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HomeMy WebLinkAbout07-4967SHAPIRO & KREISMAN, LLC BY: CHRISTOPER A. DENARDO, ESQUIIZE, ATTORNEY LD. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIRE, ATTORNEY LD. N0.81747 LAUREN R. TABAS, ESQ., ATTORNEY I.D. N0.93337 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.07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler aka Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY COMPLAINT -CIVIL ACTION MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH 1N 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 OllT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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. NOTICIA LE HAN 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 PARR 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 PARR 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 LD. NO. 78447 DANIELLE BOYLE-EBERSOLE, ESQUIItE, ATTORNEY I.D. NO. 81747 LAUREN R. TABAS, ESQ., ATTORNEY I.D. N0.93337 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 N0.07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler aka Robert D. Geiler, Jr 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Wells Fargo Bank, N.A., the address of which is, l Home Campus Drive Des Moines, Iowa 50328, brings this action of mortgage foreclosure upon the following cause of action: 1. (a) Parties to Mort~a~e: Mortaa~ee: Mortgage Electronic Registration Systems, Inc. as nominee for First Magnus Financial Corporation Mort~a or(s): Robert D. Geiler and Lisa L. Geiler (b) Date of Mort~a~e: May 14, 2003 (c) Place and Date of Record of Mort a e: Recorder of Deeds Cumberland County Mortgage Book 1814 Page 1602 Date: May 30, 2003 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) Assi ents: Assignor: Mortgage Electronic Registration Systems, Inc. as nominee for First Magnus Financial Corporation Assignee: Wells Fargo Bank, N.A. Date of Assignment: As Recorded Recording Date: 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 111 Media Ao~ad, Carlisle, Pa 17013 and is more specifically described as attached as part of Exhibit 4. The name and mailing address of each Defendant is: Robert D. Geiler aka Robert D. Geiler, Jr., 111 Media Road, Carlisle, PA 17013; Lisa L. Geiler, 111 Media Road, 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 April 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 August 16, 2007: Principal of Mortgage debt due and unpaid Interest currently due and owing at 6% per annum $92,085.56 calculated from March 1, 2007 at $15.14 each day Late Charge of $33.38 per month assessed on the 16th of each $2,558.16 month from April 16, 2007 to August 16, 2007, (5 Months) Escrow Balance (Credit to Defendant) $166.90 Suspense/Unapplied Balance ($485.04) Title Search/Report Fees ($196.27) Attorneys' Fees and Costs $250.00 T A $4,604.27 $98,983.58 8. Interest accrues at a per diem rate of 15.14 each day after August 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 Mortgage. 9. The attorneys' fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs sale. If the Mortgage is reinstated prior to the sale, reasonable attorneys' fees will be charged based on work actually performed. 10. The original principal balance of the Mortgage exceeds Fifty Thousand Dollars ($50,000.00). Accordingly, Notice of Intention to Foreclose pursuant to 41 P.S. § 403 is not required. 11. The Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. § 1707-1715z-18). Accordingly, the Homeowners' Emergency Assistance Act of 1983, 35 P.S. § 1680.402c is not applicable. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in paragraphs 7 and 8, together with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Mortgage and for the foreclosure and sale of the mortgaged premises. Date: BY: S & K File No. 07-29771 SHAPIRO & KREISMAN, LLC a~i~ i~ pn°~RT ~, IlfiC1EP, Y(uUmt Ill: fiRS7 kIAGMUS FINANCIAL rpRP., dba OFIARTEt1 FUNDING S2B4 E. W!!1lAM CIRCLiti a'20d6 ruc3ora, Air a5T77 1'encet tantsber. LOAN NOa 2718006751 INIERS Phonor 7~888.87Syt?777 ~' +Ue'N 7kle Wo: tee EuYdad DWj- (`nrn+rrm.,-, /rL pt F.4t~q~rl~ ~~(r~~•y+~+~1 p F A ~t1 0. =•+LJ1~,11J1y~~,, <47.7737840.703 ~TFitS MORTCRCB (•Saadryll~wume,t^) b ~Ivesl oa Tlt• MOf[~tyo[ It NµY 1 /, x6r~3 ROdFR7 U. GEILER ANi3 t:BA L GEII!•7a, I~U5QA(,p An•D ~y~ {"6arrower"7. 7'llly Srcud(y Irutrucreat it Etvee to Martgare Eiectraalt: P,o~slta@ne tiytt:mt, fn,:. `^ Cepna. hlE,RS is e~ NreQ and ~~tl' ~' herebc~yd~i~ed, aad Lender a suar~suro 1md asaipnvJ. a,, mon ui un6er dIe Paws of aefsttare. anB !ur oe canter alP.o. Sex x ~ZO. FUaI, Mi 48YDI•Etr/b, rsl. {eei} ,n•4.~, uld+s~s urti t.lnphoec FIRST !MGNUS FINANCIA: CORPORItTIOM, AN ARQONA CORPOIiIUTIUIV l" Ln+der9 k erEvllud twd ~ under the wti'n et lat an eddreu p1 e2ed EAST iklltiAGiS CIRCLE, SUITE 2L+06, 7UC30N, ~ 7 ; •'~, NINE7Y SEVEN ruDUSANn oN6 HaIaaREG TFtIkTY frvC krae taat6D a x~x a`~'~~~"~p~ ~~, nr Ool}an (G,S. i aT,136.6C i 71$A ro,.rhal„ 3[met„R.:an LU"aF • aliYt + Vt~lPiktAlf ru»; nnaa~ U ~w.+rK ui+otewreRr:rrrtvsn.•..x~G~;~r~elvtnror, Exhibi+"A" aisis~4PG16O2 "A" +idir~x~ 'flits debt 1s et93enc:d by 13omotaer's aatc dated the xme dxe by this 5sa+riry tnsaumeW (',Vote'), wNett provtdea far tanatlily payttwats, wttb Use full debt, tt aot paid eulter, duo snd pryiic oa lUr1E 01, 1033 .7hts Seat-ity Cnstrumaat sesvast to Lander: (s) fho teyayuunt of Use dohs vvld+ua:d by Use Nara, tvlth tniuxsr. and atl rerwwats, mAerubM ned owdttknuonr bf d!a Notr, (b} the pr~ruwu of alt otbar wau. tvitb tnteta~t, advanced nader panaraph 7 a protace Ne satvdtg of Ihts Beauty Iracrwneet; and (c) Ux ptufirtmmce of Borrower's eovestaniy sRd a6~@cpd ~~ tbls Scarify InitMaeot sad Use Nota. Far ttds purpou, 8arowar does AtrtUy man=age, eraut atd svav,.y fo iL~RS (sok(y m twmtuoa Iur l.atdh and Leach's auea~mrs and wsit~lt} and to iea 9atTesW: sod wlsos of MFRS, the tailowtnC described ptop.ry logfad to cUM$ER1ANtt cauuy, Pennaylw~da: A4AkT1CULARLY OESCRf0E6 IAN ptH19~tTr^~it' A~'f'rA~tJkE7 NER T&0 ~~ M ~ D A~p HER80i. tvtucb has Lte addtesy o[ 111 MEbIA hoAD (5treeti cR~usts: (Gtry) , Poaarylvanta ~ »u (ztp coda} {'Ymparty Adieu`}; •TOCirI7iHti UVLTH eU dra Itopctrvcfacrts aaw a Leto>iter traetad an Ilia propefty, and at! assama~N, eppwieaances and !!fi'rYe. tww dr bsrestucr a pan o[ Uia pmparty. Alt repl,cuucau aad addidoaa s6aU. atu lx covered by dds Secuttry trtlrureaar. All of tba foregoing tt refnncd m b ddo Setutlty iRShuraost s Urc 'Property." Berrowcr nndesstartds sad agprs that MFRS }raids ordy tegM etle b sir btert+s'ts prantad by Borrosrar la lltlt Soaa'lty Iasla4tAenq but, !(neeoe~Jiy to eoas}tly w<~ taa~ or cuaWro, NtERS, (as fwrntnea for ieodx and I.fadv's successors and assiero), itu du tight: m eserrisc eny or all of Utosa tnlctesfs, lacludlag, but t»t Ifatu.d to, dn: tight b brsclow and sell fbe Praputy, sad w~L xdon r*quhwt of Levdar inctudGfg. but not Bmttcd to. rcktsG~ or cenrrttng flits 5.~pity BORFtg1M1QeA CO~BNANTS lfiat Banower k laWCiT1y nelaad at Uu estate 1w~eby eaovaytd end bw $a b gteetgal'e. t;~ aed coney the Ptoper(y and dtat the PtopetRy k uaataunbtred, except [rx errafm6taaces of rocoztl. e:rtrower ~fraatts and kiB detnad Ftnoraliy the tide m slit Ptapetry apaist al! cizlrm and detosrls, subJact b aoY entxttaka'atteas of tacos,!. THIS St:t:UR1TY [NSTRCI-.[PNT eottdfliSec us(foem cavaaanis for naUanai use and nou•rm:fatm covenants with Itmtrod vati3Uocs bybttisdteeloe a aositttufe a fstdfwm atasily tastmmant rave:tnp rral property. YttR,4Np+A} to:ve }.t.ra rn yark~~~1+1 Ai{i814PG1o03 aorrcmtr+wd LeaEer wraaam and ague as lououa: U V3Ft}liM COYENaMS. i. Pttytaept of Prledpa4 IrttrteR sad [.ota Cbis' Cutovrar rhall buy caber. due tka {x4rclpal ol, au6 intrrast ae, lke dabs Mld<pcmd kY Ike Nok and lal- due nailer ~e Nair. soaaddy peyreent. tops cy Nwt ~ rho prleq~pr1 a~od ia~ ty s,t rronA inn uw Notr aaa aafbitte chacros. a ~m ~ G) ux~s and spoclst Ws>amenbt levkd ar b be lavNd apsuu Wa proper, (Id 4;~p~d psymenb or grmmd reMt! ea Uto Pup,lrty, and (c) pnatlams far Yot+raau roquireJ emdcr I>angnph 1. 1r. uy ,reu !A svklek tha Leudar duet pay a morl;agt YNUtteae pneolarn to ilk ScgaVry at doa4~ end Ucbaa Daelopmcat l`Seaafary•), or 4! any ytor !a which suck PRmluo, would hove bane ragaUad it Lends salt NW Ihs 5eruttq Ytetstaatau, cads moodily payment shall ahn ka3nda altbar, a sum fiv Vie nanoel ntottgate ha:rsau pamlup m D. pt{d by Grodcl f, the SatroUry, ar (t!) a acoathiyOdurge taaksd er a tnmppe taturaaaa peeatk:m u dds SrauYty Utaantment a urea by dw Su:npay, to a raassnoWc eaaouel le bt detanabod k9 tka 5aeretsry. 8xeaft for the awndrty tSuga by the Scat4rY, thcrr hems are esCod "Escranv irums• sad uK a>QU pdd b Lemb.K an eenad "Eserovr Cvark,' Laada day, at oar tlmt, enuect and Gold amowxs lor?urow floras m as suretafc amoant eot ro SelMlatatt PtaNdurrs Atti7'4.