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HomeMy WebLinkAbout10-273416 FllED-?r ? ??P??Y 2010 AE'4i 23 Fn 1' 53 rt ,1 ?i?j fF' 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 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 236585 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS 445 RUN ROAD CARLISLE, PA 17015-7732 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 16 - a73? CUMBERLAND COUNTY CIVII. ACTION - I.AW COMPLAINT IN MORTGAGE F0RF.C1.0SI1RF. ? CL c*iL g3`13sv File #: 236585 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 236585 1. Plaintiff is WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS 445 RUN ROAD CARLISLE, PA 17015-7732 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 10/06/2003 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to WASHINGTON MUTUAL BANK, FA which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1841, Page 0257. By Assignment of Mortgage recorded 04/03/2007 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 735, Page 3059. 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 05/01/2009 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 #: 236585 6. The following amounts are due on the mortgage: Principal Balance $91,488.81 Interest $4,704.70 04/01/2009 through 04/20/2010 (Per Diem $12.22) Attorney's Fees $650.00 Cumulative Late Charges $552.42 10/06/2003 to 04/20/2010 Property Inspections/Property Preservations $30.00 Non Sufficient Funds Charge $15.56 Costs of Suit and Title Search $550.00 Escrow Deficit $1,2.45-26 TOTAL $99,236.75 7 8 Plaintiff is not seeking a judgment of personal liability (or an in nersonam 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. 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. File #: 236585 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $99,236.75, together with interest from 04/20/2010 at the rate of $12.22 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. 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 ? 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 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 236585 C LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Subdivision Plan for Donald B. Rudy, recorded in the Office of Recorder of Deeds for Cumberland County in Plan Book 38, Page 20, as follows: BEGINNING at a spike in the center line of Township Road T-454, at corner of land now or formerly of Robert Martin; thence by said land now or formerly of Robert Martin, north 78 degrees 42 minutes 51 seconds East 363 feet to an iron pin; thence by other land now or formerly of Donald B. Rudy, South 10 degrees 16 minutes 58 seconds East 675.21 feet to an iron pin; thence by land now or formerly of John C. Foster, South 67 degrees 00 minutes West 322.45 feet to an iron pin; thence by land now or formerly of Robert L. Kurtz, North 23 degrees 00 minutes West 353.27 feet to an iron pin on the Eastern side of Township Road T-454 aforesaid, said iron pin being 16.471 feet from the center line of said Road; thence along and through said Road, North 6 degrees 01 minutes 21 seconds West 395.35 feet to the point of BEGINNING. CONTAINING 5.984 acres and being Lot No. 2 on the aforesaid Subdivision Plan. Being Known as and numbered 445 Run Road, Carlisle, Pennsylvania. PARCEL NO. 14-05-0421-031H PREMISES: 445 RUN ROAD, CARLISLE, PA 17015-7732 File #: 236585 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. Attorney for Plaintiff DATE: `l -o (r 10 File #: 236585 SHERIFF'S OFFICE OF CUMBERLAND COUNTY~~~~ r~~_~+r,~ Ronny RAnderson 'Jr T}-I~ f`;;`"if~ I"''aO~,~RY Sheriff ~~~~titti, o~ C':~un~~~,r~~~ Jody S Smith ~~~~ J~i';r ~~ ~~ ~' v~ Chief Deputy ~ '~' ~ .~ . r, Richard W Stewart ~~- ~ C~.1"r ~ -"~It~ Solicitor r~ u~ c~F -~~ ~..~~~FF r t. ~;'~ ~ ! ~,`~ ~ r'+, Wells Fargo Bank, NA Case Number vs. 2010-2734 Harry G. Raudabaugh (et al.) SHERIFF'S RETURN OF SERVICE 05/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 25, 2010 at 1351 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Donna J. Raudabaugh. After several attempts at 445 Run Road, Carlisle, PA 17015 the Complaint in Mortgage Foreclosure has expired. 05/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 25, 2010 at 1351 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Donna J. Raudabaugh. After several attempts at 25 Horseshoe Road, Carlisle, PA 17013 the Complaint in Mortgage Foreclosure has expired. 05/25/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on May 25, 2010 at 1351 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Harry G. Raudabaugh. After several attempts at 445 Run Road, Carlisle, PA 17015 the Complaint in Mortgage Foreclosure has expired. 06/22/2010 07:35 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2010 at 1935 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donna J. Raudabaugh, by making known unto herself personally, at 104 November Drive Apartment 6, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. .~f .%' NOAH CL E, DEPUTY SHERIFF COST: $100.00 June 23, 2010 SO ANSWERS, ~. RON R ANDERSON, SHERIFF c) CnuriSuite Sheriff. Teieosoft Inc. ~ F~LFz r ~ -i ,~R,Y 2010 .i[!'_ ! `~ ~~'11 ~ • i ~. c~F~ emu.. ~ ~,~~~~ 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 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs. HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DNISION CUMBERLAND COUNTY No. 10-2734-CNIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE ~+~ 9 7 r9 0 ~-.f 0 TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ELAN 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 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff Date: July 14.2010 /j j 1, Svc Dept. File# 236585 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson - S_t _ I Sheriff Uptr of +e<'np~~r~,~ ,,.