HomeMy WebLinkAbout09-7600SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA
PLAINTIFF
vs.
Jimmie B. Naugle and Occupants
204 Hummel Avenue
Lemoyne, PA 17043
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. OQ - 1466 cuiC-Tker'l
CIVIL ACTION EJECTMENT 21000
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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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
717-249-3166
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED
QUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS
SIGUIENTES,USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA
DE LADEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA
APARIENCIAESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA
CORTE ENFORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS
ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE,LA
CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED
SINPREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE
ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO OSUS
PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO
TIENEABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDECONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
06-27371
SHAPIRO & DENARDO, LLC
ATTORNEYS AT LAW
3600 Horizon Drive, Suite 150, King of Prussia, Pennsylvania 19406
GERALD M. SHA PIRO
Admitted in Illinois and Florida Only
DAVIDS. KREISMAN
Admitted in Illinois Only
CHRISTOPHER A. DeNARDO
Managing Partner
DANIELLE BOYLE-EBERSOLE +
MICHAEL J. CLARK +
ILANA ZION
LESLIE RASE
+ Also Licensed in New Jersey
Tel: (610) 278-6800, Fax: (610) 278-9980
90 DAY NOTICE PURSUANT TO PROTECTING TENANTS OF
FORECLOSURE ACT, PUBLIC LAW 111-22
TO: Tenants
204 Hummel Avenue
Lemoyne, PA 17043
AND ALL OTHER TENANTS IN POSSESSION:
AT PREMISES KNOWN AS
204 Hummel Avenue
Lemoyne, PA 17043
NOTICE IS HEREBY GIVEN, that Wells Fargo Bank, NA has purchased the
above-described property at a foreclosure sale and is the record owner of the Property.
NOTICE IS FURTHER GIVEN that, pursuant to the Protecting Tenants of
Foreclosure Act, Public Law 111-22, All Tenants are given ninety (90) day notice to
vacate the premises. If you fail to vacate the premises within the ninety (90) day period,
Wells Fargo Bank, NA will proceed to have an eviction and lockout scheduled to have
you removed from the Property.
Pursuant to Protecting Tenants of Foreclosure Act, Public Law 111-22, if you
have a pre-existing lease extending beyond ninety (90) days from the date of receipt of
this notice, you may choose to deliver a bona fide lease agreement to the attorney's office
listed below. If you choose to produce your lease agreement, you will be expected to pay
contractual rent monthly to the Wells Fargo Bank, NA for the rest of the period of your
lease agreement to the attorney's office listed below. If rent is not paid timely, Wells
Fargo Bank, NA will proceed with legal action for POSSESSION. ALL TENANTS
ARE REQUIRED TO DELIVER POSSESSION of the premises at the scheduled end of
said lease agreement.
Enclosed herewith is a copy of the recorded Deed declaring Wells Fargo Bank,
NA as the lawful owner of said premises.
I suggest you consult an Attorney or contact the undersigned to discuss the actual
date you plan to vacate the premises or submit your lease agreement pursuant to
Protecting Tenants of Foreclosure Act, Public Law 111-22.
Leslie J. Rase, Esquire
Attorney for Purchaser
Shapiro & DeNardo, LLC
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
(610)278-6800
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA
PLAINTIFF
VS.
Jimmie B. Naugle and Occupants
204 Hummel Avenue
Lemoyne, PA 17043
DEFENDANTS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: D `?- 'J G ?? Cu?f ?c
CIVIL ACTION EJECTMENT
Plaintiff hereby complains against Defendants as follows:
1. Plaintiff, Wells Fargo Bank, NA ("Plaintiff'), a corporation, has an office located
at 1 Home Campus Drive, Des Moines, IA 50328, and is properly conducting business in the
Commonwealth of Pennsylvania.
2. Defendants are Jimmie B. Naugle and Occupants ("Defendants") and they reside
at 204 Hummel Avenue, Lemoyne, PA 17043 ("the Premises").
3. The Premises, which is where the ejectment is to take place, is located at 204
Hummel Avenue, Lemoyne, PA 17043. A true and correct copy of the legal description of the
Premises, is attached hereto, incorporated herein by reference, and marked as Exhibit "A."
4. The Premises were sold at Sheriffs sale by the Sheriff of Cumberland County,
Pennsylvania, after due advertisement and according to law, under and by virtue of a Writ of
Execution issued to satisfy a Judgment In Mortgage Foreclosure entered in the Court of Common
Pleas of Cumberland County, Pennsylvania, at the suit of: Wells Fargo Bank, NA v. Jimmie B.
