The URL can be used to link to this page

Home My WebLink About10-4063~~ Phelan Hallman & Schmieg, LLP 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., 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 2]5-563-7000 233305 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 ,~t- T r:,-- TA,;~V _~~ C'c,. i , .. , . ., X010 ~~~~ i ~ f ~'~ I?~ ~~ ip - ~t~f~~~ Cu~~r ~,, j~ I :w~ ~'kf1't ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff v. DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 29 ADAMS STREET AKA 29 ADDAMS STREET ENOLA, PA 17025 MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 29 ADAMS STREET AKA 29 ADDAMS STREET ENOLA, PA 17025 VIRGINIA COX, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 101 BRENTON STREET INDIAHOMA, OK 73552 VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 233A MARKET STREET MECHANICSBURG, PA 17055 Defendants TERM CUMBERLAND COUNTY CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 233305 s ~ a-- 6~ ~ ~ ~r caw' 966/+4Q ~~~y3 sti7 ~, 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 #: 233305 Plaintiff is WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 29 ADAMS STREET AKA 29 ADDAMS STREET ENOLA, PA 17025 MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 29 ADAMS STREET AKA 29 ADDAMS STREET ENOLA, PA 17025 VIRGINIA COX, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 101 BRENTON STREET INDIAHOMA, OK 73552 VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 233A MARKET STREET MECHANICSBURG, PA 17055 who is/are the real owner(s) of the property hereinafter described. 3. On 06/22/2001 mortgagor's CARL K. BEERS and MARTHA J. BEERS 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. 1725, Page 910. 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 File #: 233305 Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those 4 5 6 documents are of public record. 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 10/27/2009 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. The following amounts are due on the mortgage: Principal Balance $72,534.17 Interest $2,608.91 09/27/2009 through 03/08/2010 (Per Diem $16.20) Attorney's Fees $650.00 Cumulative Late Charges $71.46 06/22/2001 to 03/08/2010 Property Inspections/Property Preservations $45.00 Costs of Suit and Title Search $550.00 TOTAL $76,459.54 7. 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 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 File #: 233305 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. 9. By virtue of the death of CARL K. BEERSon 10/05/09, MARTHA J. BEERS became the sole owner of the mortgaged premises as surviving tenant by the entireties. 10. Mortgagor MARTHA J. BEERS died on 10/31/09, leaving a Will dated 11/25/86. Letters Testamentary were granted to DEBRA BEERS on 02/08/10 in Cumberland County, No. 21-09-1170. Decedent's surviving heirs at law and next-of--kin are DEBRA BEERS, MARY BEERS, VIRGINIA COX, and VAL PARR. 11. Plaintiff hereby releases CARL K. BEERS ftom liability for the debt secured by the mortgage. 12. Plaintiff does not hold the named Defendants, DEBRA BEERS, MARY BEERS, VIRGINIA COX, AND VAL PARR, personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendants in the aforesaid real estate only, and the Defendants have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa C.S.A. § 301(b). File {/: 233305 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $76,459.54, together with interest from 03/08/2010 at the rate of $16.20 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 r B ^ I~,awrence 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 #1: 233305 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the north side of Addams Street, said point being a distance of one hundred seventy-five (175) feet in a westerly direction from the western line of a fifteen (15) foot alley; thence in a northerly direction along the westerly line of Lot # 154 on the hereinafter mentioned plan of lots one hundred fifty (150) feet to the southerly line of Monroe Street; thence in a westerly direction along the southerly line of Monroe Street seventy-five (75) feet to the easterly line of Lot #158 on the hereinafter mentioned plan; thence in a southerly line along the easterly line of said lot #158, one hundred fifty (150) feet to a point on the northerline line of Addams Street; thence in an easterly direction along the northern line of Addams Street seventy- five (75) feet to the place of BEGINNING. HAVING THEREON ERECTED a one story single frame dwelling known as No. 29 Addams Street, Enola. BEING lots Nos. 155, 156 and 157 on the Plan of Lots laid out by Pyne and Addams said Plan being recorded in the Office for the Recording of Deeds in and for Cumberland County in Plan Book No. 1, Page 17. BEING the same premises which Robert B. Failor, Sheriff of Cumberland County, by his deed dated September 18, 1967 and recorded in Cumberland County Deed Book 'M,' Volume 22, Page 959, granted and conveyed unto the Peoples Bank of Enola. Cumberland County National Bank and Trust Company is successor by merger to the Peoples Bank of Enola. PARCEL NO. PREMISES 17025-2829 09-15-1291-291 29 ADAMS STREET AKA 29 ADDAMS STREET, ENOLA, PA File #: 233305 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. ] 024 (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: `~' j~ ~ Attorney for Plaintiff File #: 233305 a Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 I~~.a~i~ G. Schmieg, Esq., Id. No. 62205 I~:ich~;le M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 ~~d~c,ctal R. Shah-Jani, Esq., Id. No. 81760 N ;iii ~ ~c 1; , f )avey, Esq., Id. No. 87077 1_.auren R 1'abas, Esq., Id. No. 93337 i~~~;ek Srivastava, Esq., Id. No. 202331 .~~°,~,~ [3. Jones, Esq., Id. No. 86657 ~'ec~r .~ .Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 .I,~;rt~~° McGuinness, Esq., Id. No. 90134 E'i~r:,~~vr~lante P. Fliakos, Esq., Id. No. 94620 .l~~sl~~ua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 An~ir~-v, C. Bramblett, Esq., Id. No. 208375 '~ ~~ ~ -~ .~ ~~}t E>oulevard, Suite 1400 {.~n , ~'r~~~~ ~~`enter Plaza ~y~,r!;,?~;,~?pl~=<~ PA 19103 ~. ~,al(} ~~~~ ~;C.;l.S ~'ARGO BANK, N.A. SB/M 'I'(I ~~ACHOVIA BANK OF i:~ 1? ~ . ~. ~4 A RE, N.A. F/K/A FIRST I ~ ~()N NATIONAL BANK OF ~ I~1 hA WARE Plaintiff vs. I)~;BRA BEERS MARY BEERS V[RC:INIA COX VAI. PARR Defendant(s) 1 1 : 1 2010 Jt~i~3 2~ Phi t : 41 s~t;~~ C~t~tJrt -. .~ a k'~„Iv~Y~?