~ '.9 ~~ ~ Botroaer'a u~°1° servant under de Real Ertate Pact 3San, rs tAty nsq 6t zaeadad tram time b data C~A~axlatpicaps ua~ibe a~u~tla~i pr reserro petdltWd by 1t'ESPA for thtaadrllmtnd dlsbutsamealr a dlsbaseateots bofore tke SatroKVrn:~apymea4 sre ovau~.~ia~~aon~-~dmSaytatd~er ~ PsaosvUeaisb e~xoaed the ~ is Panalckd ~natd~by Rh~FA. j,aadm aball accourd to BoraoWer for the excats fmads n ngwred py RFSPA. V the aatoaeu al buds bold by Lmdor at any tlma asc act sal$dae to fay rho Eaera-v hams whoa due, radar esy +>attfy tha g~~rEaiC ro F~undesortow ~m ta+du o the shartaga a Putvtcond EY R.~,SPA. if Borrowtr hodera m Lenda~ ~~ ad~tiawd ~tttty !or aU cams acwred by dJs Seacrtry Ira6yma~, the haloes rataalntag tar ail lture!!m nil, of au sack amss, uaa°wa sareaum rluU bo cn~ad with lawdhnett ttxl lead:: tas not bea:me oMl 1od ~ ' N1. cad (c3 and say ttartgsgc lnaumtsa pn:tnlam 'dY exreaa tiwds m Burrower. luuoEdiat ~ PsY m ~ ~~~' ~ Candor sbsg pramjnly tsfund Leads. Bomwa's aeeouat shall be aedlt~ed w h oar btiaace reaainiag for o<f fla Wrytaurts fo aerial ), (bl, sad (rJ. 7, AppSaRtam of 1'ey'atnta, All poyueats under paregtepla 1 ad : sbaU he applied by Leadrr es fouows: ~, m Vu mctfp~e Iesunnrs premium io be paid by (.order m dw Seaerary or to due rnoathiy chunae by ate Saaatsry httacad of 1ba maath>f• soortgego butrltnce premium: ,bpd, to any tmea. spcetsl nsae»maau, iararabald pay~tma or gmaad routs, end :ua, 1:oui sad ednr heart! ltereraaee pretnhrats, u svqulrod; ~{~, to lruerett duo aadar the Note; E4IITth. t7 a<tordrntloa of the. ntltcipA of ilte Wvte; and to Vsr ehtrgro due ruder the Nvte. bra, Flaai ttas t3tbrr lltt:aart lIItarr{my Borrower shay kaure alt Improwaueb ot: die waunycnUashs gegrdlrE P.lie, r1~hoLonmdsr~rs4u~w lu~ ~e~ u~w a~ha~l~eeAm tna~tu~an,a ~s-w $I!l$14PG15G4 Pm nano ani tar tha p ~ ~ a ~~ nQ~ts. Borrw~rrr shalt aIH, tart~te sIl LmpraRq~tt ao thr ptny, whether now !A try' tho &trWtp• A]l k~uraa6r a6tU be rarrka tisethrc~ora~ettnal las by flor>d: b tYa CX1C,n ngWrod pouriei rsd any eenra,rts rTalt D! kdd D • ~'~ epprosrd i+Y Lender. Tht (rts;,ran:e r fnrrn axtptrtde tr, Sander. 3 LerMlr en,i eritq k,etvda loo prya6lu cLmrxr Jo favor Ja Uu cvt,u of tc~r, Banrower rhrlf ~ ~ 14 loss U aot wade promyUy b]' Dorrvw~ p~~~~ttte notice hY uw,t. I.tadet ~u~ Nvof Or d[rected b asrla payratat far>~ lerr dkect~y to LWdCr,c~,t+aY Mnrarrwut to Bare AN a< bi' O~tbacl;red ud Rtbocdo~f me fade, a ~ L}Ir ~ ~d olrr Bairowe~od, el~d(0.1 w~t~e 6y u'++der, al tb o aPtt>sed Io tha aster to prraBraph S, atd flea m lY ~~ dnt b airy dr>hulueat arttrunt. duo drte afaj du erw ~ iFP~cttlaa al lba p~dt to q,e~~~ ac (b) to tb. rogwatltn or rapdr W}ycerMe. ~' r'~1nAatttt wkkit tra eefarraA ro is ~~ rRtl! aat adeud or port thr rmde: the ~ excess lrtna>ece Jtroaeodr ever as ataormt 1"a9~6 a' ~d,tapr der taowu~ ~ Note aad lUia Sarort ~ rtgtttttd b Lq oDtedseu In +6t treat of fa.odesa o e[ t~,^,~• sb 6a pdd td tbt tatl k~ lad tadd,bdnarr, atl N artry tosv ~ mtkhd iterate. tstlnpdat,ay din cwt w• y~,a r of tl8o to Wt lmperry tact 'boll F~ to the p;esha,tr, 6t,t tide atd Jraarest of Aonawar to and b larataiea polWrs in force ~pGeaO~o~7`r t?etervndon, Jrtt:[AICAraOe aa3 FiaaaatJrm or the Fro resldtac! tid ~ry~ ~ ~t~ extcutfaca~ecihls ~~ end ~a dx Ptaperip dncoaar~i pdt rip~'d ad! o; trtanfer of the Peopary} ~ ~p caaetnue~autty ittrtroatent (or t~itWn residtac! far at Iemi one year rfter tfre den of OtleaFY the P ~'~ or a fatu prW uadat t+opettY >9 Bonnwtr'a Pdacigri banttdtP for 6orraaror, err ~°p°°~' amass Lender due,raya ffut raasttatwt sutll Borrawvrs tbatrol, 'b11fY Leaner at~y lhCnastbacas tatutok vgt4 err fife Batratt'ar s6sdl y +atann tl `~ '~~ ~ tiayond rouaeahle wlar,rM ~~ez~kd Ltt~id~r~au~Yda,tte dsa TropurgrUK ~~ ccel.~tBd+eou't~ ~on~ err iht toter tr !a tfeftult. 1.ar,d+r taa y 1nTiatCt the Proppty tf mr Propmy it gtisf or abatabned atn,adtmad Propetry. 13orrgw~ akafl airye bt ~~ralhle acdoa to prattst aad Prnorva wch vacytin or no ta7tarially 6f:c or uucamla dae a,~zt>w~ub b [~a~ dartna tha Porn aPP~t~onr~dpracacr, ~Y ntrltrtrl ~cutt~tlntlu8 crrewer~oo h~ Ob later trtdtnxd by !Vo Ncu 4RIciS hul~aot liedtrdsb, +'eprt5ea-gtfom uyrtney of the Pre re tle ~c fs as e~ u J~+rehoJd anrJ~fJcr UUt snaJ'~cot ~ Waro of shame tea eall8naowsrx~„tt~ to Yrtitlr~ ~ Frn rnerltd un4ss Lender rFroes b, Wt ruarder coaneelian wl ndea+aado~a err atltaer ult+awaluf Qom, !or damaNm. dtr.t, or corwxluetatal, in al tbttdatu,atlOn, are katahy aalgnut cnd SbaU b. ~~ ~ n of tk! Fropury, err for twdvtysnce kt puce ~t`d0`sr Otat nnt~rs! ++eptid awdsr tbo Notr rPid ~~ b tl,t ateat of tkt full tmoual al the Ptoaeeda to Ott uodueaoa of dm trdthtedatsti ~ 5etun~}r 7aaatatw, Leader ahrtl appty wstt tWtrquaat atucuntr ~ u tt,a ceder '~ t4t Nae and dtb 6ecodry Jastruu+eat tiro la as Ptlyments, wht i a~tt:Grred b m~ ~ d~m~q~ v ~pathea to ~ Feyarat of pdactprl, PmtnaS aver an PmEt~pk 2. or tlua`o d,e aa+catec or sub ` detr of th! uwatNy Iro',ei,mtnt stud( W d w ~ eau ~ WY a[l auutaadio~ tadehttdrusa urtdar u,t Payments. An+ tttettt ~ i~UY cattded lh~to. host aced tb+r Satwtty vrewe,;r•~t pro,, r~ r a,o owe~,~~f~ ~N18i4PG1605 7. Cheroot m Bcrrox,r sad Pratocdao at LgSdet't ~l,gbtr la flu Propcsiy. Harrower chap pay a!1 Favtraamnte! ar mualapgl charges, llo,u tad lapositloen that ere reef Lrdudtd kr ~ Poi' lbasa aDtlgstlonc as tla-a divat(y to Ure nU ~~~ ~ fJgh+c~t >a pDy>aroald ~Ce d~v tdlku Lwder'e bttreert b ~ prDPa-ry. upat Ltndv c tveq,HSt lionrowar abaft Tuvurpuy byoLsb sdpb evidttclag tbece pymeats, NBo:towa folk to racks >~ p+yrrMHa ru• rhr payraeafr nAutrld try P~"~R'sPh 7. or tlaL- b pariurrn ash other coveaaalt sad agnalaaao osabbs.:d b tbts Sen's!Y Imtrumant, or them is a feg8 pmceedtng coedestnetl ~ w~ (arm liw~s d~ n rti;bu !n the Proptrri+ (sucA d a praeedta8 in banknptey. fa jvlallvas), dr+e Ltadu tray da tsd pay wAatevu (s ne~ZStsry w prokd the value of Ibe ptoppCJ rid Lxrrder'a rsgLm is Urr Pmprrty, lacTadleg payment of taxes, hazard iwvraar:a end other teems ramtloard is ptrepaph 2. Arty ramaata dhbtttsed by Lnadu rwbsr this F~Cr+ph s>rxlt ~e ~ sddlthsaal dFbt o! Eolruw.r end ~ taycttrad by Ws Sancrtfy itatrumeot. T7ww amoaats .hall hear lottrest foam IAa date of dtcbrrstaamt, ee rite Nets veto, ford et t5a optlos a! Candor. sAall M lmmtdtete(i floe tad~rgabble. eartowtr slop promptly dltdorge arty lien K'fikD 3a Datrowers W ~~ la vNtdng tv 16t m rrt t6t o tlo~~ e~x ~ &ntritr imbtrtrlmt udess ro Lerdtt; (bj tzamsa >n goad fettb Um~ Lm hugs nwnd by tlx oat Ur a eeaaaer eeeepnble Ptaatdiogc wGlcb !o ~ t~utdee'e o by, ar deWds aphl>A eafovctmsnt of the Uat ln, IeYa! from du balder of the ilea sn eL'ir~mca~lheklom ~~ rho ar-tbtaeetenc of fire elan: ur (c1 aeeotes Lauamtent. tf Leader dahsadltas t6st rY io I.uslet' tuborriinetlsy the ba m tltls Secartty aver lids SetuNty Gu4amrtit. LtrldsralrY Itm of Ure property b cp[~,scs W a Hee white may ettelrt priority atW/gibe Has or take ou ar ~ plvt Homes a aoilct tdan!!li+Ing Ore Bea. Borrower shale >~ of tb. xitars rat lords tbovr vrltltia ill deyv oClhe ghing of aodce. s. Faro. Landrr wy eolTect (ces tad c5erxrc tuthurlud by tAe Secretary, 0. Croondslor Aocekzatiswatlaebt, (a? bafaah. Leader may, exeepl as 1latitcd by rejuhtluas issued by the 9atremrf, !a tie tortes a! 1>Ryraam defaults, totpsles bourldlara pawm„et in fun of all sorts steered by Ws Sci~lrvty Insttrauat iL (tl >iatto~sr dtfttrTts br terAag b pay m roll stn' mantbiy peymeat r.qulnd ey tide Sears Gnhumtat prior to a to the doe date of tit saR mo>tWy ~r~, ~ ~' Nj iZarrnuWr ddtaltr by lYiUal, for a period aClNlrry Jaya. b perform say odwr oldigauoac codbbred <Q Ws Smuttyl*cttament Ibj Ssls Wttbotll Crodlt Apps:tn~rl. Leader shell, Q ptrmlttad by app4wbbs Iuw Mduding Sealoa 3C3(tq of Ike Graa•3C Gtrrosdsr 17Fpostlary instltutlom Art o! tosz, ;x U.S.C. ~~` b Urb ~ °~°~ et the Slattery, rngttlto bwa>rdiua ptymeu is fide of ap U? All or part of th. ~ issenrascal Ifi Property, or s 6:oeddol late,•est >n a hull owaing tAl or part of tee Property. it sold arabntsrise trasrfarred (aUrer Urea hydevtw er dae:sad, and Nj The Peopony b rwt acdepird by the ptrehescr or cntea as Al+ or ha Ph~r1 rasideace, or the ptrehu+p or ~ro ~ ~ °~' >aa Pro ~, but hit or Ircr crcdk haz sot brut approved !a aaeotdertea :Htb the regtdraueats of uto °rxsvtuy. (tj Ya Wolyq, if dreuautaice~ occur thri sroald pemth Larder ip rvgnlre tronrdlatr pziaaent !n Rdl. 6nrrroLeaden~oes not requJte suds payfieay. Leader dons twt wdve I~ rightr wllh respeec w vaa.snfla,~l romrr r.a,suse ".car BKi8i4PG1606 !d) AtBnlahovt o[ ~ Senecasa ot~Y a+ctmvraaeea reg,tetivw isurd 6y the 5etxstuy suet im11 teodtr'e ~ payment daudtr, b and forecinse U oat putd ltte Seatrity Iastrameat deer oa ~~ ax-lrbm~Uoa v~ecioottr. U "a >10tnuad by t+eynladou of the Setrtmry. (~ JsFttrryap, Nor 7aauiod, Eosrotrec t~s+tu eut if tWs Suety baaument and ere Nate ue trot alstermlaed to be dtIIfhie for bswreau wader tLe Netimd Hataleg Acc eiltlla ea days from ere ddc kenaL leader bay.:t to t>pfloa. trtitdte itnmedltta Wyroeu fa fort of all sttara eaatrctt by tbls Seeattty txiratr..et A Wcttba slets'meo! or am aul(wdtod sherd of the Secretary tkNed subsegaent is 6Q days float wo dew fernot, dadLdaP to Inmre Uds Se~,ity laskumeat eml the Note, stall be deem( txradtuice pxoof of saa9- IRe4pjblllq, Natwkbs>a~lnp the fore~aa. rids oPUaa may trot bo exeedsed hY l.esulu wLen dte aaeVdlab!