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10-3296
M ~~ 20f0 ~ir;Y f $ Pri ! ~ ~4 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. 20233 ] Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 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 231359 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. MAC F4031-086 800 WALNUT DES MOINES, IA 50309 v. Plaintiff SHIRLEY A. REITZ 4 THOMAS DRIVE DUNCANNON, PA 17020-9762 Defendants t~~.~'Jt~ ji~~~rftii'v~Pa ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM CUMBERLAND COUNTY $4~.oa ~r~~~ CK.~ 4Y/..~/5/ I~`~ File #: 231359 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 170 ] 3 (717)249-3166 (800)990-9108 File #: 231359 1. Plaintiff is WELLS FARGO FINANCIAL PENNSYLVANIA, INC. MAC F4031-086, 800 WALNUT DES MOINES, IA 50309 2. The name(s) and last known address(es) of the Defendant(s) are: SHIRLEY A. REITZ 4 THOMAS DRIVE DUNCANNON, PA 17020-9762 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 10/21/2004 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book No. 1885, Page 4535. 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. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 02/26/2009 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 #: 231359 6 The following amounts are due on the mortgage: Principal Balance $86,021.95 Interest $7,664.76 01/26/2009 through 02/15/2010 (Per Diem $16.92) Attorney's Fees $650.00 Cumulative Late Charges $0.00 10/21/2004 to 02/15/2010 Costs of Suit and Title Search $550.00 Escrow Deficit R F ~Q TOTAL $95,712.71 7 8 9 Plaintiff is not seeking a judgment of personal liability (or an in nPr~~nam 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. This action does not come under Act 91 of 1983 because the mortgage premises is not the principal residence of Defendant(s). File #: 231359 10. Plaintiff hereby releases JOHN J. REITZ from liability for the debt secured by the mortgage. 11. By virtue of death of JOHN J. REITZ on 12/13/1970, Defendant became sole owner of the mortgaged premises as surviving tenant by the entireties. WHEREFORE, Plaintiff demands an in r~.m judgment against the Defendant(s) in the sum of $95,712.71, together with interest from 02/15/2010 at the rate of $16.92 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: U Lawr~ice . Phelan, E q., Id. No. 32227 ^ Fra cis S. allinan, q., Id. No. 62695 ^ Daniel G. ,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 ^ hrisovalante P. Fliakos, Esq., Id. No. 94620 LiJ 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 #: 231359 LEGAL DESCRIPTION All that certain lot of land situate in the Borough of Wormleysburg, (formerly East Pennsboro Township) Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern line of Second Street, said point being on the southern line of Lot No. 118 on Plan of Lots hereinafter mentioned; thence southwardly along the eastern line of Second Street twenty (20) feet, more or less, to a point on the line passing through the center of the partition wall of the double brick dwelling erected in part upon the lot hereby conveyed; thence in an easterly direction along said line through the center of said partition wall one hundred twenty (120) feet, more or less, to a point on the western line of a 15 foot alley; thence northwardly along the western line of said alley twenty (20) feet to a point on the southern line of Lot No. 118 on the said hereinafter mentioned Plan of Lots; thence westwardly along the southern line of said lot one hundred twenty (120) feet to a point on the eastern line of Second Street, the point or place of BEGINNING. BEING Lot No. 117 on Plan of Lots laid out by Edwin M. Hershey and known as 'Riverview', said Plan being recorded in the Recorder's Office in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 103. HAVING thereon erected the northern half of a double brick dwelling house known and numbered as 607 North Second Street, Wormleysburg, Penna. PARCEL N0.47-19-1588-010 PREMISES: 607 NORTH 2ND STREET, WORMLEYSBURG, PA 17043-1003 File k: 231359 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: ~" File #: 231359 ~ S ~r ,~ T~' ;' ; ~,r;~' ~t~ .., ulU.r~~'1 _~ r~tr`~ ~U~ ~ v1S~_ ~~.J 1.'Iv! { ~ ~ 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. vs. SHIRLEY A. REITZ Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 2010-03296 R-~ a.Ny ~ y,~ J~~9-rcc .-..~1 ed PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against SHIRLEY A. REITZ, 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 $95,712.71 Interest - 02/16/2010 to 06/29/2010 $2,267.28 TOTAL $97,979.99 I hereby certify that (1) the Defendant's last known addresses are 4 THOMAS DRIVE, DUNCANNON, PA 17020-9762 and the mortgaged premises at 607 NORTH 2ND STREET, WORMLEYSBURG, PA 17043-1103, and (2) that notice has bee n in accordance with Rule 237.1, copy attached. Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 7 ~ ~ ~ ~4 ~0 ~ ~ PHS # 231359 PROTHON ARY 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. vs. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION SHIRLEY A. REITZ No. 2010-03296 VERIFICATION 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. (b) that defendant SHIRLEY A. REITZ is over 18 years of age and her last known addresses are 4 THOMAS DRIVE, DUNCANNON, PA 17020-9762 and the mortgaged premises at 607 NORTH 2ND STREET, WORMLEYSBURG, PA 17043-1103. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. „ . U 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 ^ J ine R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff (Rule of Civil Procedure No. 236) -Revised WELLS FARGO FINANCIAL CUMBERLAND COUNTY PENNSYLVANIA, INC. vs. COURT OF COMMON PLEAS CIVIL DIVISION SHIItLEY A. REITZ . No. 2010-03296 Notice is given that a Judgment in the above captioned matter has been entered against you on ~ , ~~~ By: If you have any questions concerning this matter please contact: ^ 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 ^ Je a R. Davey, Esq., Id. No. 87077 ^ auren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 ^ Jay B. Jones, Esq., Id. No. 86657 ^ Peter J. Mulcahy, Esq., Id. No. 61791 ^ Andrew L. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua I. Goldman, Esq., Id. No. 205047 ^ Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff v SHIRLEY A. REITZ Defendant(s) TO: SHIRLEY A. REITZ 4 THOMAS DRIVE DUNCANNON, PA 17020-9762 DATE OF NOTICE: June 11, 2010 COURT OF COMMON PLEAS CIVIL DIVISON NO. 2010-03296 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 IIvIPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPI~ONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIIZE 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 # 231359 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., [d. 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., [d. 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 Phelan Hallman &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 231359 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff v. SHIRLEY A. REITZ. Defendant(s) TO: SHIRLEY A. REITZ 607 NORTH 2ND STREET WORMLEYSBURG, PA 17043-1003 DATE OF NOTICE: June 11, 2010 COURT OF COMMON PLEAS CIVIL DIVISON NO. 2010-03296 CUMBERLAND COUNTY THIS FIItM 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 AT"fEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 W[THOUT 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 # 231359 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717)240-6195 CUMBERLAND COUNTY BAR ASSOCIATION By: CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., [d. 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., Td. No. 208375 Phelan Hallman &Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 231359 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v SHIRLEY A. REITZ Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: NO. 2010-03296 CUMBERLAND COUNTY $97,979.99 sn, $2,609.82 U' $100,589.81 .moo t N N Amount Due Interest from 06/30/2010 to Date of Sale ($16.11 per diem) TOTAL O $414.00 PO Airy 12.4o I0, ar ga. 00 14. o0 " 41.50 " da1.4o - PIN aM 4 A.oo &eeo . 50 LL Note: Please attach description of property. PHS # 231359 ,* Q97103 &410'7'70 Attorney for Plaintiff 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 Q"A'ndrew C. Bramblett, Esq., Id. No. 208375 m Q N O ?' N Lzl Q a?i ? A O W cl) x? A U N .n ' r 00 pO?OC`1 M M WWI NNc`l? ooh O MNr p O O? d? Z U c a Q'Z 6zoo ow oZ? a?,Z o .. a? W azZ?-riZ-ozo??"Doz-?°w° crW c? w v H ? ?www-ow..; WWw ?w ? ;w gg v 4;- 0 10.4 W U it cox?°??oG? -; 10 c W p w -6 t's -1 woo°aaaaaa°°°° ?,aa 4+ v 3 B18 (Official Form 18) (02/09) UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA In re: Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden, and trade): Shirley Ann Reitz 607 N. 2nd Street Wormleysburg, PA 17043 Chapter 7 Case No. 1:09-bk-05232-MDF Last four digits of Social-Security, Individual Taxpayer-Identification, Employer Tax-Identification No(s)(if any): xxx-xx-3808 DISCHARGE OF DEBTOR(S) It appearing that the debtor(s) is entitled to a discharge, IT IS ORDERED: The debtor(s) is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code). BY THE COURT Dated: October 13. 