- 7~ - :, ,, Jody S Smith ~~ ~g Chief Deputy ~, `. .~ `~ , ~.~~r~~~ ~ e ... ,_ ~~. , r`E ~"~ ~g Richard W Stewart r- - ~O10 l~,)(r (( t~tY1 ~: 3 Solicitor r~~E~~ r.;G _~~~iFF r ~ ,, s,,v : - ; ~ r~ _ ~ Wells Fargo Bank, NA vs. Case Number Harry G. Raudabaugh (et al.) 2010-2734 SHERIFF'S RETURN OF SERVICE 08/09/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Harry G. Raudabaugh, 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 Harry G. Raudabaugh. Request for service at 445 Run Road, Carlisle, PA 17015 is vacant. However, The Carlisle Postmaster has confirmed they are delivering Harry G. Raudabaugh's mail to 445 Run Road, Carlisle, PA 17015. SHERIFF COST: $38.40 August 09, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CauntySuite Sheriff. Teleosoft, Inc. r?A 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 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs. kFIL?,p ,OFFICE OF THE PROTNONOTAR 2010 DEC -2 AM 11:22 CUMBERLAND COUNTY PENNSYLVANIA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY HARRY G. RAUDABAUGH : No. 10-2734-CIVIL TERM DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE *a `o? ?? as TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAIq &.,KCHMIEG. LLP By: ? awrence T. Wan, Esq., Id. o. 32227 ? Francis S. linan, 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 Sri tava, Esq., Id. No. 202331 ? Jay ones, Esq., Id. No. 86657 ? P er 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 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorneys for Plaintiff Date: December 1, 2010 /hzc, Svc Dept. File# 236585 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor , .%. O, _. FILED-OFFICE O 2010 DEC 20 Pty 2: 57 CUMBERLAND COUN" , PENNSYLVAf<d1if1% Wells Fargo Bank, NA I Case Number vs. 2010-2734 Harry G. Raudabaugh (et al.) SHERIFF'S RETURN OF SERVICE 12/13/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Harry G. Raudabaugh, 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 Harry G. Raudabaugh. Request for service at 25 Horseshoe Road, Carlisle, Pennsylvania 17013 the defendant was not found. 12/13/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Harry G. Raudabaugh, 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 Harry G. Raudabaugh. Request for service at 445 Run Road, Carlisle, Pennsylvania 17013 the defendant was not found. 12/15/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Harry G. Raudabaugh, 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 Harry G. Raudabaugh. Request for service at 104 November Drive, Camp Hill, Pennsylvania 17011 the defendant was not found. Harry G. Raudabaugh is currently incarcerated at The Cumberland County Prison. Deputies were advised, Harry G. Raudabaugh has filed bankruptcy under case number 1:09-bk-0471 1 -MDF. SHERIFF COST: $99.30 December 15, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r 1J_O-O 1~ IC4 Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 2011 FEB - P 3: O ?f ?•- 0 ; t" :ate i I.,.,?! ?.? Wells Fargo Bank, NA Case Number vs. Harry G. Raudabaugh (et al.) 2010-2734 SHERIFF'S RETURN OF SERVICE 02/01/2011 09:19 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2011 at 0919 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Harry G. Raudabaugh, by making known unto himself personally, at The Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. MI HELLE GUTSHALL, DEPUTY SHERIFF COST: $33.40 February 02, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 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 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Attorney for Plaintiff ra .- O Z C-) : CUMBERLAND COUNTY VS. : COURT OF COMMON PLEAS HARRY G. RAUDABAUGH CIVIL DIVISION DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS A/K/A JANICE No. 10-2734-CIVIL TERM LANDIS A/K/A DONNA J. STEVENSON A/K/A JANICE M. STOLTENBURG PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES aohE'k 14.00 1?4 aft Q*gts* $ 236585 TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against HARRY G. RAUDABAUGH, and DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS A/K/A JANICE LANDIS A/K/A DONNA J. STEVENSON A/K/A JANICE M. STOLTENBURG, 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 $99,236.75 Interest - 04/21/2010 to 03/08/2011 $3,934.84 TOTAL $103,171.59 I hereby certify that (1) the Defendants' last known addresses are 1101 CLAREMONT ROAD, INMATE # 10-2813, CARLISLE, PA 17015, 445 RUN ROAD, CARLISE, PA 17015- 7732, and 104 NOVEMBER DRIVE, APT 6, CAMP HILL, PA 17011, and?(0-that notice has been given in accordance with Rule 237.1, copy attached. U Lawrence T. Phelan,%W., 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 2 heetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: - PHS # 236585 PROTHONOTARY ::Z?l cc: Robert L. O'Brien, Esquire of O'Brien & Scherer 19 WEST SOUTH STREET CARLISLE, PA 17013 236585 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 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. HARRY G. RAUDABAUGH Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION DONNA J. RAUDABAUGH A/K/A No. 10-2734-CIVIL TERM DONNA J. LANDIS A/K/A JANICE LANDIS A/K/A DONNA J. STEVENSON A/K/A JANICE M. STOLTENBURG AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the 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. 236585 (b) that defendant HARRY G. RAUDABAUGH is over 18 years of age and resides at 1101 CLAREMONT ROAD, INMATE # 10-2813, CARLISLE, PA 17015 and 445 RUN ROAD, CARLISE, PA 17015-7732 (c) that defendant DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS A/K/A JANICE LANDIS A/K/A DONNA J. STEVENSON A/K/A JANICE M. STOLTENBURG is over 18 years of age and resides at 104 NOVEMBER DRIVE, APT 6, CAMP HILL, PA 17011 and 445 RUN ROAD, CARLISE, PA 17015-7732. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. March,8, 2011 ? Lawrence T. Phelalh,-B'sq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 CTheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff 236585 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISON V. Plaintiff NO. 10-2734-CIVIL TERM HARRY G. RAUDABAUGH CUMBERLAND COUNTY DONNA J. RAUDABAUGH, A/K/A DONNA J. LANDIS Defendant(s) TO: DONNA J. RAUDABAUGH, A/K/A DONNA J. LANDIS 445 RUN ROAD CARLISLE, PA 17015-7732 DATE OF NOTICE: February 23, 2011 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. EWPORTANT 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. 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. PHS # 236585 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: i. 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 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 3095,1197 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 236585 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISON V. Plaintiff NO. 10-2734-CIVIL TERM HARRY G. RAUDA13AUGH CUMBERLAND COUNTY DONNA J. RAUDABAUGH, A/K/A DONNA J. LANDIS Defendant(s) TO: HARRY G. RAUDABAUGH 1101 CLAREMONT ROAD, INMATE # 10-2813 CARLISLE, PA 17015 DATE OF NOTICE: February 23, 2011 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. 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. PHS # 236585 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 11 By: v 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 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951- Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 236585 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISON V. Plaintiff NO. 10-2734-CIVIL TERM HARRY G. RAUDABAUGH CUMBERLAND COUNTY DONNA J.RAUDABAUGH, A/K/A DONNA J. LANDIS Defendant(s) TO: DONNA J. RAUDABAUGH, A/K/A DONNA J. LANDIS 104 NOVEMBER DRIVE, APT 6 CAMP HILL, PA 17011 DATE OF NOTICE: February 23, 2011 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. 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. PHS # 236585 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 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 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 236585 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISON V. Plaintiff NO. 10-2734-CIVIL TERM HARRY G. RAUDABAUGH CUMBERLAND COUNTY DONNA J. RAUDABAUGH, A/K/A DONNA J. LANDIS Defendant(s) TO: HARRY G. RAUDABAUGH 445 RUN ROAD CARLISLE, PA 17015-7732 DATE OF NOTICE: February 23, 2011 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. 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. PHS # 236585 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 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 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 j William E. Miller, Esq., Id. No. 308951 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 236585 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISON V. Plaintiff NO. 10-2734-CIVIL TERM HARRY G. RAUDABAUGH CUMBERLAND COUNTY DONNA J. RAUDABAUGH, A/K/A DONNA J. LANDIS Defendant(s) TO: HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH, A/K/A DONNA J. LANDIS C/O ROBERT L. O'BRIEN, ESQUIRE O'BRIEN BARIC & SCHERER, 19 WEST SOUTH STREET CARLISLE, PA 17013 DATE OF NOTICE: February 23, 2011 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. IlVIPORTANT 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. 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. PHS # 236585 Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: "mil/ v 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 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951-? Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 236585 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-2734 Civil 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 HARRY G. RAUDABAUGH, DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $103,171.59 L.L.$.50 Interest FROM 03/9/11 to Date of Sale ($16.96per diem) - - $3,103.68 Atty's Comm % Due Prothy $2.00 Atty Paid $393.60 Other Costs Plaintiff Paid Date: 4/5/11 David D. B ell, Prothonot (Seal) By: Depu REQUESTING PARTY: Name: DANIEL G. SCHMIEG, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 N It PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO BANK, N.A. Plaintiff COURT OF COMMON PLEAS v HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 03/09/2011 to Date of Sale ($16.96 per diem) TOTAL s 1a.OO1:?a, at? 38. qo cw-- q°t. 10 a /I 33.4o«-V 9a,, 00 Ib,O011k I0,66(4k ILt.Dvvu Qur. M ( ??3g3.Coa ?Id aol?_ Note: Please attach description of property. PHS # 236585 ? OD (u ?. ?r . 5'D LL. CIVIL DIVISION NO.: 10-2734-CIVIL TERM CUMBERLAND COUNTY rn co :Mo. -: t $103,171.59 p r-- CA --t c") Cc-7 3103.68 DC-) xs ?z, 106.275.27 Attorney for-Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 WpDaniel!G. iS. Hallinan, Esq., Id. No. 62695 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Pk of d oa O? O? OW U d z W? a W 3 > cn a ti A d ?x p?q w y,ZA A 0 U O O ? w top a Q z M a 00 N "' ¢ O ? w O A W ? o QOo ??¢ 3 y 0¢w? -'w~ ¢ x U Q ° U O N tn NO?OO?v1 M - d OO?ONC, ? ?O N ?p t? r tI1 ,.q C.4 0?0 p M g Z N N O Q? O Mc O O OzC-4 Ob OZOM alb--d-dzzz 000 z"6 ?z W? cb vb d-„c on wb ?, ? oow ?www w 00 40 a x " 3 0 45 .14 1. -01 u ¢a?? ??????????????? Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff V Attorneys for Plaintiff ROTHONOTAR' 2011 APP, -5 AM 11: 43 CUMBERLAND COUNTY : COURT OF COMMON PLEAS PENNSYLVANIA : CIVIL DIVISION HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS Defendant(s) NO.: 10-2734-CIVIL TERM : CUMBERLAND COUNTY CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 authorities. By: "'A U Attorney for Plaintiff ° --- Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Fran_,is-S: Hallinan, Esq., Id. No. 62695 CI-Mniel 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 falsification to P WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS - Plaintiff f L t `' _ ?' CIVIL DIVISION "; I' . V. N0 TAr `r . 