$ry ot` Laurynte !s salary due ra I.ettder•a fallttro to remit a rsartpre latutana ptrmitwt to tlu Secteley, !a. xmannatn.ar, Dot wvtr~r bas a rt~tt b Lt refigtetsd U Lettda Las ruqulreJ tnraediete Iuymue la Wit baar+st oiBAetasrer~s payea etuot~,t dtu onda tha Nate or thin Senulty IasBvmeat. SWs ~not~ah~ ~~+'atore~cla=tara praar~aps a-e lattlfakd. to oebrrade the Seaairy Iroaanrent. t6 die esUnd lkey are obllzollaets of Sorrdever regatred ~ bstoj 8otroaer's account aurMt tatJudiaY, neseaable wad eratotar•,y ugtaeya' k~ wad ttsMer ttia Seatslry Lnl+umwt. fvractomre casts wad Upsa ryrotateoseuc by ~otrer, this ~ Pr°Pu1Y essot9atad uitb tiro tarodesvtr Ataeadlap. to etrct u e Leader trod not re ~ ~ lrrsnwnsnt tml t&e obtlQatkas shst !t aanutss shat! rarsuto t~rmlt ceLumtemom >t (8 i.essdesR~ bts tmmet9aH >~ut !a Coil, Htraever, Larder b Trot tsgulrad b P+ont~inJia ~~ teao pled nwutebait al(er CSe wt>w~teaceateat of fan4osue Prau. (W xNrolet+m m~ar~~Y Pnadlo$ We camttlsaamtat of a current torsctorare nitrsatetaeec tidlt aavorcety etretx flee D~tttxbtry ol~taa ~ am dlSeraot Brawate m ere r,..•„,,, nr (at7 IL dorrOteet Not Rdtteaed; Aorbenraace By lxdet 1~'o~t a Waivec.~catetWvu of Ihs Ytne of payn;erl or taotUtlatWa otaawttltabgt of the suate seettswlby reds Sewslryloswwent tbreated by I.radar m m+Y aunusaar•!a lgletsst of 8atso~rshait nei opets4 to tsLgt:e rho Uebltlry of ttu oripttwt Hurruweror Do~rotver's sueeesser In mtstesr, Leader slwll euu bo regatred -o cattgseac~e P+rott~pK Esc nay eecrrsd 6y dda S eay{ry froanmaat y reaba army demand ~ by t1r o~ eBnmower os Danaswer s wcrxssars iR fewest. pt{y turbe:r;ace by teadcr !a eytrdsiaC ~Y ligld ar rsawdy sfudl not br r teatvcr a! or ptedude d-e oxerdeo of aoy rtsid ar reaxdy. t2, Stwersaare and Aeatgaa Found; ]Drat and Sesocal Liab edreataeau at dtb Soattiry Fastsnotent stall bled end berteQt Ufa ~ 71 Co.6lgatrc 'I'tYe m+restents trod Boztower, sabjecl b tie Pmvblaea of pstagreph DibJ. 8ortotttr's wt!eaao nab ~ d ~~ of [yeulu asd and ee•Krat. ti7 Borrower vrhv coyip~tr this Satxui!/ lattrumeot twt dues alt ro dissNote~( Jits Ptn ~~ tlds &wrliy Ittstrtsmsot oNy to rttortpeye. gnat end esavey that 6oeroux.:'s latr:t+est fn thr i~+t3' +~ the terms of tole &tarlty*ltattuttteat (b) b not peraarep igetel b ptty thF saau aecurdl b I!b 5avd(71r~ucoaat; end (c) eB~ Ihiq LtmAtr and my eydrerNBorra'un- tt:~y ~ ra os;tond, modify, rarbeer or taalu nay eccrmmodatJaas wh8 tepatd W the t++ats of this 5ewrlry Iet'muatent or Uc NoW Kithnut nut ilotmtoa•'e consent, YMP~.tN{r~lJ +amr wr ~a to "~ sx~eE4FC«o~ la. l•]atite,t Any nvtlce ~ Borrower pmvidrd tar t4 fhb Securib lnstctanast shill !se gtYen by 6dirati~ t! or by tnaUing U uy ~ dasa to4!! ttrdeia tppUranla law rrqulrss use of memo- rneU;ud The notice rid! be drrrctad to the hv{~, Addrrat or aay offer addrera lian~ewor ties! rotes Lw,d.r. Mty noUee W Laadar sltatl >:e givan 6y Qrst asst map m Ceada ~ add-tss us,e6 nr~retan or a„y add,an Le,t;lar drsl~tatst Cy aalu ro'la:vtvrr. A»y aoilu pcnvidid for la iris Secudy Lt7trvaarnt shell tie d' lcerdcd t ~ vt b L~~;a b B4rrawor ar Lmdet wkea girur es provided is d5s puegryth. thS laW Of 16e ~ •5?lOr4Jl~n' f• ~Iit sQgnlrj 24f4pn1Cat i~iAll tfa gOYelDed b}t hOdOr12 tiW Ylld ~,utsdletba le tv)delr tie Pmparry k hanky 1a fke eVeat fiat wY proslrloa of rla,trr of t'Mr swarrtty laatnurreu nr du Nnln ranflrela taxi •t?lteeblF 4sr, wt:'t eentOat shill ra nffrca vtk+~r tu'rvktaaa ut'dds 5enaip+&aharnrnt or 14a Not: wnirh ao be gosmr sAaet wlfhotn tae ea,tSlstlag ptnvblvn, Ta tiro end rho ytnvlstoat of fhb S•carlry InaOumnar trod tna Sou rue dutiarad tv be srrett:.hk. lostruteeM.m mrat'o Copy. Borr>twer fba4i bs givep one a-aftntsad Dopy of d:e !Vote and of tlds Seourly 16. iit~dbttr 23ubstaarara, Bottotnt ataU sW rstaa or l'ar7ok the prrseace, uu:, or Rieaat at ~' K ~~ny ~e~es on or Jn rho Pmparr~. gwsyw~ y}~i ,wt du, aa~r~ K ~ e etse to 30, an g parr rfaE ~ la vlv2sUva of ocr F.aviroetmeaml Ls++v. Thy. pnsecdtng IKV seaisnrea shall aat vppty b Ae (ROStH,cr, use, or s,aabvt Ott Iha Property of rr4eO gttantlllea a! Has>trdous Satutaa4n that ttro i;anert;Ny racognbarJ tt be apprapriatt b norroa! rrridsr:Ual usa antt as trslokaaaeo of tbt Peopsrty, other ecaoo ~ al,4U promptly gh'e Lander wriite4 adlri ct4rtv ItnaUgalusa, cltlm, dtvuaod. lawruG or H,mrdoaaStrEatan~ugor~ namaaW Liv fwhre8~~ ~ ~iwte f» Nrclvla; the Proptny and any cr is ootlDed 6Y ab G'm'>tal or n gortettw'ba 4aWa! ka4wledgt. lt9carotvarlarro, H,asrdous Su6stepay~a~7' wtf,otity tint aey rcofovsl or adtcr romodWaoo of aoy rewedttd acaotu !n oc~a ~p~ ~yltt,~~ 'ry• Bor:vri+tr apol! Frpsnppy ~ au ~,• Aa .aNl rn •h,a Lj' rr. 'H•mu•r~us t:u3unneera die them sae.taa,rar deAard •.r taara e~ ~~°`t1° sttbt~tncra by +'or4naatsi 11-w Dad the t4Uowiag w~t„cm• aa~na, Yc„otnaa. atl,er A4aua4ble or mils petroldom p,cdr,atx, itcgr pustlchitz and het~ldtty, xafotUe snlvenL~, tenteri,t~ wntalnintr aabrstos or lotoo[dehyde, a4d radle~Uro maWrials, Iu used 1n drls peragraFb 1G. E4vG4nutee(4I Law" moans fMvrd laws ar>d laws ai the Jurisdl.~lt,a tahenr the Property is located that rslatr to hea)U,, safety cr enrira,oaenbl protecilaa. NOIV.LINIl:'OltM CgVBJQgIti'Tg, Batrowee and Lander !w'Iher eovtwml and 4grea as tolluw~: 21, ni6lpame~ at'As~le. Uemaws, ~or~kloaaUy aaslgnn 4ad Itts,.sferr to Landor all the rerC, and rew4nes of the Prnpeety, isortnwar oobattsu Leader or Lander': agtnts t4 wllou the rtr,ls and rt~en4rs had hareby direr5 mch ntwat of flu Pmpatty m pay du teats b Leader or tcadv's agenu. Hotrarer, TPmtrameat,ABetrea~ercida>< eollsc; add tecalre aU re~and t~vattues al a P.ro ~ ~ JQ Uu Secnriry batleBt o! Ladder tatd Sotreaot. Thb asaigotnat o) ~Qats ee~i,tks an absolute aui~ tmanti4dtoa n„ ~Carusat for additlvml astutltp only. 6'r+'awerasutees fa'ibeneAt~o! bender onip to(aL eap~li drb ithe rums ~ s~ ~~ ~,~,y lr~uua,tnc ro) Lendrr shill L•e v,udad m cuituct>na reaiva rdI of flee rents of U,e Yrnparty; rod (c} each vttr~rtp+!<) ~~, r.xt.~ w vey.~,,.(..1~! I~KIt3l4?G1~0~ want of tfrn Plaocrty shill pry all rods der and tatpeit to Ltndrr or Leruler's agar! as Iealrr't wHnia doanud to Utc t~tnot. Hamawer has t:o1 enewrcd aay pilot wstlntoatt ottlle rmtts aa6b,Iy av! amd tvHt no(prttare sm~ xt tltal rrOUtd pret'eat ltRdR ttatA rkenhhtg Itt Tubb rwder lhts I~CmPb t T. lnttkc Bali rW be tegnlred m mtvr upon, takt control al' ar Aadobta ibe propsrty berate or wirer gNtap aotlec of breath to Batrot+t~er. Hat~atw. Condor nr a J~H71 appo4+ttd roeattru way do w a: mq tiers two k e ia+aath, ,ray al~igttlan of roots tdtelt not Dora or coarse my defao[t or lev~tdate any otlur tiglu or remufy of lcndrr. ?Wt, malgaraant of earw o[ drr prcpt;rry ebdl larrahiatc wbra Ike debt Leaved by the 3a~.wily Lubument trp~d to ftd1. lei, 1<rOr4e10eur0 PsoCddars. V Candor Yngaue. bnaatdiatr poyasert in full 4ctte! paralprsph 9. Leader troy taraelow this Savrlty [tsstrntamt by jndt:§-1 prtrceadieg. Lwdtu tdlaU be asaitled to wlirct tall estpeest incurred is peraaiug iho rtmsttdiw protddsd la chit paragsrpb lt, iatd:sdiaA, but xot Lratitad fq ttlmrarire' lees ead aoets of tl13t t:Wdtrrct IY the I.rmdc~r fatetssE h- this t>uusit), Iastttimtatt L held by the tirt'etory snd the Soaeattuy fF~eita imtsediate ptq'amt sa lttH trader Puasrtrph 4, Orr SeatxtQy racy iavohc the aoq~adieiai pima' m' taair prentde~a m tea Stagto Ystatd Moryey NaroGaatue ~ at svKC Cnsa'1 tit U.S.C. 3751 u amy.) by rEgagtitlj a imneiptrue mnrmdadader ttttslgarttd ruder rho Aet ro caatmenoe ituerbatre trod ro reH for Property ae yyravtdod fo tho /kt. Ntrshlag tar t~ ptcad'atH wttmta Mali daprfoe ~ho~~~Se,stetsry of troy tigbir nahcrg3sC availsbk to s Leader aadu this tterabraph t8 ar step-eebl~tlet and rho ealete canvty~rlsrltp ~I unrrudnsit bespmo yo1 giber ae'dloeerlrrertCe, ieader dill d~ltc ~e end >atyy Wo Sanuiy lrourrtord totthnal ebar;a m Sortvwen Haaawar :Roar pey trp' rtrutdruan CWtr. 30. Wtuiettt ltortsnver, to tba taatatt patsnttlyd b!' apyllcsbte taw, castors aril nlaaus arty error ar detects In proceedings to enforce t~is 5ecnrity lrslrument, ead hereby HyliYes die bei>:.tit of any plesear or faturo lswe providlrrg tar stay aP exaaHaa, lxlent4M o[ tlmr, rxcrnptton from ntlarirrrl,;n4 Iety ead sate, and 6amrslmd rxemptttat 2L Rtlnriateueol Patnd. Hvrso~rm'r tlrae q ralnrGtte provldsr! in pa'aQntrh 10 shall exited to ono boor pilot is the caahrtetuetrrant rf blddhtg U a sbetUTs rolo ar other aria parsaant to dds Security [asltumaeL ~. ?wchase Maary MattHltfe, lf.ay aC the debt reamed by this Samrlry fnsirament b feat ro Harrower to ecgaln tltL to sba Properly, tlds t3eerusty Uuttumrrd><rall be r psrchese tacasy awr , G,5 23. taterat Rrta gRtr 7ndtprcnt. Barl+Divgr Agnes that tee fnWrrst tat6 payaEla otter a rJ~cttgrnenr L: enkr-d w tbo Nou or la ar arkaa a[ taortgsgo forectatura sbslt be Ihr rate paye6la cram grrz to time undat the !l`aL . ?h. Rides to this Ecet>xlry l~ttttateat If owe or tnotx rldeta are t^cotvttd by Rorrowor tuna rreoMed toEadttr with tlda Saatrity lestnrmen(. the oovwne; of uch web rid:r :Gall be taetttporw~i lnm card short ttruerld ead sappbuent Ibe cevenaals wad sgrremrrra of Ibis St~viry iuwtaeor u U die rWutsi :vote a part of 11th Secteip~ Irabitment. [Chedt eq,Hcabk box(es) j. AdJwtabte llik 1•ifdor d Gndemlalant Radar (~ Crotr~ing Fqutry RJder © Gradast:d Pyyn+ms Itkier ~ plamed Urit 1ktatop;ttoat Rlder (~ Aehr,Wlltstlaa [.wan FJdcr Othu(i) (:pacify) w~tfai qmn ry a x io rra. t~ BY,18i~°;i609 BY SfpIVINC. 