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HomeMy WebLinkAbout07-4344PHELAN HALLINAN &SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 X215) 563-7000 lsssss WELLS FARGO FINANCIAL PENNSYLVANIA, INC. 3476 STATEVIEW BLVD FORT MILL, SC 29715 v. Plaintiff RANDALL K. DORMAN CHRISTINE P. DORMAN 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 07- /.f3~~ Civil lenK CUMBERLAND COUNTY CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 1ss88s 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 155885 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS File #: 155885 COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. File #: 155885 1. Plaintiffis WELLS FARGO FINANCIAL PENNSYLVANIA, INC. 3476 STATEVIEW BLVD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: RANDALL K. DORMAN CHRISTINE P. DORMAN 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 11 /22/2003 mortgagor(s) made, executed, and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1849, Page: 1005. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01/28/2006 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 155885 6. The following amounts are due on the mortgage: Principal Balance $169,670.83 Interest $29,664.21 12/28/2005 through 07/23/2007 (Per Diem $51.77) Attorney's Fees $1,250.00 Cumulative Late Charges $0.00 11 /22/2003 to 07/23/2007 Cost of Suit and Title Search 550.00 Subtotal $201,135.04 Escrow Credit $0.00 Deficit $0.00 Subtotal 0.00 TOTAL $201,135.04 7. 8 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 155885 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or haslhave been denied assistance by the Pennsylvania Housing Finance Agency. 10. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $201,135.04, together with interest from 07/23/2007 at the rate of $51.77 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN &SCHMIEG, By: /s rancis S. H man LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 155885 ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Silver Spring in the County of Cumberland and Commonwealth of Pennsylvania, as set forth on a Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company, as prepared by Gannett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 47, Page 52, and more particularly described as follows: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lot Nos. 141 and 142, as shown on the aforementioned Subdivision Plan; thence along same North 79 degrees 54 minutes 56 seconds East, a distance of 207.53 feet to a point; thence South 25 degrees 16 minutes 2 seconds West, a distance of 137.38 feet to a point at the dividing line between Lot Nos. 192 and 143; thence along same North 79 degrees 47 minutes 36 seconds West, a distance of 148.10 feet to a point; thence along the right-of-way line of Honeysuckle Drive, by a curve to the left, having a radius of 175.0 feet, an arc distance of 61.98 feet with a cord bearing North 16 degrees 33 minutes 17 seconds West, a cord distance of 233.39 feet to the point and Place of BEGINNING. BEING Lot No. 142 on the aforementioned Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company. CONTAINING 16,008 square feet, more or less. UNDER AND SUBJECT t a sanitary and storm sewer easement, other easements, set back lines and conditions as shown on the aforementioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynnewood West Development Company that is recorded in Cumberland County Miscellaneous Book 308, Page 206. BEING THE SAME PREMISES WHICH Sewalt, Incorporated, a Pennsylvania Corporation, by Deed dated July 18th, 1986 and recorded in the Office of the Recorder of Deeds in and for the County of Cumberland, Pennsylvania, in Deed Book A32, Page 825, granted and conveyed unto Chanh Trung Nguyen and Thanh Trang Nguyen, the Grantors herein. PARCEL#; 38-21-0289-142 PROPERTY BEING: 27 HONEYSUCKLE DRIVE VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. ~~12~~~ Francis S. Hallinan, Esquire Attorney for Plaintiff DATE: - ~~ ~p ~ .F~- r,., 5 C ~~ -~ c c.-~ ~ .:: n j "' d ~ ~ (J1 -~ - _ -~O ~ b ~_- ~ ~`f c _: =- O t, .. .