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HomeMy WebLinkAbout09-2039 q Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., 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 Sheetal 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 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 200979 WELLS FARGO BANK, NA 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. ROBERT C. KECK ROBERT L. KECK 1908 GEORGE AVENUE, CARLISLE, PA 17013-1126 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON'PLEAS CIVIL DIVISION TERM C?. NO. ©rf _ 3'/ CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 200979 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 (717) 249-3166 File #: 200979 1. Plaintiff is WELLS FARGO BANK, NA 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: ROBERT C. KECK ROBERT L. KECK 1908 GEORGE AVENUE, CARLISLE, PA 17013-1126 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 01/26/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR ACCESS NATIONAL MORTGAGE which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1950, Page 2668. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 11/01/2008 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 #: 200979 6. The following amounts are due on the mortgage: Principal Balance $106,320.72 Interest $3,207.32 10/01/2008 through 03/30/2009 (Per Diem $17.72) Attorney's Fees $1,300.00 Cumulative Late Charges $109.10 01/26/2006 to 03/30/2009 Property Inspections $30.00 Mortgage Insurance Premium 1 $86.32 Private Mortgage Insurance Cost of Suit and Title Search 750.00 Subtotal $111,803.46 Escrow Credit ($651.19) Deficit $0.00 Subtotal 651.19 TOTAL $111,152.27 7. 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. 8. 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 #: 200979 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 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 $111,152.27, together with interest from 03/30/2009 at the rate of $17.72 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 Lawrence T. Phelan, Esquire Z. ?qr ancis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Attorneys for Plaintiff File #: 200979 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND IS SITUATE IN North MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED IN ACCORDANCE WITH Plan OF SUBDIVISION FOR EDLU CORPORATION DATED 4/25/74 AND RECORDED 6/12/74 IN THE RECORDER OF DEEDS OFFICE IN AND FOR THE COUNTY OF CUMBERLAND IN PLAT BOOK 25 PAGE 43 AS FOLLOWS: BEGINNING AT A POINT ON THE Western LINE OF 50 FOOT WIDE GEORGE Avenue AT THE DIVIDING LINE BETWEEN Lots 2 AND 3; THENCE FROM SAID POINT AT THE PLACE OF BEGINNING ALONG SAID DIVIDING LINE, North 83 DEGREES AND 15 MINUTES West, A DISTANCE OF 155 FEET TO A POINT ON THE Eastern LINE OF LAND NOW OR LATE OF VINAL S. BOWERS; THENCE ALONG SAID LINE OF LAND NOW OR FORMERLY OF VINAL S. BOWERS, North 6 DEGREES AND 45 MINUTES East, A DISTANCE OF 44.23 FEET TO AN IRON PIN IN LINE OF LAND FORMERLY OF H. W. FRY, AND NOW THE Southern LINE OF Plan OF Lots KNOWN AS Plan NO.2 OF SCHLUSSER VILLAGE, THENCE ALONG SAID Southern LINE OF SAID Plan OF Lots, North 68 DEGREES 45 MINUTES AND 59 SECONDS East, A DISTANCE OF 175.53 FEET TO AN IRON PIN; THENCE ALONG THE Western LINE OF SAID 50 FOOT WIDE GEORGE Avenue, South 6 DEGREES AND 45 MINUTES West, A DISTANCE OF 124.66 FEET TO A POINT AT THE DIVIDING LINE BETWEEN Lots 2 AND 3 AT PLACE OF BEGINNING. CONTAINING 13008.98 SQUARE FEET AND BEING ALL OF Lot 3 AS SHOWN ON SUBDIVISION Plan OF EDLU CORPORATION RECORDED IN Plan BOOK 25 PAGE 43. FOR INFORMATIONAL PURPOSES ONLY: THE APN IS SHOWN BY THE COUNTY ASSESSOR AS 29-17-1585; SOURCE OF TITLE IS BOOK 177, PAGE 428 (RECORDED 05/18/98). PARCEL NO: 29-17-1585-086 PROPERTY ADDRESS: 1908 GEORGE AVENUE File #: 200979 VERIFICATION I attorney for Plaintiff in this matter, that Plaintiff is hereby state that I am the and/or the verification could not be obtained within outside the jurisdiction of the court d to make this e time allowed for the filing of the pleading, that I am authorized .1024 (c), and that the statements made in the foregoing verification pursuant to Pa.R.C P lied by the ' Mortgage Foreclosure are based upon information supplied Civil Action in knowledge, information and belief. Plaintiff and are true and correct to the best of my on receipt. el intends to substitute a verification from Plaintiff up s Furthermore, counsel ect to the penalties understands that this statement is made subj The undersigned of 18 Pa.C.S. Sec 4904 relating to uns?'Orn falsifications to authorities. Attorney for Plaintiff DATE:3 3 6-s?- OF j I- 9 APR -I pQxW S' 7e, s? p d- Csy CJ446 ?9a ?36 M!i: 55 24- d-23 0 (o 3 Sheriffs Office of Cumberland County R Thomas Kline aa,tr 01 Z u 1pbr1,1144 Edward L Schorpp Sheriff }. Solicitor O, Ronny R Anderson Jody S Smith OFFICE '= I: I "E SHERIFF Civil Process Sergeant Chief Deputy SHERIFF'S RETURN OF SERVICE 04/06/2009 04:00 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to la , states that on April 3, 2009 at 1600 hours, he served a true copy of the within Complaint in Mortgage oreclosure, upon the within named defendant, to wit: Robert L. Keck, by making known unto himself ersonally, defendant at 687 Shippensburg Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. 