Naugle.
5. The case number of said Judgment is: 06-5089.
6. The sale was held on: September 2, 2009.
7. Jimmie B. Naugle was the previous owner of the Premises by virtue of a Deed
dated September 23, 2003, and recorded in the Office of the Recorder of Deeds for
CUMBERLAND County, Pennsylvania on September 25, 2003, in Deed Book 259, page 2482
CUMBERLAND County, Pennsylvania.
8. Plaintiff purchased the Premises at the Sheriffs sale.
9. The Plaintiff acquired valid title to the Premises on the date of and by virtue of
said Sheriffs sale.
10. Plaintiff is still the real owner of said Premises and is entitled to immediate
possession of the Premises.
11. The Deed in favor Wells Fargo Bank, NA was recorded with the
CUMBERLAND County Department of Records in Deed Document ID# 200933428, on
September 29, 2009.
12. Said Deed is a matter of State public record and therefore, is hereby incorporated
by reference herein as if fully set forth at length. A true and correct copy of the Sheriff's Deed,
is attached hereto, incorporated herein by reference, and marked as Exhibit "B."
13. The persons in possession of the Premises are believed to be the Defendant in this
action who are occupying the Premises without right and without claim to title.
14. Plaintiff is entitled to immediate possession of the Premises.
WHEREFORE, Plaintiff demands judgment, in ejectment, for immediate possession of
the Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in
this action.
Respectfully submitted,
SHAPIRO & DeNARDO, LLC
Date: 2 d BY:
Leslie J. Rase, Esquire
Attorney for Plaintiff
File # 06-27371
ALL THAT CERTAIN lot of land situate in the Borough of Lemoyne, County of Cumberland,
and Commonwealth of Pennsylvania, more particularly bounded and described as follows:
BEGINNING at a point, the Southwestern corner of Hummel Avenue and Second
Street(formerly Cherry Alley); thence along Hummel Avenue in a Westerly direction 40 feet to a
point; thence in a Southerly direction along the Easterly line of Lot No. 13, Section B on the
hereinafter mentioned Plan of Lots 150 feet to Peach Alley; thence in an Easterly directio along
the Northerly line of Peach Alley 40 feet to a point on the Westerly line of Second Street; thence
along Second Street in a Northerly direction 150 feet to a point, the place of BEGINNING.
HAVING thereon erected a two and one-half story frae dwelling house No. 204 Hummel
Avenue, Lemoyne, Pennsylvania.
BEING Lot No. 12 Section B on the Plan of Lots known as Plan no. 1 of riverton, said plan
being recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book J,
Vol. 4, Page 40.
BEING the same premises which Jeri Ann Blanch, executrix of the Estate of Mary Jane Lowe,
also known as Mary Jayne Long Lowe, by Deed dated September 23, 2003 and recorded in the
Cumberland County Recorder of Deeds Office on September 25, 2003 in Deed Book 259, page
2482, granted and conveyed unto Jimmie B. Naugle, married.
EXHIBIT "A"
K03
Tax Parcel No. 12-21-0265412
Know all Men by these Presents
That 1, R. Thomas Kline, Sheriff of the County of Cumberland, In the State of
Pennsylvania, for and in consideration of the sum of $1.00 (One Dollar), to me in hand
paid, do hereby grant and convey to Wells Fargo Bank, NA
Real Estate Sale No. 67
Writ No. 2006-5089 Civil Tenn
Wells Fargo Bank, NA
VS
Jimmie B. Naugle
Attorney Michael J. Clark
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of land situate in the Borough of Lemoyne, County of
Cumberland, and Commonwealth of Pennsylvania, more particularly bounded and described
as follows:
BEGINNING at a point, the Southwestern corner of Hummel Avenue and Second Street
(formerly Cherry Alley); thence along Hummel Avenue in a Westerly direction 40 feet to a
point; thence in a Southerly direction along the Easterly line of Lot No. 13, Section B on the
hereinafter mentioned Plan of Lots 150 feet to Peach Alley; thence in an Easterly direction
along the Northerly line of Peach Alley 40 feet to a point on the Westerly line of Second
Street; thence along Second Street in a Northerly direction 150 feet to a point, the place of
BEGINNING.