~ CASE NO: 2007-04344 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO FINANCIAL VS DORMAN RANDALL K ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DORMAN RANDALL K the DEFENDANT at 1111:00 HOURS, on the 1st day of August 2007 at 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 by handing to RANDALL K DORMAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 ~'~ 11 I e'1 ~,, _~ 0 0 3 6 Sworn and Subscibed to before me this day So Answers: ~~E~ R. Th mas Kline 08/02/2007 PHELAN HALLINAN SCHMIEG By: Deputy heriff of A.D. ,- ~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-04344 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO FINANCIAL VS DORMAN RANDALL K ET AL WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DORMAN CHRISTINE P the DEFENDANT at 1111:00 HOURS, on the 1st day of August 2007 at 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 by handing to RANDALL K DORMAN (HUSBAND) a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 f-~ . 0 0 Y~ ~'I I d'l t-~,,., 16.0 0 Sworn and Subscibed to before me this day of , So Answers: .~~ /• R. Thomas Kline 08/02/2007 PHELAN HALLINAN SCHMIEG Deputy Sheriff A.D. PHELAN HALLINAN &SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. CUMBERLAND COUNTY 3476 STATEVIEW BLVD COURT OF COMMON PLEAS FORT MILL, SC 29715 . Plaintiff, v. CIVIL DIVISION NO. 07-4344 CIVIL TERM RANDALL K. DORMAN CHRISTINE P. DORMAN 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against RANDALL K. DORMAN and CHRISTINE P. DORMAN, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff s damages as follows: As set forth in Complaint $201,135.04 Interest from 07/24/07 to 09/20/07 $3,054.43 TOTAL $204,189.47 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ANIEL . SCH G, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. n DATE: T Q~/ s ~c.8 1~ O PROTHY D~ 155885 P~HELAN HALLINAN &SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (2151563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. 3476 STATEVIEW BLVD Plaintiff, v. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.07-4344 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant RANDALL K. DORMAN is over 18 years of age and resides at , 27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050-3166 . (c) that defendant CHRISTINE P. DORMAN is over 18 years of age, and resides at , 27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050-3166. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DANIEL G. SCH G, ESQUIRE Attorney for Plaintiff 'PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (2151 563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. :COURT OF COMMON PLEAS Plaintiff Vs. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendants TO: RANDALL K. DORMAN 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 DATE OF NOTICE: AUGUST 24, 2007 ~. 4 ,~' S"3 q 0 ~~ ~~ ~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 F CIS S. HALL A ,ESQUIRE Attorneys for Plaintiff CNIL DIVISION CUMBERLAND COUNTY NO. 07-4344-CIVIL TERM PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T, Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 X215) 563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. :COURT OF COMMON PLEAS Plaintiff Vs. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendants TO: CHRISTINE P. DORMAN 27 HONEYSUCKLE DRIVE MECHANIC5BURG, PA 17050-3166 DATE OF NOTICE: AUGUST 24, 2007 ~ ~~' ~~~ ~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CIVIL DIVISION CUMBERLAND COUNTY NO. 07-4344-CIVIL TERM LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 .- i F NCIS S. HA INAN, ESQUIRE Attorneys for Plaintiff I~HELAN HALLINAN &SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff, v. RANDALL K. DORMAN . CHRISTINE P. DORMAN Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-4344 CIVIL TERM CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: Q an FHA mortgage O non-owner occupied () vacant (~) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DANIEL G. SCHMIE ,ESQUIRE Attorney for Plaintiff \vw '~.' ~~ ~Q ~` 6. V .,,~ C.''A "1r ~Cl _ C" C~1 _~ry , ~,- 'C ~', J ` ) ~~ { _, ~ Gg ^. {V%, (Rule of Civil Procedure No. 236) -Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW WELLS FARGO FINANCIAL PENNSYLVANIA, INC. 3476 STATEVIEW BLVD CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendant(s). CIVIL DIVISION NO. 07-4344 CIVIL TERM Notice is given