HomeMy WebLinkAbout08-2400GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413-2311
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE
CERTIFICATEHOLDERS OF SOUNDVIEW HOME
LOAN TRUST 2007-OPT1, ASSET-BACKED
CERTIFICATES, SERIES 2007-OPT1
6501 Irvine Center Drive
Irvine, CA 92618
Plaintiff
VS.
WREN A. CLEGG
Mortgagor and Real Owner
870 Alexander Spring Road
Carlisle, PA 17015
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term 09- ag00 civa
No. -F*xu
CIVIL ACTION: MORTGAGE
7 RI=m_,01,;l JRF
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 the 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 claim in the Complaint
of 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.
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 BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELCFONO LA OFICINA FIJADA AQU?ABAJO. ESTA OFICINA
PUEDE PROVEERO CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, OSTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website hitp://www.phfa.org/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at 800-648-9605 and ask to speak to someone about Loss Mitigation
or Home Retention options.
6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email
at homeretention(&goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm s Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64764FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF
SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES
2007-OPT1, 6501 Irvine Center Drive, Irvine, CA 92618.
2. The names and addresses of the Defendant is WREN A. CLEGG, 870 Alexander Spring Road, Carlisle,
PA 17015, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3. On February 28, 2007 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to NATIONS HOME MORTGAGE CORP., which mortgage is recorded in the
Office of the Recorder of Deeds of Cumberland County as Book 1984, Page 2434. The mortgage has
been assigned to: WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATEHOLDERS
OF SOUNDVIEW HOME LOAN TRUST 2007-OPTI, ASSET-BACKED CERTIFICATES, SERIES
2007-OPT1 by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or
transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to
Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course
of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this
reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the
Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public
record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
A ( Property ).
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for January 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such
payments for a period of one month or more, the entire principal balance and all interest due and other
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance .....................................................................
Interest from 12/01/2007 through 04/30/2008 at 7.4500%......
Per Diem interest rate at $53.19
Reasonable Attorney s Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph..
Late Charges from 01/01/2008 to 04/30/2008 .........................
Monthly late charge amount at $102.65
Costs of suit and Title Search ..................................................
Suspense ...................................................................................
NSF Charges .................................................................
Fees
$282,944.08
7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney s Fees 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 is entitled to collect Attorney s fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
Monthly Escrow amount $327.44
............$260,628.39
................$8,084.87
.............. $13,031.42
................... $513.25
..... $900.00
...-$298.85
.......$20.00
................................................................................................. T6S nn
8. Plaintiff is not seeking a judgment of personal liability (or an in nersonam judgment) against the
Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners Emergency Mortgage Assistance has
been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit B . The Defendant have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $282,944.08,
together with interest at the rate of $53.19, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property.
By: -Ct
GOLDBECK Me AFFE TY & Me FEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
TopGko Love
as the representative of the Plaintiff corporation
within named do hereby verify that I am authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the
best of my knowledge, information and belief. I understand that false statements therein are made
subject ?to1the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date: `7 p) - (-) S
OPTION ONE RTGAGE CORPORATION
T(-)r ck0 Lc ve Assistant Secretary
0022903926 WREN A. CLEGG
E..xhibitA
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et ax., North 11 dog m 36 MWO WOO 495.17 he to a je oa tba cealaC lino o
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Tha a6reWd tract is dowdbed in acoa r&nm with; a raevey by 1 wow A. NcA R.,
26,196$.
FOR DWORMAIM MIRPOSBS ONLY:
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Exthi6it (B
January 14, 2008
Wren A Clegg
870 Alexander Spri
Carlisle PA 17015
Homeowners Name: Wren A Clegg
Property Address: 870 Alexander Spri, Carlisle PA 17015
Loan Account No.: 0022903926
Original Lender: OPTION ONE MORTGAGE CORPORATION
Current Lender/Servicer: Option One Mortgage Corporation
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
02793 (Page 1 of 9)
11 0 ?
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
designated consumer credit counseling agencies listed at the end
of this 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,
or you may find them by visiting the website at http://www.phfa.org/
applications/counseling agencies.aspx. It is only necessary to
schedule one face-to-face meeting. Advise your lender immediately of
your intentions to schedule one face-to-face meeting.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default
for the 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.
(Page 2 of 9)
OP793 016 R35
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
YOUR 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.