~, ~SY``,~4i ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO.10-4063-CIVIL CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION ~'}1~ +?: 2.33305 TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP 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 ^ 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 llate: 6-23-10 f' f +` ~; '#: 233305 VERIFICATION Anne Neely ,hereby states that he/she is v.P. ~oa~ oo~Umenc~no» of, WELLS FARGO HOME MORTGAGE, INC., servicing agent for Plaintiff in this matter, WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE, that he/she is authorized to take this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 6/11/10 Name: Anne Neely Title: V.P. Loan Documentation Servicer: WELLS FARGO HOME MORTGAGE, INC. File #: 233305 Name: BEERS Phelan Hallinan &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel (~~. 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 Vivf•~: Sr?vastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter a . '~,q ulcahy, Esq., Id. No. 61791 Anti; ~. ~.r (_. Spivack, Esq., Id. No. 84439 Jaii~~~~ `~~IcGuinness, Esq., Id. No. 90134 Chr~~;.~~~,~l:~nte P. Fliakos, Esq., Id. No. 94620 Jos}tt,it '. C)oldman, Esq., Id. No. 205047 Coi+a~te~l~y R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 161 % Jl K Boulevard, Suite 1400 Ong `~e;,~~ Center Plaza Phil:~~ic;ihhia, PA 19103 215-563-7000 WF ~ I.S FARGO BANK, N.A. SB/M T(I ~~ ;OC'HOVIA BANK OF D E x~ W A RE, N.A. F/K/A FIRST C' N ~ ~ ~ ~; i~ .~ `TIONAL BANK OF Plaintiff vs. DEBRA BEERS MARY BEERS VII~tINIA COX VAL: PARR Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO.10-4063-CIVIL CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: PT-I~ j;~: 233305 DEBRA BEERS 29 ADAMS STREET ENOLA, PA 17025-2829 MARY BEERS 29 ADAMS STREET ENOLA, PA 17025-2829 VIRGINIA COX 101 BRENTON ST INDIAHOMA, OK 73552 VAL PARR 233A MARKET ST MECHANICSBURG, PA 17055-3342 EDWARD P. SEEBER 555 GETTYSBURG PIKE, SUITE C-400 MECHANICSBURG, PA 17055 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: c~ awrence T. Phelan, Esq., Id. o. 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., ld. No. 205047 ~} Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 Date: 6-23-10 d~~ ~" ,<I. 233305 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~Qtti~ite of ~itt~b~~.#,r~~ ~'I ~~ T' ~. - i:_ F "~-ter i'w ~. [ i .~ tiv Cr::. .~ ~..- ~ ~ v~ v:; Richard W Stewart Solicitor S,~F~ L"E~~~ '"c',B;~~EPoFF C`+~~ ~pJ-,. ~ y., ++ tt ,, .~; ~ ; ~ ~~!'~I Jt,1 rLYt~ yr ~1 Wells Fargo Bank, NA vs. Case Number Debra Beers (et al.) 2010-4063 SHERIFF'S RETURN OF SERVICE 06/17/2010 05:55 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2010 at 1750 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Debra Beers, by making known unto herself personally, at 29 Adams Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEPUTY 06/18/2010 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: Virginia Cox, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Virginia Cox. Debra Beers, current resident of 29 Adams Street, Enola, PA 17025 advised Deputies Virginia Cox is residing in Oklahoma. 06/24/2010 03:38 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 24, 2010 at 1538 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mary Beers, by making known unto herself personally, at 422 1st Street Floor 1, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. ~~ NOAH CLINE, DEPUTY 07/01/2010 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: Val Parr, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Val Parr. Request for service at 233A Market Street, Mechanicsburg, PA 17055 does not exist. 07/01/2010 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: Val Parr, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Val Parr. Debra Beers, current resident at 29 Adams Street, Enola, PA 17025 advised Deputies Val Parr is residing at 233A Market Street, Mechanicsburg, PA 17055. However, 233A Market Street, Mechanicsburg, PA 17055 does not exist. SHERIFF COST: $134.90 July 01, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj founiySutte Sherdf_ l'eleosofl. Inc. I'I,AINTIFF i5'};L,t.S FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF t1Ga.A WARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF UF:I,AWARE UEl?'ENDANT Dk;BRA BEERS YIARY BEERS VIR(G1IA COX VAL PARR PHS # 233305 SERVICE TEAM/ cec COURT NO.: 10-4063-CIVIL SERVE VIRGINIA COX AT: TYPE OF ACTION 101 BRENTON ST XX Mortgage Foreclosure -,~, ~=~~ ~ a INDIAHOMA, OK 73552 XX Civil Action r , ~ , - C t' ~~4~ ~~ SERVED .. V1 t~r; Served and made known to VIRGIlVIA COX ,Defendant on the'~_ day oQul~ , 20 LQ 2[t. ~ ,- ~ `~ o'clockAM.,at101 Brenton;Tnc3iahc~m~tthemannerdescribedbelow: ~__ Defendant personally served. OK 7 3 5 5 2 _^ Adult family member with whom Defendant(s) reside(s). ~ - e Relationship is ~ ~ ___ Adult in charge of Defendant's residence who refused to give name or relationship. ____ ~/Ianager/Clerk of place of lodging in which Defendant(s) reside(s). __ _ ~. ~ ent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _ __ _. (7ther: `icstription: Age 50 Height 51411 Weight 160 Race W Sex F Other i. L~rrv Maples , a competent adult, being duly sworn according to law, depose and state that I personally 'a._~~at_~:'. ,r true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned ;~:r Aux ti)e date and at the address ~ dicated above. `.~ucian to and subscribed `~`1~B,t,gtf4bciot ~ me is -~ day --~ ~~"s ", ,2o t'SS-a9a ~' ~° ~°T ~ trooot ~'~ ~~ K~ W ~~/ad -~ =rn orn.~~A~n2 a- ` NOT ERVED ?rye A~.~ . `~e day of , 20_, at _ o'clock _. M., Defendant NOT FOUND because: ~ryi~ ~F OK~-p.```~ Vacant _ Bad Address _ Moved _ Does Not Reside (Not Vacant) thnunnn~N No Answer on at at Service Refused C)th~r: ~ ern to and subscribed l,~ , c. me this day uf. ~~ By: Notary: AFFH)A~v IT OF SERVICE CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF Iawlmm T. Phelan, Esq., Id. No. 32227 Francis S. HaBb,an, Esq., Id. No. 62695 Uaniel G. Schmieg, Esq., Id. No. 62205 Mirhde M. Bradford, Esq., Id. No.69849 Judith T. Rorreno, Esq., Id. No. 58745 Sheelai R Shah-Jan4 Esq., Id. No. 81760 Jenire R Davey, Esq., hl. No.87077 Lauren R Tabs; Esq., hl. No.93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., td. No. 86657 Peter J. Malwlry, Esq., Id. No. 61791 Andrew L. Spivack Esq., hi. No. 84439 Jaime McGuinness, Esq., Id. No.98134 Chrisovalarde P. FBakas, Esq., td. No. 94620 Jashm I. Gotlman, Esq., Id. Nw 206047 Coarterray R Dmrq Esq., hL No. 206779 Andrew C. Brarxblett, Esq., Id. No. 208375 One Penn Censer W Snb Station 1617 John F. Kennedy Bhvl., Suite 1400 Philsdelphiy PA 19103-1814 (215)563-7000 "~ i _-t r . ~=' ~_ ~ ~l°I 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 ~/Cauren 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. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff vs. DEBRA BEERS MARY BEERS VIRGINIA COX VAL PARR Defendants ~..;'F' ~v!° ~G= ~o~ P .. ~~ ~ ' ,, d ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 10-4063-CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE $10.0o Po Airy c~ 9e~+cd9 e~ ay`sa~ TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. HALLINAN & SCHMIEG, LLP "LJ'Lawrence T. Phelan, Esq., Id-Nr~2227 ^ 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 ^ S etal 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. 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: August 0.2010 /cec, Svc Dept. File# 233305 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. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff vs. ,;;._ ~~ („' 4 ,3 een. •_~". Rai Aa P!1 a^~ _,: ~ ~ ~, ~~ ~.S .,3 .I, c..ilt~El`~iJ1 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY DEBRA BEERS, IN HER CAPACITY AS No. 10-4063-CIVIL AEXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VALL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED O ~lo• oo Po A-ml C~ IDOfo a.8$ ~ a~~o Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN & SCHMIEG, LLP By: awrence 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: September 21, 2010 /arm, Svc Dept. File# 233305 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson; ? Y RY Sheriff ?qt'?' of ?aar{l?pin? Jody S Smith Est j ; 19 Chief Deputy rt i Richard W Stewart Solicitor Wells Fargo Bank, NA vs Case Number . Debra Beers (et al.) 2010-4063 SHERIFF'S RETURN OF SERVICE 09/03/2010 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: Val Parr, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Val Parr. Request for service at 233A Market Street, Mechanicsburg, PA 17055 does not exist. SHERIFF COST: $42.00 September 03, 2010 SO ANSWERS, R-ONI'V R ANDERSON, SHERIFF (ej Coon sputa Shentf. T'OK)soft, Inc, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r,F l E rrtF cRtFF t r7'?,l Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, NA vs. Debra Beers (et a).) Case Number 2010-4063 SHERIFF'S RETURN OF SERVICE 09/24/2010 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: Val Parr, in her capacity as Heir of The Estate of Martha J. Beers, Deceased, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Perry County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 09/29/2010 Perry County Return: And now, September 29, 2010 I, Carl E. Nace, Sheriff of Perry County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Val Parr the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in the County of Perry and therefore return same NOT FOUND. Defendant is thought to be residing at 233-A W. Main Street, Mechanicsburg, PA 17055. 10/04/2010 08:07 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 4 2010 at 2007 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Val Parr, by making known unto herself personally, at 233A W. Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $53.00 October 05, 2010 l_ ROB RT BITNER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF %c; CountySuite Shenk, Teleo=oft. Inc. SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania- Perry County Branch No. 2010-4063 Cumberland Co. Wells Fargo Bank NA Vs Val Parr 501 Windy Hill Rd. #66 Shermans Dale, PA 17090 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit Val Parr, but was unable to locate him/her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure for the above named Defendant(s) Val Parr at 501 Windy Hill Rd. #66, Shermans Dale, PA 17090. NOT FOUND. DEFENDANT LIVES AT 233-A W. MAIN ST., MECHANICSBURG, PA 17055. Sincerely, Sworn and ubscrib d to before me this ay of , 2010. W EAK OF PENNSYLVANIA NOTARIAL SEAL JOY S. aRANCE NO ARy PUBLIC NEW BLOOMFIELD BORO., PERRY COUNTY MY COMMISSION EXPIRES MARCH 6 ,2014 Carl E. Nace Sheriff of Perry County 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 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE VS. DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX, IN HER CAPACITY AS OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED a,Mk Ak 14. 3co i)D y s j, 9L53 233305 Attorney for Plaintiff c -OZ rnM Z3 -ti c.n r C M ) .?d "fro Sr -? `ry : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-4063-CIVIL 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 DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED, MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED, VIRGINIA COX, IN HER CAPACITY AS OF THE ESTATE OF MARTHA J. BEERS, DECEASED and VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED, 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 Plaintiffs damages as follows: As set forth in Complaint $76,459.54 Interest - 03/09/2010 to 12/08/2010 $4,455.00 TOTAL $80,914.54 I hereby certify that (1) the Defendants' last known addresses are 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829,422 1ST STREET, FL 1, CARLISLE, PA 17013-1801, 101 BRENTON STREET, INDIAHOMA, OK 73552-5017,233A WEST MAIN STREET, MECHANICSBURG, PA 17055-6226, and (2) that notice has been given in accordance with Rule 237 1 copy attached. U Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 6269 ? Daniel G. Schmieg, Esq., Id. No. 622 ? Michele M. Bradford, Esq., Id. No. 6 849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-.Tani, 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 gCourtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: /ra LIk4t;tI, - A CC:EDWARD P. SEEBER, ESQUIRE 555 GETTYSBURG PIKE, SUITE C-400 MECHANICSBURG, PA 17055 PHS # 233305 PROTHONOTARY 233305 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 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 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 VS. DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX, IN HER CAPACITY AS OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS . CIVIL DIVISION : No. 10-4063-CIVIL 233305 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. (b) that defendant DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED is over 18 years of age and last known address is 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829. (c) that