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HomeMy WebLinkAbout09-4033 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 Courtenay R. Dunn, Esq., Id. No. 206779 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 208334 WELLS FARGO BANK, NA 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM C 1'V +* j v. NO. Q q - tl?S3 RICHARD D. ALBERTSON 132 BRIAR PATCH DRIVE CARLISLE, PA 17015-9075 CUMBERLAND COUNTY Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 208334 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 #: 208334 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: RICHARD D. ALBERTSON 132 BRIAR PATCH DRIVE CARLISLE, PA 17015-9075 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 11/21/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS A NOMINEE FOR SUPERIOR HOME MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1847, Page 207. 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 #: 208334 6. The following amounts are due on the mortgage: Principal Balance $56,468.80 Interest $2,651.76 10/01/2008 through 06/11/2009 (Per Diem $10.44) Attorney's Fees $1,325.00 Cumulative Late Charges $19.46 11/21/2003 to 06/11/2009 Cost of Suit and Title Search 750.00 Subtotal $61,215.02 Escrow Credit $0.00 Deficit $218.47 Subtotal 218.47 TOTAL $61,433.49 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 #: 208334 9. The mortgage premises are vacant and abandoned. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $61,433.49, together with interest from 06/11/2009 at the rate of $10.44 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 IIALLINAN & SCHMIEG, LLP By: Lawxnce T. Phelan, FraKcis S. allinan.. Ddniel G. Schmi<, 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 IV# 4%93 Courtenay R. Dunn, Esquire Attorneys for Plaintiff File #: 208334 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Village of Hogestown, Township of Silver Springs, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point on the southern side of the west bound lane of U.S. Route 11 at a corner of land now or formerly of Stephen K. Wolfe; thence by land now or formerly of Stephen K. Wolfe, south 14 degrees 40 minutes east one hundred fifty (150) feet to a point on an alley, sometimes called Second Street; thence by the northern line of said alley south 75 degrees 20 minutes west eighty (80) feet to a point at land now or formerly of George Waggoner; thence by land now or formerly of George Waggoner, north 14 degrees 40 minutes west one hundred fifty (150) feet to a point on the U.S. Route 11; thence by the southern line of U.S. Route 11, north 75 degrees 20 minutes east, eighty (80) feet to a point, the place of BEGINNING. HAVING thereon erected a double brick dwelling house and garage. BEING A PART of Lot No. 40 and all of Lot No. 41 in the original Plan of Hogestown. THE description used herein is in accord with a survey made by W. G. Rechel, Registered Surveyor, on January 18, 1957. PARCEL NO. 38-18-1332-038 PROPERTY BEING: 6603 CARLISLE PIKE File #: 208334 VERIFICATION The undersigned attorney hereby states that I am the attorney for the 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: ?7* / --I Z//'4(- A7 ey or Plaintiffv? fsoLD?"iAN ! A * 7056-11 File #: 208334 ?s All FD4',FrR0E OF THE ry OTAf?`l 2009 J1614 16 AM 10: 0 4 0/i, ?g ??? jlv arcs Sheriffs Office of Cumberland County R Thomas Kline %v 9tEdward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFQE ` THE S-ERIFF Civil Process Sergeant Wells Fargo Bank, NA I Case Number vs. 2009-4033 Richard D. Albertson SHERIFF'S RETURN OF SERVICE 06/17/2009 02:58 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard D. Albertson, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard D. Albertson. Request for service at 6603 Carlisle Pike Mechanicsburg, Pennsylvania 17055 is vacant. An exact address is not available. 06/17/2009 11:08 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard D. Albertson, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard D. Albertson. The tenant of 245 E. Main Street Mechanicsburg, Pennsylvania 17055 stated that the defendant does not own the building. An exact address is not available. 