that a Judgment in the above-captioned matter has been entered against you on ~~F, a(~ T 007 . By. ~~~ . ~ AIcQ If you have any questions concerning this matter, please contact: DANIEL G. SCHMIE ,ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff, v. No. 07-4344 CIVIL TERM RANDALL K. DORMAN . CHRISTINE P. DORMAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 09/20!07 to MARCH 5, 2008 ' (per diem -$33.57) Add'1 Costs TOTAL $204,189.47 $5,606.19 and Costs $2,211.50 $212,007.16 i DANIEL G:-SCHMIEu3„~QUIRE One Penn Center at S ban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 155885 d O~ d~ W''~,, a~ z '~ a UZ wo OV ~z O~ V~ F~ '"' U ~~ A od ,.c 6` -.~ t31 _°~ 00 d UV d~ wz O `~ ~a d ~'' ~r ~ ~z aW W Q'` d~ ~~ OA Aa ~W A `n x U O V ~' W O~ w ~~ ~ ~ °~ a~ V w i o. ~. 00 o ~ "fl O tea o g ~ c ~ D - ~ -- F ~ ~ ~ M O N a r- d a a V d x U W W W O x N ~ ` SELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff, v. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendant(s). . CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.07-4344 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050-3166 . 1. Name and address of Owner(s) or reputed Owner(s): Name RANDALL K. DORMAN CHRISTINE P. DORMAN Last Known Address (if address cannot be reasonably ascertained, please indicate) 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None t , ~-~ 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) WELLS FARGO FINANCIAL BANK 3201 N. 4TH AVE SIOUX FALLS, SD 57104 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TenantlOccupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 20, 2007 DATE DANIEL G. SCH G, ESQUIRE Attorney for Plainti~ f .~ t~„ _ , ~ _ ~ ~`,~ ~" .. C''' '_ .. '";'1 _ i ~p _. = '-~ ""; - .. - ` rGr C.i' r WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff, v. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendant(s). TO: RANDALL K. DORMAN September 20, 2007 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 CUMBERLAND COUNTY No. 07-4344 CIVIL TERM CHRISTINE P. DORMAN 27 HONEYSUCKLE- DRIVE MECHANICSBURG, PA 17050-3166 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at , 27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050- 3166, is scheduled to be sold at the Sheriffs Sale on MARCH 5, 2008 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $204,189.47 obtained by WELLS FARGO FINANCIAL PENNSYLVANIA, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. r ' You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money. bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 TITLE REPORT ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Silver Spring in the County of Cumberland and Commonwealth of Pennsylvania, as set forth on a Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company, as prepared by Gannett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 47, Page 52, and more particularly described as follows: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lot Nos. 141 and 142, as shown on the aforementioned Subdivision Plan; thence along same North 79 degrees 59 minutes 56 seconds East, a distance of 207.53 feet to a point; thence South 25 degrees 16 minutes 2 seconds West, a distance of 137.38 feet to a point at the dividing line between Lot Nos. 142 and 143; thence along same North 79 degrees 47 minutes 36 seconds West, a distance of 148.10 feet to a point; thence along the right-of-way line of Honeysuckle Drive, by a curve to the left, having a radius of 175.0 feet, an arc distance of 61.98 feet with a cord bearing North 16 degrees 33 minutes 17 seconds West, a cord distance of 233.39 feet to the point and Place of BEGINNING. BEING Lot No. 142 on the aforementioned Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company. CONTAINING 16,008 square feet, more or less. UNDER AND SUBJECT t a sanitary and storm sewer easement, other easements, set back lines and conditions as shown on the aforementioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynnewood West Development Company that is recorded in Cumberland County Miscellaneous Book 308, Page 206. TITLE TO SAID PREMISES IS VESTED IN Randall K. Dorman and Christine P. Dorman, husband and wife, by Deed from Chanh Trung Nguyen and Thanh Trang