20111T-R-5 NO.: 10-2734-CIVIL TERM HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A IJ y Defendant(s) I FN "NS YLVANIA CUMBERLAND COUNTY PHS # 236585 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., 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 445 RUN ROAD, CARLISLE, PA 17015-7732. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 1101 CLAREMONT ROAD, INMATE # 10-2813 CARLISLE, PA 17015 104 NOVEMBER DRIVE, APT 6 CAMP HILL, PA 17011 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MANUFACTURERS AND TRADERS ONE M & T PLAZA TRUST COMPANY_ BUFFALO, NY 14240 M & T BANK, N.A. P.O. BOX 4091 BUFFALO, NY 14240-4091 MANUFACTURERS AND TRADERS 1 FOUNTAIN PLAZA, 4T' FLOOR TRUST COMPANY BUFFALO, NY 14203 ATTN: DOCUMENTATION AND COLLATERAL MANUFACTURERS AND TRADERS TRUST COMPANY_ C/O GROUP 9 2150 CABOT BOULEVARD WEST LANGHORNE, PA 19047 MANUFACTURERS AND TRADERS TRUST COMPANY_ C/O GROUP 9 2005 CABOT BOULEVARD WEST LANGHORNE, PA 19047 + J Y 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 445 RUN ROAD CARLISLE, PA 17015-7732 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 DONNA J. RAUDABAUGH A/K/A 26 W HIGH STREET DONNA J. LANDIS CARLISLE, PA 17013-2922 C/O CAROL J. LINDSEY, ESQ. HARRY G. RAUDABAUGH 3528 BRISBAN STREET C/O CHARLES E. PETRIE, ESQ. HARRISBURG, PA 17111 HARRY G. RAUDABAUGH & 19 W SOURTH ST DONNA J. RAUDABAUGH A/K/A CARLISLE, PA 17013 DONNA J. LANDIS C/O ROBERT L. O'BRIEN, ESQ. JANICE M. RAUDABAUGH 3884 PAWNEE RD 1 COLUMBIA, PA 17512-9742 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements h n are made ubject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: ' By: Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 C- iiniel 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 WELLS FARGO BANK, N.A. { 1L E0 :,.,F iC`L ar THE: Fi%TH0N0TA Plaintiff 2011 f 1'? -5 AM I I : 4 ti : COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY HARRY G. RAUDABAUGH PENNSYLVANIA DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS Defendant(s) : CIVIL DIVISION NO.: 10-2734-CIVIL TERM : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. 1101 CLAREMONT ROAD, LANDIS INMATE # 10-2813 104 NOVEMBER DRIVE, APT 6 CARLISLE, PA 17015 CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 445 RUN ROAD, CARLISLE, PA 17015-7732 is scheduled to be sold at the Sheriff's Sale on 09/07/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $103,171.59 obtained by WELLS FARGO BANK, N.A. (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 Sheriff's Sale, you must take immediate action: 1. The sale will be canceled 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 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-2734-CIVIL TERM WELLS FARGO BANK, N.A. vs. HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS owner(s) of property situate in LOWER FRANKFORD TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 445 RUN ROAD CARLISLE PA 17015-7732 Parcel No. 14-05-0421-031H (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $103,171.59 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Subdivision Plan for Donald B. Rudy, recorded in the Office of Recorder of Deeds for Cumberland County in Plan Book 38, Page 20, as follows: BEGINNING at a spike in the center line of Township Road T-454, at corner of land now or formerly of Robert Martin; thence by said land now or formerly of Robert Martin, north 78 degrees 42 minutes 51 seconds East 363 feet to an iron pin; thence by other land now or formerly of Donald B. Rudy, South 10 degrees 16 minutes 58 seconds East 675.21 feet to an iron pin; thence by land now or formerly of John C. Foster, South 67 degrees 00 minutes West 322.45 feet to an iron pin; thence by land now or formerly of Robert L. Kurtz, North 23 degrees 00 minutes West 353.27 feet to an iron pin on the Eastern side of Township Road T-454 aforesaid, said iron pin being 16.471 feet from the center line of said Road; thence along and through said Road, North 6 degrees 01 minutes 21 seconds West 395.35 feet to the point of BEGINNING. CONTAINING 5.984 acres and being Lot No. 2 on the aforesaid Subdivision Plan. Being Known as and numbered 445 Run Road, Carlisle, Pennsylvania. UNDER AND SUBJECT to restrictions and conditions as now appear of record. TITLE TO SAID PREMISES IS VESTED IN Harry G. Raudabaugh and Donna Raudabaugh, by Deed from Harry G. Raudabaugh, joined by Donna J. Raudabaugh, his wife, dated 06/19/2001, recorded 07/19/2001 in Book 247, Page 2426. PREMISES BEING: 445 RUN ROAD, CARLISLE, PA 17015-7732 PARCEL NO. 14-05-0421-031H LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Subdivision Plan for Donald B. Rudy, recorded in the Office of Recorder of Deeds for Cumberland County in Plan Book 38, Page 20, as follows: BEGINNING at a spike in the center line of Township Road T-454, at corner of land now or formerly of Robert Martin; thence by said land now or formerly of Robert Martin, north 78 degrees 42 minutes 51 seconds East 363 feet to an iron pin; thence by other land now or formerly of Donald B. Rudy, South 10 degrees 16 minutes 58 seconds East 675.21 feet to an iron pin; thence by land now or formerly of John C. Foster, South 67 degrees 00 minutes West 322.45 feet to an iron pin; thence by land now or formerly of Robert L. Kurtz, North 23 degrees 00 minutes West 353.27 feet to an iron pin on the Eastern side of Township Road T-454 aforesaid, said iron pin being 16.471 