not du, nor allow jayone else to do, anyd* aft' the pcopcrty (4) that is in violation of any Eavirommental ?. (b) which orates an Envimntuentai =n on, or (c) which due to the pccscace, use, or release of a Hazardous Substance, creates a condition that adversely affects tje value of the Pr two sentences shall not apply to the! presence. use, or storage on the Property of small gumiid Hazardous Substances that are rem pized to be apprapriate to wriaai residential uses and to mainten Borrower shall ance of the Pwpeny CIE but not Emite d to, ban us substances in consumer products) or other action pmtnptiy give Lauder written notice of (a) any utveadadctnt claim, demand, lawsuit by mW govcmmental or xegulstory aged or private party involving the Property and an Hazardous Subetaa:e or Env3mauteutal Law of Windt Borrower has actual Imowlod any Eavitor monral Condition, including but not limited tp, a pilling, , ?) any ralraae of any Hazardous Substance, and (a) any eoadt caq?sed ? fi e' Ialeass or threat of ?Hyrazardoguas 5ttbsPuft which adversdy d1bats the value of We PrutpaR-by life . If Borrower learns, rorr relew is no4ficd yHazard or ingom or any private party that any removal or other seatediation of asd Pnoperey is necessary, Bo'rawer shall promptly take all necessary retnelal actions is gpw a B ordance with Fm ronnueatal Law. Nothing herein a create any obligation on Lender for an EnvlrommmW Cleanup. NON-UNIFORM COVENANTS. Borrower and Leader &rdwr covmm and agree as follows: 22. A!eeeies'ation, Reanedics. Lender shall give notice to Bas"weer or to accdawou hHow? Barrowers btuseb of fury eoveaant or agog tueut In " Saatu* ant (but cwt prior to acceleration under Section 18 unless Ap a Law pt'aWas otlerwisc). Lendar shall notify Borrower of, among other tWWt the dfta; (b) the aciion rtgttlred to enure the dthwi; (c) when th e ddhalt mutt be cured; and ( drat fdwe to an the default as specified May result in accalarafl c n epf the a®s ttectuEd by 6eemity laslrt ctit, formloeurec by 3udikid protxe t and y Leader pW fbrtber Inform Borrower of tltt right to reaaostide after acceleration WW the right to amn In due foreclwam pvccWft the uoa m of a default or any other defense of Borrower to awdeaafi n And hr$dWom It the ddfim t is not coned as spexdlied, Leader at its option niq require imme iMe peinent In full of all stump secured by this Swm ty law ment without fmtther demand said may o[ ceclose ON StutWO indrimst ut by 3'2me i p meang. Leader sWtll be =WW to collect all eatpe m hmm W 1h pmsi t the rusedies provided is thus Sectlim 22, Indadltm, but not 8ntited to, attorneys' teas and costs of title evidence to the extent pumitttd by ApplimWe law. 23.9dease. Upon payment of all sums secarcd by this Security Imtrument, this Swirity Instrument and &a estate couveyed shall tenniuates and became void. After such occurrence, Leader shall discharge and satisfy This Security Ipatrtment. Borrower shall pay ury rtcosdadon cost,. Irader may edge Borrower a he for rdnsmg this Security laeretment, but apply if tiro foe is paid to a third parry for services rendered and the: charging of the fee is permitted suder Applicable Law. 24. Walvets. Bonower, to tic exceptpermit by Applicable Law, waives and releases any error or defects in proceWiags to enforce this Security kairument, mud hereby waives the benefit of any preheat or fume laws providing for stay of execution, extension of time, exemption bin attachment, levy and sale, and ltnmeserad exemption. 25. Rdlostatememt Period. Borrower's time to reinstate provided in Section 19 shall amend to one hour prior Insaumeal to the commencement of bidding at a sberiff's We or other sale pursuant to ibis Security 26. >Eurchase Money Mortgage. N a;qy of the debt secured by this Security b mtrument is lent to Borrower to WgVize tide to the , this Security Instrument shall be a purchase money mortgage. 27. Wercst Rate After Judgment. Borrower agrees that elm imerest rate payable after a judgment is enteral on the Note or in an argon of mor9pSe foreclosure shall be the rate payable from tune to time under the Note:. (0. GA(PA) Im"I edtWF eiw 14 at 1a iorm 3tl89 Tlet1 9K i 857PG4516 BY SIGNING BELOW. Borrower ncmTa and agr= to the terms and covenants aomnined in this Security Instrument and in any Rider executed by Borrower and recorded with it. WitnGases: ,P? (b G (Seal) -aVrMWCT (Sod) (Seal) -8oaowar -Borrower (Sal) (Seal) Barmwer -Borrowor 42-6A(PA) rowel - Mm) (Seal) Bmwer -9armwar "Is cr io Faro 3035 1101 BKt857PG4517 CertMeate of kesidence 1' , do hereby certify that the correct address of the within-nwed Mortgagee is P.O. Box 2026, Rar, MI 48501.2026. Witness my hand this 19th day of March 2004 COMKONWF-LILTS OFPMSnVANIA, Cumberland On this, the 29th day of March 2004 tmdmigued officer, Personally appeared Tina Coyle Agent of Martgagee County ss.. , before me, the satisfaetoril ]mown to the (or Y Proved) to be the Person(s) whose name(s) isltttt sois9cd6ed to the within inetraruettt and acknowledged that hdshehhq executed the two for the purposes heroin eenthined. IN WITNESS WHEREOF, I hereunto sat my band and of eW seal. my Commission Expires: EAL 'LAa?