9CCOW. Bnr:awrr naYyu artd marks a rda urioa waairpcd C7 dais 5aarrlry lravum.ar and ]n Bey ddcrG) a~asud dy Bamoasr and rccerdeA w&h G, Wlte~us: ~'~ -~~. Cs++rrrs E, ,~li~t/1 •wrwa ~~i~ r ~ ~ ~, L, o. •~ ------_.~(Ses!) ~~V~~ o~ Uwe. rSenl ) •Dars~p --'--'•'--^-M ~ brut) .it~ti~ ----~--- rSail) rSeoq •@xrar-r ~ -Ha~wu ydU'•1M(R11 piap p,r, ~ ~ a 8K4t3t4PL1610 C~atrrah+ tiRt;ddeaer I, '~ tha mrrea s e7~ of l~{ wlWin~mtned !1(a~~ , da hereGy ew1((v ttu{ P,a6 b P.O. Boz It1t6, Fitat, ?a1 sR,501-2926, Vutmrts raytwad Uvs 'u~ l 'u1 of i/}'L,,, c'~7© ~~ ~ "'--'b=---' A;an( pf~lonfegx ~+ c.T'~. ~onaaloxwpal.7x aF r~t+r>.sxrvn~,~ C~'e~.~.it~~rtxvp On this, titr /tfr~ Couary ~ uadersiirted a~ur. _ day of JYLli''y , a2r~ 3 RaeER7 p. GEti,EF AND U AYLD ~ . 6NoR me, Ua ~fsu adty graven) to >w tha persm(s) whs~ asroe(sj adrra txtheatbad to Ur rvithia ia:lromau ami ~E~- hY iafiJoa/they exacWtd the sstw fer the putpmw hentn aeabir~td. fN WflNESS VilF7G}tr'~F,1 yemtmlo xt my k,md aad af8aiol seal, M,I/ ComDast<tvn E.npIRS: uL v'~ ~ i~~ ~F `, ~'.~ ~~~'- :ir 1, ' ,yar,~t,si y ~ r ~li y (rw • ~. TItIC of OIiSCtr '~ -...• K' ~.~'~~' '"^~' 1 - V drWISS11 -~.~' «~ 1 ~'a~~bJ''+?~w0Vt0011110Ce6'1,' f_~rr,E+ol~arrast,Ptaa i Mampq PangM.ir+wo:~, y vuaan~i A.en hr to a w ~k~~~ 1 CLTrFi/ t y t ji5 t0 ~''~~ ~ r rlan~i rG h ~orded ~CCOrd rr u~~Lk4 ~~ISI~;PGI6l t ~Z~ lYi~ iT tob 0z 1'#oai af' gtu~m ef.tu,ati is 4.be llittb Nasdl of thr ffareu 3a o! <wes'll•la, Cv~b~elatod~ Catra'tyr 1Pinaeylviruts, 6vurtdsB •anEf ~sioas3~rs4 ~sr. ta+llrtu~ . at +~ pout ve. tf+s, l'outhas~lusn ooicnac erC ftsel3i .fluid, sA1 Yeia~ri.s++ >laudl tA«na..,lang !1!v lina vt• ra#tajyyr •Iduad iba~ $7 ds~svsi 3ti alnute~n leek tl'• ft~ri'tc 1~0 : t 8~ tlea' li'us • ar Lot. >Ac.. ?~ als th.: ttixiaai~. ~aitiani~d~ !loaf t~4s' aT~ tbs'liee ot, . sid:q' Lot • ~ Saa~p 78 tN,igsoae •lo' R#antsp •tfa~e Ob . lgeR td R ~+o~st1 tbaso4r alortq Lat 110. _$' as •si.[d plem, tloc!th a7 d~igraoi .30' lwvy.~^ 8s ~'vnt tot iu t><e lurid. of Nsrl3r f~qd f tlo~tae, ala~ig kba 'l..iwo °! dead 1ios~fr 2~ 7~e4SCSioc ,D ritrlgem~ ~Aik 100 last !-a.a' 3etb, tfii•ftil~o'of Hia~gitonl.wgf dnd l~eit~q #1ey~r~vr~ xit>z a 3 1/3 eeo~'~dwml.haus~s. ~eitli • a::trca3~~d' pm.~;agM, k~+eeao good mspbcse~ e-m 331 >rtad ltaaod. BRID'jrse~tiresa beot~ug Lat lto. ~!~ alauic •Cc o+r !b>4 lira o! ~milton ID+w-alo~m~bC . as eba :~e~ s~pozei , #n" •kf-e , 4~tf tea oP tiFw • ltaaosdis eft Da1mo 3n and Ear ~ruc6aslatlW Oauv4ty.'is ylud 6aok t7.r .L'aslt'4~A. AL7A Conunihnerst s~r,eawe a tAP003J1Z5.Pf0lA10030125/2) 8K18~4PGt6~2 VERIFICATION Ilana Zion, Esquire hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to make this Verification as the Plaintiff is outside the jurisdiction of the Court and Plaintiff's verification could not be obtained within the time necessary to file this pleading, and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. SHAPIRO & KREISMAN, LLC BY: Dated: ~ I~~ ~~ Ilana 710, Esauire for n ~ ~ ra ~.. C: ? ~~ ~ ~ ..V; `rl ~ ~ '^F ~ C ~ ~ i 0 '"~iP ,~ r SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Baz # 87137 3600 HORIZON DRNE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29771 We11s Fargo Bank, N.A. ; 1 Home Campus Drive Des Moines, IA 50328 PLAINTIFF VS. ; ; Robert D. Geller, a/k/a Robert D. Geller, Jr. and ' Lisa L. Geller DEFENDANT(S) ; COURT OF COMMON PLEAS CUMBERLAND COUNTY N0:07-4967 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, E, Attorneys for ~,, ! ~ ~ Wells Fargo Bank, N.A. v. Robert D. Geiler aka Robert D. Geiler, Jr. and Lisa L. Geiler VERIFICATION The undersigned is of Fidelity National Foreclosure Solutions, as attorney in fact for Wells Fazgo Bank, N.A. and as such is familiaz 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 WeI1s Fazgo Ba~n~k, N.A. Date: $'~ (~}- Name: Title: ~-• ~. ~~ Company: Loan: 0607644556 07-29771 ~. O -r~ -,~t ~- ~~ ' ' -~ , 4'7 [ i I~ ' t fs; f-E ^~ L~~ t _~__. ~ ~ ~ ++S SHERIFF'S RETURN - REGULAR r rCASE NO: 2007-04967 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS GEILER ROBERT D ET AL CPL 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 GEILER LISA L DEFENDANT the at 0911:00 HOURS, on the 24th day of August 2007 at 111 MEDIA ROAD CARLISLE, PA 17013 ROBERT GEILER by handing to HUSBAND) together with a true and attested copy of COMPLAINT - MORT FORE 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 00 q I bz~o 1 ~^ 1 Sworn and Subscibed to before me this day of , So Answers: ~~E~ R. Thomas Kline os/27/2007 SHAPIRO & KREI By: eputy Sherif f A.D. SHERIFF'S RETURN - REGULAR CASE N0: 2007-04967 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS GEILER ROBERT D ET AL CPL RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE GEILER ROBERT D AKA ROBERT D GEILER JR the DEFENDANT at 0911:00 HOURS, on the 24th day of August 2007 at 111 MEDIA ROAD CARLISLE, PA 17013 ROBERT GEILER was served upon by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Q ~ 61.'07 18.00 4.80 .00 10.00 .00 / 32.80 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 08/27/2007 SHAPIRO & KREIS By: eputy Sheriff A.D. SHERIFF'S RETURN - NOT FOUND .~ CASE NO: 2007-04967 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS GEILER ROBERT D 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 ..~~__~___~. b t unable to locate Him in his bailiwick /"1 /'11R T1T T TLTT LR/1T)T L1P1D L7 u was He therefore returns the the within named DEFENDANT 111 MEDIA ROAD OCCUPANT NOT FOUND as to CARLISLE, PA 17013 NO OTHER OCCUPANT RESIDE AT LISTED ADDRESS Sheriff's Costs: So answers;._. ~--~'~----""~' Docketing 6.00 """~ r~~~ .~..__.- Not Found 5.00 ~~~~.~ Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21 .0 0 / 9~o~~a ~ ~-, 00/00/0000 Sworn and Subscribed to before me this day of , A.D. M 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. 07-29771 Wells Fargo Bank, N.A. ~ COURT OF COMMON PLEAS PLAINTIFF CIVIL DIVISION vs. ~ CUMBERLAND COUNTY Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler N0:07-4967 Civil Term DEFENDANTS PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES Enter Judgment IN REM in the amount of $101,312.12 in favor of the Plaintiff and against the defendants, 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 Interest at 6% from March 1, 2007 to September 25, 2007 (209 days @ $15.14 per diem) Late charges (for certain months prior to default and every month after at a rate of $33.38 per month) Escrow Advance Mortgage Insurance Premium Title Search Report Fees Attorneys Fees TOTAL AMOUNT DUE $92,085.56 $3,164.26 $200.28 $970.30 $37.45 $250.00 $4,604.27 01,312.12 v Lauren R. Tabas, Esquire Attorney for Plaintiff AND NOW, judgment is entered in favor of the Plaintiff and against the Defendants and damages are assessed as above in the sum of $101,312.12. 07-29771 . IC Pro. Prothy. 9/aslo7 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. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS NO: 07-4967 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Lisa L. Geiler DATE OF NOTICE: September 14, 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 Cazlisle, 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 IlVIPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado 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 cone 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 pars 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: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 r Ilana Zion, Esquire Shapiro & Kreisman, LC Attorney for Plaintiff 5HAPIRO & 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. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS NO: 07-4967 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Robert D. Geiler, a!k/a Robert D. Geiler, Jr. DATE OF NOTICE: September 14, 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 fmd 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 IlVIPORTANTE Usted se encuentra en estado de rebeldia por no haber tornado la action requirida de su pane en este caso. Al no tomar la action debida dentro de un termino de diez (10) dias de la fecha de esta notification, el tribuna podra, sin necesidad de compararecer usted in torte o escuchar preuba alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos importantes. Debe Ilevar esta notification a un abogado immediatamente. Si usted no tiene abogado o si no tiene dinero suficiente Para tal servicio, vaya en persona o flame por telefono a la oficina cuya direction 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: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 Ilana Zion, Esq Shapiro & Krei , LLC Attorney for Plaintiff • SHAPIRO & KREISMAN, LLC BY: ILANA ZION, ESQUIRE ATTORNEY I.D. NO: PA Bar # 87137 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS NO: 47-4967 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, September 14, 2007 to the following Defendants: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 Kevin Dwyer, Legal Assistant to Ilana Zion, Esquire for Shapiro & Kreisman, LLC ' '~. , SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIlZE 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. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF vs. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0:07-4967 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 persons or their attorney of record: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 Date mailed: BY: & KREISMAN, LLC Lauren R. Tabas, Esquire Attorney for Plaintiff 07-29771 a ~ SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIRE ATTORNEY I.D. NO: PA Bar # 93337 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF vs. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0:07-4967 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 addresses of the judgment debtor (Defendants) is: Robert D. Geiler, aIk/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 S O & KREISMAN, LLC ~~~- ~~ BY: Lauren R. Tabas, Esquire Attorney for Plaintiff 07-29771 '~"' '= .-~ _Y ~~ -1 p ~ 73 J . yr : ~6 6 U _ti ~, OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Curtis R. Long Prothonotary TO: Robert D. Geiler, alk/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Wells Fargo Bank, N.A. ; PLAINTIFF vs. Robert D. Geiler, aJk/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0:07-4967 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 R. Long Prothonotary [XX] Judgment by Default [ ]Judgment for Possession [ ]Judgment on Award of Arbitration [ ]Judgment on Verdict [ ] 3udgment 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 s CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Wells Fargo Bank, N.A. PLAINTIFF vs. ()Confessed Judgment ()Other File No. 07-4967 Civil Term Amount Due $101,312.12 Interest September 26, 2007 to March 5, 2008 is $2,697.30 Atty's Comm Costs Robert D. Geiler, a/k/a Robert D. Geiler, Jr. ; and Lisa L. Geiler DEFENDANTS 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 Lepal 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 lisp dens agaias#fe~l a of the defendant(s) described in the attached exhibit. Date: Signatur Print Na :Lauren R. Tabas, Esquire Address: 3600 Horizon Drive, Ste.150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 93337 ...~ ,--, -T- ~, `HI. - s { tit _ ~ QQ Q - -- ~ 4 Cf V d ~ 4' -p ~ _ ~ - W-h - ~ ~~. ..,Q o g d ~ ~ ~. FD ~ ~ c~ 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 N0.07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler aka Robert D. Geiler, Jr 111 Media Road Carlisle, PA 17013 Lisa L. Geiler COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 111 Media Road Carlisle, PA 17013 DEFENDANT(S) STATE OF: M.N COUNTY OF: 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 Foreclosure ion as attorney in fact for Wells Fargo Bank, N.A. _..__- - By: NAME: 't-~.k-r~ ~~r--2 TITLE: ~ u.~e~ ~~ Sworn to and subscribed before me this ~ day a , 2007. t a h"" ,Notary Public 07-29771 .,....,~, JAMES C. MORRIS • t NOTARY PUBLIC ~ MINNESOTA EXPi~B JAN$311 2009 C? ~ ....,J .-. ~ ~'.c. LIr~ ...,..: .J ~ ~,i ~ , ~_ ._, f_d.y __~ tr _ ,u; . , ~ _.: r*^, -- ~~i'f , ; ~~ ..-. "` ,' ~, SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIItE 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. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF vs. Robert D. Geiler, a/k/a Robert D. Geiler, Jr and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-4967 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 111 Media Road, Carlisle, PA 17013. 1. Name and address of Owners or Reputed Owners Robert D. Geiler, a!k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road 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 L, J 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 First Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 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 maybe 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 maybe affected by the sale: TENANT OR OCCUPANT 111 Media Road 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. BY: & KRFISMAN, LLC R. Tabas, Esquire 07-29771 .~J ~ C7 c_> j "il f.. -~~ . ,-; ~~ _ ~ l.i 1 1 {'~ .. r- ~_ '~ - !;7 -* ' , i 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. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF vs. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-4967 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Your house (real estate) at: 111 Media Road, Carlisle, PA 17013 06-19-1641-193 is scheduled to be sold at Sheriffs Sale on March 5, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM, to enforce the court judgment of $101,312.12 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 maybe 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 maybe 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. You maybe 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 ca11717-240-6390. 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. 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 maybe 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. 07-29771 ~r ALL THAT CERTAIN lot or piece of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southeastern corner of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 % story dwelling house with attached garage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by Deed dated April 20, 1993 and recorded in the Cumberland County Recorder of Deeds Office on Apri122, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler, Jr. and Lisa L. Geiler, husband and wife. .~ ~, , . SHAPIRO & KREISMAN, LLC BY: LAUREN R. TABAS, ESQUIlZE 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. 07-29771 Wells Fargo Bank, N.A. ~ COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY vs. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. NO: 07-4967 Civil Term and Lisa L. Geiler DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lisa L. Geiler 111 Media Road Carlisle, PA 17013 Your house (real estate) at: 111 Media Road, Carlisle, PA 17013 06-19-1641-193 is scheduled to be sold at Sheriffs Sale on March 5, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM, to enforce the court judgment of $101,312.12 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 maybe 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 maybe 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. You maybe 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 ca11717-240-6390 . 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. 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 maybe 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. 07-29771 .~ ~.,~ , ALL THAT CERTAIN lot or piece of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southeastern corner of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 %z story dwelling house with attached garage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by Deed dated Apri120, 1993 and recorded in the Cumberland County Recorder of Deeds Office on April 22, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler, Jr. and Lisa L. Geiler, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4967 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELL FARGO BANK, N.A., Plaintiff (s) From ROBERT D. GEILER a/k/a ROBERT D. GEILER, JR. and LISA L. GEILER (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 $101,312.12 Interest 9/26/07 to 3/05/08 is $2,697.30 Atty's Comm Atty Paid $188.80 Plaintiff Paid Date: 9/25/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs S C rtis R. Long, Prothonota By: Deputy REQUESTING PARTY: Name LAUREN R. TABAS, ESQUIRE Address: 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 93337 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. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF I VS. 1 1 Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-4967 Civil Term CERTIFICATION OF NOTICE TO LIENHOLDERS PURSUANT TO PA RC.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 October 22, 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: ~~,..