2009 Mary D. France United States Bankruptcy Judge SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION. This document is electronically signed and filed on the same date. Case 1:09-bk-05232-MDF Doc 12 Filed 10/15/09 Entered 10/16/09 01:09:19 Desc Imaged Certificate of Service Page 1 of 3 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO FINANCIAL P Plaintiff V. SHIRLEY A. REITZ Defendant(s) C RED-_0r ?? rC.? --3 P? ?? 22 Uty ENNSYL000%a CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 2010-03296 : CUMBERLAND COUNTY 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 (X) the premises is non-owner occupied ( ) the premises is vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswom falsification to authorities. By: Attorney`for Plaintiff Phelan Hallinan & Schmieg, LLP D Lawrence T. Phelan, Esq., Id. No. 32227 D Francis S. Hallinan, Esq., Id. No. 62695 D Daniel G. Schmieg, Esq., Id. No. 62205 D Michele M. Bradford, Esq., Id. No. 69849 D Judith T. Romano, Esq., Id. No. 58745 D Sheetal R. Shah-Jani, Esq., Id. No. 81760 D Jenine R. Davey, Esq., Id. No. 87077 D Lauren R. Tabas, Esq., Id. No. 93337 D Vivek Srivastava, Esq., Id. No. 202331 D Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 D 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 ?Cndrew C. Bramblett, Esq., Id. No. 208375 WELLS ARGO FINANCIAL PENNSYLVANIA, INC. ?laintiff " P v. SHIRLEY A. REITZ Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 2010-03296 CUMBERLAND COUNTY PHS # 231359 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO FINANCIAL PENNSYLVANIA, INC., 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 607 NORTH 2ND STREET AACA 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) SHIRLEY A. REITZ Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 4 THOMAS DRIVE DUNCANNON, PA 17020-9762 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) Household Finance Consumer Discount Company Household Finance Consumer Discount Company Wells Fargo Financial Bank Household Finance Consumer Discount Company C/O Records Processing Services 25 Gateway Drive, Suite 107 Mechanicsburg, PA 17055 25 Gateway Drive Gateway Square, Suite 107 Mechanicsburg, PA 17055 3201 North 4A Avenue Sioux Falls, SD 57104 577 Lamont Road Elmhurst, IL 60126 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) ? ?rf ?t77 :n ? ,?.dl Z ? j ( "'t . 1. s N None. 6. ?,01ame 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) TENANTlOCCUPANT Domestic Relations of Cumberland County 607 NORTH 2ND STREET WORMLEYSBURG, PA 17043-1003 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 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program River view Associates 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 6`h Floor, Strawberry Square Dept28061 Harrisburg, PA 17128 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 Hilt's Lane North of Private Road Wrightsville, PA 17368 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 herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. 2010 By: Attorney for Plaintiff 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 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Joshua I. Goldman, Esq., Id. No. 205047 V ourtenay R. Dunn, Esq., Id. No. 206779 ndrew C. Bramblett, Esq., Id. No. 208375 lam) WkLS FARGO FINANCIAL PENNSYLVANIA, INC. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION VS. NO. 2010-03296 SHIRLEY A. REITZ CUMBERLAND UN'TYq Defendant(s), , NOTICE OF SHERIFF'S SALE OF REAL PROPERTY` =_ - TO: SHIRLEY A. REITZ C 4 THOMAS DRIVE na DUNCANNON, PA 17020-9762 ;v "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 607 NORTH 2ND STREET A/K/A 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003 is scheduled to be sold at the Sheriff's Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $97,979.99 obtained by WELLS FARGO FINANCIAL PENNSYLVANIA, INC. (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. 2010-03296 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. vs. SHIRLEY A. REITZ owner(s) of property situate in the BOROUGH OF WORMLEYSBURG, Cumberland County, Pennsylvania, being (Municipality) 607 NORTH 2ND STREET AIKJA 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003 Parcel No. 47-19-1588-010 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $97,979.99 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION All that certain lot of land situate in the Borough of Wormleysburg, (formerly East Pennsboro Township) Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit:- - BEGINNING at a point on the eastern line of Second Street, said point being on the southern line of Lot No. 118 on Plan of Lots hereinafter mentioned; thence southwardly along the eastern