feet from the center line of said Road; thence along and through said Road, North 6 degrees 01 minutes 21 seconds West 395.35 feet to the point of BEGINNING. CONTAINING 5.984 acres and being Lot No. 2 on the aforesaid Subdivision Plan. Being Known as and numbered 445 Run Road, Carlisle, Pennsylvania. UNDER AND SUBJECT to restrictions and conditions as now appear of record. TITLE TO SAID PREMISES IS VESTED IN Harry G. Raudabaugh and Donna Raudabaugh, by Deed from Harry G. Raudabaugh, joined by Donna J. Raudabaugh, his wife, dated 06/19/2001, recorded 07/19/2001 in Book 247, Page 2426. PREMISES BEING: 445 RUN ROAD, CARLISLE, PA 17015-7732 PARCEL NO. 14-05-0421-031H Two (a) AFFIDAVIT OF SERVICE (FNMA) 77fW P TS PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, N.A. PHS # 236585 DEFENDANT SERVICE TEAM/ lxh HARRY G. RAUDABAUGH COURT NO.: 10-2734-CIVIL TERM DONNA J. LANDIS A/K/A DONNA J. RAUDABAUGH SERVE DONNA J. LANDIS A/K/A DONNA J. RAUDABAUGH AT: TYPE OF ACTION 25 HORSESHOE ROAD XX Notice of Sheriff's Sale CARLISLE, PA 17013 SALE DATE: 09/07/2011 SERVED Served and made known to DONNA J. RAUDABAUGH , Defendant on the 25 day of 4+1 20 -1%, at 6 +a ,o'clock _P. M., at ( 7 E . P iNe ST MT 14*W SMuois f Air'r'the manner described below: C= r.a - Defendant personally served. -? - Adult family member with whom Defendant(s) reside(s). tai G7 C... Relationship is _ M - Adult in charge of Defendant's residence who refused to give name or relationship. =f` N _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). CD Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. =C Other: ? ?=? - yy Description: Age 46 Height 5'4" Weight 130 Race W Sex ? Other - s ' r_?x 1, N b MOIL , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. % DEf-END"T DO&5 DATE: Its 11 NvTt ?Dk L $ 4NAME: /Nv96T%&Ar(0N DKCU? cfw ^i'%W AM RQFVNWO*RJNTED NAME: 'Rap+o /Vl0 LL U<Ib" (? E. PINE 'VT. TITLE: RAm-f-'55 441: oou-y Sp¢ 0 ubs, lF NOT SERVED On the day of , 20-, at _ o'clock _. M., Defendant NOT FOUND because: Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: 1 understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF 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 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 -i =C 4`:D c»+ rILEG-OrrlCE, `RSTr' u's rtl # " ! ?'s 2GI I AUG - I AM 9: 3 i UMBERLAND COUHT';' PENNSYLVANIA Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff v. HARRY G. RAUDABAUGH ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County DONNA J. RAUDABAUGH No.: 10-2734-CIVIL TERM A/K/A DONNA J. LANDIS Defendants PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its Attorneys, Phelan Hallinan & Schmieg, LLP, moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. Plaintiff commenced this foreclosure action by filing a Complaint on April 23, 2010. 2. Judgment was entered on March 10, 2011 in the amount of $103,171.59. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit "A". 3. Judgment against Donna J. Raudabaugh A/K/A Donna J. Landis is hereby confirmed. 236585 4. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item which can be calculated from the complaint, i.e. bringing the interest current. However, new items cannot be added at the time of entry of the judgment. A Sheriffs Sale of the mortgaged property at 445 RUN ROAD, CARLISLE, PA 17015-7732 (hereinafter the "Property") was postponed or stayed for the following reason: a.) Defendant Donna.l. Raudabaugh A/K/A Donna J. Landis filed a Chapter 07 Bankruptcy at Docket Number 1:10-06535 on August 11, 2010. The Plaintiff obtained relief from the bankruptcy stay by order of court dated September 10, 2010. A true and correct copy of the Relief Order is attached hereto, made part hereof, and marked as Exhibit "B". 6. The Property is listed for Sheriffs Sale on September 7, 2011. 7. Additional surns have been incurred or expended on Defendants' behalf since the Complaint was filed and Defendants have been given credit for any payments that have been made since the judgment. The amount of damages should now read as follows: Principal Balance $91,488.81 Interest Through September 7, 2011 $10,860.98 Per Diem $12.22 Late Charges $552.42 Legal fees $1,550.00 Cost of Suit and Title $1,325.00 Property Inspections/ Property Preservation $694.00 Escrow Deficit $5,336.99 TOTAL $111,808.20 The judgment formerly entered is insufficient to satisfy the amounts due on the Mortgage. 9. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of judgment against the Defendants. 236585 10. Plaintiff's foreclosure judgment is in rem only and does not include personal liability, as addressed in Plaintiff's attached brief. 11. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on July 22, 2011 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants. A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and certification of mailing are attached hereto, made part hereof, and marked as Exhibit "C". 12. No judge has previously entered a ruling in this case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan & Schmieg, LLP DATE: 1! ?y: ? Lawrence . 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? W' iam E. Miller, Esq., Id. No. 308951 elissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 236585 P %r- Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff 'LEG` T' 13 t'" .4`. C , i v 2011 AUG - I AM 4.31 CUMBERLAHD COUNT PENNSYLVANIA ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division v. HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS Defendants CUMBERLAND County No.: 10-2734-CIVIL TERM CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, were sent to the following individuals on the date indicated below. HARRY G. RAUDABAUGH 1101 CLAREMONT ROAD INMATE # 10-2813 CARLISLE, PA 17015 CAMP HILL, PA 17011 DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS HARRY G. RAUDABAUGH 104 NOVEMBER DRIVE APT 6 CAMP HILL, PA 17011 HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS 445 RUN ROAD CARLISLE, PA 17015-7732 HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS 25 HORSESHOE ROAD CARLISLE, PA 17013 236585 DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS ROBERT L. O'BRIEN O'BRIEN BARIC & SCHERER 19 WEST SOUTH STREET CARLISLE, PA 17013 DATE: 17 E PINE ST MOUNT HOLLY SPRINGS, PA 17065-1420 Phelan Hallinan & Schmieg, LLP Bv? To La7wrerice T. Phelan1. 