_ L MUMMIt t Rubllc i KstltY tandto„ PA 1 4 A h Wires Aug.1 i, 2007 Ilk of Officer SA(PA mom wd?"-? ?® t Pape 15 x116 Farm 3039 1101 UKI857PG4518 LBOALDESCR MON ALL THAT certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: 13OUNDED on the South by Valley Drive; bounded on the West by Lot No. B of Section "G" of the hereinafter referred to Plan of Lots, bounded on the North by Lots 12 and 13 of Section "G" on said plan, and bounded on the East by Lot No. 8 of Section °C" of said plan, and having a frontage of t fleet on the North side of Valley Drive and extending at an even width 140 feet in depth. The above described lot Is Lot No. 7 of Section "G" of the Plan of Lots known as Cloverieaf Acres No. 2, recorded in the Office of the Recorder of Deeds of Cumberland County, in Plan Book S. Page 43 and being improved with a dwelling known and numbered as 153 Valley Drive, Carlisle, Pennsylvania T Certify this to be recurdcd In Curnbcr]and CauntV PA h • .. `! . 01 H. iMK' ?• BN 1857PG451 9 PEOq-* MI ayp igh Rider to Paragraph 19 (Mortgage) I/We, the undersigned Borrower(s), do hereby agree that the following Rader to Paragraph 19 of the Mortgage, executed by me/us this 19th day of March, 2004 shall be effective in accord with the terms and conditions there of and shall be deemed to be a condition of the mortgage. The "reasonable attorney fees", as set forth in Paragraph 19 hereof, shall be deemed to mean five percent. (54) of the principal due at the time of foreclosure or $1,250.00, whichever is greater. This provision shall be void in the event this Mortgage is transferred to the Federal Home Loan Mortgage Corporation ("Freddie Mac"), the Federal National. Mortgage Association ("Fannie Mao"), or any other entity utilizing assignment or transfer. This provision shall also be voided if this Rider to Paragraph 19 is in violation of any provision of FreddiaAac or Fannie Mae. (SEAL) (SEAL) (SP-AL) (SEAT,) (SEAL) (SEAL) (19EAL) Hu 1 As .. . - - -7 p(' I ??,} Wells Fargo Home Mortgage P.O. Box 1225 Charlotte, NC 28201-1225 April 9, 2007 7100 4047 5100 4001 1760 TINA COYLE 153 VALLEY DR CARLISLE PA 17013 003760/936Am91 RF.: Wells Fargo Home Mortgage Loan Number 0614847754 Mortgagor(s): Tina Coyle Mortgaged Premises: '153 Valley Dr.. Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortRaae on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paves. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice ex- plains ow the program works. EDIT LA NOTTFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. ST NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCTA (PENNSYLVANIA HOUSING FINANCE AGENCY) STN CARGOS Al. NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDTDA DEL DERECHO A REDIMIR SU HIPOTECA. ?X-8181T •' B- This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counscling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. HOMEOWNER'S NAME(S): Ti PROPERTY ADDRESS: I S3 Valley Dr- Carlisle, PA 17013 LOAN ACCT. NO.: 0614847754 ORIGINAL LENDER: CURRENT LENDER/SERVICER: WELLS FARGO BANK, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH AN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1953 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. T Y SJAY OF R-- Underthe Act, you are entitled to a temporary stay 0 ores osure on your mortgage or t irty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS_MEE NG MUST OCCUR WITHIN THE NEXT ED I ht's notice! If you meet with one of the consumer credit counse i aggencies listed at the en o t is notice, t e lender may NOT take action against you for thirty 30) days after the date of this meeting. The names addresses and telephone numbers of sin e consumer redit c nselin nc:e or t e county in which r r is locatcd r is only necessary to schedule one ace-to-face meeting. Advise your lender immediately o your intentions. APCLI?4TION A - Your mortgage is in default for the reasons set ort later in this Notice (see o owing pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mort age Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's mergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST he filed or postmarked within thirty (30) days of your face-to-face meeting. YOU M FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICW60N FOR MORTGAGE ASSISTANCE WILL BE DENIED. 