HAVING thereon erected a two and one-half story frame dwelling house No. 204 Hummel
Avenue, Lemoyne, Pennsylvania.
BEING Lot No. 12 Section B on the Plan of Lots known as Plan no. 1 of riverton, said plan
being recorded in the Office of the Recorder of Deeds of Cumberland County in Deed Book
J, Vol 4, Page 40.
BEING the same premises which Jeri Ann Blanch, executrix of the Estate of Mary Jane
Lowc, also known as Mary Jayne Long Lowe, by Deed dated September 23, 2003 and
recorded in the Cumberland County Recorder of Deeds Office on September 25, 2003 in
Deed Book 259, page 2482, granted and conveyed unto Jimmie B. Naugle, married.
The same having been sold by me to the said grantee on the 2nd day of September,
Anno Domini Two Thousand and Nine (2009) after due advertisement according to law,
under and by Virtue of a Writ of Execution issued on the 25`n of February Anno
Domini 2009 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and Six (2006) Number 5089 at the suit of
Wells Fargo Bank, NA -vs- Jimmie B. Naugle.
In Witness' 4'ti'ereof, I have hereunto affixed my signature this 24 day of September
Anno Domini Two Thousand and Nine (2000)
lt'.Thomas Kline, Sheriff
Commonwealth of Pennsylvania, ss.
County: of Cumberland
Before the undersigned, Curtis R. Long, Prothonotary of the Court ofCommon
Pleas of Cumberland County, Pennsylvania, personally appeared R. Thomas Kline,
Sheri ff of Cumberland County aforesaid, and in due form of law declared that the !acts
Set forth in the foregoing Deed are true, and that he acknowledged the same in order that
Said deed might he recorded. Witness my hand and. seal ofsuid Court, this 24 day
of September Anno Domini Two Thousand and Nine (2009)
A_ --?
I hereby certify that the residence
And Post Office address ofthe
Within Grantee is
1 Home Campus Drive
Des Moines, Iowa 50328
Solicitor
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200933428
Recorded On 9/29/2009 At 10:07:49 AM
* Instrument Type - DEED-SHERIFF'S
Invoice Number 53182 User ID - RAK
* Grantor- NAUGLE, JIMMIE B
* Grantee - WELLS FARGO BK N A
* Customer - CUMBERLAND SHERIFF
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JUSTICE
RECORDING FEES - $13.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
WEST SHORE SCHOOL $0.00
DISTRICT
LIMYNE BOROUGH $0.00
TOTAL PAID $50.50
* Total Pages - 5
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
RECORDER O D DS
" - Information denoted by an asterisk may change during
the verification process and may not be retkcted on this pale.
11111111111111111
VERIFICATION
The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an
officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification
on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records
maintained by persons supervised by the undersigned who maintain the business records of the Property held by
Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge,
information and belief of the undersigned.
I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO
THE PENALTIES OF 18 PA.C.S SECTION 4904 RELATING/TO UNSWORN
FALSIFICATION TO AUTHORITIES.
DATE:
111 LT Holty Lombard
COMP Y: We President Loan Documentation
File # 06-27371
FLTD-O FFICF
2o?q lJOV -4 Mi g, 3 b
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eK-=t/ 33174.4 334.8.;Z3
A--fi c2 3,2-9 yv
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
Wells Fargo Bank, NA
vs.
Jimmie B. Naugle
?axrrtt? cif ? u rn tern{???
FILED-0!7r-2E
2009NOY 20 AM 8.43
CUi'? ?a Ty
Case Number
2009-7600
SHERIFF'S RETURN OF SERVICE
11/17/2009 01:27 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on
November 17, 2009 at 1327 hours, he served a true copy of the within Complaint in Ejectment, upon the
within named defendant, to wit: Jimmie B. Naugle, by making known unto himself personally, at 204
Hummel Avenue Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time
handing to him personally the said true and correct copy of the same.
11/17/2009 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: Occupants of 204 Hummel Avenue Lemoyne, PA
17043, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in
Ejectment as not found as to the defendant Occupants. Jimmie B. Naugle is the only resident at this
address.
SHERIFF COST: $63.40
November 18, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
By
y Sheriff
(c; cote? ySuae She, f, ie eosoft inc.
