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Home My WebLink About03-5945COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 WELLS FARGO BANK MINNESOTA N.A, As Trustee for Delta Funding Home Equity Loan Trust 1998-4 by its attorney in fact, Ocwen Federal Bank FSB 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 VS. NO. Q3 - SQys Co C ?4-1 ROY E. BAILEY AND PATRICIA A. BAILEY 342 AIRPORT ROAD SHIPPENSBURG, PA 17257 CIVIL ACTION- MORTGAGE FORECLOSURE This is an attempt to collect a debt and anv information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense 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 Civil I:\Helen\complain\CUMBERLANI)\rosenberry. bailey cumberland 11-03.wpd Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR 4TH FL., CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 J:\Helen\complain\CUMBERLAND\rosenberry. bailey cumberland 11-03.wpd NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ., YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN ADMISSION OF LIABILITY BY YOU. IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION OF THIS DEBT. THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1:\Helen\complain\CUMBERLAND\rownberry. bailey Cumberland I1-03.wpd COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 WELLS FARGO BANK MINNESOTA N.A. As Trustee for Delta Funding Home Equity Loan Trust 1998-4 by its attorney in fact, Ocwen Federal Bank FSB 1665 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 VS. ROY E. BAILEY AND PATRICIA A. BAILEY 342 AIRPORT ROAD SHIPPENSBURG, PA 17257 NO. 63- S 9q,5 l.: l Oi C- l CIVIL ACTION- MORTGAGE FORECLOSURE 1. Plaintiff is Wells Fargo Bank Minnesota N.A. as Trustee for Delta Funding Home Equity Loan Trust 1998-4 by its attorney in fact, Ocwen Federal Bank FSB, a federal savings bank with offices located at 1665 Palm Beach Lakes Blvd., West Palm Beach, FL 33401. 2. Defendants are Roy E. Bailey and Patricia A. Bailey, adult individuals with a last- known addresses of 342 Airport Road, Shippensburg, PA 17257. 3. Under date of November 5, 1998, Larry and Gloria Rosenberry executed and delivered to Delta Funding Corporation a mortgage upon premises 342 Airport road, Shippensburg, PA 17257 to secure the payment of the sum of $52,000.00. The said mortgage is recorded in the Department of Records in and for the County of Cumberland in Mortgage Book No. 1496, page 891, recorded November 12, 1998 and is incorporated herein by reference. A copy of the legal description of the premises is attached hereto and made a part hereof as Exhibit "A". J:\Helen\complain\CUMBERLANL\rosenberry. bailey cumberland 11-03.wpd 5. The note and mortgage have been duly assigned to Wells Fargo Bank Minnesota N.A. and the assignment is in the process of being recorded. 6. Ocwen Federal Bank FSB is the duly authorized servicing agent for Wells Fargo Bank Minnesota N.A. 7. By virtue of an upset tax sale, said premises was conveyed to Roy E. Bailey and Patricia A. Bailey by deed dated December 2, 2002, recorded December 2, 2002 in Book 254, page 3820. 8. Said premises was purchased by the defendants subject to the Delta Funding Corporation mortgage,. 9. In accordance with Act 91 of 1983, as amended, a combined notice providing the information required by §403 of Act 6 of 1974, and Act 91 aforesaid, was sent to the defendants and no response was made in the appropriate period of time. A true and correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B". 10. The said loan is in default as a result of the failure to pay the monthly installments of $622.87 due on June 6, 2003 and on the 1st day of each month thereafter. It. The following is due on the loan: PRINCIPAL BALANCE $39,573.33 INTEREST (accrued thru 11/6/03 of $3,120.57. 3,120.57 Interest after 11/6/03 shall accrue at the per diem rate of $13.39.) LATE CHARGES (accrued thru 11/03 of $403.59. 