the Plaintiff is without information sufficient to determine whether the defendant MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 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; and (d) that defendant MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED is over 18 years of age and last known addresses are 422 1 ST STREET, FL 1, CARLISLE, PA 17013-1801 and 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829. (e) that defendant VIRGINIA COX, IN HER CAPACITY AS OF THE ESTATE OF MARTHA J. BEERS, DECEASED is over 18 years of age and last known addresses are 101 BRENTON STREET, INDIAHOMA, OK 73552-5017 and 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829. (f) that defendant VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED is over 18 years of age and last known addresses are 233A WEST MAIN STREET, MECHANICSBURG, PA 17055-6226 and 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829. This statement is made subject to the penalties of 1 Pa C.S. Se n 4904 relating to unsworn falsification to authorities. December 8, 2010 ? Lawre ce'f. h?an, Esq., Id. No. 227 ? Fran s S. H linan, Esq., Id. No. 695 ? Dan' I G. Sc mieg, Esq., Id. N 62205 ? Mi ele M. adford, Esq., I . o. 69849 ? Ju ith T. Rom o, Esq., WeNo. 58745 ? Sheetal R. Shah- sq., 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 ? aime McGuinness, Esq., Id. No. 90134 hrisovalante 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 Attorney for Plaintiff 233305 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A. SB/M TO CUMBERLAND COUNTY WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF COURT OF COMMON PLEAS DELAWARE VS. CIVIL DIVISION DEBRA BEERS, IN HER CAPACITY AS No. 10-4063-CIVIL EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX, IN HER CAPACITY AS OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 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 ? 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 please contact: 4+ ? aime McGuinness, Esq., Id. No. 90134 LChrisovalante P. Fliakos, Esq., Id. No. 94620 U 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 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 YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY" 233305 WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff V. COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4063-CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTIIJG 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. PHS # 233305 I 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Coin. louse Square CUMBERLAND COUNTY COURTHOUSE Carlisld PA `17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 j 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., Id. No. 69849 Judith T. Romano, Esq. Id. No.' 58745 ,? a . r .. _ _ ......, ... w...: , . , ....r .. .. Sheetal R. Shah-Jani, Esq.; Id. No. 81760 Jenne R Davey, Esq., Id. No. 87077 -Lauren R. Tabas , Esq., .:.:,,.. - 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. o. ;. - __ - s, .e. ... a uv,..... . .. r ... _ 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 206779 No . , . . Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 233305 A' WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE COURT OF COMMON PLEAS CIVIL DIVISON NO. 104063-CIVIL Plaintiff V. CUMBERLAND COUNTY . x" DATE OF NOTICE: November 18, 2010 _ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO. COLLECT, A DEBT.. THIS NOTICE IS SENT TO,,-YOU IN AN ATTEMPT TO COLLECT TIC 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. PHS # 233305 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA. 170113 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 Y: Lawrede. 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. N6.'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. Id: Nok90134, Chrisovalante P. Fliakos, Esq., Id. No. 94620 _ Joshua I. Goldman, Esq., Id. No. 205047 rt .. r a_..... . - Courtenay R Dunn Esq.; Id ` No 206779 , Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 PHS # 233305 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff V. DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX; IN HER CAPACITY AS HEIR" OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAT PARR, IN HER CAPACITY AS HEIR OIL COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4063-CIVIL CUMBERLAND COUNTY THE ESTATE OF MARTHA J. BEERS DECEASED Defendant(s) um.M'aro..m:.:+,.,v.+we.+,..:?+W.Toe+n.:vwu_._....:........w»awA a..r...ms:ika.9.ruN+?-;,.. «.,a-....w +n.....rw...:«..w. .w...v.:.rv,ro.,.?;.:_:......?..s:'....Fr...+...iGUi..W+...?::..•v:,n.r,4....a..u?.Swu... ?'t+..?ah.w...s...uneinW - ?.... . TO: VIRGINIA COX, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA L BEERS, DECEASED 29 ADAMS STREET A/K/A 29 ADDAMS STREET DATE OF NOTICE: November 18, 2010 . ....'. , ., .. .. ...... ... .-.. .... -,,.a .«.._..._ ... .q.... 1- M wfuw. Y+rYiM!.udw? .'w-iri THIS FIRM IS A DEBT COLLECTOR :? .. e I ?R 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. PHS # 233305 IIVIPORTANT 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, T HIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY 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. Schmie1r :_. Esq.', Id. No. 62205 <.: ..._ - -. _ , . Michele 'M.'Bradford,=Esq., Id No: 69849 Judith T: Romano, Esq., Id. No. 58745. Sheetal R Shah=Jani, Esq., Id. No. 81760 Jenne ,;Esq., Id No.87077, 'Lauren R'Tabas"E .`Id.No.93337 ??? .... Vivek Srivastava, Esq., Id. No. 202331 ?:. _.. Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 '1wh1in+4bWaWe3rl. •; vw„ka.... . ., KAndrew L. Spivac Es Id.t _ _:.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 Hallinan & Schmie& LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 233305 s WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4063-CIVIL Plaintiff CUMBERLAND COUNTY V. DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY:AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED . - VIRGII,TIA COX,1N HER CAPACITY'A OF THE ESTATE OF MARTHA J.- BEERS, _ DECEASED VAL PARR, IN HER CAPACITY AS HEIR OF T._,.. THE ESTATE OF MARTHA J BEERS, w d DECEASED Defendant(s) r s.. .._:'MllMO^rrr.y 3.. k? r t ., rt' - TO: VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, _ DECEASED 29 ADAMS STREET A/K/A 29 ADDAMS STREET ENOLA, PA 17025-2829 w , ,.... , . .+k'wi41H1mt4ewa U3 "if ' _ iJi¢3c' :tfik+eil+-'tf.q>f+.