(Page 3 of 9)
OP794 013 R35
0-1 --
Re: Loan No. 0022903926
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:
870 Alexander Spri, Carlisle PA 17015
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following
months and the following amounts are now past due:
(a) Monthly payments: 2 MONTHS @ $ 2,103.80
1 MONTHS @ $ 2,038.31
(b) Previous late charges;
(c) Other charges; Escrow, Inspection,
NSF checks
(d) Other provisions of the mortgage obligation,
if any
(e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED
AS OF THIS DATE
$ 6245.91
$ 205.30
$ .00
$ 0.00
$ 6451.21
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
OP795 (Page 4 of 9)
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 $6451.21, 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:
Overnight Mail Address Western Union Quick Collect
4600 Touchton Rd E Pay to: Option One Mortgage Corporation
Bldg 200 Ste 102 Code City: OptionJax, Fl
Jacksonville, FL 32246
Mailstop: J1 CASH
You can cure any other default by taking the following action within
thirty (30) days of the date of this letter. (Do not use if not
(applicable.)
(Page 5 of 9)
OP795 022 R35
?!C?ti
Re: Loan No. 0022903926
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 brings 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 for the
unpaid principal balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you 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 Sheriff's
Sale. You may do so by paying the total amount then ast due, Pius
ablate or other charges then due, reasonable attorney's fees and
costs connected with the foreclosure sale and an other costs
connected with the Sheriff's Sale as specified in writing b the
lender and by performing any other requirements under the mortgage.
02796 (Page 6 of 9)
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 Sheriff's Sale of the mortgaged property
could be held would be approximately (6) SIX Months from the date
of this Notice. A notice of the actual date of the Sheriff's Sale
will be sent to you before the sale. Of course, the amount needed
to cure the default will increase the longer you wait. You may find
out at any time exactly what the required payment or action will be
by contacting the lender.
(Page 7 of 9)
OP796 014 R35
Ill
Re: Loan No. 0022903926
HOW TO CONTACT THE LENDER:
Name of Lender: Option One Mortgage Corporation
Address: 4600 Touchton Road East Bldg 200 Ste 102
Attn: Trivonda Porter, Sara Haliko and Selena Moore
Address: Jacksonville, FL 32246
Phone Number: 904-996-1730 or 1-800-326-1500 ext. 61730
Fax Number: 1-866-497-1263
Contact Persons: Trivonda Porter, Sara Haliko and Selena Moore
Office hours: Monday through Friday 8:00 a.m. to 5:00 p.m. EST
Email Address: PHFA@OOMC.com
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will
end your ownership of the mortgaged property and your right to occupy it.
If you continue to live in the property after the Sheriff's Sale, a
lawsuit to remove you and your furnishings and other belongings could
be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may or X may not (CHECK ONE) 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:
* 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 CURED THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAT 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.
OP797 (Page 8 of 9)
* TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
* TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE. THIS DOES NOT IMPLY THAT OPTION ONE IS
ATTEMPTING TO COLLECT MONEY FROM ANYONE WHOSE DEBT HAS BEEN
DISCHARGED UNDER THE BANKRUPTCY LAWS OF THE UNITED STATES.
(Page 9 of 9)
OP797 035 R35
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02400 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO BANK NA
VS
CLEGG WREN A
MARK CONKLIN
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
CLEGG WREN A
the
DEFENDANT
at 0855:00 HOURS, on the 8th day of May , 2008
at 870 ALEXANDER SPRING ROAD
CARLISLE, PA 17015
WREN CLEGG
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 n
18.00
5.00
.00
10.00
.00
33.00
Sworn and Subscibed to
before me this
day
So Answers:
R. Thomas Kline
05/09/2008
GOLDBECK MCCAFFERTY MCKE VER
By:
Depu y erg. f f
of A. D.
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever . '.
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
for Plaintiff
WELLS FARGO BANK, N.A., AS TRUSTEE
FOR THE CERTIFICATEHOLDERS OF
SOUNDVIEW HOME LOAN TRUST 2007-
OPT1, ASSET-BACKED CERTIFICATES,
SERIES 2007-OPT1
6501 Irvine Center Drive
Irvine, CA 92618
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 08-2400
WREN A. CLEGG
870 Alexander Spring Road
Carlisle, PA 17015
Defendant
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
MICHAEL T. MCKEEVER, ESQUIRE
•i
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