Loading...
HomeMy WebLinkAbout07-7668PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 MICHELE M. BRADFORD, ESQ., Id. No. 69849 SHEETAL SHAH-JANI, ESQ., Id. No. 81760 JUDITH T. ROMANO, ESQ., Id. No. 58745 JENINE R. DAVEY, ESQ., Id. No. 87077 MICHAEL E. CARLETON, ESQ., Id. No. 203009 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 167214 WELLS FARGO HOME MORTGAGE, INC F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 V. Plaintiff BRIAN K. LANDIS LISA A. LANDI8 7 WEST BEALE AVENUE ENOLA, PA 17025 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 0'1 CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 167214 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 167214 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS File #: 167214 COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. File #: 167214 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: BRIAN K. LANDIS LISA A. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 04/21/1995 mortgagor(s) made, executed, and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1259, Page: 1022. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2007 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 167214 6 The following amounts are due on the mortgage: Principal Balance $69 164.86 Interest , $3 532.28 05/01/2007 through 12/19/2007 , (Per Diem $15.16) Attorney's Fees $1 250.00 Cumulative Late Charges , $0.00 04/21/1995 to 12/19/2007 Cost of Suit and Title Search 550.00 Subtotal $74,497.14 Escrow Credit $0.00 Deficit $359 57 Subtotal . 359.57 TOTAL $74,856.71 7. 8. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 167214 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $74,856.71, together with interest from 12/19/2007 at the rate of $15.16 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP N By: CIS S. HALLINAN, ES IRE jDANIEL G. SCHMIEG, ESQUIRE MICHELE M. BRADFORD, ESQUIRE SHEETAL R. SHAH-JANI, ESQUIRE JUDITH T. ROMANO, ESQUIRE JENINE R. DAVEY, ESQUIRE MICHAEL E. CARLETON, ESQUIRE Attorneys for Plaintiff File #: 167214 LEGAL DESCRIPTION BEGINNING AT A POINT ON THE Northern LINE OF West BEALE Avenue, SAID POINT BEING 175 FEET East OF THE Northeast CORNER OF West BEALE Avenue AND A 15 FEET WIDE ALLEY/THENCE ALONG THE DIVISION LINE BETWEEN Lots NO. 42 AND Lots NO. 40 AND 41 ON THE HEREINAFTER MENTIONED Plan OF Lots, North 05 DEGREES 30 MINUTES West, 150 FEET TO A POINT ON THE South SIDE OF COVERT Streets THENCE ALONG SAME, North 84 DEGREES 30 MINUTES East, 50 FEET TO A POINT ON THE DIVISION LINE BETWEEN Lots NO. 40 AND 41 AND Lot NO. 39 ON SAID Plan; THENCE ALONG SAME, South 05 DEGREES 30 MINUTES East, 150 FEET TO A POINT ON THE Northern LINE OF West BEALE Avenue; THENCE ALONG SAME, South 84 DEGREES 30 MINUTES West, 50 FEET TO A POINT, THE PLACE OF BEGINNING. PARCEL#: 09-15-1291-275 PROPERTY BEING: 7 WEST BEALE AVENUE File #: 167214 VERIFICATION I hereby state that I am the attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: aZ g'd 6 Attorney for Plaintiff I. b - &4111 N ,, 4 -? CNI w I"Ti CIO am N 9 SHERIFF'S RETURN - REGULAR CASE NO: 2007-07668 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS LANDIS BRIAN K ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LANDIS BRIAN K the DEFENDANT , at 1755:00 HOURS, on the 31st day of December-, 2007 at 7 WEST BEALE AVENUE ENOLA, PA 17025 by handing to 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 14.40 Affidavit .00 Surcharge 10.00 .00 ?/d 91dY ?, 4 2 . 4 0 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/02/2008 PHELAN HALLINAN tS HMIEG J By: Deputy Sheriff A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-07668 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS LANDIS BRIAN K ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE LANDIS LISA A was served upon the DEFENDANT , at 1755:00 HOURS, on the 31st day of December , 2007 at 7 WEST BEALE AVENUE ENOLA, PA 17025 LISA A LANDIS by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 00 ?l9'l oy4 Z16.