`rf+r DATE OF NOTICE: November 18, 2010 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. PHS # 233305 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. 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, P.A. 17013 (717) 249-3166 By. Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallman, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. X6,62205 . Michele M. Bradford, Esq., Id. No. 69849 _ ._ .. _. ?. 4... Judith T. Romano, Esq., .-No.58745 _: p.. Sheetal R, Shah=Jani, Esq., Id. No: 81760 Jenine R Davey, Esq., Id. No. 87077 . , ..?., ?., _. ., ?«-- ..Lauren:P, Tabas,.Esq., Id..No._93337 .,. , , .n :::.. _.. Vivek Srivastav . , - a, Esq., Id. No. 202331 Jay W Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61,791 Andrew L..Spivack, Esq., Id. No. 84439 . ,cGuinn .?.,'.` tea.. acne Mess, Esq.; Id: No. 90134 -- _. Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua L Goldman Id. No. 205047 Courtenay R N Esq: Id.-No: 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 233305 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff V. DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR - OF THE ESTATE OF MARTHA J: BEERS, _ .., __... DECEASED - - VIRGINIA COX; INNER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR, IN HER CAPACITY AS HEIR OF COURT OF COMMON PLEAS CIVIL DIVISON NO. 104063-CIVIL CUMBERLAND COUNTY THE ESTATE OF MARTHA J BEERS, -DECEASED . ?.?....?M...... ..., . a Defendant(s) TO:- ?-MARY BEERS, IN,HER CAPACITY--AS HEIR OF TIE ESTATE OF MARTHAJ. BEERS; - T A T DECEASED 422 1 ST STREET FL 1 _ CARLISLE, PA 17013-1801 dY11rMF4?IR?++ . - _ ?.,ae.,;.rfu...a. •?.m-?- DATE OF NOTICE: No.vember 18, 2010 K g. THIS FIRM IS A DEBT rCOLLECTOR 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. PHS # 233305 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 HIIZING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY 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 r. n? ----- -- __ By. Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hailinan, 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 n 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,.M. 84439 Jaime McGuinness, Esq. Id. No: 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620. Joshua I. Goldman, Esq., Id. No. 205047 Courtena R. Dunn Id.:No `206779 y .; _ Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 233305 r WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 104063-CIVIL CUMBERLAND COUNTY DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF:THE ESTATE OF MARTHA J. BEERS; DECEASED VIRGINIA-COX;-IN HER CAPACITY AS-HEIR r._.-_-- OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTkiEOF MARTHA J. BEERS', :_.? - DECEASED ,,:. ..,:;...,? w_._ ,?...?;.?.:,??. ,...._.,.,w. ._., _,._..,?.,...,..?. TM...., ..._ ,_ Defendant(s) TO: VIRGINIA COX, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 101 BRENTON STREET INDIAHOMA, OK 73552-5017.6 . . ........... .,y _ _ DATE OF NOTICE: November 18,,-2010 THIS FIRM IS 'A DEBT O ECTOR ATTEMPTING TO COLLECT x. T., ...,. A DEBT. 'THIS NOTIC ICE " 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. PHS # 233305 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. 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 r _ By. )Lawrence T. Phelan, Esq., Id. No. 32227 Francis & Hallinan, Esq., Id. No. 62695 Daniel G "Schmieg, EsqId. No. 62205 ri Michele M: Bradford, Esq.; Id. No'. 69849 Judith '.:Roman, Esq.; Id. No.58745 zSheetal R. Shah-Jani, Esq., Id. No. 81760 -a -« Jennie R=Davey Esq. Id. No. 87077 --- --__ Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq.; Id.'N6.`202331 Jay B. Jones, Esq., Id. N6.86657 Peter J. Mulca_ hy, Esq., Id No,, 61791 p-vack, Esq., Id. No. 84439' Jaime McGuinness, Esq.; Id. No. 90134 Chrisovalan to P. Fliakos, Esq., Id. No. 94620 JoshuaI. Goldman,. Esq., Id.,No.205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmie& LLP 1617 JFK.Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 233305 j WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff V. COURT OF COMMON PLEAS CIVIL DIVISON NO. 104063-CIVIL CUMBERLAND COUNTY DEBRA BEERS, IN HER CAPACITY AS EXECUIRI)C AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED COX, IN HER CAPACITY AS HEIR __._.r::u OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR, IN HER CAPACITY AS HEIR OF. _ THE ESTATE OF MARTHA J. BEERS, DECEASED Defendant(s) TO: VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, w .; DECEASED 233A WEST MAIN STREET ",,.-,-,o..,,,m..4, .-,, ,: :: MECHANICSBURG, PA_17055-6226. DATE OF NOTICE: November 18,2010 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. PHS # 233305 IM?ORTANT 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. 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. N6.62695 _ . ,:. Daniel G. Schmieg, Esq., Id. No. 62205. Michele'M. Bradford,ESq Id 'N6 69849 Judith T.'Romano; Esq., Id. N6.58745' Sheetal R. Shah-Jani, Esq.; Id. No 81760 +u 'dm rm. .W.N k ?i w . _..... ... .e.apy.kxaiM,c + .., . _ ,.. .. >e.. _. n, .a .. . a .r :nlr. . . <._?. Jenine-R: Davey, Esq.'Id.No. 8,7077, , vwpgNMtCru.i'!nuNYa1..WM4.iA.i s ?. q ...... x . _ . _ _ Lauren R. Tabas Es ., Id. No.'93337 - Vivek Srivastava, Esq., Id. No `202331 - _ .:.. _ . A Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id No. 61791 ,,, _...: Andrew LAS ivac "?E Id. ' No 39 , .. P .?l•? Jaime McGuinness, Esq., Id.No.-90134 _.... Chrisovalante P. Fliakos, Esq., Id. No. 94620 „?.. Joshua 1`061 dman, Esq., I. N6.20504 7 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 233305 WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4063-CIVIL Plaintiff v. CUMBERLAND COUNTY DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS,. DECEASED MARY BEERS, IN HER CAPACITY AS HEIR OF THE. ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL. PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED Defendant(s) TO: DEBRA BEERS, IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF BEERS,"DECEASED; MARY BEERS; IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED, VIRGINIA COX, IN HER CAPACITY AS OF HEIR THE ESTATE OF MARTHA J. BEERS, DECEASED, VAL PARR, IN HER CAPACITY AS HEIR OF THE ESTATE OF MARTHA J. BEERS,: DECEASED » .. r.- .C/O EDWARD?P...SEEBER ESQUIRE,::,- 555 . r GETTYSBURG PIKE, SUITE C-400 MECHANICSBURG, PA 17055 DATE OF NOTICE: November 18, 2010 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. PHS # 233305 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. 