line of Second Street twenty (20) feet, more or less, to a point on the line passing through the center of the partition wall of the double brick dwelling erected in part upon the lot hereby conveyed; thence in an easterly direction along said line through the center of said partition wall one hundred twenty (120) feet, more or less, to a point on the western line of a 15 foot alley; thence northwardly along the western line of said alley twenty (20) feet to a point on the southern line of Lot No. 118 on the said hereinafter mentioned Plan of Lots; thence westwardly along the southern line of said lot one hundred twenty (120) feet to a point on the eastern line of Second Street, the point or place of BEGINNING. BEING Lot No. 117 on Plan of Lots laid out by Edwin M. Hershey and known as 'Riverview', said Plan being recorded in the Recorder's Office in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 103. HAVING thereon erected the northern half of a double brick dwelling house known and numbered as 607 North Second Street, Wormleysburg, Penna. TITLE TO SAID PREMISES VESTED IN John J. Reitz and Shirley A. Reitz, his wife, by Deed from H. James Steckbeck and Grace Ann Steckbeck, his wife, dated 10/15/1964, recorded 10/15/1964 in Book J-21, Page 907. By virtue of the death of John J. Reitz on 12/13/1970, Defendant became sole owner of the mortgaged premises as surviving tenant by the entireties. PREMISES BEING: 607 NORTH 2ND STREET AIK/A 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003 PARCEL NO. 47-19-1588-010 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-3296 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff (s) From SHIRLEY A. REITZ (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 $97,979.99 L.L. $.50 Interest from 6130110 to Date of Sale ($16.11 per diem) -- $2,609.82 Atty's Comm % Due Prothy $2.00 Atty Paid $204.90 Other Costs Plaintiff Paid Date: 9/3/10 uell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: ANDREW C. BRAMBLETT, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 208375 ~~' ~~~`~. ~ ~ ±`~ ~1~7~y^ l ~'~~ ~ ~ '~ ,t y ~ k t1)~~~t AFFIDAVIT OF SER VICE a n ~ ` L ~ F CUMBERLAND COUNTY j tt ~~, .. ° ~ ~,Y ~~ ~ j ARGO FINANCIAL PENNSYLVANIA, INC. WE I.S L PHS#231359 ~~ f~ai ~ DEFENDANT SERVICE TEAM/ lotc ) ~s l~.fii'~~ ~,D~i~Y ~ ! = s `ti ~ t'~! ~1 t1 ~,s 1 ~ ~ ` ~' ° SHIRLEY ANN RETTZ A/K/A SHIRLEY A. REITZ COURT NO.: 2010-03296 ' '° SERVE SHIRLEY ANN RE1TZ A/K/A SHIRLEY A. REITZ AT: TYPE OF ACTION 4 THOMAS DRIVE XX Notlce o[ Shecitf's Sale DUNCANNON, PA 17020-9762 SALE DATE: 111'08/2010 SERVED Served and made known to SHIRLEY A. RETIZ ,Defendant on the day of S£CIEM REi2 , 20 (Q_, at (o : 3~ , o'clock ~ M., at 4 D1t.'DVNCANN ON a ~- , in the manner described below: y[ Defendant personally served. _ Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) inside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _ Other. Des^cri~ption: Age ,17~~5 Height t0 ~~ Weight ~0 Race 1~1~ Sex ~ Other I, KOrIaf.U IVIDI.t- , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subsc 'bed before me this ~ day KIMBER~,y CURTY of SE P7 , 20 NOTARY P[J$L1C: / STATE OF 1V$H,,EY N y~ ~` N S M1'COMM1SS101Y EXPIRES MARCH ~, I4i3 e , 20 , at _ o clock _. M., Defendant NOT FOUND because: _ scant _ Dces Not Exist _ Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other. Sworn to and subscribed before me this day of ~_. By: Notary: g~QRNEY FOR PLAIN7'1FF I~eneae T. Help HO~, Ii No. ]¢237 FneeY S }4ieee, ~e0+ Id Nw 63155 1hNd C. SeYVeB,FSq„ d. Na 62200 Mkide T9. lndhed. B+V+ Y. Na f9M9 ]udW Z Racer, Yq., li. Na Si/LS SYedY R 9r6-Jri, 6p„ K Na SYiN Jeedr R. Daaer, He9+id. Na 870T! I~em R 716ay 69+IL Nwfl317 VFak SAareYa; F.q., 3L Nw ffiW Jq & 3oMa. Fiq., Y. Na 86667 Paler2. L1eba6y, Flq., W. Na 61791 Aedeew L SFiaael, l+9~. )d Na.814.19 )dace McGaio~eae, Fq, K Na 90131 Qeieaaalree P. Files, ~4. ii Nw 446M loera~ L GeWoar, Fiq, Y. Na 205017 C+~r R Ilan, F1p., li Na 306779 Aedrerr G Be'ebklt,Id. Na Z1t775 16177a~e.