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 01/02/2008 PHELAN HALLINAN SCHMIEG By. eputy Sheriff of A. D. PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM BRIAN K. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 LISA A. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against BRIAN K. LANDIS and LISA A. LANDIS, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 12/20/07 to 2/19/08 TOTAL $74,856.71 $939.92 $75,796.63 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. \). -AJ DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ..3 3 O? PR PROTHY 167214 PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant BRIAN K. LANDIS is over 18 years of age and resides at, 7 WEST BEALE AVENUE, ENOLA, PA 17025. (c) that defendant LISA A. LANDIS is over 18 years of age, and resides at, 7 WEST BEALE AVENUE, ENOLA, PA 17025. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM Notice is given that a Judgment in the above-captioned matter has been entered against you on 200 By: If you have any questions concerning this matter, please contact: DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., : COURT OF COMMON PLEAS F/K/A NORWEST MORTGAGE, INC. Plaintiff : CIVIL DIVISION Vs. BRIAN K. LANDIS LISA A. LANDIS Defendants TO: LISA A. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 DATE OF NOTICE: JANUARY 23, 2008 CUMBERLAND COUNTY NO. 07-7668-CVIL TERM THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN HALLMAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., : COURT OF COMMON PLEAS F/K/A NORWEST MORTGAGE, INC. Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY BRIAN K. LANDIS :NO. 07-7668-CVIL TERM LISA A. LANDIS Defendants TO: BRIAN IC LANDIS 7 WEST BEALE AVENUE t r E ENOLA, PA 17025 DATE OF NOTICE: JANUARY 23, 2008 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 FRANCIS S. HAL AN, ESQUIRE' Attorneys for Plaintiff I I PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. No. 07-7668-CIVIL TERM BRIAN K. LANDIS LISA A. LANDIS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 2/20/08 TO 6/11/08 (per diem -$12.46) Add'1 Costs TOTAL $75,796.63 $1,407.98 and Costs $2,166.50 $79,371.11 [). - 1JI/N.- -'* . DANIEL G. SCHMIEG, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 167214 oz Q rn ? 4cj zz ?Q ?a off H w u Z, W. ?D cc Oct) ou xw 04 v? ?4z z? ww z a? a ?Q dd kf) N N N O O as d? as 00 z ww 0 U r r w° ? as ao ?' W W Q+ air o w 45 a b as a? a 3 d- N ?o 1 LEGAL DESCRIPTIOIN ALL THAT CERTAIN tract or parcel of land situate in East Penusboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, R.S. dated July 30, 1974, as follows: BEGINNING at a point on the northern line of West Beale Avenue, said point being 175 feet east of the northeast corner of West Beale Avenue and a 15 foot wide alley; thence along the division line between Lots Nos. 42 and Lots Nos. 40 and 41 on the hereinafter mentioned Plan of lots, North 05 degrees 30 minutes West, 150 feet to a point on the south side of Covert Street; thence along same, North 84 degrees 30 minutes East, 50 feet to a point on the division line between Lots Nos. 40 and 41 and Lot No. 39 on said plan; thence along same, South 05 degrees 30 minutes East, 150 feet to a point on the northern line of West Beale Avenue; thence along same, South 84 degrees 30 minutes West, 50 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a one and one-half story frame dwelling and frame garage, known as 7 West Beale Avenue, Enola, PA 17025. TITLE TO SAID PREMISES IS VESTED IN Brian K. Landis and Lisa A. Landis, his wife, by Deed from William S. Sumski, Jr. and Jennifer A. Sumski, his wife, dated 04/21/1995, recorded 04/24/1995, in Deed Book 121, page 163. BEING PREMISES: 7 WEST BEALE AVENUE, ENOLA, PA 17025 BEING PARCEL NO. 09-15-1291-275 a. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-7668 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. Plaintiff (s) From Brian K. Landis and Lisa A. Landis (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 $75,796.63 L.L.