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: 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 N6.5.8745 Sheetal R..Shah-Jani, Esq., Id. No. 81760 .w-w..„.Jenu iie R..Davey Esq., Id. No.,$7077. Lauren R. Tabas, Esq., Id. No. 93337 r Vivek Srivastava, Esq., Id. No.202331 Jay B. Jones, Esq., Id. No. 86657 i- • "ikceN•uG:'saekslDVh?e:+M•,1gs fs'itrYAhR+h,p271 SQL!-awk+.W__.:,a?ied:.a.?S+i..raq,y.aY,aS?w•.,aU .. ; Peter J. Mulcahy, Esq., Id. No. 61791 - . . Andrew L.`Spivack, Esq,"Id. No: 84439' Y u... _ _.._._ .. __ _ Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq, Id. No. 94620 . 7oshua I. Goldt a 'E Id No:0.2... ... ... y. ,. sq:, 5047 Courtenay R. Dunn, Esq., Id. No. 206179 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 233305 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A COURT OF COMMON PLEAS FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff CIVIL DIVISION NO.: 104063-CIVIL DEBRA BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 12/09/2010 to Date of Sale ($13.30 per diem) TOTAL *&4.0c) Pb ^try/ IS4.40 CBF yo?. 00 ?3. oo ga.00 " 10.00 " a. So N 384.40 -PA ATh/ Note: Please attach description of property. PHS # 233305 ta.00 Olw? 50 L.L r-* 104 M-58 p,f oti5a9lo/ CUMBERLAND COUNTY OF o ®ao - 0 -rt 80914.54 iv $2,327.50 J$3,242. 04 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 cis 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 I'. 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 Ow ¢w ¢w Qw z XU U XU ZU ww(A ?QH FAQ XQ ..7 4viQA ?r/iW ?vi Uv? ?v? Z UwUE Ww ww W ?W O wWAW WpgCA X? W? UGU .b 1.0 %n ?? A y N ? O U H? ,o Uw? °aw c vwW v, a¢,wOw.... e?G i? ""? E WO "oNO ?F• ? (??E-W v V??a Qc N p?+0 ccninWWd w Ow Wv? c?Wxa OUWxz0O ¢' xW? U FFQp pu]gF a'a WE Ana ¢Fz0E-r??naa z ?H?Ew" ? dpL?q1? C/) ?O?x a03 a w?pW,7 WH .d Cq?¢O L?"Np/ ?rjga]LriQ7a ?rrrp?'MU 3 Fx i4 Enw Q AzNw ?V QU i4 G r1 .LN a ?" w p O C wWw AxP?W A QQ?A k ? V?Ua U ? o w W W4 ON CA w o ',Do EA- tzt "?' M?O? p00 O0OMN 1?0O?zNN C? az ~?F.rUa U O Cz?zo?o a, C pb+ CAM p'z QVeF zzo z° d d o 0 ?zz "zz o zw ?,daM w abbb " -zzz - Z -d U pd W?"+Wb.,?-zONW.. F z Ua? O z x a 04 ,w d rFn L W w W v" th " C' O T7 N W W w w 1+ xU arG4 C CA apo W ?W W W "?W SS vi" q W C? as mo w" 3eo n ?~ g>ca pE O E? 04 a ae" ?aJq W s > w *a.5 a;b a? hi ?z W W W U-4 F- o a. ?t/?`n w'a;ACG 0 7 c t 0, evUu 0.4 wdp- OwO??g04Q °O No? a? U > ??????????????? Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff DEBRA BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 104063-CIVIL CUMBERLAND COUNTY MARTHA J. BEERS, DECEASED VIRGINIA COX IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF R MARTHA J. BEERS, DECEASED ?=+ VAL PARR IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED Defendant(s) M CERTIFICATION C : C -a The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned mattq,?Qth -? rt attie prix are not subject to the provisions of Act 91 because: .. r ? ( ) the mortgage is an FHA Mortgage ILI - w ( ) 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 relating to unsworn sto authorities. By: y Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Fr is S. Hallinan, Esq., Id. No. 62695 aniel G. Schmieg, Esq., Id. No. 62205 Ile ? 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 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARI, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE Plaintiff DEBRA BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 CUMBERLAND COUNTY PHS # 233305 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE, 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 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829. Name and address of Owner(s) or reputed Owner(s): Name DEBRA BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED Address (if address cannot be reasonably ascertained, please so indicate) 29 ADAMS STREET, AKA 29 ADDAMS STREET ENOLA, PA 17025-2829 M 4221ST STREET, FL 1 -<3> Z CARLISLE, PA 17013-1801 °. C: , p 1 101 BRENTON STREET 77 - i INDIAHOMA, OK 73552-5017 VAL PARR IN HER CAPACITY AS EXECUTRIX 233A WEST MAIN STREET AND HEIR OF THE ESTATE OF MARTHA J. MECHANICSBURG, PA 17055-6226 BEERS, DECEASED 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) 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 25 GATEWAY DRIVE, GATEWAY SQUARE/SUITE 107 CONSUMER DISCOUNT COMPANY MECHANICSBURG, PA 17055 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) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-4063-CIVIL 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: Nate Address (if address cannot be " reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA EDWARD P. SEEBER, ESQUIRE 29 ADAMS STREET AKA 29 ADDAMS STREET ENOLA, PA 17025-2829 13 North Hanover Street Carlisle, PA 17013 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 555 GETTYSBURG PIKE MECHANICSBURG, PA 17055 COMMONWEALTH OF PENNSYLVANIA BUREAU OF 6'H FLOOR, STRAWBERRY SQ. DEPT. 280601 INDIVIDUAL TAX INHERITANCE TAX DIVISION HARRISBURG, PA 17128 ATTN: JOHN MURPHY PO BOX 8486 DEPARTMENT OF PUBLIC WELFARE TPL WILLOW OAK BUILDING CASUALTY UNIT ESTATE RECOVERY PROGRAM HARRISBURG, PA 17105-15222 228 WALNUT STREET U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR HARRISBURG, PA 17108 THE MIDDLE DISTRICT OF PA FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my person owled 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 unswom falsifca i to orities. December 21, By: Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 cis 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 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. COURT OF COMMON PLEAS F/K/A FIRST UNION NATIONAL BANK OF DELAWARE CIVIL DIVISION Plaintiff NO.: 104063-CIVIL VS. _ DEBRA BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE CUMBERLAND CO T1 f y ESTATE OF MARTHA J. BEERS, DECEASED ? a) MARY BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE =M n rTi ?