~..ea7^a+.. seWe~1400 HIYde~hla, PA 191031814 (21.51 663 78 8 0 Y' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO FINANCIAL PENNSYLVANIA, CUMBERLAND COUNTY INC. Plaintiff, COURT OF COMMON PLEAS V SHIRLEY A. REITZ Defendant(s) CIVIL DIVISION No.: 2010-03296 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA PHILADELPHIA COUNTY As required by Pa. R.C.P. 3129.1(a) Notice of S, and any known interested party in the manner require the persons or parties named, at that address' set forth applicable. A copy of the Certificate of Maili g (Form Receipt stamped by the U.S. Postal Service is a, , SS: (has_ been given to Lienholders by Pa. R.C.P. 3129.2(c) on each of n tl ie Affidavit and as amended if and/or Certified Mail Return ,rnin TT- h ; h,i ." A 75 ;""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 Sh tal R. Shah-Jani, Esq., Id: No. 81760 ? nine 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. Spivac]<, Esq,, Id; No. 844'u9 ? Jaime McGuinness, Esc., Id. No. 9!0134 ? Chrisov'alante R Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett; Esq., Id. Na. 208375 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It maynot 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 #231359 IP F' ci £ 0 b6 L 3000dIZ World 0311dW oioz sods 99z?Zzoooo a9Z" i M z o S3M08 A3N1Id _ C c> u> ?nT ?h??$oa ?ydy5 W Q 0 N H Q O b U U u?r o y 0 V tz Cl U c V a Y U GI O ! y s«. M i . J ., C D° °? > y ? v V TJ N ?" = o iL :o T i. p ?C Q C1r O ® p Q? CL *?' O Q O ?? . p v' a s L 'd Z w> 00 N .:d O L, G wr y eh bJ ? Cd IS ?', ?LJ V. W 1" t U J? ? E5 L 0 ? O M ? y "? ?' > el G ... gyp. C ? , Q CC n , y . 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U?5 , dZ7 ?J w?' ,? > : C1. >hCU7GL .,Q G, ?C! cC '[ _ x A ? cC '? ?, w &,. ? < '. N' IV LYi 6a it s. 'G aY h ^ 17'-o q tV w O . 5 bb .• ' W 4.r d '?' +2 y w (li r Q O?" V 4, 1" ? ? ? CJ C :{. C O ? p L ? ? ._. t.. N ? O Qa ..?". p _ > u 4 r ' U O ? ? •:; , . L td O C C C C O. s ? ? . . ? ? ? w A d C i ' C O i rv . , E cC Z h p Lx? Z i O C E L O y C,' y U] f/1 N C,7 u aJ -. x .L L° r ; Zi ?" 1 ?4 1;,? tV U .-•t u O , cC U A d cC ' ? ` ° ?n d p In Nv c? N , ro (: ro y - ., ?, :-I P, . ,.7 G? t`3 N N ?/ M C/7 ? : U W - ? , a Q t ° ? E N ?, N I - _ .7? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f lLc-v" Sheriff „ r'0 ' ,, atit???n °` wubrr?l? THE. ) 1 ri t e.`. Jody S Smith ? Chief Deputy 2011 M1 27 A41 8• Richard W Stewart vUMBERLAND COUN FY Solicitor Wells Fargo Financial Pennsylvania Inc Case Number vs. 2010-3296 Shirley A. Reitz SHERIFF'S RETURN OF SERVICE 10/14/2010 04:26 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1626 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Shirley A. Reitz, located at, 607 North 2nd street, a/k/a 607 North Second Street, Wormleysburg, Cumberland County, Pennsylvania according to law. 10/14/2010 04:26 PM - Deputy Amanda Cobaugh, being duly sworn according to law, attempted service to the Defendant, to wit: Shirley A. Reitz at 607 North Second Street, Wormleysburg Borough, Wormleysburg, PA 17043. The address was found to be vacant. 10/18/2010 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: Shirley A. Reitz, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Shirley A. Reitz, address is Vacant, defendant did not leave forwarding address at Post Office. 12/08/2010 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, Pennsylvania on Dec 08, 2010 at 10:00 AM. He sold the same for the sum of $ 23,600.00 to Central Penn Capital Management, LLC on behalf of Chesapeake Loan Servicing, LLC, 100 South 7th Street, Akron, PA 17501, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,546.20 SO ANSWERS, January 19, 2011 RON R ANDERSON, SHERIFF YI.01D POP. ". a op P), 10 ti, ?` a 5??307 . ? A SCHEDULE OF DISTRIBUTION Date Filed: 1/5/11 Writ No. 2010-3296 Civil Term Wells Fargo Financial Pennsylvania, Inc. Vs Shirley A. Reitz 607 North 2nd Street Wormleysburg, PA 17043 Sale Date: December 8, 2010 Buyer: Chesapeake Loan Servicing, LLC Bid Price: $ 23,600.00 Real Debt: Interest: Attorney Writ Costs Total: DISTRIBUTION: $ 97,979.99 2,609.82 204.90 $ 100,794.71 Receipts: Cash on Account (09/17/2010): $ 1,500.00 Cash on Account (12/08/2010): 2,360.00 Cash on Account (12/27/2010): 24,483.50 Total Receipts: $ 28,343.50 . V a Disbursements: Sheriffs Costs $ 1,246.20 Legal Search 300.00 Transfer Tax State 1,235.75 Transfer Tax Local 1,235.75 Cumberland County Tax Claim Bureau 1,896.52 Alma Berresford Wormleysburg Tax Collector 2010 1,746.44 Alma Berresford Wormleysburg Tax Collector 2011 1,818.60 (This Total Represents 2010 Spring Taxes x 3 for 2011 Spring Taxes) Borough of Wormleysburg (Sewer/Refuse) 840.95 Attorney Daniel G. Schmieg 1,500.00 Wells Fargo Financial Pennsylvania, Inc. 16,523.29 Total Disbursements: ($ 28,343.50) Balance for distribution: 00.00 So Answers: Ronny R. Anderson Sheriff WELLS FARGO FINANCIAL PENNSYLVANIA, INC! Plaintiff 1 COURT OF COMMON PLEAS CIVIL DIVISION V. SHIRLEY A. REITZ Defendant(s) NO. 2010-03296 CUMBERLAND COUNTY PHS # 231359 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO FINANCIAL PENNSYLVANIA, INC., 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 607 NORTH 2ND STREET A/K/A 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003. Name and address of Owner(s) or reputed Owner(s): Name 2. 