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I Employee # : 175T~235'b93ATURE $~'AFloyeeVName: NAUGLE, JIMMIE
Week Ending 1 111 5/2 0 09 Check # 74176 7 417 6
REGULAR OVERTIME DOUBLE SICK VAC HOL OTHER NONTAX GROSS FICA FED WIH ST W1H MEDICAR LO W/H NET
CURRE NT
HRS 40.00 6.50 0.00 0.00 0.00 0.00 46.50
DOL 440.00 107.25 0.00 0.00 0.00 0.00 0.00 0.00 547.25 33.93 10.40 16.80 7:94 5.47 301.91
YTD
HRS 1465.55 201.66 0.00 0.00 0.00 8.00 1675.21
DOL 15289.38 3141.22 0.00 0.00 0.00 88.00 0.00 0.00 18518.60 1148.18 976.65 568.51 268.54 185.20 9192.68
FILING STATUS: FDMW 02 ~ PA 02 ~ PA 02
COMPANY WORK SITE(S): XPEDX R 40.00 ~ 11.00, XPEDX OT 6.50 ~ 16.50
ADJUSTMENTS CURRENT YTD ADJUSTMENTS CURRENT YTD
CHILD SUPPORT PAYMENT 170.31 6110.20 OCCUPATIONAL TAX
UL'EMPLOYMENT TAX 0.00
0.99 52.00
16.69
TOTAL DEDUCTIONS: 170.80 6178.84
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5HAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY LD. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 1 S0
KING OF PRUSSIA, PA 19406
TELEPHONE:, (610)278-6800.
S & D FILE NO. 06-27371
Wells Fargo Bank, NA
PLAINTIFF
v.
Jimmie B. Naugle and Occupants
DEFENDANTS
F1tFf)-0~"'1{:E
20I O JU~i 24 ~P9 I I= i 0
CUM~~.~~ .~;~~~ ;~S:;G(~TY
~EP~N~YL~;^~dffii
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-7600 Civil. Term
CERTIFICATE OF SERVICE
I, Leslie J. Rase, Esquire, Counsel for Plaintiff, hereby certify that on ~f1-o1~ ~~~ , a
true and correct copy of the attached Argument .Notice was served by mailed same by regular
mail, postage prepaid, to:
Jimmie B. Naugle
204 Hummel Avenue
.Lemoyne, PA 17043
Occupants
204 Hummel Avenue
Lemoyne, PA 17043
SHAPIRO & DENARDO, LLC
BY: ,-~'
Leslie J. Rase, Esquire
•1, r
Ofd ce of the Prothonotary
Cumberland County
David D. Buell
Prothonotary
Leslie J. Rase, Esq.
3600 Horizon Dr., Ste. 150
King of Prussia, PA 19406
DATE: June 17, 2010
TO Attorney Rase:
THIS IS TO NOTIFY YOU THAT CASE NUMBER 09-7600
Wells Fargo Bank, N.A.
VS.
Jimmie B. Naugle and Occupants
HAS BEEN LISTED FOR ARGUMENT ON July ._7, 2010
Cumberland County Argument Court Rules 1028(c),
1034(a) and 1035.2(a) shall be strictly enforced. If the
issue was listed for prior argument you must re-file
your brief as per Local Rule 1028(c)10.
David D. Buell
Prothonotary
WELLS FARGO BANK, NA
PLAINTIFF
V.
JIMMIE B. NAUGLE AND
OCCUPANTS,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 09-7600 CIVIL
IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT -CIVIL ACTION
EJECTMENT
BEFORE OLER. J. AND EBERT, J.
ORDER OF COURT
AND NOW, this 12th day of July, 2010, upon consideration of Plaintiff's Motion for
Summary Judgment and after oral argument,
IT IS HEREBY ORDERED AND DIRECTED that the Plaintiff's Motion for
Summary Judgment is GRANTED. Judgment is entered in favor of the Plaintiff and
against Defendant, Jimmie B. Naugle and Occupants, and accordingly possession of
the real property located at 204 Hummel Avenue, Lemoyne, PA 17043 is awarded to
the Plaintiff, Wells Fargo Bank, NA.