- OF MARTHA J. BEERS, DECEASED r-- VIRGINIA COX IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE :n t? p M C) ESTATE OF MARTHA J. BEERS, DECEASED < VAL PARR IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF > MARTHA J. BEERS DECEASED Defendant(s) N r"?r NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DEBRA BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 29 ADAMS STREET, AKA 29 ADDAMS STREET ENOLA, PA 17025-2829 MARY BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 422 1ST STREET, FL 1 CARLISLE, PA 17013-1801 VIRGINIA COX IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 101 BRENTON STREET INDIAHOMA, OK 73552-5017 VAL PARR IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED 233A WEST MAIN STREET MECHANICSBURG, PA 17055-6226 "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 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829 is scheduled to be sold at the Sheriff's Sale on 06/01/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $80,914.54 obtained by WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE (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: 215-563-70M 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. t 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 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land, situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the North side of Addams Street, said point being a distance of 175 feet in a Westerly direction from the Western line of a 15 foot alley; THENCE in a Northerly direction along the Westerly line of Lot # 154 on the hereinafter mentioned plan of lots, 150 feet to the Southerly line of Monroe Street; THENCE in a Westerly direction along the Southerly line of Monroe Street, 75 feet to the Easterly line of Lot # 158 on the hereinafter mentioned plan; THENCE in a Southerly line along the Easterly line of said lot # 158, 150 feet to a point on the Northerly line of Addams Street; THENCE in an Easterly direction along the Northern line of Addams Street, 75 feet to the place of BEGINNING. HAVING thereon erected a one story single frame dwelling known as No. 29 Addams Street, Enola. BEING Lots Nos. 155, 156 and 157 on the Plan of Lots laid out by Pyne and Addams, said Plan being recorded in the Office for the Recording of Deeds in and for Cumberland County in Plan Book No. 1 page 17. TITLE TO SAID PREMISES VESTED IN Carl K. Beers and Martha J. Beers, his wife, by Deed from Cumberland County National Bank and Trust Company, S/B/M to Peoples Bank of Enola, dated 07/18/1974, recorded 07/19/1974 in Book S-25, Page 37. PREMISES BEING: 29 ADAMS STREET, AKA 29 ADDAMS STREET, ENOLA, PA 17025-2829 PARCEL NO. 09-15-1291-291 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 104063-CIVIL WELLS FARGO BANK, N.A. SIBIM TO WACHOVIA BANK OF DELAWARE, N.A. FIK/A FIRST UNION NATIONAL BANK OF DELAWARE vs. DEBRA BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED MARY BEERS IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VIRGINIA COX IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED VAL PARR IN HER CAPACITY AS EXECUTRIX AND HEIR OF THE ESTATE OF MARTHA J. BEERS, DECEASED owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being (Municipality) 29 ADAMS STREET AKA 29 ADDAMS STREET ENOLA PA 17025-2829 Parcel No. 09-15-1291-291 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $80,914.54 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 Jr WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-4063 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., s/b/m to WACHOVIA BANK OF DELAWARE, N.A., f/k/a FIRST UNION NATIONAL BANK OF DELAWARE, Plaintiff (s) From DEBRA BEERS, in her capacity as Executrix and heir of the Estate of Martha J. Beers, Deceased MARY BEERS, in her capacity as Executrix and heir of the Estate of Martha J. Beers, deceased VIRGINIA COX, in her capacity as Executrix and heir of the Estate of Martha J. Beers, deceased VAL PARR, in her capacity as Executrix and heir of the Estate of Martha J. Beers, deceased (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 $80,914.54 L.L. $.50 Interest from 12/9/10 to Date of Sale ($13.30 per diem) -- $2,327.50 Atty's Comm % Due Prothy $2.00 Atty Paid $382.40 Other Costs Plaintiff Paid Date: 12/30/10 avid D. B ell, Prothonotary (set} By: Deputy FtEQU-FSTING PARTY: Name: DANIEL G. SCHMIEG, ESQUIRE 1 Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, N.A. SB/M WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNI?N NATIONAL BANK OF PHS # 233305 DELAWARE DEFENDANT SERVICE TEAM/ kxc DEBRA BEERS COURT NO.: 10-4063-CIVIL MARY BEERS '; VIRGINIA COX VAL PARR rn - m = SERVE MARY BEERS AT: TYPE OF ACTION M ; --c ? 4221ST STREET, FL 1 XX Notice of Sheriffs Sale 70 CARLISLE, PA 17013-1801 SALE DATE: 06/01/2011 y. SERVED =p C:) Served and made known to MARY B ERS , Defendant on the f SIAday of fMay*? , 20 at 3>= _ I)Lzw , o clock p. M., at 72 I Sf S71 T;L 1 l.(SLk , in the manner described below: - =r` Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's resi ence who refused to give name or relationship. Manager/Clerk of place of lodging n which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of sai Defendant's company. Other: Description: Age A?,?{ S Height t6 Weight 1 gd Race 1A) Sex F Other I, ??-c.-A 1? 4 f-L , a compe ent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the otice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indi ated above. Sworn to and subscribed KIMBERLY C t.'RTY before me this ( day N0 i`., 1 ; Il t i MY COIMISSf?, N f ?,z5:??RCH 7, 2013 ofWon STR11 ,rc .M ,AR NotarNOT S ED On th 20?, at o'clock _. M., Defendant NOT FOUND because: t EJ(Iist Moved Does Not Reside (Not Vacant) at Service Refused Other: Sworn to and subscribed before me this day of -T By: Notary: ATTORNEY FOR PLAINTIFF 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., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Welk, Es ., Id. No. 309519 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 30 PLAINTIFF WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE DEFENDANT DEBRA BEERS MARY BEERS VIRGINIA COX VAL PARR SERVE VAL PARR AT: 233A WEST MAIN STREET MECHANICSBURG, PA 17055-6226 PHS # 233305 SERVICE TEAM/ kxc COURT NO.: 10-4063-CIVIL TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 06/01/2011 G c; . Mao M zz = 01 Ulm ..-{ c) .. n = =o CC) rte Ty ? , SERVED Served and made known to VAL PA $R ,Defendant on the j day of FA AsQ $20 1 , at o'clock ?. M., at 33 W- iN 5 in the manner described below: Defendant personally served. M MW 1C--1 6 i/Q(Tf ') _ 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 'n which Defendant(s) reside(s). Agent or person in charge of Defen ant's office or usual place of business. an officer of sai Defendant's company. Other: Description: Age // Height Weight 3d Race V) Sex - Other _ I, ?d? !V(A t-?- , a compet nt adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the otice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indi ated above. Sworn to and subscriiped before me this _5 day of FM, 2011. Notary: On Wa-1 20 at ot E s t at Service Refused Other: Sworn to and subscribed before me this day of _. By: Notary: AFFIDAVIT OF SERVICE CUMBERLAND COUNTY KIPv bvRLY C'.'