3 4 SHIRLEY A. REITZ Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 4 THOMAS DRIVE DUNCANNON, PA 17020-9762 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) Household Finance Consumer Discount Company Household Finance Consumer Discount Company Wells Fargo Financial Bank Household Finance Consumer Discount Company C/O Records Processing Services 25 Gateway Drive, Suite 107 Mechanicsburg, PA 17055 25 Gateway Drive Gateway Square, Suite 107 Mechanicsburg, PA 17055 3201 North 4`h Avenue Sioux Falls, SD 57104 577 Lamont Road Elmhurst, IL 60126 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 ro,, i!? c i 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 t!ti ;r. oo t,, be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 607 NORTH 2ND STREET WORMLEYSBURG, PA 17043-1003 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 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program River view Associates 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 6`h Floor, Strawberry Square Dept 28061 Harrisburg, PA 17128 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 Hilt's Lane North of Private Road Wrightsville, PA 17368 I verify that the statements made in this affidavit are true and correct to the best of n knowledge or information and belief I understand that false statements herein are made t n ; of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Agust-2-';, 2010 By: Attorney for Plaintiff 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 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Joshua I. Goldman, Esq., Id. No. 205047 ^^ llfis Cii:i?' _?'e e_'eii F. i. i':i• si7. ''" [Andrew C. Bramblett,'Esq., Id. No. 208375 l V AA/TT T C P A 1DC- 1 FTN A Add- A T FLd?S .. .R PTi'NllTCVT V A NT A INC a_s a_ . A . a: as a . i .i lS PnTTRT n1W f n1%4X4!1N PIN A C Plaintiff : CIVIL DIVISION VS. SHIRLEY A. REITZ Defendant(s) : NO. 2010-03296 : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SHIRLEY A. REITZ 4 THOMAS DRIVE DUNCANNON, PA 17020-9762 "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 607 NORTH 2ND STREET A/K/A 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003 is scheduled to be sold at the Sheriff's Sale on 12/08/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $97,979.99 obtained by WELLS FARGO FINANCIAL PENNSYLVANIA, INC. (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.) VnIT MAV CT114, RIP, ABLE, TO SA IF THE VF YOUR PROPERTY AND YOU HAVE, OTHER RI 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. 2010-03296 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. vs. SHIRLEY A. REITZ owner(s) of property situate in the BOROUGH OF WORMLEYSBURG, Cumberland County, Pennsylvania, being (Municipality) 607 NORTH 2ND STREET A/K/A 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003 Parcel No. 47-19-1588-010 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $97,979.99 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION All that certain lot of land situate in the Borough of Wormleysburg, (formerly East Pennsboro Township) Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit:- - BEGINNING at a point on the eastern line of Second Street, said point being on the southern line of Lot No. 118 on Plan of Lots hereinafter mentioned; thence southwardly along the eastern line of Second Street twenty (20) feet, more or less, to a point on the line passing through the center of the partition wall of the double brick dwelling erected in part upon the lot hereby conveyed; thence in an easterly direction along said line through the center of said partition wall one hundred twenty (120) feet, more or less, to a point on the western line of a 15 foot alley; thence northwardly along the western line of said alley twenty (20) feet to a point on the southern line of Lot No. 118 on the said hereinafter mentioned Plan of Lots; thence westwardly along the southern line of said lot one hundred twenty (120) feet to a point on the eastern line of Second Street, the point or place of BEGINNING. BEING Lot No. 117 on Plan of Lots laid out by Edwin M. Hershey and known as 'Riverview', said Plan being recorded in the Recorder's Office in and for Cumberland County, Pennsylvania, in Plan Book 1, Page 103. HAVING thereon erected the northern half of a double brick dwelling house known and numbered as 607 North Second Street, Wormleysburg, Penna. TITLE TO SAID PREMISES VESTED IN John J. Reitz and Shirley A. Reitz, his wife, by Deed from H. James Steckbeck and Grace Ann Steckbeck, his wife, dated 10/15/1964, recorded 