By the Court,
'~ Leslie J. Rase, Esquire
Attorney for Plaintiff
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
Jimmie B. Naugle and Occupants,
Defendant
204 Hummel Avenue
Lemoyne, PA 17043
bas r?ppi~s I~-~a.;l~ ~~la/i~
~~L
~~
M. L. Ebert, Jr., J.
:~ :~'~ Z I i~~ 010Z
`'~' '~;1 ~;Hi Ali
AL~7 w
~-r r I ~ t'"
_. _ .,_ _ ,.1-~11~
' i'
SHAPIRO & DeNARDO, LLC
BY: LESLIE'J. RASE,BSQUIRE f~'E ~
ATTORNEY LD. NO: PA Bar # 58365 T~ ; - ":~ ~~
3600 HORIZON DRIVE, SUITE 150 ~ c qqp. I1 PM 3~ 57
KING OF PRUSSIA, PA 19406 2~ ~ ,~,~ , ~, ~ ; ~ ; ~:
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371 ~+; ".' _ ~ . .: ~,i-~;
Wells Fargo Bank, NA ; COURT OF COMMON PLEAS '~'= ~ -
PLAINTIFF ~ CUMBERLAND COUNTY
VS.
Jimmie B. Naugle and Occupants ~ NO: 09-7600 CIVIL TERM
204 Hummel Avenue
Lemoyne, PA 17043
DEFENDANTS
PRAECIPE FOR JUDGMENT FOR POSSESSION
IN ACCORDANCE WITH COURT ORDER
Enter Judgment for immediate possession of the Premises located at: 204 Hummel Avenue, Lemoyne,
PA 17043, in favor of Plaintiff and against the Defendants above captioned in accordance with the attached
Order of Court.
Les ie J. Rase, Esquire
Attorney for Plaintiff
AND NOW, judgment for immediate possession of the Premises located at 204 Hummel. Avenue,
Lemoyne, PA 17043 is entered in favor of the Plaintiff and against t e D fendant.
Pr . Prothy.
~1~,~ ~A~f t-'1
e~
ay ~~ ~y
WELLS FARGO BANK, NA
PLAINTIFF
V.
JIMMIE B. NAUGLE AND
OCCUPANTS,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 09-7600 CIVIL
IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT -CIVIL ACTION
EJECTMENT
BEFORE OLER, J. AND EBERT, J.
ORDER OF COURT
AND NOW, this 12th day of July, 2010, upon consideration of Plaintiff's Motion for
Summary Judgment and after oral argument,
IT IS HEREBY ORDERED AND DIRECTED that the Plaintiff's Motion for
Summary Judgment is GRANTED. Judgment is entered in favor of the Plaintiff and
against Defendant, Jimmie B. Naugle and Occupants, and accordingly possession of
the real property located at 204 Hummel Avenue, Lemoyne, PA 17043 is awarded to
the Plaintiff, Wells Fargo Bank, NA.
By the Court,
~~
M. L. Ebert, Jr., J.
Leslie J. Rase, Esquire
Attorney for Plaintiff
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
Jimmie B. Naugle and Occupants,
Defendant
204 Hummel Avenue
Lemoyne, PA 17043
bas
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA
PLAINTIFF
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. ~~~ ~'lo~O
Jimmie B. Naugle and Occupants
204 Hummel Avenue
Lemoyne, PA 17043
DEFENDANTS
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF: ~~~~
l s.s.:
COUNTY OF:~/, ~ / (~_
THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon
investigations made and records maintained by us either as Plaintiff or as servicing agent of the Plaintiff herein
and that the above named Defendant is not in the Military or Naval Service of the United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last
known residence and employment of each Defendant are as follows:
Defendant: Jimmie B. Naugle
Age: Over 18
Residence: 204 Hummel Avenue, Lemoyne, PA 17043
Employment: Unknown
Defendant: OCCUPANT
Age: Unknown
Residence: 204 Hummel Avenue, Lemoyne, PA 17043
Employment: Unknown /
Title:
Sworn to and subsc ibed
before met is day
of b 2009.
o ary Public
~,~ ts~ ANNA it+l. NI=LEON
:° :Commission Number 716748
My Commission E~ires
ow May 28, 2011
06-27371
Holy Lombard
Vice President Loan Documenta~on
.
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING'OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D-FILE NO. 06-27371
Wells Fargo Bank, NA ~ COURT OF COMMON PLEAS
l Home Campus Drive CUMBERLAND COUNTY
Des Moines, Iowa 50328
PLAINTIFF ~ NO: 09-7600 CIVIL TERM
VS.
Jimmie B. Naugle and Occupants
204 Hummel Avenue
Lemoyne,. PA .17043. ;
DEFENDANTS ;
CERTIFICATION OF ADDRESS
Thereby certify that the correct addresses of the judgment creditor (Plaintiff) and that the
last known address of the judgment Debtors (Defendants) are as above.