~ Heather Whitman Legal Assistant 07-29771 r ~ ~ ~ T o ~o W a Q c W~c 3 V . ~ N ~ `z N °o N ~ O ~ ~ 2 ~c ~ J 1I ~ ~~ ~' (~Q~ ~ [D ((NDD N 3 N m ~ W `~ ~ ~~ x 0 d b O N .9 n N Si .. eo 3 m .. 0 vl rn~ UI ', A W N o w v 00 FD' O b ~ OV N ~"'. cn p ~ ~ ~~~. Qoa ~ ? n ~ .. a n ~ ~ h ~ a "O y > Apo ~ ~ a ~r" N C] ~ 2 c rn °~ ~ 3 o C' w W~ P~ ..•.~ ro m ~• ~ o o' ~ Q ~ r" ~ ~ o ~ ~ co ~ ~ a ~ m o c~ c) ~ x ~ ~ ~ ~ ~ ~~ Jo ~ vw G °Z' olio 0 „b~•a o~ ~ oa^cs ~ -~ m o .~~'. ~ p c~u d ~ ~ (j • N (A ~ .'D .Z1 ~ ~ ~~.~ ~ w ,'~~ 3 y c m ~ ~ m~aa ~ ~ o~ O ~ ~~ ~. ~ ~ m o ~ ` ~ ~ 'o ~ ~ ~ m S ~ ~ 7 N N o, o 5i m o'i m '-' Ob~$$AD T fD y N• Q ai ~ ~ H y ~Gtpp ~ ~ 4"Gm nN .b 711 ?RC d 3 n ~ N'~ y V magw~ _ / ~~1G fi pA ~ = a `. ' m ~ ~. f da ~ G~;~ !~ l ~ cB m v~ SAS ' ~~ - - ~ o N unur~D livery onfirm tion o N ~ ® s9~ Signat re Con irmati n ~ ~ a ~~ N ~ Specia Handl ng ~ ~ ~ o~p~ Re ricted Delive m N-~ Return `° Nc ~ Recei t a o to ~~ o ,~_ _. _ ., ,._~. ~:.; ., . _~ ;_;, ~, ;._ -_-, i- ; - cs; .r, ~.> _,.; i~.. c- Wells Fargo Bank, N.A. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Robert D. Geiler a/k/a Robert D. Geiler, Jr. Writ No. 2007-4967 Civil Term And Lisa L. Geiler Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 06, 2007 at 1725 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: Robert D. Geiler a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler, by making known unto Robert Geiler, personally and adult in chazge for Lisa L. Geiler, at 111 Media Road, Cazlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copies of the same. Michael Bazrick, Deputy Sheriff, who being duly sworn according to law, states that on January 09, 2008 at 0959 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 Robert D. Geiler a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler located at 111 Media Road, Cazlisle, 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 nazned defendants, to wit: Robert D. Geiler a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler by regulaz mail to their last known address of 111 Media Road, Carlisle, PA 17013. These letters were mailed under the date of January 8, 2008 and never returned to the Sheriff s 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. Sheriff s Costs: Docketing 30.00 Poundage 16.96 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 9.60 Levy 15.00 Surchazge 30.00 Postpone sale 20.00 Law Journal 355.00 Patriot News 339.83 Share of bills 16.17 $865.06 So w ,/'~ ~:~~'~ R. Thomas Kline, Sheriff BY `J~~ c J~~~ Real Estate S geant .,ll'~ Sl U ~~ ~. ~K~ X43 7 ;~-•~ ~~~60~1 ~} 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. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF vs. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-4967 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 111 Media Road, Carlisle, PA 17013. Name and address of Owners or Reputed Owners Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road 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 First Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 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 maybe 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 maybe affected by the sale: TENANT OR OCCUPANT 111 Media Road 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, BY R. Tabas, Esquire 07-29771 ~.~^ 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. 07-29771 Wells Fargo Bank, N.A. ~ COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY vs. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. NO: 07-4967 Civil Term and Lisa L. Geiler ; DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lisa L. Geiler 111 Media Road Carlisle, PA 17013 Your house (real estate) at: 111 Media Road, Carlisle, PA 17013 06-19-1641-193 is scheduled to be sold at Sheriff s Sale on March 5, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM, to enforce the court judgment of $101,312.12 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 maybe 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 maybe 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.) s YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE 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) 278-6800. 5. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed 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 ca11717-240-6390 . 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 maybe 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 Cazlisle, 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. 07-29771 ALL THAT CERTAIN lot or piece of ground situate in the Fifth Wazd of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southeastern corner of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 %2 story dwelling house with attached gazage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by Deed dated Apri120, 1993 and recorded in the Cumberland County Recorder of Deeds Office on Apri122, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler, Jr. and Lisa L. Geiler, husband and wife. 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. 07-29771 Wells Fazgo Bank, N.A. PLAINTIFF vs. ; Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler ; DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY N0: 07-4967 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Your house (real estate) at: 111 Media Road, Carlisle, PA 17013 06-19-1641-193 is scheduled to be sold at Sheriffs Sale on March 5, 2008 at: Cumberland County Sheriffs Office 1 Courthouse Squaze Carlisle, PA 17013 at 10:00AM, to enforce the court judgment of $101,312.12 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 Fazgo 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 maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You maybe able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the mare 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. 4. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 5. You maybe 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 ca11717-240-6390. 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 maybe entitled to a shaze 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) aze 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 Cazlisle, 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. 07-29771 ALL THAT CERTAIN lot or piece of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southeastern corner of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 1/z story dwelling house with attached garage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by.Deed dated Apri120, 1993 and recorded in the Cumberland County Recorder of Deeds Office on Apri122, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler, Jr. and Lisa L. Geiler, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4967 Civil CML ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELL FARGO BANK, N.A., Plaintiff (s) From ROBERT D. GEILER a/Wa ROBERT D. GEILER, JR. and LISA L. GEILER (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 $101,312.12 Interest 9/26/07 to 3/05/08 is $2,697.30 Atty's Comm Atty Paid $188.80 Plaintiff Paid Date: 9/25/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs 's R. Long, Prothonotary By: I Deputy REQUESTING PARTY: Name LAUREN R. TABAS, ESQUIRE Address: 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for: PLAINTIFF Telephone: 610-278-6800 Supreme Court ID No. 93337 Real Estate Sale # 26 On November 1, 2007 the Sheriff levied upon the defendant's interest in tl~e real property situated in Carlisle Borough, Cumberland County, PA Known and numbered as 111 Media Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date; Nove~ber_1, 20U7 ByV ~~ `~ Real Estate Sergeant _. ..,~ 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. Marie Covr~e, Editor SWCSRN TO AND SUBSCRIBED before me this 8 day of February. 2008 Notary Nou,R~ sEAI, DEBORAH A COLIINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 ~~~ Writ No. 2007-4967 Civil Wells Fargo Bank, N.A. vs. Robert D. Geiler a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler Atty.: Lauren Tabas DESCI;IPTIQN ALL THAfi t~'!'11~t ~ ~ of gro~d in the P'M6 of __ the Borate of Cie, d Cotitts~r, F~yia, amd dea~a~ ~ ile~rwa: BEGIN1vING at a point on the Southeastern comer of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 1/2 story dwelling house with attached garage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by Deed dated April 20, 1993 and recorded in the Cumberland County Recorder of Deeds Office on April 22, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler, Jr. and Lisa L. Geiler, husband and ~* '-'T.he Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE c'~e~atriot-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 This ad ran on the date(s) shown below: 01 /30/08 02/06/08 02/13/08 ,~ ....... ,. _ ..