10/15/1964 in Book J-21, Page 907. By virtue of the death of John J. Reitz on 12/13/1970, Defendant became sole owner of the mortgaged premises as surviving tenant by the entireties. PREMISES BEING: 607 NORTH 2ND STREET A/K/A 607 NORTH SECOND STREET, WORMLEYSBURG, PA 17043-1003 PARCEL NO. 47-19-1588-010 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-3296 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff (s) From SHIRLEY A. REITZ (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 $97,979.99 L.L. $.50 Interest from 6/30/10 to Date of Sale ($16.11 per diem) -- $2,609.82 Atty's Comm % Due Prothy $2.00 Atty Paid $204.90 Other Costs Plaintiff Paid Date: 9/3/10 David D. BuelJProth ar y (Seal) By: Deputy REQUESTING PARTY: Name: ANDREW C. BRAMBLETT, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone : 215-563-7000 Supreme Court ID No. 208375 On September 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA, Known and numbered as, 607 North 2nd Street A/K/A 607 North Second Street, Wormleysburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: Real Estate Coordinator F i The Patriot-News Co. 2020 Technology, Pkwy Suite 300 Mechanicsburg, PA 170.50 Inquiries - 717-255-8213 Zhe Patr1*otAkXtws Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market StreE!t, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the fact; 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: 2010-32% Chill Term 10/15/10 Wells Fargo Financial Pennsyhranla Inc 10/22/10 vs Shirley A. Reitz 10/29/10 Atty: Daniel G Schmleg By virtue of a Writ of Execution NO. 2010- J1 1 03296 ........ ? . `?? ?_-.? , . . l... . WELLS FARGO FINANCIAL. PENNSYLVANIA, INC. vs. Sworn to ansh- (scribed be e thi 1q,day gi?November, 2010 A.D. SHIRLEY A. REITZ / owner(s) of property situate in the BOROUGH OF WORMLEYSBURG, Cumberland County, Pennsylvania, being --- (Municipality) Notary Public 607 NORTH 2ND STREET A/K/A 607 NORM SECOND STREET, WORMLEYSBURG, PA 17043-1003 Parcel No. 47-19-1588-010 (Acreage or street address) Improvements thereon: RESIDENTIAL COMMONWEALTH OF PENNSYLVANIA DWELLING Notarial 5Ial JUDGMENT AMOUNT. $97,979.99 Sherrie L Klsner, Notary Public EmLyo we r Paxton Twp., Dauphin County Commisslon Expires Nov. 26, 2011 Member. pennsvhrania Associatinn of Notaries PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 22, October 29, and November 5, 2010 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. L L-11- isa Marie Coyne, Edijor SWORN TO AND SUBSCRIBED before me this 5 day of November 2010 J Notary , NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL Writ No. 2010-3296 Civil Wells Fargo Financial Pennsylvania Inc. VS. Shirley A. Reitz Atty.: Daniel G. Schmieg By virtue of a Writ of Execution NO. 2010-03296, WELLS FARGO FINANCIAL PENNSYLVANIA, INC. vs. SHIRLEY A. REITZ, owner of property situate in the BOROUGH OF WORM- LEYSBURG, Cumberland County, Pennsylvania, being 607 NORTH 2ND STREET A/K/A 607 NORTH SEC- OND STREET, WORMLEYSBURG, PA 17043-1003. Parcel No. 47-19-1588-010. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $97,979- .99. 103 SNELBAKER & BRENNEMAN, P. C. ATTORNEY AT LAW 44 W. Main Street Mechanicsburg, PA 17055 TITLE REPORT TO: Sheriff of Cumberland County RE: Sheriffs Sale, Writ No. 2010-3296 held December 8, 2010 EFFECTIVE DATE: December 8, 2010 PREMISES: 607 North 2"d Street, Wormleysburg, Borough of Wormleysburg, Cumberland County, Pennsylvania, Tax Parcel No. 47-19-1588-010 (the "Premises") RECITAL: Being the same premises which H. James Steckbeck and Grace Ann Steckbeck, husband and wife, by their deed dated October 15, 1964 and recorded October 15, 1964 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book "J", Volume 21, Page 907, granted and conveyed unto John J. Reitz and Shirley A. Reitz, husband and wife. The Premises identified above and as more fully described in the legal description attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items and exceptions. All recording and docket locations identified are in the Office of the Recorder of Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County. EXCEPTIONS: 1. Claims and charges for improvements and repairs to the Premises or delivery of materials thereto for which payment has not been made. 2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments. The rights or claims of any tenants or other parties in possession. 4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of 1997, as amended. 5. Any environmental liens or claims filed or on record in the Federal District Court. 6. Payment of state and local real estate transfer tax, if applicable. 