003780/936 AGL?JCY AI -- Available funds for emergency mortgage assistance are very limited. They will be disburse y the Agency under the eligibility criteria esta lashed by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES O&LY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). - - The MORTGAGE debt held by the above lender on your property JJQW TO CIjRF THE - - You may cure the default within THIRTY (30) DAYS of the ate o this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHK'H IS $ 1.449.12 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BhCOME DUE DURI13G THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order" made payable an sent to: WELLS FARGO HOME MORTGAGE 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: - - If you do, not cure the default within THIRTY (3U) DAYS means tna[ the enure outstanding naiance or tors dent will ne considered due immediately and you may lose the chance to pay the mort a e in monthly installments. If full payment of the total amount past due is not made within THIRTi0) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged aroperty. IF THE MORTGAGE IS FORECLOSED UPON - - The mortgaged property will be sold by the Sheriff to pay o the mortgage debt. teen er re ers your case to its attorneys, but you cure the delinquency be ore the lender begins legal proceedings against you you will still be required to pay the reasonable attorney's fees that were actually incurred, up to 550.1)0. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender which may also include other reasonable costs. If you cure the default within the THIRTY 1301 DAV nerind_ you OTHER LENDER REMEDIES - -The lender may also sue you personally for the unpaid principal balance an a other sums uc under the mortgage. A. YOU HAVF NOT MADE. MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: I chruary 2007 - April 2007 51,449.12 B. YOU HAVE FAILED TO TAKE; THE FOLLOWING ACTION 003290/939 RI HT TO RE THE DEFAULT PRi R T SHERIFF'S ALE - ifyyou have not cured the default within the T 0 Y period an foreclosure proceedings ave be un, ou still have the right f n prcvent 1- 1 n 'm fo h Sheriff's do so h a in the total amount then past ue lus an late or other charges then due reasonable attorne 's fees an costs connected with t e orec osure sae an any other costs connected with t e Seri 's Sae ass ifie in writing h telender an Fi performing other re uirements under the mortgage. Curing, your a au t in the manner set ort in is notice will restore your mortgage tot the same position as if you had never defaulted. EARLIEST POSSIBLE SHIRRIFFS SALE DAT -- it is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. }IOW TO CONTACT THE LENDER: Name of Lender: Wells Fargo Home Mortgage Address: 3476 Stateview Boulevard Fort Mill, SC 29715 Phone Number: 1-800-766-0987 Fax Number: 803-396-6063 Contact Person. Clarice Townsend EFFECT O 'S SAL You should realize that a Sheriff's Sale will end your ownership of the mortgage property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could he started by the lender at any time. ASSUMPTION OF MORTGAGE -- You may or may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE. MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGF. RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED IF YOU CURE. THE DEFAULT. HOWEVER YOU DO NOT HAVE THIS RIGHT TO GiURE YOUR DEFAULT MORE THAN THRFV. TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE. MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. PROGRAM CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro PA 17268 (717) 762-31,85 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX# (717) 234-2227 YWCA of Carlisle 301 G Street Carlisle, PA '17013 (717)243-3818 FAX# (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 The Pennsylvania Housing Finance Agency can be reached TOLL FRF.F. at 1 (800) 342-2397. 11.0. Box 1225 Charlotte, NC 28201-1225 April 9, 2007 TINA COYLE 153 VALLEY OR CARLISLE PA 17013 0032591936Ac191 RE: Wells Fargo Home Mortgage Loan Number 0614847754 Mortgagor(s): 'Tina Coyle Mortgaged Premises: 153 Valley Dr. Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can helo. you must MEET WITH A (717) 780-1869). This Notice contains important legal information, if you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, DUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCTONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. f _ HOMEOWNER'S NAME(S): Tj PROPERTY ADDRESS: 153 Vallcy Dr. Carlisle, A 17013 LOAN ACCT. NO.: 0614847754 ORIGINAL LENDER: CURRENT LENDER/SERVICER: FELLS FARGO BANK, N.A. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS If YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT,,), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. 1JEAdEQRARY STAY OF F E -- Under the Act, you are entitled to a temporary stay 0 foreclosure on your mort gage or t irty 30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST O .CIIR WITHIN THE NEXT R - If you meet with one of the consumer credit counse m a encies listed at the en o this notice, t e lender may NOT take action against you for thirty 3days after the date of this meeting. The names addresses nd telephone numbers of designated consumer re i counseling a neies for t n in which the 12rogergy is lQcated are ?Z forth at the end of this Noti?g, -k is only necessary to schedule one ace-to-face meeting. Advise your lender immediately o your intentions. AP A MQRTLA" A5SISTAN?E - Your mortgage is in default for the reasons set forth later in this Notice sec following pages or specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to appply for financial assistance from the Homeowner's Emergency MortEgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's mergency Assistance Pro ram Application with one of the designated consumer credit counseling agencies listed at the en of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submittin a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MIICT FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATON FOR MORTGAGE ASSISTANCE WILL BE DENIED. 003769!936 A NCY ACTIO? -- Available funds for emergency mortgage assistance are very limited. They will e disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if yqu have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES O&LY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). at: - - The MORTGAGE debt held by the above lender on your property A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: F..l,?.- (1[17 - Anril 707 $1.449.12 HQ'W - - You may cure the default within THIRTY (3 date o this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE Ll IS S _1.449.12 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WI DUE DURING THF. THIRTY (30) DAY PERIOD. Pa meats must be made either check, certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE 1 HOME CAMPUS X2501-01 H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: E THE DEFAULT - - If you do not cure the default within THIRTY (30) DAYS telender mten s to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of tnls aent will ne conslaerea aue lmmeulately ana you ma lose the chance to pay the mort a e in monthly installments. If full payment of the total amount past due is not made within THIRTi0) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon our mortgaged vroperty. IF THE MORTGAGE IS FORECLOSED UPON - - The mortgaged property will be sold by the Sheriff to pay a the mortgage debt. telender re ers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against ou you will still be required to pay the reasonable attorney's fees that were actually incurred, up to 50.110. However, if legal proceedings are started aggainst you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $.50.00. Any attorney's fees will be added to the amount you owe the lender which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAB period. you OTHER LENDER REMEDIES - - The lender may also sue you personally for the unpaid principal balance an a other sums ue under the mortgage. 11. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION 003289/936 I HT T URE TH DEFAULT PRI R T SHERIFF'S SALE -- If you have not within t e IR (30) DAY period an ores osure proceedings have begun,ou st mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. ' -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would he approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE ENDER: Name of Lender: Wells Fargo Home Mortgage Address: 3476 Stateview Boulevard Fort Mill, SC 29715 Phone Number: 1-800-766-0987 Fax Number: 803-396-6063 Contact Person: Clarice Townsend EFFECT OF SHERIFF'S SAL E -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or may not sell or transfer your home to a uyer or transferee who wi assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage arc satisfied. YOU MAY ALSO HAVE THE RIGHT- • TO SELL THE. PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE, DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME. POSITION AS IF NO DEFAULT HAD OC'C'URRED IF YOU CURE THE. DEFAULT. (HOWEVER YOU DO NOT HAVE. THIS RIGHT TO efJRE YOUR DEFAULT MORE THAN THREE'TIMES IN ANY CALENDAR YEAR.) • 'TO ASSERT THE. NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE. MORTGAGF. DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. PROGRAM CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX# (7'17) 234-2227 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 'fhe Pennsylvania Housing Finance Agency can he reached T01.1. FREE at 1 (800) 342-2397. 