~~ .. w ...... . Sworn to an¢s~?b~cribed before(me~s 25~k1y Qf February, 2008 A. D. Notary Public COMMONWEALTH OF PENNSYLVANIA Nota~a! Sea! Stienis L Kisrse~, Nratary Public CNyOfHeriatiurra. r~~uphin County My Commii^ :, . ,x," aov. 26, 2011 AMmber, PennayMania Association of Notarlea REAL ESTATE SALE N0.26 Writ No. 2007-4967 Civil Term Wells Fargo Bank, N.A. VS Robert D. Geiler a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler Attorney Lauren Tabas DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in the Fifth Ward of the Borough of Carlisle. Cumberland County, Pennsylvania, bounded and described as follows: BEGINNBVG at a point on the Southeastern comer of Media Road and Fairview Road: thence along the line of Fairview Road South 6? degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan: thence along the line of said Lot No._ South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan. North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a ] I/2 story dwelling house with attached garage. known and numbered as 1 I I Media Road. SAID premises being Lot No. L Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds m and for Cumberland County in Plan Book 12, Page 60. R~ 'VG the same premises which Joseph M. Mainello by Deed dated April 20, 1993 and recorded in the Cumberland County Recorder of lleeds Office on April 22, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler. )r. and Lisa L. Geiler, husband and wife. SHAPIRO & DENARDO, LLC BY: CHRISTOPHER A. DENARDO, ESQUIRE ATTORNEY I.D. NO: PA Bar # 78447 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610) 278-6800 S & K FILE N0.07-29771 Wells Fargo Bank, N.A. PLAINTIFF ; VS. ; Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 07-4967 Civil Term SUGGESTION OF BANKRUPTCY TO THE PROTHONOTARY: It is hereby suggested of record that Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler Defendant(s) in the above captioned case has filed a Chapter 13 bankruptcy under case number 08-00450 on February 14, 2008, in the Middle District of Pennsylvania and the above captioned Action in Mortgage Foreclosure is accordingly stayed during the pendency of the Bankruptcy. ~~ ~~ BY: Christopher A. DeNazdo, Esquire Attorney for Plaintiff C} ~ C7 ~~ c~ oc, `r- - ~ __.. 1 - .; j{ 4 ~ . G 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. ~~ - ~9~ 7 Amount Due $101,312.12 Interest September 26, 2007 to March 3, 2010 is $14,818.50 Atty's Comm Costs Robert D. Geiler, a/k/a Robert D. Geiler, Jr and Lisa L. Geiler 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 a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: Signature: V Print Name: Michael J. lark Es uire Address: 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Supreme Court ID # PA Bar # 202929 FlIED-~~1~ - .,,~.~ r+ v('J•'1VL 2049 OCT 14 P~ 2~ 0 T CUB=~~9~~ - ~ ,{ - t~ JJ~°V ~ i a< Y Lam' ~ „„/ ~ .. .~~ -~-a .~+ ., l~~oo " a~ . oo ~ " ~~= o~ ~ u i~ as ~~. op ~~ ~ ~~ /r>>s'~~ ~ `` WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-4967 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 Robert D. Geller, a/k/a Robert D. Geller, Jr. and Lisa L. Geller (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 $101,312.12 L.L. Interest September 26, 2007 to March 3, 2010 is $14,818.50 Atty's Comm % Due Prothy $2.00 Atty Paid $1075.36 Other Costs Plaintiff Paid Date: October 14, 2009 (Seal) REQUESTING PARTY: Name Michael J. Clark, Esq. Address: 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Telephone: Supreme Court ID No. 202929 Curtis R. Long, Prothonotary Deputy SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0:07-4967 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I hereby certify that I am the Attorney of record for the Plaintiff in this Action against Real Property and further certify this Property is: X FHA -Tenant Occupied or Vacant Commercial As a result of a Complaint in Assumpsit That the Plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Act including but not limited to: (a) Service of notice on Defendants (b) Expiration of 30 days since the service of notice (c) Defendants failure to request or appear at meeting with Mortgagee or Consumer Credit Counseling Agency (d) Defendants failure to file application with Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff of Cumberland County for any false statement given herein. SHAPIRO & DeNARDO, LLC BY: ~ Michael J. ark, Esquire PA Bar # 202929 ,,~~ ~~L~L~'-;°'~t ~(~ r J^;^ r zoos ocr r ~ ~1~ 2: o ~ ,~~_ ~~.:frr Etiti,~, ~ ~ i, r',; v u'i IN THE iJNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: ROBERT D. GEILER A/K/A ROBERT D. GEILER, JR. Bk. No. 1:08-00450 MDF LISA L. GEILER Debtors Chapter No. 13 WELLS FARGO HOME MORTGAGE, INC., AS SERVICER FOR THE MORTGAGEE OF RECORD Movant 11 U.S.C. §362 v. ROBERT D. GEILER A/K/A ROBERT D. GEILER, JR. LISA L. GEILER Respondents ORDER MODIFYING SECTION 362 AUTOMATIC STAY Upon Consideration of the Motion of WELLS FARGO HOME MORTGAGE, INC., AS SERVICER FOR THE MORTGAGEE OF RECORD (Movant), and after Notice of Default and the filing of a Certification of Default, it is: ORDERED AND DECREED THAT: The Automatic stay of all proceedings, as provided by 11 U.S.C. 362 is modified with respect to premises, 111 MEDIA ROAD, CARLISLE, PA 17013, as more fully set forth in the legal description attached to said mortgage, as to allow the Movant to foreclose on its mortgage or take any legal or consensual action enforcement of its right to possession of, or title to, said premises (such actions may include but are not limited to the signing of a deed in lieu of foreclosure or entering into a loan modification agreement) and to allow the purchaser of said premises at Sheriil's Sale (or purchaser's assignee) to take any legal or consensual action for enforcement of its right to possession of, or title to, said premises; and it is fiuther; ORDERED AND DECREED THAT: Rule 4001(a)(3) is not applicable and WELLS FARGO HOME MORTGAGE, INC., AS SERVICER FOR THE MORTGAGEE OF RECORD may immediately enforce and implement this Order granting Relief from the Automatic Stay. BY #h! C411Tfi, Dated: September 24, 2009 ?'his document is electronically stgned and,filed an tl:e same date. Case 1:08-bk-00450-MDF Doc 48 Filed 09/24/09 Entered 09/24/09 15:17:25 Desc Main Document Page 1 of 1 2Q~90CT I4 PM 2~ 07 C~r~~~;~. ;: ; ;_ (~:T~1 r, ~ ~ 'v .r :Ji `v~ j SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CNIL DIVISION CUMBERLAND COUNTY N0:07-4967 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 addresses of the judgment debtors (Defendants) are: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 SHAPIRO & De ARDO, LLC BY: Michael J. Cl k, Esquire Attorney for P aintiff 07-29771 ,-~~ ,~~ ~€; ~~-~~l,~,,~7ARY 20Q9 OCR 14 PPS 2~ 07 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0:07-4967 Civil Term CERTIFICATE OF SERVICE I, Michael J. Clark, 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: Robert D. Geiler, a/k/a Robert D. Geiler, Jr., 111 Media Road, Carlisle, PA 17013 Lisa L. Geiler, 111 Media Road, Carlisle, PA 17013 Date Mailed: ~ ~ 13 ~~_ SHAPIRO & DeNIAR^DO', LLC V " BY: Mic ael J. Cl ,Esquire Attorney for Plaintiff ~L~~--~,~r1C~ 2009 OCI I ~ P~ 2.0 7 SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-29771. Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 07-4967 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 111 Media Road, Carlisle, PA 17013. 1. Name and address of Owner(s) or Reputed Owner(s) Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road Carlisle, PA 17013 2. Name and address of Defendants in the judgment: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Lisa L. Geiler 111 Media Road 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 First Federal Credit Union 5000 Louise Drive Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest maybe 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 maybe affected by the sale: TENANT OR OCCUPANT 111 Media Road 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. SHAPIRO & DeNARDO, LLC BY: Michael J. Cl k, Esquire 07-29771 FILED-+~;~r~ -~E +r nn~r+ f~~ X004 oc i ~ ~ P~ 2: a ~ do-.,,. ~ ~ ~- J ~- SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar ~# 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 07-4967 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA 17013 Your house (real estate) at: 111 Media Road, Carlisle, PA 17013 06-19-1641-193 is scheduled to be sold at Sheriffs Sale on March 3, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $101,312.12 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 maybe 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 maybe able to stop the sale through other legal proceedings. 4. 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. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. 6. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. 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. 8. 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. 9. 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. 