04/14/2009 09:20 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to la , states that on April 14, 2009 at 0920 hours, he served a true copy of the within Complaint in Mortgage oreclosure upon the within named defendant, to wit: Robert C. Keck by making known unto Robert C Keck personally, at 1908 George Avenue, Carlisle, Cumberland County, Pennsylvania, 17013, its content and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $65.60 SO ANSVER April 14, 2009 R THOMA§ K INE XHERyW Docket No. 2009-2039 Wells Fargo v Robert C. Keck & Robert L. Keck Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., 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 Sheetal 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 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA Plaintiff VS. ROBERT C. KECK ROBERT L. KECK Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-2039-CIVIL TERM : CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE PHS #: 200979 TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire J nine R. Davey, Esquire auren R. Tabas, Esquire ?3M-) Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Date: 05-04-09 Phelan H 'nan & Schmieg, LLP Atto ey o intiff - - - By nce T. La PHS #: 200979 VERIFICATION Barrett Herndon hereby states that he/she is Vice President of Loan Documentation of WELLS FARGO BANK, N.A., servicing agent for Plaintiff, WELLS FARGO BANK, N.A., 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 understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 41rft,olon Name: Barrett Herndon DATE: 4 - 2 - 0 9 Title: Vice President of Loan Documentation Company: WELLS FARGO BANK, N.A. File #: 200979 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., 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 Sheetal 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 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA Plaintiff VS. ROBERT C. KECK ROBERT L. KECK : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-2039-CIVIL TERM : CUMBERLAND COUNTY Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a strue and correct copy of Plaintiff s Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: ROBERT C. KECK 1908 GEORGE AVENUE, CARLISLE, PA 17013-1126 ROBERT L. KECK 687 SHIPPENSBURG ROAD NEWVILLE, PA 17241 Date: 05-04-09 Phelan ?llinan & Schmieg, LLP Atti6rnor Plaintiff -_= B U ?_ La Vence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire L.-Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire FILED- -(;)F,*Fi E OF THE PP.07?n,NC APY 2009 MAY -7 PH a: 06 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., 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 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenne 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 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 / Joshua I. Goldman, Esq., Id. No. 205047 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA VS. ROBERT C. KECK ROBERT L. KECK Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 09-2039-CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against ROBERT C. KECK, and ROBERT L. KECK, Defendant(s) for failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $111,152.27 Interest - 03/31/2009 to 05/21/2009 $921.44 TOTAL $112,073.71 I hereby certify that (1) R BERT L. KECK'ss last known address is 687 SHIPPENSBURG ROAD, NEWVIL LE. PA 17241, and the mortgaged premises located at 1908 GgQRGE AVENUE., CAU15LE, PA 17013-1126, and ROBERT C. KECK's last known address 1908 GEORGE AVEtM- CARLISLE, PA 17013-1126, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ) , La efic T. Phel , Esquire Fr cis Hal ' Esquire Daniel G. c Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire IJoshua I. Goldman, Esquire i p 0 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE:' J. z, ?o I I Lk?lvlqu.1000" 24", 7 Pxs # 200979 PROTHONOTARY Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., 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 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenne 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 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA VS. ROBERT C. KECK ROBERT L. KECK Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 09-2039-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney, hereby verifies that he/she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she 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 it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant ROBERT C. KECK is over 18 years of age and resides at 1908 GEORGE AVENUE„ CARLISLE, PA 17013-1126, (c) that defendant ROBERT L. KECK is over 18 years of age and resides at 687 SHIPPENSBURG ROAD, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. e-/? /e!nc?T. Phel Esquire al ' Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire /Joshua I. Goldman, Esquire 40?x,509-1 Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, NA VS. ROBERT C. KECK 1908 GEORGE AVENUE, CARLISLE, PA 17013-1126 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ROBERT L. KECK 687 SHIPPENSBURG ROAD NEWVILLE, PA 17241 No. 09-2039-CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on By: ? If you have any questions concerning this matter lease contact: Ac e e T. Phel Esquire i S. Hall' ,Esquire Daniel . c iee. Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenne R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire 4oshua I. Goldman, Esquire 10 4 2os0-1 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** Pll ? } ? t WELLS FARGO BANK, NA V. Plaintiff ROBERT C. KECK ROBERT L. KECK Defendant(s) TO: ROBERT C. KECK 1908 GEORGE AVENUE, CARLISLE, PA 17013-1126 DATE OF NOTICE: May 5, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2039-CIVIL TERM CUMBERLAND COUNTY 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 APPERANCE 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. PHS # 200979 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 /Lawrence T. Phelan, Esq., 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 Sheetal R. Shah-Jani, Esq., Id. No. 81760 JJ me 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 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 200979 WELLS FARGO BANK, NA v Plaintiff ROBERT C. KECK ROBERT L. KECK Defendant(s) TO: ROBERT L. KECK 687 SHIPPENSBURG ROAD NEWVILLE, PA 17241 DATE OF NOTICE: May 5, 2009 COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-2039-CIVIL TERM CUMBERLAND COUNTY 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. IWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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. PHS # 200979 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 By: Lawrence T. PId. No. 7 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 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Z Jee me R. Davey, Esq., Id. No. 87077 ?I.auren 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 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 200979 FILED- OF a 2669 M,' Y 22 ?`, 11: i CUM '06 d- to 14- ?9 "?1 c.? IA- P? it ?5