Nguyen, husband and wife, dated 10/1212001, recorded 11 /01 /2001, in Deed Book 249, page 140. PREMISES BEING: 27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050 PARCEL # 38-21-0289-142 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4344 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff (s) From RANDALL K. DORMAN & CHRISTINE P. DORMAN (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 $204,189.47 L.L. $.50 Interest from 9/20107 to 3/05/08 - (per diem - $33.57) - $5,606.19 and Costs Atty's Comm Atty Paid $172.60 Plaintiff Paid Date: 9/26/07 (Seal) Due Prothy $2.00 Other Costs $2,211.50 5 C is R. Long, Pro~vt/honot By: ~e~ L . ~ ~ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: PHELAN HALLINAN &SCHMIEG, LLP ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F KENNEDY BLVD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO FINANCIAL PENNSYLVANIA, INC. DEFENDANT(S) RANDALL K. DORMAN CHRISTINE P. DORMAN SERVE RANDALL K. DORMAN AT 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 SERVED CUMBERLAND COUNTY No. 07-4344 CIVIL TERM ACCT. #155885 Type of Action - Notice of Sheriff s Sale Sale Date: MARCH 5, 2008 Served and made known to RAN cq~, t,, k • 1.a6 RM ~~ ,Defendant, on the 3 l~ day of C f R~ 200, at '=~o ,o'clock~.m., at o~~ E~I SuCKLE 1>RI uE ~ ~~ ¢~/1CS a ~tR..(~- ,Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age 3D S Height ~~ u e Weight ~36 Race ~ Sex /U Other I, ~Qflq'(.D ~61-L , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this 3 day of , 200 7 ~~Z~~ ` ~V t~~'~'~l Notary: By: EA E A EMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. J EPH J. SAROCY NOTARY Pui~uC OF NEW JERSFY NOT SERVED On a o , 200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer ls` Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this day of , 200_ Notary: Vacant 2°d Attempt: / / Time: Attornev for Plaintiff DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 One Penn Center at Suburban Station, Suite 1400 By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215)563-7000 2~ ~~yz °.µ T ~.~ i_ ~_s ~ `S '/ { p ..=. -' n,a ~ ~ , . . ~.,,. , r; ,. AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO FINANCIAL PENNSYLVANIA, INC. DEFENDANT(S) RANDALL K. DORMAN CHRISTINE P. DORMAN SERVE CHRISTINE P. DORMAN AT 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA I7050-3166 CUMBERLAND COUNTY No. 07-4344 CIVIL TERM ACCT. #155885 Type of Action - Notice of Sheriff s Sale Sale Date: MARCH 5, 2008 ' SERVED Served and made known to ` ~rsrf ~~ [~ ~ boi;11~1>~.-h1 ,Defendant, on the 3 ~ day of ~~8~. 200 at ~=~ ,o'clock ~.m., at a~ I~auFy~u~~' I.E ~fzl U~. t ~/(.~~ ~ N -CS $u 2G- Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. I - -Adult family member with whom Defendant(s) reside(s). Name and Relationship is ~c'~~ ~ ~ $ t7~ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: ? /~ c -, Description: Age JJ7~g Height b ~ Weight ~ .Race W Sex M Other I, _ ~G ~ (~l0 t.l_ , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and su ribed before me this day of 200 ~~~„~~~ Nota By; I`' P ~ATTE~~e~ERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE J 5~A A:T ATTEMPTED. N®TARY PtD~UC 4F f~tEYV JOEY COIIIlI111 El(pli'dlS i~~~ NOT SERVED ' On the day of 200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer 1st Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this day of , 200_ Notary: Vacant 2°a Attempt: / / Time: Attorney for Plaintiff DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 One Penn Center at Suhurban Station, Suite 1400 By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215)563-7000 z7 ~~ Y" WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff, v. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendant(s). WELLS FARGO FINANCIAL PENNSYLVANIA. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at :27 HONEYSUCKLE DRIVE, MECHANICSBURG. PA 17050-3166 . AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) 1. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated.Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.07-4344 CIVIL TERM Last Known Address (if address cannot be reasonably ascertained, please indicate) 6th Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. O January 31, 2008 DATE DANIEL G. SC IEG, ESQ Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FAItGO FINANCIAL PENNSYLVANIA, INC. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION RANDALL K. DORMAN . CHRISTINE P. DORMAN NO. 07-4344 CIVIL TERM Defendant(s) . AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND COUNTY ) SS: 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: 27 HnNF,YSi 1C'KT.F. T)RiVF._ MF.C'HANi('SRi JRG, PA 17050-~ 1 FF, As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the Affidavit No. 2 (previously filed) and/or Amended Affidavit No. 2 on the date indicated. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. P ~ DANIEL G. SCHMIE ,ESQUIRE Attorney for Plaintiff Date: 7an~ 31, 2008 IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not he cold in the ahsence of a representative of the plaintiff at the 4heriff c 4al .The sale must be postponed or stayed in the event that a-representative of the plaintiff is not present at the sale. 155885 £0 t6 L 3 t00i; 4i ~. o~~'~ ~ 531NOL a O~ O a; v° ~~~F 0 ~~ ~ ~~ ~s 7~~~0 ~~~~ a~~a ~U~'-~ ((~~ 'L3 .~Ti ~ ~ ~ ~ f1e ~ ~ Gam. b °~ y~ a r i ~ pCdj '~ ~4~ ~ ~ u , w ? x.~. ~$ '~~' ~ ~~. y p~ 9 w ~ u xx ~ m o ~ ~/ ~ g~ f ~, ~ aoodrz woad o~row :_ ~ ~ ti $ ~ i0 ~ 0 L09 4YVb0i; 0 ~•'~ 1 /JN4.kl OI~~• r~ ~ ` .~ . ~~ ~ ~~ $ '~ 6 ~; ~ ~ w ~ .. o o •; a .• $ s ~ ~ ~ ~ ~s ~ r O w a ~ c.7 ~ ~ ~ '~ a` ~ ~g.s`~ ~'so~~ H ~ "` ~ o ~ ~~s~ oo ~ ~ ~ ~~ w ~•, ~ y O ~ ~ ~~g~ ~ ~ ~' > b ~ c ~ ~ oB ~ a o n ~~ ~~ x ~ ~ ~ o ~ ~ .~ ~ ~ U ~s ~ ~ a ~ ~ ~ ~ ~i'N ~ ~ ~ a ~ U v~i~ O , ~ a~ > ~ y ~pq 2 '~' ~ ~ U ~ k" o ~ ~ x N A ~ ;, ~ ~ -~~ ~p ~ Zp 0 0 'o ~~' ... ~~ .~ o ov' a ~ ~ .~ u `'~ a O o~o^ ~ O A ~ v ~ 3~ ~'~ ~°O W ~ ~G4 ~ ~ w map ~ ~~S Z C] U~ E-~ U ~O .~"i Cdr ~ Q p, `rte M ~ ~ a 3 z m ~ a ~~ ~~ .~~' N c+1 ~7 N ~O l~ 0o C~ O .;. ~ ti ~ ~ z ~ ..a a ~ ~ ry _ ~~ ~ C!~ ~} _y~ ~ ~ ~~ 3 ,.~; ~'" C_ .. t _,r `""` G3 COMMONWEALTH OF PENNSYLVANIA CCrUNTY O'? CUMBERLAND } SS: I, Robert P. Zie Iffier, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which WELLS FARGO FINANCIAL PA INC is the grantee the salve having beers sold to said grantee on the 5TH day of MARCH A.D., 2008, under and by virtue of a writ Execution issued on the 26TH day of SEPT, A.D., 2007, out of the Court of Common Pleas of said County as of Civil Term.. 2007 Number 4344, at the suit of WELLS F'ARGO FINA:~ICIAL PA INC against RANDALI, K DORMAN & CHRISTINE P is duly recorded as Instrument Number 200808338. IN TESTIMONY WHER'.EOF', I have hereunto set my hand ~~_ and seal of said office this ~,~ ~.`~ day of ,. ~ ~ --- Recorder of Deeds _ "~R"_ .. /. j` Wells Fargo Finan~~ial Pennsylvania Inc. In the Court of Common Pleas of VS Cumberland Count., Pennsvlvania Randall K. Dorman and Christine P. Dorman Writ No. 2007-4344 Civil Term Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to la~~~, states that on December 13, 2007 at 2008 hours, he served a true copy of the within Real estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Randall K. Dorman and Christine P. Dorman, by making known unto Randall Uorrnan, personally and husband of Christine P. Dorman at 27 Honeysuckle Drive, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true. and correct copies of the same. ~~serald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 1947 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 Randall K. Dorman and Christine P. Dornyan located at 27 Honeysuckle Drive, Mechanicsburg, Cun-iberland 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-3 notice oi~the pendency of the action to the within named defendants, to wit: Randall K. Dorman and Christine P. Dorman by regular mail to their last known address of 27 Honeysuckle Drive. Mechanicsburg, PA 17050-3166. These letters were mailed under the date of January 8, 20U8 aJ~d never returned to the Sheriff s Office. R. "l'homas Kline, Sheriff, who being duly sworn according; to law, states that after due and legal notice had been given according to Iaw, he exposed the with~:n described premises at public venue ter outcry at the Courthouse, Carlisle, Cumberland County, 1Pennsylvania on March O5, 2008 at 10:0-1 o'clock F,.