10. You maybe 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 days after the Sheriff 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. 11. 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. 07-29771 r ALL THAT CERTAIN lot or piece of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southeastern comer of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 % story dwelling house with attached garage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by Deed dated April 20, 1993 and recorded in the Cumberland County Recorder of Deeds Office on Apri122, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler, Jr. and Lisa L. Geiler, husband and wife. F1LFG-ut=~-~1~;~ 2009 OC~i 14 P~9 2~ 0 7 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Clerk Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Curtis R. Long Prothonotary TO: Lisa L. Geiler 111 Media Road Carlisle, PA 17013 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 07-4967 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 R. Long 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 MICHAEL J. CLARK, ESQUIRE AT (610)278-6800. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO: 07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS '-I~ ~~V _t` h ~ ~ Yii: 2t~lG J~.~y 22 0;; ! ~ 0 ,,i~~i ~, COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 07-4967 Civil Term SUGGESTION OF BANKRUPTCY TO THE PROTHONOTARY: It is hereby suggested of record that Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa. L. Geiler Defendants in the above captioned case have filed Bankruptcy under Chapter BK 13, under Docket No. 10-00062 on January 6, 2010, in the Middle District of Pennsylvania and the above captioned Action in Mortgage Foreclosure is accordingly stayed during the pendency of the Bankruptcy. BY: Attorney for SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~4wtirttr mt 4rtr~b~~„~~i~~ >: ~ ~~ OF T}-'~ ~°,~J?`,'-'",~O~a~Y 20 f 0 >~~„~? ~ 8 r~ '~~ G 1 Edward L Schorpp Solicitor Wells Fargo Bank, N.A., vs. Robert D Geiler (et al.) ~_ G. '~ t ~` ~.: ~'~ Case Number 2007-4967 SHERIFF'S RETURN OF SERVICE 12/17/2009 07:10 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2009 at 1910 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 Robert D. & Lisa L. Geiler, located at, 111 Media Road, Carlisle, Cumberland County, Pennsylvania according to law. 12/29/2009 05:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 29, 2009 at 1715 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: Lisa L. Geiler, by making known unto, Lisa L. Geiler, personally, at, 111 Media Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/29/2009 05:20 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 29, 2009 at 1715 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: Robert D. Geiler, by making known unto, Lisa L. Geiler, wife of defendant, at, 111 Media Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1 the same. 01/19/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED per instruction letter from Attorney Clark on 1/14/10 SHERIFF COST: $120.58 SO ANSWERS, March 04, 2010 RON R ANDERSON, SHERIFF ~ .aj ~~~ . L"~ - ui~ 7~ro3G~ (c GountySuite Sherff. Teieosoft Inc. /`" ` ~3 90~' SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF VS. Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler DEFENDANTS COURT OF CCSMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 07-4967 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Robert D. Geiler, a/k/a Robert D. Geiler, Jr. 111 Media Road Carlisle, PA .17013 Your house (real estate) at: 111 Media Road, Carlisle, PA 17013 06-19-1641-193 is scheduled to be sold at Sheriffs Sale on March 3, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $101,312.12 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 Sheriff s 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 maybe 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 maybe able to stop the sale through other legal proceedings. 4. 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. h 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610) 278-6800. ' 6. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 7. 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 ca11717-240-6390. , 8. 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. 9. 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. 10. You maybe 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 days after the Sheriff Sale. This schedule will state who will be receiving the money. The money wili 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. 11. 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. 07-29771 ALL THAT CERTAIN lot or piece of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the Southeastern corner of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line ~of Media Road North 22 degrees 34 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 '/2 story dwelling house with attached garage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by Deed dated Apri120, 1993 and recorded in the Cumberland County Recorder of Deeds Office on Apri122, 1993 in Deed Book F36, page 1022, granted and conveyed unto Robert D. Geiler, Jr. and Lisa L. Geiler, husband and wife. SHAPIRO & DeNARDO, LLC BY: MICHAEL J. CLARK, ESQUIRE ATTORNEY I.D. NO: PA Bar # 202929 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 07-29771 Wells Fargo Bank, N.A. PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION VS. ~ CUMBERLAND COUNTY Robert D. Geiler, a/k/a Robert D. Geiler, Jr. and Lisa L. Geiler NO: 07-4967 Civil Term DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Lisa L. Geiler 111 Media Road Carlisle, PA 17013 Your house (real estate) at: 111 Media Road, Carlisle, PA 17013 06-19-1641-193 is scheduled to be sold at Sheriffs. Sale on March 3, 2010 at: Cumberland County Sheriffs Office 1 Courthouse Square Carlisle, PA 17013 at 10:00AM to enforce the court judgment of $101,312.12 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 maybe 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 maybe able to $top the sale through other legal proceedings 4. 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. 5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (610)278-6800. 6. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared. to the value of your property. 7. 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 ca11717-240-6390. 8. 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. 9. 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. 10. You maybe 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 days after the Sheriff 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. 11. 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. 07-29771 ALL THAT CER~'AIN lot or piece of ground situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pepnsylvania, bounded and described as follows: BEGINNING at a point on the Southeastern corner of Media Road and Fairview Road; thence along the line of Fairview Road South 67 degrees 30 minutes West 95 feet to a point at the line of Lot No. 2 as the hereinafter mentioned Plan; thence along the line of said Lot No. 2 South 28 degrees 30 minutes West 100 feet to a point; thence along Lot No. 29 on said Plan, North 67 degrees 30 minutes 83 feet to a point in the line of Media Road; thence along the line of Media Road North 22 degrees 30 minutes East 100 feet to a point, the Place of Beginning and being improved with a 1 % story dwelling house with attached garage, known and numbered as 111 Media Road. SAID premises being Lot No. 1, Block "D" on the Plan of Hamilton Development as the name appears in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 12, Page 60. BEING the same premises which Joseph M. Mainello by Deed dated April 20, 1993 and recorded in the Cumberland County Recorder of Deeds Office on April 22, 1993 in Deed Book F36, page 1022, granted and. conveyed unto Robert D. Geller, Jr. and Lisa L. Geller, husband and wife. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N007-4967 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 Robert D. Geller, a/k/a Robert D. Geller, Jr. and Lisa L. Geller (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 $101,312.12 L.L. Interest September 26, 2007 to March 3, 2010 is $14,818.50 Atty's Comm % Due Prothy $2.00 Atty Paid $1075.36 Other Costs Plaintiff Paid Date: October 14, 2009 .'s ~ ~%~~~ .c''.S~-nom Curtis R. Long, Prothonotary d (Seal) By: ?~ Deputy REQUESTING PARTY: Name Michael J. Clark, Esq. Address: 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 Attorney for: Plaintiff Telephone: Supreme Court ID No. 202929 On October 27, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Carlisle, Cumberland County, PA, Known and numbered as 111 Media Road, Carlisle, more fully described on Exhibit "A" . filed with this writ and by this reference incorporated herein. Date: October 27, 2009 By: R stat oo din r r " y~ "f~~ r~.~ iii _, ~~ t_~ f