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? Wi E. Miller, Esq., Id. No. 308951 elissa J. Scheiner, Esq., Id. No. 308912 ATTORNEY FOR PLAINTIFF 236585 r ? Cf? ? 1 -`•? F?7 . a s ? CD -. CD {:- ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff V. HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS Court of Common Pleas Civil Division CUMBERLAND County No.: 10-2734-CIVIL TERM Defendants RULE AND NOW, this day of u/G 2011, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant(s) shall have twenty (20) days of the date of this Order to file a responsive pleading to Plaintiff s Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY THE COURT ?Z J. 236585 S 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 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 Phelan Hallman & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 TEL: (215) 563-7000 FAX: (215) 563-3459 HARRY G. RAUDABAUGH 1101 CLAREMONT ROAD INMATE # 10-2813 CARLISLE, PA 17015 ? DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS HARRY G. RAUDABAUGH 104 NOVEMBER DRIVE APT 6 CAMP HILL, PA 17011 ROBERT L. O'BRIEN O'BRIEN BARIC & SCHERER 19 WEST SOUTH STREET CARLISLE, PA 17013 ? HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS 445 RUN ROAD CARLISLE, PA 17015-7732 HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH A/K/A DONNA J. LANDIS 25 HORSESHOE ROAD CARLISLE, PA 17013 V/ DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS 17 E PINE ST MOUNT HOLLY SPRINGS, PA 17065-1420 Mellmj- Zakeiner, 5. PH4-5 236585 eAkb 236585 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff, V. HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J LANDIS Defendant(s) CUMBERLAND COUNTY ' COURT OF COMMON PL r?z CIVIL DIVISION - C No.: 10-2734-CIVIL TE C-) Co ?c o C) C7= A AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 1 ) .n or Certified Mail Return Receipt stamped by the U.S. Postal Service is atta a to ibit "A". ? Lawr ce 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ?? Allison F. Wells, Esq., Id. No. 309519 m E. Miller, Esq., Id. No. 308951 ANOTIC-E: Melissa J. Schemer, Esq., Id. No. 308912 Attorney for Plaintiff Date: IMPORTAN This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 236585 EXHIBIT A b .? ?A" ? 1h A W N? p ?O m J O? VI A W r? - n ?. gz H Ob ? o ro v S R? n r ? z ? a " y ? 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N M er i!1 IA ? 'a D WELLS FARGO BANK, N.A. Plaintiff V. HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-2734-CIVIL TERM CUMBERLAND COUNTY PHS # 236585 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., 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 445 RUN ROAD, CARLISLE, PA 17015-7732. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) HARRY G. RAUDABAUGH 1101 CLAREMONT ROAD, INMATE # 10-2813 CARLISLE, PA 17015 DONNA J. RAUDABAUGH A/K/A DONNA J. 104 NOVEMBER DRIVE, APT 6 LANDIS CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 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 Address (if address cannot be reasonably ascertained, please indicate) M&T Bank 1100 Wehrle Drive Williamsville, NY 14221 M&T Bank, c/o 701 Market Street Goldbeck, McCafferty & McKeever Philadelphia, PA 19106 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MANUFACTURERS AND TRADERS ONE M & T PLAZA TRUST COMPANY_ BUFFALO, NY 14240 M & T BANK, N.A. P.O. BOX 4091 BUFFALO, NY 14240-4091 MANUFACTURERS AND TRADERS 1 FOUNTAIN PLAZA, 4TH FLOOR TRUST COMPANY BUFFALO, NY 14203 ATTN: DOCUMENTATION & COLLATERAL MANUFACTURERS AND TRADERS TRUST COMPANY_ C/O GROUP 9 MANUFACTURERS AND TRADERS TRUST COMPANY_ C/O GROUP 9 2150 CABOT BOULEVARD WEST LANGHORNE, PA 19047 2005 CABOT BOULEVARD WEST LANGHORNE, PA 19047 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 445 RUN ROAD CARLISLE, PA 17015-7732 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS C/O CAROL J. LINDSEY, ESQ. HARRY G. RAUDABAUGH C/O CHARLES E. PETRIE, ESQ. HARRY G. RAUDABAUGH & DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS C/O ROBERT L. O'BRIEN, ESQ. JANICE M. RAUDABAUGH P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 26 W HIGH STREET CARLISLE, PA 17013-2922 3528 BRISBAN STREET HARRISBURG, PA 17111 19 W SOURTH ST CARLISLE, PA 17013 3884 PAWNEE RD 1 COLUMBIA, PA 17512-9742 I,verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infohnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. Date: By: G Attorney for P ain iff 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 feiissa J. Scheiner, Esq., Id. No. 308912 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?at??lf, oti' 4?tfttlj?rlr?a FILED-OFFICE O'F T 9E P?CTHONOTAR Y Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, NA vs. Donna J. Raudabaugh (et al.) 2011 NOV 21 AM 13: 03 CUMBERLAND CGUNT`f PENNSYLVANIA Case Number 2010-2734 SHERIFF'S RETURN OF SERVICE 06/28/2011 08:12 PM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 445 Run Road, Carlisle, PA 17015, Cumberland County. 06/30/2011 07:47 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Donna J. Raudabaugh, a/k/a Donna J. Raudabaugh, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 104 November Drive, Apt 6, Camp Hill, PA 17011, deft does not reside at address stated. 