SHAPIRO & DeNARDO, LLC
L e, Esquire
Attorney for Plaintiff
~;:
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY LD. NO: PA Bar # 58365
3600 HORIZON DRNE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA ~ COURT OF COMMON PLEAS
PLAINTIFF .CUMBERLAND COUNTY
VS.
Jimmie,B. Naugle and Occupants ~ N0: 09-7600 CIVIL TERM
204 Hummel Avenue ;
Lemoyne,' PA 17043
DEFENDANTS
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the attached papers on
/b ' / y to all parties named herein at their last known address or upon their
attorney of record as below listed by regular mail, postage prepaid:
Jimmie B. Naugle, 204 Hummel Avenue, Lemoyne, PA 17043
Occupants, 204 Hummel Avenue, Lemoyne, PA 17043
SHAPIRO & DeNARDO, LLC
Date: ~'- /d /~ BY: -''``~"
Leslie J. Rase, Esquire
Attorney for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
David D. Buell, Prothonotary
TO: Jimmie B. Naugle
204 Hummel Avenue
Lemoyne, PA 17043
Wells Fargo :Bank, NA ~ COURT OF COMMON PLEAS
PLAINTIFR CUMBERLAND COUNTY
VS.
Jimmie B. Naugle and Occupants ~ NO: 09-7600 CIVIL TERM
204 Hummel Avenue ;
Lemoyne, PA 1.7043
DEFENDANTS
NOTICE
.Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
David D. Buell
Prothonotary
[XX] Judgment by Court.Order
~f " ~ro
[XX] Judgment for Possession
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY LESLIE J. RASE,. ESQUIRE. BY CALLING (610)278-6800.
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRNE, SUITE 150
.KING OF PRUSSIA, PA 19406
TELEPHONE:. (610)278-6800
S & D FILE NO'. 06-27371
Wells'Fargo Bank, NA
PLAINTIFF ;
VS. ;
Jimmie B. Naugle and Occupants
204 Hummel Avenue
Lemoyne, PA 17043
DEFENDANTS
~iL~_~ ..
aao ~ tt PN ~~ 5?
i- ~. ,.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-7600 CIVIL TERM
PRAECIPE FOR WRIT OF POSSESSION
TO THE PROTHONOTARY:
Kindly issue a Writ of Possession in the above matter for property located at 204
Hummel Avenue, Lemoyne, PA 17043 as more fully described in the Complaint.
(Costs to be added) $
~a'~4.oo PIS A7f`/
1o3.4b ~~'
?8.50 w
h{.oo
~11-a.ga - Po ~
~a.oo D~~ [~o
~~ 39~8g7
e~ ~.y6 4y9
~ ~~
IRO & DeNARDO, LLC
LESLIE J. RASE, ESQUIRE
,, f ~!
1of 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA
VS.
No. 09-7600 Civil Term
JIMMIE B. NAUGLE and OCCUPANTS
204 HUMMEL AVENUE
LEMOYNE, PA 17043
Costs
Attorney's $ 179.90
Plaintiffl s $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
WELLS FARGO BANK, NA
being: (Premises as follows):
204 HUMMEL AVENUE, LEMOYNE, PA 17043
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
Da uell, rothonotary,
Common Pleas Court of Cumberland County, PA
Date 8/11/10
(Seal)
,~ i~,
2of2
No 09-7600 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA
VS.
JIMMIE B. NAUGLE and OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 179.90
Plff (s~ $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
LESLIE J. RASE, ESQUIRE - ID# 58365
SHAPIRO & DeNARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
610-278-6800
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the day of I caused the within
named , to have possession of the premises described with the
appurtenances, and
Sworn and subscribed to before me this
Day of ,
Prothonotary
So Answers,
Sheriff
By
Deputy
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA
PLAINTIFF
VS.
Jimmie B. Naugle and Occupants
204 Hummel Avenue
Lemoyne, PA 17043
DEFENDANTS
Fi~r~-a~~ic~
4F Tt~E ~~t~~'~-fO~OTAR`~
2QlQ SEP 27 ~~P# !0~ 00
~U~iBErr~LA~~O GOU~lT``
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 09-7600 CIVIL TERM
PRAECIPE TO TISSUE THE WRIT OF POSSESSION
TO THE PROTHONOTARY:
Kindlys~- issue the Writ of Possession in the above matter for property located at 204
Hummel Avenue, Lemoyne, PA 17043 as more fully described in the Complaint.