-R Y A?iI5_0t + L :XRCH 7, 2013 1v1 ECO NOTSERVED o'clock _. M., Defendant NOT FOUND because: Moved - Does Not Reside (Not Vacant) at 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-Jana, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 VNek 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. Fliekos, Esq., Id. No. 94620 Joshua 1. Goklmaq Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bromblett, Esq., Id. No. 208375 Allison F. Wells, EN Id. No. 309519 One Pam Center at uburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 o PLAINTIFF WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNIT NATIONAL BANK OF DELAWARE DEFENDANT DEBRA BEERS MARY BEERS VIRGINIA COX VAL PARR SERVE DEBRA BEERS AT: DAMS STREET PHS # 233305 SERVICE TEAM/ kxc COURT NO.: 10-4063-CIVIL TYPE OF ACTION 29 A XX Notice of Sheriffs Sale AKA 29 ADDAMS STREET SALE DATE: 06/01/2011 ENOLA, PA 17025-2829 i SERVED Served and made known to DEBRA EERS , Defendant on t?e Iltday of F, 20 H , at o'clock P.M., at SS Rol?a Ii QKSWA& , in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's resi ence who refused to give name or relationship. _ Manager/Clerk of place of lodging n which Defendant(s) reside(s). _ Agent or person in charge of Defe ant's office or usual place of business. an officer of sa' Defendant's company. r?.. t13 _rt ?t _ Other: Description: Age 465 Height 17 Weight '90 Race V) Sex _F Other 1, k$N,t_bid L-L, a comment adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the otice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. 7* 6A F-&NND V#C4*jT, I /j 1/ Tt6,tn /Ol o - 6X4, 1 k?<, 4 Notary: By: NOTSERVED a - 20, _ o'clock _. M., Defendant NOT FOUND because: On the at acant Does Not E 1st Moved Does Not Reside (Not Vacant) _ No Answer on at_ at Sworn to and subscribed A SQ-06-P T47 *WAvbr T PS-SIDS CFJ 4535 'RO" (261"-T before me this t day Mt.0N KSg?Q(? ?-? _?? 201! f Service Refused Other: Sworn to and subscribed before me this day of By: Notary: KIMBERLY CURT NOTARY RIBUC. ST.gl: F I?1r.W ;BRSE MY C0?vtMl S'. E "RF514A CH 7.20!3 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Fsq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq. Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Pew J. Mulcahy, Esq., Id. No. 61791 Andrew L Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Flinkos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 CourZy R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Welk, Esq., Id. No. 309519 One Penn Center at Suburban Station 1617.fohn F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 C3 C. 3` C-J ca AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE DEFENDANT DEBRA BEERS MARY BEERS VIRGINIA COX VAL PARR SERVE VIRGINIA COX AT: 101 BRENTON STREET INDIAHOMA, OK 73552-5017 PHS # 233305 rw SERVICE TEAM/kxc R 1W i(`: COURT NO.: 10-4063-CIVI L CD -4 cz? 7:;- TYPE OF ACTION p - XX Notice of Sheriffs Sale SALE DATE: 06/01/2011 t` SERVED Served and made known to VIRGINIA COX , Defendant on the 1 St day of January , 20 11 at 10 • (1(b'clock AM., at 101 Brenton InChahCrna in the manner described below: X Defendant personally served. OK 73552 - 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) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age 60 _ Height 56" Weight 140 Race W Sex F Other 1, Larry W. Maples, 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. n1 t d gpunr/ ```?IIg111 % Sworn to and subscribed ??0 07 ` a 1-1 before me this 4th day 1" 3 *lxrotesol3 of January , 20 1 ?,ocP. »rom2.= Q Notary By: P$5-09-2 9r!°uek!? ??o0 ED ??i??n ?OFmQ N ?P? On the day of 2 _, at _ o'clock _. M., Defendant NOT FOUND because: Vacant Does Not Exist Moved - Does Not Reside (Not Vacant) No Answer on at Service Refused Other: Sworn to and s sc ibed bef re me this day of ? / ? By. Notary: C1? ?0O 1 ua hSC - ?•••?o"rte`° #ppp7 } ?E?f'• 7Iro6506 ! ???ri OF OK1-P???? ???/I/1111111111111\ at CRV 1EY_F'OR PLAINTIFF Lawrestee T. Phelan, Esq., Id. No. 32227 Francis S. Hailinnn, Esq., Id. No. 62695 Danid G. Schmie8, Esq„ Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. $8745 Sheelnl R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., )d. No. 202331 Jay D. 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. Flinkos, Esq., Id. No. 94620 Joshua 1. Goldiu-, Esq., Id. No. 205047 Conrtcnay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblelt, Esq., 1d. No, 208375 Allison F. Wells, Esq., 1d. No. 309519 One Penn Center at Suburban Statiall 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563.7000 .' J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. SB/M TO CUMBERLAND COUNTY':-1 r-?' WACHOVIA BANK OF DELAWARE, N.A. F/K/A FIRST UNION NATIONAL BANK OF DELAWARE COURT OF COMMON P S ; Plaintiff, z 1n va CIVIL DIVISION V. DEBRA BEERS MARY BEERS VIRGINIA COX VAL PARR Defendant(s) No.:10-4063-CIVILr? AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: -n ?rn r p-r7 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 3817) and/or Cfied-hfa*l Return Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". L_j Lawrence T. P , Esq., Id. No. 32227 E1 Francis SFBradford, n, Esq., Id. No. 62695 ? Daniel G g, Esq., Id. No. 62205 ? Michel 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 ?_ ESjef3 --Mulcahy, Esq., Id. No. 61791 er] 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 Date: Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the 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 # 233305 w £ 0 l6 L 3000 dEZ now 03iivw ar -s ? O??0Z OZ 030 99ZLLZb000 oVZ?t?O $ WL ZO : e "?8 S31UO6 A3NLd ?? C rCe O V! x N ? U b ? s H ? w W r?7 ? N "' w A '? S ????? 7t: ? • w a a ? ? ? ? ? 0y , ? ? r LAG W a w A M N W• I i w ? \ N h ?? O V ^? C7 ?y Wv? FV ' M 1 j ° a U ? S ?, .. w N• w A a a O a- C ?G ? O A ? ? ? ? z ? ? oo "i W . . ? ? zF H C ° > o L? y ° QO w 0" U N ^i j G`? Frr , . . p 3 " a FU, ' ? ? W?? °?'v? o a a`?? a+w o °' .?, N dve?i ?jp o ? Lp".. p? z C?7pg c rs, G7 . x Er'?a a ? ?x? Op v? W ? ? ? `-+ ?a ?a ? ?' .° LA O P" A ?? o o O T N e N 7 aa p aQ 00 ° ? ? ? ? ?.f /1 p 3 C? ? a v e WA CQQ zd o w? 0.°.5 e ez ; eras ? a a a .aa $ ? ; ? ?3 ? D ? C ? ? ab ?S a? A W A as ZI aa z Wp, z E?N w , o oM as AU +U s o 0? UAa c1S? ? t/?v? ?N? ` ?? Oo 3 o? ?C a,c?d v? ? ? ?- ? .- .., .r i r 1. (=iN m.. A wo3 ? H U e 4 O N . .1 . H v ii ti rl . r E° 't? I i E M