3M -CAU0 N "ana Zion, Esquire hereb action y states that she is the Attorney for the Plaintiff in this , that she is authorized to make this Verificatio jurisdiction of the Court and Pla' n as the Plaintiff is outside the rntiff's verification could not be obtained within the t' necessary to file this time pleading, and that the statements made in th 14 ortgage Foreclosure are true and correct to the e foregoing Complaint in best of her knowledge, information and belief. The undersigned understands that this statement her ' em is made subject to the of 18 Pa. C. S Sec. 4904 relating to unworn falsification to penalties authorities. SHAPIRO & KREISMAN BY.* Rana Zion, • e Attorney for Muff Dated: S ??3 21 wZI ? ?J 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. 07-29392 Wells Fargo Bank, N.A. 1 Home Campus Drive Des Moines, IA 50328 PLAINTIFF VS. Tina Coyle DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO:07-3150 CIVIL TERM 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: Ilana Zion, Esquir Attorneys for Plaintiff Wells Fargo Bank, N.A. v. Tina Coyle 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: "--n 14 QkkyN Name 1 C? K,p LCIs'L - Title: Supervisor Company: W?Ils fm4p "kxa Loan:0614847754 07-29392 ra ? -_? -? a .. ?r ? ?? ` r, -.,! ..?± ? J t 1 ? ? Y'• ? CCi ? ` w ti 0. ? 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF VS. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Tina Coyle NO:07-3150 CIVIL TERM DEFENDANT(S) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $51,314.89 in favor of the Plaintiff and against the defendant(s), jointly and severally, 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 $47,542.32 Interest at 5.75% from January 1, 2007 to July 6, 2007 (187 days @ $7.49 per diem) $1,400.63 Late charges (for certain months prior to default and every month after at a rate of $14.59 per month) $72.95 Escrow Balance ($328.13) Title Search Report Fees $250.00 Attorneys Fees "$2,377.12 TOTAL AMOUNT DUE 51,314.89 U Lauren R. Tabas, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendant(s) and damages are assessed as above in the sum of $51,314.89. Pro. Prothy. 07-29392 r-j ? p -n a° TO n .?? OO 7 1 { 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF ; VS. Tina Coyle DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-3150 CIVIL TERM 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 21, 2007 to the following Defendants: Tina Coyle 153 Valley Drive Carlisle, PA 17013 Angela D'Antonio, Legal Assistant to Ilana Zion, Esquire for Shapiro & Kreisman, LLC 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF VS. Tina Coyle DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-3150 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Tina Coyle DATE OF NOTICE: June 21, 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 I PORTANTE 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: Tina Coyle 153 Valley Drive Carlisle, PA 17013 4?Ok- Uln Ilana Zion, Esq *re Shapiro & Kreisman, LLC Attorney for Plaintiff 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF VS. Tina Coyle DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:07-3150 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(s) or their attorney of record: Tina Coyle 153 Valley Drive Carlisle, PA 17013 Date mailed: Lauren R. Tabas, Esquire Attorney for Plaintiff 07-29392 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF vs. Tina Coyle DEFENDANT(S) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO:07-3150 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(es) of the judgment debtor (Defendant(s)) is: Tina Coyle 153 Valley Drive Carlisle, PA 17013 & KREISMAN, L uren R. Tabas, Esquire Attorney for Plaintiff 07-29392 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. 