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg, on behallr of Wells Fargo Financial Pennsylvania Inc. It being the highest bid and. best price received for the same. Wells Fargo Financial Pennsylvania Inc. of 3476 Stateview Blvd., Fort Mill., SC 29715, being; il~ie bu~~~r in this execution, paid to Sheriff R. Thomas Kline the stun of $1,183.88. Sheriff's Costa Docketing $30.00 Pound~ige 23.21 Posting Rills 15.00 .~~.dvertising 15.00 Ackno~-~°ledging; Deed 48.00 4uctioneer 10.00 I_,a~~ Library .50 Prothouotary_ 2.00 1/IileaLC 19.20 Levy 15.00 Surcharge: 30.00 Law J~~urnal 479.00 Patriot News 416.30 Share ~~f Bills 16.17 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $1,183.88 / ~` SD . SCE ~~ -~at~~3ar ~~ ,rs :~ °'~°d~r R. `l'honlas Kline, Sheriff _ r Real Estat ;Sergeant -.... r `WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff, ~. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendant(s). CUMBERLAND COUNTY COUR"C OF CO:YIMON PLEAS CIVIL DIVISION NO. 07-4344 CIVIL TERM AFFIDAVIT PURSUANT 'TO RULE 3129 (Affidavit No. 1) WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050-3166 . 1. Name and address of Owner(s) or reputed Owner(s): Name RANDALL K. DORMAN CHRISTINE P. DORMAN Last Known Address (if address cannot be reasonably ascertained, plea:;e indicate) 27 HONEYSUCKLE DRIVE MECHANICSBURG, PA 17050-3166 27 IIONEYSUC:KLE DRIVE MECHANICSBURG, PA 17050-3166 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None _' 4. Name; and address of last recorded holder of every mortgage of record: Name Last Known Address I if address cannot be reasonably ascertained, please indicate) WELLS FARGO FINANCIAL BANK; 3201 N. 4TF' AVE SIOUX FALLS, S:D 57104 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Namc and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address camiot be reasonably ascertained, please indicate} None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascerta.ined., please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 27 HONEYSUCKLE DRIVE MECHANICSI3URG, PA 17050-,166 13 North HanoverStreet Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C'.S. Sec. 4904 relating to unsworn falsification to authorities. September 20, 2007 DATE DANIEL G. SCHM~ 'G, ES~-UIRE Attorney for Plaint f WELLS FARGO :FINANCIAL PENNSYLVANIA, INC. Plaintiff, ~,. RANDALL K. DORMAN CHRISTINE P. DORMAN Defendant(s). CUMBERLAND COUNTY No. 07--4344 CIVIL TERM September :?0, ~ 007 TO IZANDALL K. DORMAN 27 HONEYSUCKLE DRIVE MECHAI`IICSBURG, PA 17050-3166 CHRISTINE P'. DORMAN 27 HONE~'SUCKLE DRIVE MECHANICSBURG, PA 17050-3166 '~ *THIS FIRMIS A DEBT COLLECTOR ATTEMPTING TO COLLECI~.9 DEBT AND ANY L'VFORMATION OBTAINED WILL BF. USED FOR THAT PURPOSE. IF YOU HAVE PREVIDUS'LYIZECI;'IVED A DLSCHARG'E IN BANKRtr`PTCYAND THIS DEBT WAS NOT RL;AFFIRMED, THIS IS NOT AND SHOULL> NOT BE CONSTRUED TO BE ANATTE~I~fPT TO COLLECTA DEBT, BUT OT/LYENFORCEMENT OFA LIE'NAGAINS'T PROPERTY. ** Your house, (real estate) at , 27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050- 3166, is scheduled to be sold at the Sheriffs Sale on MARCH 5, 2008 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $204,189.47 obtained by WELLS FARGO FINANCIAL PENNSYLVANIA, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa. R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 7'o prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled. if you pay to the mortgagee the back payments, late charges„ costs and reasonable attorney's fees due. To find out how much you must pay, ,you may call, (215) 563-7000. 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. `y'ou may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 'i'ou may need an attorney to assert your rights. The sooner. you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN [F THE SHERIFF'S SALE DOES TAKE PLACE,. k. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215 SE3-7000. .'. You may be able to petition t]he Court to set aside the saae if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the: full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. <t. 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. >. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6~. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be f-sled by the Sheriff within 30 days of the sale. This schedule will state who will be receivin€; that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are lzled with the Sheriff within ten i 10) days after the distribution is filed. E . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence o1- a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION LIBERTY AVENUF, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 TITLE REPORT ALL THhT CERTAIN tract or parcel of land and premises., situate, lying and being ;_n the To~.anship of Silver Spring in the County of Cumberland and Commonwealth of Pennsylvania, as set forth on a Final Subdivision Plan fo:r Mulberry Crossing, Sectio;c Two, W~~nnewood West Development Company, as p~epa:red by Gannett Fleming Civil i:ngineer:., Inc., and recorded in the Recorder o= Deeds Office of Cumberland County, Pennsylvania, in Plan Book 47, Page 52, and more par.ticular.ly described as f cl low, BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lot Nos. 141 and 142, as shown on the afor.ement:ioned Subdivision Plan; thence along same North 79 degrees 54 minutes 56 seconds Fast, a distance of 207.53 feet to a point; thence South 25 degrees lo' minutes 2 seconds West, a distance of 137.38 feet to a point at the dividing line bet=ween Lot Nos. 142 and 143; thence aicng ame North 79 degrees 47 minutes 36 seconds West:, a distance of 1.48.10 feet to a point; thence along the rig:nt-of-way .Line of Honeysuckle Drive, by a curve to the .lent, having a radius of 175.0 feet, an arc distance of E1.98 feet with a cord bearinc: North 16 degrees 33 minutes 17 seconds West, zr cord distance of 233.39 feet to the point: and Place of BEGINNING. BEING I,ot No. 1.42 on the aforementioned Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company,. CON'TAIi!ING 16,008 square feet., more or less. UNDER F,ND SUBJECT t a sanitary and storm sewer easement, other easements, set back 1_nes end conditions as shown on the aforernenti_oned Final Subdivision Plan and restrictions anal conditions as set forth in the Declaration of Wynnewood West Develolment Company that is recorded in Cumberland CoL.nty Miscellaneous Book 308, Page 2C E. TITLE TO SAID PREMISES IS VESTED IN Randall K. Dorman and Christine P. Dorman, husband and wife, by Deed frorri Chanh Trung Nguyen and Thanh Trang Nguyen, husband and wife, dated 10/12/2001, recorded 11/01/2001, in Deed Book 249, page 140. PREMISES BEIr(G: 27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050 PARCEL # 38-21 •-0289-142 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4344 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff (s) From RANDALL K. DORMAN & CHRISTINE P. DORMAN (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 $204,189.47 L.L. $.50 Interest from 9/20/07 to 3/05/08 - (per diem - $33.57) -- $5,606.19 and Costs Atty's Comm Atty Paid $172.60 Plaintiff Paid Date: 9/26/07 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs $2,211.50 s Curtis R. Long, Prothono By: p Deputy Name DANIEL G. SCHMIEG, ESQUIRE Address: PHELAN HALLINAN &SCHMIEG, LLP ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F KENNEDY BLVD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Real Estate Sale # OS On October 29, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as 27 Honeysuckle Drive, Mechanicsburg, more fully described on Exhibit "A" G filed with this writ and by this reference .. incorporated herein. "~ax~ Date: October 29, 2007 By: ~ ~~, t Real Estate ~rgeant ~'he Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~he~latriot•Neu-s NOw you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /30/08 o2/osros 02/13108 n Notary Public of February, 2008 A.D. COMMONWEAL s i~ (`= rr a a,=•~Y~ ~A"~'1 Note a. , ___.