06/19/2009 08:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 19, 2009 at 2050 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Richard D. Albertson, by making known unto Richard D. Albertson personally, at 132 Briar Patch Drive, Carlisle, Cumberland County, Pennsylvania, 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $98.40 June 22, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Dep ty Sheriff -r7 C- -1 r?" ` SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~!~~il-c^~=~r~ Sheriff ~ '~~ Tom' r-_~ " ~, r, ~,~,, of ~: ~ ~ ~ ~ ','1,~V Jody S Smith yilti~ ~ ~ `"~`ra Chief Deputy t ~' i ~ i ` , . , , ; ; ~ ~ Edward L Schorpp Solicitor Wells Fargo Bank, NA vs. Richard D. Albertson Case Number 2009-4033 SHERIFF'S RETURN OF SERVICE 10/03/2009 11:46 AM - Michael) Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-03-09 at 1145 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard D. Albertson, located at, 6603 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania according to law. 10/03/2009 08:32 AM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on 10-3-09 at 0830 hours, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Richard D. Albertson, by making known unto, Richard D. Albertson, personally, at, 132 Briar Patch Drive, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/01/2009 Property sale postponed to 3/3/2010. 03/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 3, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg, on behalf of, Federal Home Loan Mortgage Corporation, 8200 Jones Branch Drive, Mail Stop 202, McLean, VA 22102, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 768.50 SHERIFF COST: $768.50 SO ANSWERS, March 22, 2010 RON R ANDERSON, SHERIFF ~, ~~ Cpl) ~~,,,1. r~~` f Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. CIVIL-09-4033 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK. NA, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 6603 CARLISLE PIKE , MECHANICSBURG, PA 17050-1707 1. Name and address of Owner(s) or reputed Owner(s): WELLS F,ARGO BANK, NA Plaintiff, v. RICHARD D. ALBERTSON Name RICHARD D. ALBERTSON Address (if address cannot be reasonably ascertained, please indicate) 132 BRIAR PATCH DRIVE CARLISLE, PA 17015 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 Pennsylvania State Bank Pennsylvania State Bank C/O ROBERT D. KODAK, ESQUIRE Address (if address cannot be reasonably ascertained, please indicate) 2148 Market Street Camp Hill, PA 17001-0487 407 NORTH FRONT STREET PO BOX 11848 HARRISBURG, PA 17108-1848 ~ ~ 4. Name'and address of last recorded holder of every mortgage of record: Name None Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name None 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 Address (if address cannot be reasonably ascertained, please indicate) None WELLS FARGO BANK, NA Plaintiff, v. RICHARD D. ALBERTSON Defendant(s). CUMBERLAND COUNTY No. CIVIL-09-4033 August 2 J~, 2009 TO: RICHARD D. ALBERTSON 132 BRIAR PATCH DRIVE CARLISLE, PA 17015 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE 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 ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 6603 CARLISLE PIKE , MECHANICSBURG, PA 17050-1707, is scheduled to be sold at the Sheriffs Sale on DECEMBER 9, 2009 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $61,934.61 obtained by WELLS FARGO BANK, NA (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. 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 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Village of Hogestown, Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at a point on the southern side of the west bound lane of U.S. Route 11 at corner of land now or formerly of Stephen K. Wolfe; thence by land now or formerly of Stephen K. Wolfe, South 14 degrees 40 minutes East one hundred fifty (150) feet to a point on an alley, sometimes called Second Street; thence by the northern line of said alley, South 75 degrees 20 minutes West eighty (80) feet to a point at land now or formerly of George Waggoner; thence by land now or formerly of