07-29392 Wells Fargo Bank, N.A. ; PLAINTIFF ; vs. Tina Coyle DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 0_3i) Clvc1 1'R?e,M- STATE OF: r7r1 ?" COUNTY OF: f)a)%+Ck 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 Forec a Solutions, as attorney in fact for Wells Fargo Bank, N.A. By: NAME: Jj?s LcJI,?v(, TITLE: Supervisor Sworn to and subscribed before me thisS day of c , 2007. Notary Public 07-29392 -db"" JACQUELYN FREEMAN NOTARY PUBLIC • MINNESOTA MY COMMISSION EXPIRES JAN. 31, 2011 ES: OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEASCumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Curtis A. Long Prothonotary TO: Tina Coyle 153 Valley Drive Carlisle, PA 17013 Wells Fargo Bank, N.A. PLAINTIFF VS. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Tina Coyle DEFENDANT(S) NO:07-3150 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. Curtis ai Long l Prothonotary [XX] Judgment by Default [ ] Judgment for Possession [ ] Judgment on Award of Arbitration [ ] Judgment on Verdict [ ] Judgment on Court Findings 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 vs () Confessed Judgment () Other File No. 07- 31 SO Ci o I Ieo^_ Amount Due $51,314.89 Interest July 7, 2007 to December 5, 2007 is $1,400.63 Atty's Comm Costs Tina Coyle 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 garnishee(s) as la lis ndens against real estate of the defendant(s) described in the attached exhibit. Date: Signatur : Print Na auren R. Tabas, Esquire Address: 3600 Horizon Drive, Ste. 150 Ding of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID 4 PA Bar # 93337 V7 t? Y .tit„ 44 4 l r-41 c? Q w w {d w w ? r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3150 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 TINA COYLE (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 $51,314.89 Interest 7/7/07 TO 12/5/07 IS $1,400.63 Atty's Comm % Atty Paid $172.80 Plaintiff Paid Date: JULY 9, 2007 L.L. $.50 Due Prothy $2.00 Other Costs ??IiL\.r 'LhA 1. Curtis ong, Prothono (Seal) By: Deputy 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 .y 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF vs. Tina Coyle DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-3150 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 153 Valley Drive, Carlisle, PA 17013. Name and address of Owner(s) or Reputed Owner(s) Tina Coyle 153 Valley Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Tina Coyle 153 Valley Drive 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 1 A 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 153 Valley Drive 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 BY: R. Tabas, Esquire 07-29392 ? u V t Q N w ,TI ALL THAT certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BOUNDED on the South by Valley Drive; bounded on the West by Lot No. 6 of Section "G" on the hereinafter referred to Plan of Lots, bounded on the North by Lots 12 and 13 of Sections "G" on said plan, and bounded on the East by Lot No. 8 of Section "G" of said plan, and having a frontage of 75 feet on the North side of Valley Drive and extending at an even width 140 feet in depth. The above described lot is Lot No. 7 of Section "G" of the Plan of Lots known as Cloverleaf Acres No. 2, recorded in the Office of the Recorder of Deeds of Cumberland County, in Plan Book 8, Page 43 and being improved with a dwelling known and numbered as 153 Valley Drive, Carlisle, Pennsylvania. BEING the same premises which Kathy Zampelli and Tina Boyer now known as Tina Coyle Individually and as Executrixes of the Estate of Dona D. Boyer a/kla Dona Debres Boyer, deceased by Deed dated March 19, 2004 and recorded in the Cumberland County Recorder of Deeds Office on March 23, 2004 in Deed Book 262, Page 799, granted and conveyed unto Tina Coyle. 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. 07-29392 Wells Fargo Bank, N.A. COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY VS. ; Tina Coyle NO: 07-3150 CIVIL TERM DEFENDANTS ; NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tina Coyle 153 Valley Drive Carlisle, PA 17013 Your house (real estate) at: 153 Valley Drive, Carlisle, PA 17013 21-18-1363-014 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 $51,314.89 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. I? 4. If the Sheriff s 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. 