(Costs to be added) $
a ~t .oo ~cL ~~.
103. ~o ~
78.50 u
I ~ . nb ~~
a~. oo
$103.90 ~ PA AYrY
C'1~ 3S3'/3/
SHA O & DeNARDO, LLC
LESLIE J. RASE, ESQUIRE
lof 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA
VS.
No. 09-7600 Civil Term_
JIMMIE B. NAUGLE and OCCUPANTS
204 Hummel Avenue
Lemoyne, PA 17043
Costs
Attorney's $ 203.90
Plaintiff's $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
WELLS FARGO BANK, NA
being: (Premises as follows):
204 HUMMEL AVENUE, LEMOYNE, PA 17043
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
Da uell, Prothonot ,
Common Pleas Court of Cu Berland County, PA
Date 9/27/10
(Seal)
r
2 of 2
No 09-7600 Civil Term
Sworn and subscribed to before me this
Day of ,
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA
JIMMIE B. NAUGLE and OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 203.90
Plff (s~ $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
LESLIE J. RASE, ESQUIRE - ID# 58365
SHAPIRO & DeNARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
610-278-6800
Attorney for Plaintiff (s)
Where papers may be served
By virtue of this writ, on the day of I caused the within
named , to have possession of the premises described with the
appurtenances, and
Prothonotary
So Answers,
Sheriff
By
Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
ti., ~ of "~ tutll,nt
~~,, ;,~~
Fil ~i~-QF'FICE
OF T~l* ,'~_~"~~'C~gTARY
Zfl~O ~~~y! -2 P~~ 2~ ~4
I~U~I~:~ ,tip =?~.1LL1 [~~~U~bI~Y
Wells Fargo Bank, NA Case Number
vs.
Jimmie B. Naugle 2009-7600
SHERIFF'S RETURN OF SERVICE
10/13/2010 07:12 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Octobe
13, 2010 at 1912 hours, he served a true copy of the within writ of possession, in the above entitled action
upon the within named defendant, to wit: Jimmie B. Naugle, by making known unto Jimmie b. Naugle,
personally, at 522 Market Street, Apartment 1, Lemoyne, Cumberland County, Pennsylvania 17043 its
contents and at the same time handing to him personally the said true and correct copy of the same.
11/02/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is
returned STAYED, per request from plaintiff's attorney.
SHERIFF COST: $55.94
November 02, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
~,
Sharon R. Lantz
a.,~D~/. ~'~
~-~ 7~~~~
,~'~" ~ .~b~s~
•;c feur;ySuitc 5herdt. Te~ecso°t. 1~?:.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
vo~~}~tx of ~'tttt~t~erf~rt0
r;
~<,t ~~
r
4FFi~E OF T ~e ~uERIFP
F~~~D-~FFi%I"
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Wells Fargo Bank, NA
vs.
Jimmie B. Naugle
Z~~~~~~ ~~i A~~~~ ~~
~"~JME3~RL~ft~ ;c~~~~''.~
~F~~`~~i~~~r`~~'~~/z.
Case Number
2009-7600
SHERIFF'S RETURN OF SERVICE
10/13/2010 07:12 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October
13, 2010 at 1912 hours, he served a true copy of the within writ of possession, in the above entitled action,
upon the within named defendant, to wit: Jimmie B. Naugle, by making known unto Jimmie b. Naugle,
personally, at 522 Market Street, Apartment 1, Lemoyne, Cumberland County, Pennsylvania 17043 its
contents and at the same time handing to him personally the said true and correct copy of the same.
SO ANSWERS,
~~"4'- ~-~--.""."
October 14, 2010 RON R ANDERSON, SHERIFF
(cl CouriySuite Sheriff, Teieoso`t. Ir:~,
~,
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
~Q~~~tti~, of ~nm(,~,~.~, try
~1~~Q-~~~~CE
~F ~~~~ t ~`~?THD~OTARY
W ltd ~L.1 ~l~Y~ f~f`c t.J Vi.l ~~'~T`~
Wells Fargo Bank, NA Case Number
vs. 2009-7600
Jimmie B. Naugle
SHERIFF'S RETURN OF SERVICE
08/20/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 20, 2010 at
2015 hours a true copy of the within writ of possession was attempted to be served upon the defendant, to
wit: Occupants, of 204 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. Property
was found to be vacant. Therefore, the within Writ of Possession is being returned with no service as the
defendant, Occupant was NOT FOUND.