$.50 Interest from 2/20/08 to 6/11/08 (per diem -$12.46 $1407.98 and costs Atty's Comm % Due Prothy $2.00 Atty Paid $177.40 Other Costs $2166.50 Plaintiff Paid Date: March 3, 2008 (Seal) Curtis . Long, Protho By: / Deputy REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for: Plaintiff Telephone: (215) 563-7000 Supreme Court ID No. 62205 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, v. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at,7 WEST BEALE AVENUE, ENOLA, PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRIAN K. LANDIS LISA A. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 7 WEST BEALE AVENUE ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) FIRSTPLUS FINANCIAL, INC. 1600 VICEROY DRIVE DALLAS, TX 75235 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program 7 WEST BEALE AVENUE ENOLA, PA 17025 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 6th Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. February 19, 2008 DATE DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff 5? «Y ?r Zil PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff _ ,.... _....? --°t r.?, 4 - ?. ? ?- 6 C.? - r..., ?; WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). CUMBERLAND COUNTY No. 07-7668-CIVIL TERM February 19, 2008 TO: BRIAN K. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 LISA A. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORM47ION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN AGAINST PROPERTY" Your house (real estate) at, 7 WEST BEALE AVENUE, ENOLA, PA 17025, is scheduled to be sold at the Sheriffs Sale on JUNE 11, 2008 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $75,796.63 obtained by WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTIOIN ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, R.S. dated July 30,1974, as follows: BEGINNING at a point on the northern line of West Beale Avenue, said point being 175 feet east of the northeast corner of West Beale Avenue and a 15 foot wide alley; thence along the division line between Lots Nos. 42 and Lots Nos. 40 and 41 on the hereinafter mentioned Plan of lots, North 05 degrees 30 minutes West, 150 feet to a point on the south side of Covert Street; thence along same, North 84 degrees 30 minutes East, 50 feet to a point on the division line between Lots Nos. 40 and 41 and Lot No. 39 on said plan; thence along same, South 05 degrees 30 minutes East, 150 feet to a point on the northern line of West Beale Avenue; thence along same, South 84 degrees 30 minutes West, 50 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a one and one-half story frame dwelling and frame garage, known as 7 West Beale Avenue, Enola, PA 17025. TITLE TO SAID PREMISES IS VESTED IN Brian K. Landis and Lisa A. Landis, his wife, by Deed from William S. Sumski, Jr. and Jennifer A. Sumski, his wife, dated 04/21/1995, recorded 04/24/1995, in Deed Book 121, page 163. BEING PREMISES: 7 WEST BEALE AVENUE, ENOLA, PA 17025 BEING PARCEL NO. 09-15-1291-275 PBELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan, Esquire IDENTIFICATION NO. 62695 1617 JFK Boulevard, Suite 1400 PHILADELPHIA, PA 19103 (215) 563-7000 WELLS FARGO SOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff Vs. LANDIS, BRIAN LANDIS, LISA Defendant (s) ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURTHOUSE Court of Common Pleas CIVIL DIVISION NO. 07-7668-CIVIL- TERM CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification was sent via first class mail to the following on the date indicated below: LANDIS, BRIAN 7 WEST BEALE AVENUE ENOLA, PA 17025 LANDIS, LISA 7 WEST BEALE AVENUE ENOLA, PA 17025 r A// Francis S. Hallinan, Esquire Attorney for Plaintiff Dated: 3/5/08 r .11 VERIFICATION Kevin Marks hereby states that he/she is Vice President of Loan Documentation of WELLS FARGO BANK, N.A., servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understagds that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating lt/Asworn falsification to authorities. Name: DATE: December 24, 2007 TitleVice President of Loan Company: WELLS FARGO BANK, N.A. Loan:3031691 File #: 167214 PRELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan, Esquire IDENTIFICATION NO. 62695 1617 JFK Boulevard, Suite 1400 PHILADELPHIA, PA 19103 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff Vs. LANDIS, BRIAN LANDIS, LISA Defendant (s) ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURTHOUSE Court of Common Pleas CIVIL DIVISION NO. 07-766$-CIVIL- TERM PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Francis S. Hallinan, Esquire Attorney for Plaintiff Dated: 3/5/08 ? a -r+ AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF WELLS FARGO HOME MORTGAGE, / INC., F/K/A NORWEST MORTGAGE, INC. No. 07-7668-CIVIL TERM DEFENDANT(S) BRIAN K. LANDIS ACCT. #167214 LISA A. LANDIS Type of Action SERVE LISA A. LANDIS AT: - Notice of Sheriff's Sale 7 WEST BEALE AVENUE ENOLA, PA 17025 Sale Date: JUNE 11, 2008 //SERVED Served and made known to Defendant, on thee' day of 200_p, at 0 ' S5 , o'clock. .m., at 7 4't` 1154/ 1 ) . / , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. X Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age 3& Height -? Weight x,90 Race Sex Other 1, 1! e^' , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth here iry issued in the captioned case on the date and at the address indicated above. z Sworn to and subscribed Ken W. Baker before me this 5 " day 19 I DA1/e of ., 1 1200 Burt1 'cowls Notary: By: ATTEMPTED. THEODORE J. HARRIS NOT SERVED NOTARY PUBLIC On theSTATE Of #VN JERSEY 200, at o'clock _.m., Defendant NOT FOUND because: MY COMMISSION EXPIRES 10/2512012 Moved Unknown No Answer Vacant l" Attempt: Time: 2nd Attempt: Time: 3rd Attempt: Time: Sworn to and subscribed Attorney for Plaintiff before me this day DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 of 1200-. One Penn Center at Suburban Station, Suite 1400 Notary: By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 3 z ? ? z. ~.... No %)VI' J s a D? a = P rs PCs#,- • AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF WELLS FARGO HOME MORTGAGE, / INC., F/K/A NORWEST MORTGAGE, INC. No. 07-7668-CIVIL TERM DEFENDANT(S) BRIAN K. LANDIS ACCT. #167214 LISA A. LANDIS Type of Action SERVE BRIAN K. LANDIS AT: - Notice of Sheriffs Sale 7 WEST BEALE AVENUE ENOLA, PA 17025 Sale Date: JUNE 11, 2008 SERVED Served and made known to Defendant, on the day of _ 1 - W , 2006" at o'clock/-I.m., at 7 L(?ra ?t $crr /??virl? Commonwealth of Pennsylvania, in the manner described below: -Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age Height 6 / Weight ?d" D Race G0 Sex !12 Other I, /K V , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captione case on the date and at the address indicated above. Sworn to and subscribed / Ken th W• Bake. i before me this S" day u s - 08cie of 1200S B .?y 31 Not By: PLE SE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. THEODORE J. HARRIS NOTARY PUBLIC NOT SERVED OnF $T ATE 1rE' JERSEY , 200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer 1" Attempt: Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this day of 1200_. Notary: Vacant 2nd Attempt: / / Time: Attornev for Plaintiff DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 One Penn Center at Suburban Station, Suite 1400 By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 z?ye- ?__ „- (? _ y ?' ---t ?- , >..„ .., . , _, _.r. t ?? h44' ??sF -- i?'-' ia`"' 4 R. ?... ?. { i a M.. WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, v. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) WELLS FARGO HOME MORTGAGE„ INC-, F/K/A NORWF.ST MORTGAGE, INC'., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,7 WEST BFALE AVENUE, RNOLA, PA 17025 _ 1. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Township of East Pennsboro 98 South Enola Drive Enola, PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. .P < Mav 20OR DATE DANIEL G. SC EG, ESQUIRE Attorney for Plaintiff y , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff V. BRIAN K LANDIS LISA A. LANDIS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND COUNTY ) SS: Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 7 WEST RF.ALF. AVF.NTTF_ F.NO "A, PA 17025, As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the Affidavit No. 2 (previously filed) and/or Amended Affidavit No. 2 on the date indicated. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. Q ? DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff Date: May 1, 2008 IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not he snld in the absence of a representative of the plaintiff at the Sheriff c Sale_ The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. 167214 C(K: O x V. v A ?oU os a a O ? .a O :° a c; a a w? a b C d vt ? zap m n ? ?s -3aooa1x W°aa 031" OL4ati a O ° JN aaZ 8Z83? a Z •zo $ ?lsoas?'? ?,' ? a s g V3 . Q .r- .0w ?a 0 a W ? W F7 H i.i ? N > ? ab U -.. O 0 o ? z ?., ?810g z y pa N i• O 'r I-P V M ?WArrc4 3 ' 4? %Q 000 wC ? o 00 avQ x co? OQ u - M., U? , u3 o`? In d a 3 z m v N K1 of V'1 ?D l? 00 O? 1 a ?o a .-i 04 b rn ? U ;3m00 >, c cu ?d u ti 0-6 w??a b d ,d zdo i £016 6 3doodrz wo21e1 C1311VW eooz sz mvm O X08 M100 oW00 $ VU zo so 1 ooocflz woa-4o311vW. o loe alrooo $ M 7-0 .'? N&Od c?saau?ur ?.?? G ' SMWOg !Rw a °o A W ? V) p C ? m z m °? a - cr en ? ?n ?o n oo c+ o tv cn v -? C=3 ,. t7ti car, r r" ? f'il Wells Fargo Home Mortgage, Inc., f/k/a In the Court of Common Pleas of Norwest Mortgage, Inc. Cumberland County, Pennsylvania vs Writ No. 2007-7668 Civil Term Brian K. Landis and Lisa A. Landis David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on April 15, 2008 at 1900 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: Brian K. Landis and Lisa A. Landis by making known unto both Brian K. Landis and Lisa A. Landis personally at 7 West Beale Avenue, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to them personally the said true and correct copy of the same. David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on April 15, 2008 at 1900 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 Brian K. Landis and Lisa A. Landis located at 7 West Beale Avenue, Enola, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: Brian K. Landis and Lisa A. Landis by regular mail to their last known address of 7 West Beale Avenue, Enola, PA 17025. This letter was mailed under the date of April 17, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Daniel Schmieg. Sheriff s Costs: Docketing 30.00 Poundage 17.93 Posting Handbills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 28.80 Levy 15.00 Surcharge 30.00 Law Journal 355.00 Patriot News 350.30 Postpone Sale 40.00 Share of Bills 14.73 $914.26 ? q1 t q 0 So Answers: R. Thomas Kline, Sheriff BY'J 0 CJ' Real Estate ergeant '12.510 ?2 4.5 S91 i ` WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-7668-CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at,7 WEST BEALE AVENUE, ENOLA, PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): Name BRIAN K. LANDIS LISA A. LANDIS Last Known Address (if address cannot be reasonably ascertained, please indicate) 7 WEST BEALE AVENUE ENOLA, PA 17025 7 WEST BEALE AVENUE ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name FIRSTPLUS FINANCIAL, INC. Last Known Address (if address cannot be reasonably ascertained, please indicate) 1600 VICEROY DRIVE DALLAS, TX 75235 V 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program 7 WEST BEALE AVENUE ENOLA, PA 17025 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 6th Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 19, 2008 1 J - -A DATE DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. BRIAN K. LANDIS LISA A. LANDIS Defendant(s). CUMBERLAND COUNTY No. 07-7668-CIVIL TERM February 19, 2008 TO: BRIAN K. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 LISA A. LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA770N OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at, 7 WEST BEALE AVENUE, ENOLA, PA 17025, is scheduled to be sold at the Sheriffs Sale on JUNE 11, 2008 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the courtjudgment of $75,796.63 obtained by WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is, not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTIOIN ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance witb a survey and plan thereof made by Gerrit J. Betz, R.S. dated July 30, 1974, as follows: BEGINNING at a point on the northern line of West Beale Avenue, said point being 175 feet east of the northeast corner of West Beale Avenue and a 15 foot wide alley; thence along the division line between Lots Nos. 42 and Lots Nos. 40 and 41 on the hereinafter mentioned Plan of lots, North 05 degrees 30 minutes West, 150 feet to a point on the south side of Covert Street; thence along same, North 84 degrees 30 minutes East, 50 feet to a point on the division line between Lots Nos. 40 and 41 and Lot No. 39 on said plan; thence along same, South 05 degrees 30 minutes East, 150 feet to a point on the northern line of West Beale Avenue; thence along same, South 84 degrees 30 minutes West, 50 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a one and one-half story frame dwelling and frame garage, known as 7 West Beale Avenue, Enola, PA 17025. TITLE TO SAID PREMISES IS VESTED IN Brian K. Landis and Lisa A. Landis, his wife, by Deed from William S. Sumski, Jr. and Jennifer A. Sumski, his wife, dated 04/21/1995, recorded 04/24/1995, in Deed Book 121, page 163. BEING PREMISES: 7 WEST BEALE AVENUE, ENOLA, PA 17025 BEING PARCEL NO. 09-15-1291-275 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-7668 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Wells Fargo Home Mortgage, Inc., f/k/a Norwest Mortgage, Inc. Plaintiff (s) From Brian K. Landis and Lisa A. Landis (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 $75,796.63 L.L.$.50 Interest from 2/20/08 to 6/11/08 (per diem -$12.46 $1407.98 and costs Atty's Comm % Due Prothy $2.00 Atty Paid $177.40 Other Costs $2166.50 Plaintiff Paid Date: March 3, 2008 (Seal) &di d-4'w" Curtis WLong, Proth iy By: Deputy REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for: Plaintiff Telephone: (215) 563-7000 Supreme Court ID No. 62205 ARE C9?r: Real Estate Sale # 84 On March 13, 2008 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 7 West Beale Avenue, Enola, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 13, 2008 € 4 .8 V 9 - 8dW 9001 17d AIN[-jU By. ? ,?. vtn Real Estate ergeant CTIV C40 ?n t A31' 3 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : 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: May 2, May 9, and May 16, 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 Coyne, Editor SWORN-TO AND SUBSCRIBED before me this 16 day of May, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY MY Commission Explres Apr 28, 2010 VAj L WTA?i Sii NO. 64 Writ No. 2007-7668 Civil Wells Fargo Home Mortgage, Inc. f/k/a Norwest Mortgage Inc. vs. Brian K. Landis and Lisa A. Landis Atty.: Daniel Schmieg LEGAL DESCRIPTION ALL THAT CERTAIN tract or par- cel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and de- scribed in accordance with a survey and plan thereof made by Gerrit J. Betz, R.S. dated July 30, 1974, as follows: BEGINNING at a point on the northern line of West Beale Avenue, said point being 175 feet east of the northeast corner of West Beale Av- enue and a 15 foot wide alley; thence along the division line between Lots Nos. 42 and Lots Nos. 40 and 41 on the hereinafter mentioned Plan of lots, North 05 degrees 30 minutes West, 150 feet to a point on the south side of Covert Street; thence along same, North 84 degrees 30 minutes LaA, 50 feet to a point on the division line between Lots Nos. 40 and 41 and Lot No. 39 on said plan; thence along same, South 05 degrees 30 minutes East, 150 feet to a point on the northern line of West Beale Avenue; thence along same, South 84 degrees 30 minutes West, 50 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a one and one-half story frame dwelling and frame garage, known as 7 West Beale Avenue, Enola, PA 17025. TITLE TO SAID PREMISES IS VESTED IN Brian K. Landis and Lisa A. Landis, his wife, by Deed from Wil- liam S. Sumski, Jr. and Jennifer A. Sums1 , his wife, dated 04/21 / 1995, recorded 04 / 24/ 1995, in Deed Book 121, page 163. BEING PREMISES: 7 WEST BEALE AVENUE, ENOLA, PA 17025. BEING PARCEL NO. 09-15-1291- 275. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE the Patriot 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: 04/23/08 04/30/08 05/07/08 ...... ........... Sworn to and ub cribed before me this 27 day of May, 2008 A. D. 0444?j- kcoof 04ao Notary Pubic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Chyrle L. Sheppard, Notary Public City Of Harrisburg, Dauphin County My Commission Expires May 29, 2010 Member, Pennsylvania Association of Notaries Real Estate Sale #84 Writ No. 2007-7688 Civil Term Wells Fargo lioam Mortgage, Inc. f/k/a Norwest Mortgage Inc. VS Brian K. Landis and Lisa A. Landis Attorney: Daniel Schmieg DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Beta, R.S. dated July 30,1974, as follows: E at a paint the aattheam ljee of east of the aortlteast cores of West Seale Avenge ad a 15 foot wide Ael, tltoeoe abeg the division line between lots Nos. 42 and Lots Nos. 40 and 41 on the hereinafter mentioned Plan of lots, North 05 degrees 30 minutes West, 150 feet to a point on the south side of Covert Street; thence along same, North 84 degrees 30 minutes East, 50 feet to a point on the division line between Lots Nos. 40 and 41 and Lot No. 39 on said plan; thence along same, South 05 degrees 30 minutes East, 150 feet to a point on the northern line of West Beale Avenue; thence along sarce, South 84 degrees 30 minutes West, 50 feet to a point, the Place of BEGINNING. HAVING THEREON ERECTED a one and one-half story frame dwelling and.frame garage, known as 7 West Beale Avenue, Enola, PA 17025. TTILE TO SAID PREMISES IS VESTED IN Brian K. Landis and Lisa A. Landis, his wife, by Deed from William S. Sumski, Jr. and Jennifer A. Sumsld, his wife, dated 0412111995, recorded 0412411995, in Deed Book 121, page 163. BEING PREMISES: 7 WEST BEALE AVENUE, ENOLA, P A 17025 BEING PARCEL NO. 09-15-1291-275 - Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 cr _ SAVI3r•, r Plaintiff ^i;: ''? ERLAi?f? Gout, L\g'w 1\ WELLS FARGO HOME Court of Common Pleas MORTGAGE, INC. F/K/A NORWEST . MORTGAGE, INC. Civil Division Plaintiff . : I CUMBERLAND County vs BRIAN LANDIS LISA LANDIS Defendant : I No. 07-7668-CIVIL TERM PRAECIPE TO THE PROTHONOTARY: ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ? Please mark the above referenced case Settled, Discontinued and Ended. ® Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ? Please mark the in rem judgment Satisfied and the action Discontinued and Ended. Date: vP 9/7 /// PHELAN HALLINAN &\SCHMIEG, LLP By: - ? Lawrence ela , Esq., Id. No. 32227 ? Francis S. H li Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? dith T. Romano, Esq., Id. No. 58745 Q Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenme R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 alr-? 8 g.ODT"' - 0 ?* 110L ? Sap 2+R LOIN ? / PHS # 167214 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Schemer, Esq., Id. No. 308912 Attorneys for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. Plaintiff vs BRIAN LANDIS LISA LANDIS Defendant Attorney For Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 07-7668-CIVIL TERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: BRIAN LANDIS LISA LANDIS 7 WEST BEALE AVENUE ENOLA, PA 17025 Date: 4/7/t/ PHS # 167214 By: YVJ5?- 0 Lawrence T. Ph an, sq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 2rSheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ? Melissa J. Schemer, Esq., Id. No. 308912 Attorneys for Plaintiff