07-29392 A- ALL THAT certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BOUNDED on the South by Valley Drive; bounded on the West by Lot No. 6 of Section "G" on the hereinafter referred to Plan of Lots, bounded on the North by Lots 12 and 13 of Sections "G" on said plan, and bounded on the East by Lot No. 8 of Section "G" of said plan, and having a frontage of 75 feet on the North side of Valley Drive and extending at an even width 140 feet in depth. The above described lot is Lot No. 7 of Section "G" of the Plan of Lots known as Cloverleaf Acres No. 2, recorded in the Office of the Recorder of Deeds of Cumberland County, in Plan Book 8, Page 43 and being improved with a dwelling known and numbered as 153 Valley Drive, Carlisle, Pennsylvania. BEING the same premises which Kathy Zampelli and Tina Boyer now known as Tina Coyle Individually and as Executrixes of the Estate of Dona D. Boyer a/k/a Dona Debres Boyer, deceased by Deed dated March 19, 2004 and recorded in the Cumberland County Recorder of Deeds Office on March 23, 2004 in Deed Book 262, Page 799, granted and conveyed unto Tina Coyle. c d? ?? ?? t= .1 C""' ?f"` ?? 4? ..... 0 +? CASE NO: 2007-03150 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK N A VS COYLE TINA ET AL 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 COYLE TINA the DEFENDANT , at 1240:00 HOURS, on the 31st day of May , 2007 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 TINA COYLE 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 4.80 Affidavit .00 Surcharge 10.00 00 I S I t7'I ?-? , 32.80 Sworn and Subscibed to before me this of , So Answers: R. Thomas Kline 06/01/2007 SHAPIRO & KREIS By: Deputy Sheriff A.D. day SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-03150 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK N A VS COYLE TINA ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANT but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 153 VALLEY DRIVE , OCCUPANT CARLISLE, PA 17013 THERE ARE NO OTHER OCCUPANTS AT 153 VALLEY DRIVE. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 00 21.*00 So NOT FOUND , as to A,,,R.- Thomas Ki ine riff of Cumberland County SHAPIRO & KREISMAN 06/01/2007 Sworn and Subscribed to before me this day of A. D. ?' ' 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF VS. Tina Coyle DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-3150 CIVIL TERM CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA R.C.P 3129.2 (C) (2) I, Heather Whitman, Legal Assistant for Shapiro & Kreisman, LLC, attorneys for the Plaintiff, Wells Fargo Bank, N.A., hereby certify that Notice of Sale was served on all persons appearing on Exhibit "A" attached hereto, by United States mail, first class, postage prepaid, with Certificates of Mailing on August 16, 2007, the originals of which are attached and that each of said persons appears on Plaintiffs Affidavit pursuant to Pa. R.C.P. 3129.1. The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, SHAPIRO & KREISMAN, LLC BY: 4?? Lx?? Heather Whitman Legal Assistant 07-29392 I T CD O w co V M m 2 m N O O N ?o 0 r y O 00 ?1 (J A W N ??++ Vw V- c O oo O'J, Q o N. (? ?p w c ' ? N w ? y• 4 cn D a fD c z 3 Z 3 ? v? .n N 0 ?' lJl GJ 00000 C, y. C o c? nr O ?. cn fD m N p -? ty !73 ? o O ? O M ? ID T) o 0 ? O ? w ? ORTp fD ? ? d O n o ' a C 6 n y 0000 c` cD 'J co Q° 1 4 O °-: 3 H `a o N o :6 8 , 0 v 8 o m v y ? m C?1 Q ttuo N CD 07 v CD O ON COD > cb °c`oa c'x m 3 a O - n= ` m m 3 ? cS c d H 3 ? ? ? RI V) Oc C N N c? o a 7D fig O C o o; M Q) /V W ° C De livery onfirm tion ? , " 0 Signat re Con irmati n -n U) Specia Handl ng 2 Re ricted elive M o Return? Recei t n 3 ?o 3 O m ? "LLr Wells Fargo Bank, NA VS Tina Coyle In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2007-3150 Civil Term William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 0920 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Tina Coyle, by making known unto Corrine Boyer, adult daughter of Tina Coyle, at 153 Valley Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2007 at 0920 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 Tina Coyle located at 153 Valley Drive, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Tina Coyle by regular mail to her last known address of 153 Valley Drive, Carlisle, PA 17013. This letter was mailed under the date of October 12, 2007 and never returned to the Sheriffs Office. 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. Sheriffs Costs: Docketing 30.00 Poundage 1,114.06 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 4.80 Levy 15.00 Surcharge 20.00 Law Journal 355.00 Patriot News 283.19 Share of Bills 14.92 ? 'la $1,869.47 So?s: -?4? R. Thomas Kline, Sheriff BY e ' Real Estat ergeant 5 Cx 4yiy ' -2 0,9 3 G"s' 1 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. 