07/12/2011 09:24 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be MATTHEW HOCKLEY-BOYFRIEND, who accepted as "Adult Person in Charge" for Donna J. Raudabaugh at 17 E. Pine Street, Mt Holly Springs, PA 17065, Cumberland County. 09/07/2011 Ronny R. Anderson, Sheriff, 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 Cumberland County Courthouse, Carlisle, Cumberland County, PA on September 7, 2011 at 10:00 a.m.. He sold the same for the sum of $119,901.00 to McCabe, Weisberg and Conway, 123 South Broad Street, Ste 2080, Philadelphia, PA 19109, being the buyer in this execution, paid to the Sheriff the sum of 10/05/2011 Proposed Schedule Of Distribution Posted 10/17/2011 Exceptions to Proposed Schedule of Distribution filed in Sheriffs Office. SHERIFF COST: $792.54 SO ANSWERS, November 21, 2011 RON R ANDERSON, SHERIFF s? l Pe (c; CounfySuite Sher. f. Teleo.=. ft. Irr;. ?, 7 ?? r W WELLS FARGO BANK, N.A. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v. HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS Defendant(s) NO.: 10-2734-CIVIL TERM CUMBERLAND COUNTY PHS # 236585 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., 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 445 RUN ROAD, CARLISLE, PA 17015-7732. Name and address of Owner(s) or reputed Owner(s): Name HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J LANDIS Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 1101 CLAREMONT ROAD, INMATE # 10-2813 CARLISLE, PA 17015 104 NOVEMBER DRIVE, APT 6 CAMP HILL, PA 17011 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MANUFACTURERS AND TRADERS ONE M & T PLAZA TRUST COMPANY_ BUFFALO, NY 14240 M & T BANK, N.A. P.O. BOX 4091 BUFFALO, NY 14240-4091 MANUFACTURERS AND TRADERS 1 FOUNTAIN PLAZA, 4TH FLOOR TRUST COMPANY- BUFFALO, NY 14203 ATTN: DOCUMENTATION AND COLLATERAL MANUFACTURERS AND TRADERS TRUST COMPANY_ C/O GROUP 9 MANUFACTURERS AND TRADERS TRUST COMPANY_ C/O GROUP 9 2150 CABOT BOULEVARD WEST LANGHORNE, PA 19047 2005 CABOT BOULEVARD WEST LANGHORNE, PA 19047 ?. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 445 RUN ROAD CARLISLE, PA 17015-7732 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 DONNA J. RAUDABAUGH A/K/A 26 W HIGH STREET DONNA J. LANDIS CARLISLE, PA 17013-2922 C/O CAROL J. LINDSEY, ESQ. HARRY G. RAUDABAUGH 3528 BRISBAN STREET C/O CHARLES E. PETRIE, ESQ. HARRISBURG, PA 17111 HARRY G. RAUDABAUGH & 19 W SOURTH ST DONNA J. RAUDABAUGH A/K/A CARLISLE, PA 17013 DONNA J. LANDIS C/O ROBERT L. O'BRIEN, ESQ. JANICE M. RAUDABAUGH 3884 PAWNEE RD 1 COLUMBIA, PA 17512-9742 4 I verify that the statements made in this affidavit are true and correct to the best of my personal )knowledge or information and belief. I understand that false statements h n are made ubject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. Date: By: V G` Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Frapcis 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 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 r WELLS FARGO BANk, N.A. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS Defendant(s) NO.: 10-2734-CIVIL TERM CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. 1101 CLAREMONT ROAD, LANDIS INMATE # 10-2813 104 NOVEMBER DRIVE, APT 6 CARLISLE, PA 17015 CAMP HILL, PA 17011 "THIS THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 445 RUN ROAD, CARLISLE, PA 17015-7732 is scheduled to be sold at the Sheriff's Sale on 09/07/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $103,171.59 obtained by WELLS FARGO BANK, N.A. (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 Sheriff's Sale, you must take immediate action: 1. The sale will be canceled 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 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s 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 215-563-7000. 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 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. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-2734-CIVIL TERM WELLS FARGO BANK, N.A. vs. HARRY G. RAUDABAUGH DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS owner(s) of property situate in LOWER FRANKFORD TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 445 RUN ROAD, CARLISLE, PA 17015-7732 Parcel No. 14-05-0421-031H (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $103,171.59 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Lower Frankford Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Subdivision Plan for Donald B. Rudy, recorded in the Office of Recorder of Deeds for Cumberland County in Plan Book 38, Page 20, as follows: BEGINNING at a spike in the center line of Township Road T-454, at corner of land now or formerly of Robert Martin; thence by said land now or formerly of Robert Martin, north 78 degrees 42 minutes 51 seconds East 363 feet to an iron pin; thence by other land now or formerly of Donald B. Rudy, South 10 degrees 16 minutes 58 seconds East 675.21 feet to an iron pin; thence by land now or formerly of John C. Foster, South 67 degrees 00 minutes West 322.45 feet to an iron pin; thence by land now or formerly of Robert L. Kurtz, North 23 degrees 00 minutes West 353.27 feet to an iron pin on the Eastern side of Township Road T-454 aforesaid, said iron pin being 16.471 feet from the center line of said Road; thence along and through said Road, North 6 degrees 01 minutes 21 seconds West 395.35 feet to the point of BEGINNING. CONTAINING 5.984 acres and being Lot No. 2 on the aforesaid Subdivision Plan. Being Known as and numbered 445 Run Road, Carlisle, Pennsylvania. UNDER AND SUBJECT to restrictions and conditions as now appear of record. TITLE TO SAID PREMISES IS VESTED IN Harry G. Raudabaugh and Donna Raudabaugh, by Deed from Harry G. Raudabaugh, joined by Donna J. Raudabaugh, his wife, dated 06/19/2001, recorded 07/19/2001 in Book 247, Page 2426. PREMISES BEING: 445 RUN ROAD, CARLISLE, PA 17015-7732 PARCEL NO. 14-05-0421-031H WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO10-2734 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 HARRY G. RAUDABAUGH, DONNA J. RAUDABAUGH A/K/A DONNA J. LANDIS (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $103,171.59 L.L.