George Waggoner, North 14 degrees 40 minutes West one hundred fifty (150) feet to a point on U.S. Route 11; thence by the southern line of U.S. Route 11, North 75 degrees 20 minutes East eighty (80) feet to a point, the place of BEGINNING. HAVING thereon erected a double brick dwelling house and garage. BEING a part of Lot No. 40 and all of Lot No. 41 in the original Plan of Hogestown. THE description used herein is in accord with a survey made by W.G. Rechel, Registered Surveyor, on January 18, 1957. TITLE TO SAID PREMISES IS VESTED IN Richard D. Albertson, married man, by Deed from Hereward W. Ransom, administrator of the Estate of Helen R. Bryant, deceased, dated 11/21/2003, recorded 12/02/2003 in Book 260, Page 3126. PREMISES BEING: 6603 CARLISLE PIKE, MECHANICSBURG, PA 17050-1707 PARCEL NO. 38-18-1332-038 WRiiT OF EXEC T U ION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-4033 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N A , Plaintiff (s) From RICHARD D. ALBERTSON (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 $61,934.61 L.L. $.50 Interest from 7/30/09 - 12/9/09 (per diem - $10.18) -- $1,353.94 Atty's Comm % Due Prothy $2.00 Atty Paid $217.40 Other Costs Plaintiff Paid Date: 8/25/09 7 rtis R. Lon not (Seal) By: Deputy REQUESTING PARTY: Name: SHEETAL R. SHAH-JANI, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 208375 Real Estate Sale # On September 8, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA Known and numbered as, 6603 Carlisle Pike, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 8, 2009 By: c ~~ ~~~ Real Estate Coordinator 4y~ ! , <~ i _.\ `~ `..j ~. (:.. -~.~ Y l 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: October 23, October 30 and November 6, 2009 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. Writ No. 2009-4033 Civil Wells Fargo Bank, NA vs. Richard D. Albertson Atty: Daniel Schmieg By virtue of a Writ of Execution No. CIVIL-09-4033, WELLS FARGO BANK, NA vs. RICHARD D. AL- BERTSON, owner of property situate in the SILVER SPRING TOWNSHIP, Cumberland County, Pennsylvania, being 6603 CARLISLE PIKE, ME- CHANICSBURG, PA 17050-1707. Parcel No. 38-18-1332-038. Improvements thereon: RESIDEN- TIAL DWELLING. Coyne, SWO`f~N TO AND SUBSCRIBED before me this 6 day of November 2009 -, '/ Notary NOTARIAL SEAL DEBORAH A COLL{NS Notary Pubi?c CARLISLE BORO, CUM6ERLAND COUNTY My Commission Expires Apr 28, 2UI0 ~'he Patriot-News Co. 812'Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ~e ~latriot•News NOw you know 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 Leslie Kramer, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 she 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 she 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: 10/23/09 WrR No. 2009-4033 Clvll Term Wells Fargo Bank, NA 10/30/09 Vs Richard D. Albertson 11 /06/09 tty~ B virtue of a WDanlel Schmleg y rit of Execution No. CIVIL-09- .~ - - - ~'~ ' • `~- ~~~~ • - j~~~~.~•'~: ~.~'• 4033 WELLS FARGO BANK, NA V5• f ) ( LBERTSON ~ Sworn toand-subscribed before me this 1 d~of November, 2009 A.D. owner s o RICHARD D. A property situate in the SILVER SPRING ~\ ~ " TOWNSHIP, Cumberland County, ` ,G! `„ ~ ~ / _ ~ ~ ` ~ _ ~ Pennsylvania, being (Municipality) Notary PUbIIC 6603 CARLLSLE PIKE, MECHANICSBURG, PA 17050-1707 Parcel No. 38-181332-038 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING CdMMCNWERI.TH OF PFNNSYLVANI.4 Notatia9 Seal ~ Shettifl L• Kis°~e;; Notary Public City C-f t°Iarrist,Jrq, Daufrhin Courtty My Ccmmisviort E,{pir~ N ov. 26, 24311 Member, P~~~,~et,13 a ~~ Je„~ : ~t oe. ref Natari~c COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which FEDERAL HOME LOAN MTG CORP is the grantee the same having been sold to said grantee on the 3RD day of MARCH A.D., 2010, under and by virtue of a writ Execution issued on the 25TH day of AUG, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 4033, at the suit of WELLS FARGO BANK N A against RICHARD D ALBERTSON is duly recorded as Instrument Number 201007320. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~ ~ -~ day of `ZdiL.~ ~ , A.D. ~ ~ /~ rr„~~.G Recorder of Deeds