08!20/2010 08:15 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on August 20,
2010 at 2015 hours a true copy of the within writ of possession was attempted to be served upon the
defendant, to wit: Jimmie B. Naugle, of 204 Hummel Avenue, Lemoyne, Cumberland County,
Pennsylvania 17043. Property was found to be vacant. Therefore, the within Writ of Possession is being
returned with no service as the defendant, Jimmie B. Naugle was NOT FOUND.
11/02/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of possession is
returned STAYED, per request from plaintiff's attorney.
SHERIFF COST: $66.14
November 02, 2010
SO ANSWERS,
`"~.
RON R ANDERSON, SHERIFF
By
haron R. La z
,~ ~ ~s~
;C,1 (~nll:'.'t S~ISw J`F;;':.J{, TOf?O50'; ~, ~I^:i;.
.. ,
a
lof 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA
VS. No. 09-7600 Civil Term_
JIMMIE B. NAUGLE and OCCUPANTS
204 HUMMEL AVENUE
LEMOYNE, PA 17043
Costs
Attorney's $ 179.90
Plaintiff's $
Prothonotary $ 2.00
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
WELLS FARGO BANK, NA
being: (Premises as follows):
204 HUMMEL AVENUE, LEMOYNE, PA 17043
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
C
David D. Buell, Protho otary,
Common Pleas Court f Cumberland County, PA
Date 8/11/10
(Seal)
' ~
2of2
No 09-7600 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA
VS.
JIMMIE B. NAUGLE and OCCUPANTS
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 179.90
Plff (s~ $
Prothy $ 2.00
Sheriff $
Plaintiff (s) attorney name and address:
LESLIE J. RASE, ESQUIRE - ID# 58365
SHAPIRO & DeNARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
610-278-6800
Attorney for Plaintiff (s)
By virtue of this writ, on the
named
appurtenances, and
Where papers may be served
day of I caused the within
_, to have possession of the premises described with the
Sworn and subscribed to before me this
Day of ,
Prothonotary
So Answers,
Sheriff
By
Deputy
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA
PLAINTIFF
VS. '
Jimmie B. Naugle and Occupants
DEFENDANT
OF THE PROTHONOTAR
Y
1010 NOV 23 4H114.00
CUMBERLAND COUNTY
"°NNSYIVANIA
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 09-7600 CIVIL TERM
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the Judgment entered on August 11, 2010 in the above entitled action
vacated without prejudice to Plaintiff.
SHAPIRO & DeNARDO, LLC
BY:
L ie J. Rase, Esquire
Attorney for Plaintiff
?4to
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA ;
PLAINTIFF
VS. '
Jimmie B. Naugle and Occupants
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 09-7600 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the Praecipe to Vacate
Mortgage Foreclosure Judgment on / 1- 0 -/d to all parties named herein at their
last known address or upon their attorney of record as below listed by regular mail, postage
prepaid:
Jimmie B. Naugle
204 Hummel Avenue
Lemoyne, PA 17043
Occupants
204 Hummel Avenue
Lemoyne, PA 17043
SHAPIRO & DeNARDO, LLC
BY:
Leslie J. Rase, Esquire
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA ;
PLAINTIFF
VS. ;
Jimmie B. Naugle and Occupants
DEFENDANT
OF THE PROTWpMOTARY
2010 NOY 23 dM I I: 00
CUMBERLAND COUNTY
PENNSYLVANIA
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 09-7600 CIVIL TERM
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above-captioned matter SETTLED, DISCONTINUED AND ENDED,
without prejudice.
SHAPIRO & DeNARDO, LLC
BY:
Leslie J. Rase, Esquire
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: LESLIE J. RASE, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 06-27371
Wells Fargo Bank, NA
PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
VS.
Jimmie B. Naugle and Occupants
DEFENDANT
NO: 09-7600 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that I have served a true and correct copy of the Praecipe to Settle,
Discontinue and End on ! I - / g "/ 6 to all parties named herein at their last known
address or upon their attorney of record as below listed by regular mail, postage prepaid:
Jimmie B. Naugle
204 Hummel Avenue
Lemoyne, PA 17043
Occupants
204 Hummel Avenue
Lemoyne, PA 17043
SHAPIRO & DeNARDO, LLC
BY:
Leslie J. Rase, Esquire
Attorney for Plaintiff