$.50 Interest FROM 0319111 to Date of Sale ($16.96per diem) - - $3,103.68 Atty's Comm % Due Prothy $2.00 Atty Paid "3.60 Other Costs Plaintiff Paid Date: 4/5/11 David ADuell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: DANIEL G. SCHMIEG, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 TRUE COPY FROM RECORD in Testimony whereof, i here unto set my hand and the seal of said Court at Carlisle, O- This ` day of--'L'- ' ? ???? n Prothonotary On May 11, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Lower Franford Township, Cumberland County, PA, Known and numbered as, 445 Run Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 11, 2011 By: Real Estate Coordinator _ :?, U CUMBERLAND LAW JOURNAL Writ No. 2010-2734 Civil Wells Fargo Bank, NA VS. Donna J. Raudabaugh Harry G. Raudabaugh Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 10-2734-CIVIL TERM WELLS FARGO BANK, N.A. vs. HARRY G. RAUDABAUGH, DONNA J. RAUDA- BAUGH A/K/A DONNA J. LAN- DIS, owner(s) of property situate in LOWER FRANKFORD TOWNSHIP, Cumberland County, Pennsylvania, being 445 RUN ROAD, CARLISLE, PA 17015-7732. Parcel No. 14-05-0421-031H. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENTAMOUNT: $103,171- .59. 55 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: July 15, July 22 and July 29, 2011 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. isa Marie Coyn Editor SWORN TO AND SUBSCRIBED before me this C2da of Jul 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH. CUMBERLAND COUNTY My Commission Expires Apr 2B, 2014 The Patriot-News Co. '2020 Technology Pkwy Suite 306 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE the Pahiot News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, 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 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, 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/ Community Weekly 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: ..f 07115/11 07/22/11 IL 07/29/11 L............... .. . ?.... Sworn to a ubscribed b m this 18"& August, 2011 A.D. c. !; l ?__ Notary Public -t- COMMONWEALTH OF PENNSYLVANIA ?„rI Sherrie L Kisne' N try Public Lower Paxton Twp,, Dauphin County My Commisslon res Nov. 26, 2011 Member, Pennsylvania Association of Notaries 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 M & T Bank is the grantee the same having been sold to said grantee on the 7 day of September A.D., 2011, under and by virtue of a writ Execution issued on the 5 day of April, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 2734, at the suit of Wells Fargo Bank, N.A. against HaM G. Raudabaugh and Donna J. Raudabaugh A/K/A Donna J. Landis is duly recorded as Instrument Number 201132271. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this l day of A.D. O l 1-1 of Deeds %CNW h1 kV Co M1W3n E*= fM c7 .., C, -? 3 ? --t Zrn rrl rr7rt IN THE COURT OF COMMON PLEAS ?r- " ro ' x( ..2 CUMBERLAND COUNTY, PENNSYLVANIA r `- 0, WELLS FARGO BANK, N.A., ?C s" c5r3 X Plaintiff : CIVIL DIVISION ? CO ,r V. Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 : NO. 10-2734 HARRY G. RAUD BAUGH and DONNA RAUDABAUGH a k/a DONNA J. LANDIS, Defendant : THE HONORABLE ALBERT MASLAND PETITION 1. Pe itioner is the law office of Saidis, Sullivan & Rogers. 2. Re pondent is Donna Raudabaugh a/k/a Donna J. Landis. 3. Pe itioner has not entered the appearance of the firm in the within matter. 4. Pe itioner has not been retained by Respondent to represent her. 5. Petitioner represented Respondent in a divorce action which was resolved with the entry of a Divorce Decree dated August 9, 2011 to docket number 2007-2960. 6. A opy of this Petition has previously been forwarded to Donna Landis and she does not obj ct with the relief requested. WHEREFORE, Petitioner requests your Honorable Court to direct the Prothonotary's Office to send copies of Orders in this matter to the Respondent directly and discontinue cor)iel; to this law firm. Respectfully submitted, SAIDIS, SULLIVAN & ROGERS /1 A Mares s, Esquire Attorney 14919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Dated: /z-/? l CERTIFICATE OF SERVICE I hereby c rtify that on this day of 2011, a true and correct copy of the foreg ing document was served upon the party listed below, via First Class Mail, postage , addressed as follows: Donna Landis 17 East Pine Street Mount Holly Springs, PA 17065 SAIDIS, SULLIVAN & ROGERS L+s? Marylou , Esquire 'F- Supreme Goud ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 C') t? r=-n IN THE COURT OF COMMON PLEAS -<3' c °? CUMBERLAND COUNTY, PENNSYLVANIA ;c c: ? > WELLS FARGO BANK, N.A., v ?:? --?'; Plaintiff n CIVIL DIVISION V. NO. 10-2734 HARRY G. RAUDABAUGH and DONNA RAUDABAUGH a/k/a DONNA J. LANDIS, Defendants THE HONORABLE ALBERT MA SLAND ORDER OF COURT AND NOW, this ?D day of 20e'*'/, upon consideration of Petitioner's Petition, it is hereby ordered and directed that the Prothonotary shall mail all Orders in this matter to the Defendant, Donna Raudabaugh, a/k/a Donna J. Landis, and discontinue copies of Orders in this matter to the law firm of Saidis, Sullivan & Rogers. BY THE COURT, J. ??na lix??0??.? ie8 ?al?l d?