403.59 Late charges after 11/03 shall accrue at the monthly rate of $27.45.) FEES BILLED 380.00 COSTS 300.00 ATTORNEY'S FEE 2.000.00 TOTAL $45,777.49 WHEREFORE, Plaintiff, Wells Fargo Bank Minnesota N.A. as Trustee for Delta Funding Home Equity Loan Trust 1998-4 by its attorney in fact, Ocwen Federal Bank FSB requests this I:\Helen\complain\CUMBERLAND\rosenberry. bailey cumberland 11-03.wpd Court to enter judgment for foreclosure of the mortgaged property for the sum of $39,573.33, plus interest thereon of $3,120.57 plus $13.39 per day from 11/6/03 until judgment is paid in full, late charges of $403.59, plus late charges of $27.45 per month from 11/03 until judgment is paid in full, fees billed of $380.00, costs of $300.00, attorney's fees of $2,000.00, plus record costs. STERN AND STERCHO BY: R CHARD F. STERR'-"-"- Attorney for Plaintiff 7:\Helen\complain\CUMBERLAND\rosenberry. bailey cumberland 11-03.wpd VERIFICATION ANN GARBISis the Default Servicing Manager of OCWEN FEDERAL BANK FSB and is authorized to sign this Verification on behalf of same, and states that she verifies the foregoing Civil Action - Mortgage Foreclosure against Roy E. Bailey and Patricia A. Bailey and avers the statements of fact therein contained are made subject to the penalties of 18 PA C. S. Section 4904 relating to the unworn falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief. ANN GARBIS Manager of Default Servicing DATE: 11/6/03 All those two certain tracts of land situate in the Township of Southampton, Cumberland County, Pennsylvania, known as 342 Airport Road, Shippensburg, Southampton Township, Cumberland County, Pennsylvania bounded and described as follows: TRACT NO. 1: Beginning at a point in the center of the Pine Road at corner of land now or formerly of Larry Rosenberry and Gloria Rosenberry, his wife; thence along the Pine Road in an Eastwardly direction one hundred (100) feet to a point in the said road at land now or formerly of Scott Wolfe; thence at right angles to said road, one hundred fifty (150) feet in a Northwardly direction along lands now or formerly of the said Scott Wolfe to an iron pin: thence in a Westerly direction and parallel to the said road, one hundred (100) feet by land now or formerly of Scott Wolfe, to an iron pin at corner of land now of formerly of Larry Rosenberry and Gloria Rosenberry, his wife; thence in a Southwardly direction and at right angles to the aforesaid road by land now or formerly of Lary Rosenberry and Gloria Rosenberry, his wife, one hundred fifty (150) feet to the place of beginning in the aforesaid road. TRACT NO. 2: Beginning at an iron pin at comer of lands now or formerly of Larry Rosenberry and Gloria Rosenberry and land now or formerly of Anna M. Helm; thence along land now or formerly of Larry Rosenberry and Gloria Rosenberry, North zero (00) degrees twenty (20) minutes West, one hundred thirty-five and eight- tenths (135.8) feet to an iron pin at lands now or formerly of Larry Rosenberry and Gloria Rosenberry; thence by Rosenberry land North eighty-nine (89) degrees five (05) minutes East one hundred (100) feet to an iron pin at lands now or formerly of Scott Wolfe; thence by Wolfe lands now or formerly of Wolfe South zero (00) degrees twenty (20) minutes West one hundred thirty-eight (138) feet to an iron pin; thence by other lands of Anna M. Helm, North eighty-nine (89) degrees forty (40) minutes West one hundred (100) feet to the place of beginning. BEING the same premises which The Tax Claim Bureau of the County of Cumberland, by Tax Claim Deed dated 12/02/2002, and recorded 12/02/2002, in Book 254, Page 3820, granted and conveyed unto Roy E. Bailey and Patricia A. Bailey, in fee. PIN # 39-13-0104-026 J STERN & STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 Date: September 29, 2003 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save vour home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice. If you have anv questions, you may call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2?97.(Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attornev in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO FOR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMHI SU HIPOTECA. HOMEOWNER'S NAME(S): ROY E. BAILEY AND PATRICIA A. BAILEY PROPERTY ADDRESS: 342 AIRPORT ROAD, SHIPPENSBURG, PA 17257 LOAN ACCT. NO.: 89726533 ORIGINAL LENDER: DELTA FUNDING CORPORATION/ ORIGINAL MORTGAGOR: LARRY AND GLORIA ROSENBERRY CURRENT LENDER/SERVICE: WELLS FARGO BANK MINNESOTA, N.A. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this letter, this firm will send you the name and address of the original creditor if different from above. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end ofthis Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED"HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONFORMORTGAGE ASSISTANCE - Your mortgage is in defaultforthe reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOU APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: 342 Airport Road, _ Shippensburg> 'PA 17257 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: JUNE THROUGH SEPTEMBER 6, 2003 EACH IN THE AMOUNT OF $622.87 FOR A TOTAL OF $2,491.48 Other charges (explain/itemize): late charges of $403.79, fees billed of $109.00 TOTAL AMOUNT PAST DUE: $ 3,004.27 HOW TO CURE THE DEFAULT --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 3.004.27. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: Richard F. Stem 410 The Pavilion Jenkintown, PA 19046 215-572-8111 IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally forthe unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- Ifyou have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Ocwen Federal Bank FSB Address: 1675 Palm Beach Lakes Blvd. West Palm Beach, FL 33401 Phone Number: 1-877-836-5626 Contact Person: Cindy Anderson EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You_ may or _X_ may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (See Attached) Sincerely, STERN & STERCHO BYV//? RD/F( RIHA . STAN VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND REGULAR MAIL CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 TJ a t5p SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-05945 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS BAILEY ROY E 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 BAILEY ROY E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named DEFENDANT BAILEY ROY E 342 AIRPORT ROAD SHIPPENSBURG, PA 17257 DEFENDANT MOVED AND LEFT NO FORWARDING ADDRESS. 342 AIRPORT ROAD IS VACANT. Sheriff's Costs: Docketing 18.00 Service 13.80 Not Found 5.00 Surcharge 10.00 .00 46.80 So answerer R. Thomas Kline Sheriff of Cumberland County STERN AND STERCHO 11/19/2003 Sworn and subscribed to before me this day of A. D. Prothonotary SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-05945 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS BAILEY ROY E 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 BAILEY PATRICIA A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT 342 AIRPORT ROAD SHIPPENSBURG, PA 17257 DEFENDANT MOVED AND LEFT NO 342 AIRPORT ROAD IS VACANT. ADDRESS. Sheriff's Costs: So answers: Docketing 6.00 r Service .00 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 STERN AND STERCHO 11/19/2003 Sworn and subscribed to before me this day of A. D. NOT FOUND , as to BAILEY PATRICIA A Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2003-05954 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JUMPER TERESA D VS MILLER NICHOLAS A J. MICHAEL ICKES Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon MILLER NICHOLAS A the DEFENDANT , at 1335:00 HOURS, on the 13th day of November , 2003 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to NICHOLAS A MILLER a true and attested copy of PROTECTION FROM ABUSE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before mey this /y ?= day of YUr c? a00 A.D. rQ `? othonotary So Answers: R. ?Thomas Kline tt! 00/00/0000 FL By:? Deputy Sheri?f COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW RICHARD F. STERN, ESQUIRE STERN AND STERCHO 410 The Pavilion Jenkintown, PA 19046 (215) 572-8111 I.D. #03315 WELLS FARGO BANK MINNESOTA N.A. As Trustee for Delta Funding Home Equity Loan Trust 1998-4 by its attorney in fact, Ocwen Federal Bank FSB VS. : NO. 03-5945 Civil Term ROY E. BAILEY AND PATRICIA A. BAILEY PRAECIPE TO REINSTATE CIVIL ACTION Kindly reinstate the Civil Action in the above matter. STERN AND STERCHO BY: RI ARD F. STERN Attorney for Plaintiff 12/23/03 N o C: -, W .-f ., C T -1: :i l{ ? ?t ?... n {t:, C"J ?? 1? -n ? 1 fi . ?t= _ ? ? C.J ?? . __ j?,l - -" `r: = r? - !J --- rA, v SHERIFF'S RETURN - REGULAR CASE NO: 2003-05945 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS BAILEY ROY E ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BAILEY ROY E the DEFENDANT , at 1521:00 HOURS, on the 9th day of January 2004 at 55 PEACHY ANN DRIVE NEWVILLE, PA 17241 by handing to PATRICIA A BAILEY, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this /y day of o2 /ho f A.D. i /,/) . Prothonotary So Answers: R. Thomas Kline 01/12/2004 STERN & STERCHO By: Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2003-05945 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK MINNESOTA VS BAILEY ROY E ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BAILEY PATRICIA A the DEFENDANT , at 1521:00 HOURS, on the 9th day of January , 2004 at 55 PEACHY ANN DRIVE NEWVILLE, PA 17241 by handing to PATRICIA A BAILEY a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /y day of ??Ru y a4U`f A.D. P othonotary So Answers R. Thomas Kline 01/12/2004 STERN & STERCHO By: Deputy Sheriff Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 03 - 5949 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573