~ City OFHamet~ur° ~'; !i1 t;nunty My CgrxrNSS~= •^~a. 26, 2011 Member, Pennsart~sa~.,. , ,, , °=,~a~`~rr of Notaries i~lEAt. E$'TATE SALE NO. S 1M~1>1rs Kan Prsn M, htwc. YS lResdall IC. Dorm~sn and Cht P. Daen~ At6ornsy U~el St~unlsg ALL THAT. CERTAIN tract or parcel of land and premises, situate, lying and being in the Towns)gp of Silver Spring. in the County of Cumberland and Commonwealth , of Pem>sylvattia; as set forth on a £~mal Subdivision Plan for Mn~etry Crossing, Section Two, Wynnewaod_ West Devetoptnent Company, as PAY Gaimett Fleming Civil Engineers, Ltc., and`recaded in the Recorder of Deeds Office of C~btshmd County, Pennsylvania, in Plan Book 47, Page 52, and more particularly described as follows: B~ at a point on theright-0f-way line of HoneyBadde ire at ~ drviding hne between Lot Nos. 141 and 142, as shown on the aforemenrio6Kd Subdivision PLnr; thence along same North 79 degrees 54 minwes 56 seconds East, a distacee of 201.53 feet. to a poi th~ce South 25 degrees l6'ms 2 secaads West, a distance of 137 38 feet ~ a poiffi at the dividing line between Lot 13os. 142 and 143; thence along. same Nc~vli 79 des 47 minutes 36 seconds West, a distance of 148.10 feet to a point, thetx:e along the rigln-vf-way lip of Honeysodde Drive, by a curve to the left, havigg a radios of 175.0 feet, an arc distance of 61.98 fed with a cord bearing'Notdi 16 degrees 33 minutes 17 seconds West, a cord distance of 233.39 feet to the point and Place of BEGINNING. BEING Lot No. 142 on d-e aforementioned Final Subdivision Plan far Mulberry Crossing, Section 1vro, Wyrmeuraod Wei Development ~p~ 1~~ s~ feet, ire ~ less. ib a samlaty and storm sewei easnmest, other ea~ments, setback lines and Conditions as shown on the aforementioned Final Sutidivicion Plan and restrictions and conditions as act forth is the DecluaEion of Wymewood VYat Davetapmeat Comp~}r that is recordod in Cumberland C Misodlar+eaps Book 30~, Page 206. TD SAID'PIREfdISES I5 VESTID IN Randall K: Dorman and Christine P. Dorman, husband and wife, by Deed from Chanh Tnmg Auyen and Thtmh Ttaag Ngul~ee, husband and damd 16t121200t, reooidod I 1/01!2001, in Deed Beak 249, page 140. PRENIISES BEING: 27 HONEYSUCKLE DRIVE, MECHANICSBURG, PA 17050 PARCEL tk 38 21-0289-142 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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: January 25, February 1 and February 8, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Coyne, SWORN TO AND SUBSCRIBED before me this 8 day of _ February, 2008 Notary ' ?a~~TARIAI SEAL DEBGRAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNN My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 5 Writ No. 2007-4344 Civil Wells Fargo Financial Pennsylvania, Inc. vs. Randall K. Dorman and Christine P. Dorman Atty.: Daniel Schmieg DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situ- ate, lying and being in the Township of Silver Spring in the County of Cumberland and Commonwealth of Pennsylvania, as set forth on a Final Subdivision Plan for Mulberry Cross- ing, Section Two, Wynnewood West Development Company, as prepared by Gannett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 47, Page 52, and more particularly described as follows: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lot Nos. 141 and 142, as shown on the aforementioned Subdivision Plan; thence along same North 79 degrees 54 minutes 56 seconds East, a distance of 207.53 feet to a point; thence South 25 degrees 16 minutes 2 seconds West, a distance of 137.38 feet to a point at the divid- ing line between Lot Nos. 142 and 143; thence along same North 79 degrees 47 minutes 36 seconds West, a distance of 148.10 feet to a point; thence along the right-of-way line of Honeysuckle Drive, by a curve to the left, having a radius of 175.0 feet, an arc distance of 61.98 feet with a cord bearing North 16 degrees, 33 minutes 17 seconds West, a cord distance of 233.39 feet to the point and Place of BEGINNING. BEING Lot No. 142 on the afore- mentioned Final Subdivision Plan for Mulberry Crossing, Section Two, Wynnewood West Development Company. CONTAINING 16,008 square feet, more or less. UNDER AND SUBJECT to a sanitary and storm sewer easement, other easements, set back lines and conditions as shown on the aforementioned Final Subdivision Plan and restrictions and condi- tions as set forth. in the Declaration of Wynnewood West Development Company that is recorded in Cum- berland County Miscellaneous Book 308, Page 206. TITLE TO SAID PREMISES IS VESTED IN Randall K. Dorman and Christine P. Dorman, husband and wife, by Deed from Chanh Trung Nguyen and Thanh Trang Nguyen, husband and wife, dated 10/ 12 / 2001, recorded 11 / O 1 / 2001, in Deed Book 249, page 140. PREMISES BEING: 27 HONEY- SUCKLE DRIVE, MECHANICSBURG, nn i ^~ncn