07-29392 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Tina Coyle DEFENDANTS NO: 07-3150 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 153 Valley Drive, Carlisle, PA 17013. Name and address of Owner(s) or Reputed Owner(s) Tina Coyle 153 Valley Drive Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: Tina Coyle 153 Valley Drive 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 I 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 153 Valley Drive 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 BY: R. Tabas, Esquire 07-29392 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. 07-29392 Wells Fargo Bank, N.A. COURT OF COMMON PLEAS PLAINTIFF ; CUMBERLAND COUNTY vs. ; Tina Coyle DEFENDANTS NO: 07-3150 CIVIL TERM NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tina Coyle 153 Valley Drive Carlisle, PA 17013 Your house (real estate) at: 153 Valley Drive, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on December , 2007 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00am, to enforce the court judgment of $51,314.89 obtained by Wells Fargo Bank, N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT T IS 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 SALEM DOES TAKE PLACE. 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) 278-6$00. 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. 07-29392 ALL THAT certain lot of ground situate in Middlesex Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BOUNDED on the South by Valley Drive; bounded on the West by Lot No. 6 of Section "G" on the hereinafter referred to Plan of Lots, bounded on the North by Lots 12 and 13 of Sections "G" on said plan, and bounded on the East by Lot No. 8 of Section "G" of said plan, and having a frontage of 75 feet on the North side of Valley Drive and extending at an even width 140 feet in depth. The above described lot is Lot No. 7 of Section "G" of the Plan of Lots known as Cloverleaf Acres No. 2, recorded in the Office of the Recorder of Deeds of Cumberland County, in Plan Book 8, Page 43 and being improved with a dwelling known and numbered as 153 Valley Drive, Carlisle, Pennsylvania. BEING the same premises which Kathy Zampelli and Tina Boyer now known as Tina Coyle Individually and as Executrixes of the Estate of Dona D. Boyer a/k/a Dona Debres Boyer, deceased by Deed dated March 19, 2004 and recorded in the Cumberland County Recorder of Deeds Office on March 23, 2004 in Deed Book 262, Page 799, granted and conveyed unto Tina Coyle. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-3150 Civil COUNTY OF CUMBERLAND) 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 TINA COYLE (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 $51,314.89 L.L. $30 Interest 7/7/07 TO 12/5/07 IS $1,400.63 Atty's Comm % Due Prothy $2.00 Atty Paid $172.80 Other Costs Plaintiff Paid Date: JULY 9, 2007 (Seal) Curtis Aong, r oth a By: 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 Deputy NIA Real Estate Sale # 40 On August 17, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA Known and numbered as 153 Valley Drive, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 17, 2007 By: •J a Real Estate Sergeant The Patriot-News Co. 812 Market :3t. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE the P_atrlot'w News 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 ---www own= fm R19*611111111k *A u l? b TAPA ft CMW*Ad 71 a M P46ftimJ7 mad p a? afy? Bali by ? u ae?elFnt? iat iVs. f f1^ ?' Ety ie refu nd 1a ?y silm fie M06 y Lab I2 atd t3 of A NIL m Ptrk a t h vow an to 9otttnr "Q' of a w PI, h + ft ow of 75 lit at rdr Notch i This ad ran on the date(s) shown below: 10/24/07 10/31/07 11/07/07 Sworn to and lbed before me this 30 day of November, 2007 A.D / Notary Public COMMONWEALTH OF PENNSYLVANI Notarial Seal James L. Clark, Notary Public City Of Harrisburg, Dea#dn County My Commission E)ires June 2, 2008 Member, Pennsylvania Association of Notari 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 publications are true. REAL ESTATE BALE NO. 40 Writ No. 2007-3150 Civil Wells Fargo Bank, NA vs. Tina Coyle Atty.: Lauren Tabas DESCRIPTION ALL THAT certain lot of ground situate in Middlesex Township, Cum- berland County, Pennsylvania, more particularly bounded and described as follows: BOUNDED on the South by Valley Drive; bounded on the West by Lot No. 6 of Section "G" on the hereinafter referred to Plan of Lots, bounded on the North by Lots 12 and 13 of Sec- tions "G" on said plan, and bounded on the East by Lot No. 8 of Section "G" of said plan, and having a frontage of 75 feet on the North side of valley Drive and extending at an even width 140 feet in depth. The above described lot is Lot No. 7 of Section "G" of the Plan of Lots known as Cloverleaf Acres-No. 2-re- Marie Coyne, Edi SWOVUN-10 AND SUBSCRIBED before me this 9 day of November, 2007 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010