7. Any secured transactions with respect to the Premises. 8. The area of the Premises is not certified. 9. Those matters which a view or inspection of the Premises would reveal. 10. The accuracy of the measurements and dimensions of the Premises or the rights or title of or through any person or persons in possession of same, conflicts with adjoining property, encroachments, projections or any other matter disclosed by an accurate survey of the Premises. 11. The right of use as may be determined by any applicable municipal zoning ordinance or regulation. 12. Any matter not of record at the Court House as of the effective date of this Title Report and subsequent to the date hereof. 13. Any tax increase based on additional assessment made by reason of new construction or major improvements. 14. The absence or failure of proper and required notice being given to all owners and holders of liens and encumbrances intended to be divested by the Sheriffs sale and procedural defects by any judgment creditor or lienholder executing on the Premises giving rise to the Sheriffs sale noted above. 15. Identity and legal competency of all parties at any closing or conveyance of the Premises should be established. 16. Access to the Premises by public road or street is not certified. 17. Suitability or existence of sewer and water facilities on or available to the Premises is not certified. 18. Real Estate taxes on the Premises due and payable but not turned over for collection to the Tax Claim Bureau. 19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate taxes accruing on and after January 1, 2010. 20. Mortgage in the amount of $23,950.00 from John J. Reitz and Shirley A. Reitz to Household Finance Consumer Discount Co. dated July 21, 1997 and recorded July 23, 1997 in Mortgage Book 1395, Page 51. -2- 21. Mortgage in the amount of $38,066.00 from John J. Reitz and Shirley A. Reitz to Household Finance Consumer Discount Co. dated October 19, 1998 and recorded October 23, 1998 in Mortgage Book 1491, Page 478. 22. Mortgage in the amount of $88,430.00 from John J. Reitz and Shirley A. Reitz to Wells Fargo Financial PA, Inc. dated October 21, 2004 and recorded October 28, 2004 in Mortgage Book 1885, Page 4535. 23. Judgment against Shirley A. Reitz in the amount of $97,979.99 in favor of Wells Fargo Financial of Pennsylvania entered July 6, 2010 and docketed to No. 2010-3296. 24. Subject to the legal operation and effect of the absence of John J. Reitz in the mortgage foreclosure action docketed to number 2010-3296, the absence of any estate opened with respect to John J. Reitz, if deceased and the rights of any spouse, if any, of Shirley A. Reitz subsequent to any death of John J. Reitz. 25. Subject to all building set-back lines, easements, restrictions, conditions, notes and all other matters appearing on the Plan of Riverview recorded in Plan Book 1, Page 103. 26. Subject to the rights granted PPL in Misc. Book 110, Page 462. 27. Subject to the easements of any and all partition walls. 28. Subject to the rights of others in and to those portions of the Premises lying within or adjoining North 2"d Street, also known as North Second Street and the alley which abuts the Premises. 29. Subject to the legal operation and effect of the lack of any legal description contained in any notice of the Sheriffs Sale of the Premises. The undersigned shall not be bound by this Title Report to any person, firm or entity other than the Sheriff of Cumberland County. Snelbaker & Brenneman, P. C. By: ?G y Keith O. Brenneman -3- . . Writ No. 2010-3296 Civil Wells Fargo Financial Pennsylvania Inc. vs. Shirley A. Reitz Atty.: Daniel G. Schmieg By virtue of a Writ of Execution NO. 2010-03296, WELLS FARGO FINANCIAL PENNSYLVANIA, INC. vs. SHIRLEY A. REITZ, owner of property situate in the BOROUGH OF WORM- LEYSBURG, Cumberland County, Pennsylvania, being 607 NORTH 2ND STREET A/K/A 607 NORTH SEC- OND STREET, WORMLEYSBURG, PA 17043-1003. Parcel No. 47-19-1588-010. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $97,979- .99. EXHIBIT A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Chesapeake Loan Servicing LLC is the grantee the same having been sold to said grantee on the 8th day of December A.D., 2010, under and by virtue of a writ Execution issued on the 3rd day of September, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 10 Number 3296, at the suit of Wells Fargo Financial Pa Inc against _Shirley A Reitz is duly recorded as Instrument Number 201103308. IN TESTIMONY WHEREOF, I have hereunto set my hand and eal of said office this 2 day of JA 11, A.D. 201Z recorder of Deeds