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HomeMy WebLinkAbout10-6330SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?Q?ntr of ?untbrr/,??d C. OFf CE OF .KE : ZRirF I r 9F C If1P Wells Fargo Bank, NA vs Case Number . Donald L. Martin, Jr. 2010-6330 SHERIFF'S RETURN OF SERVICE 10/07/2010 03:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 7 2010 at 1525 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donald L. Martin Jr., by making known unto Julie Schlotterbeck, adult in charge at 112 E. Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 October 08, 2010 ROB ?BITNIER, DEPUTY SO ANSWERS, RONNVY- R ANDERSON, SHERIFF (ci Goun?,Suite Sheriff. Teleosoft. Inc. 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. VS. DONALD L. MARTIN, JR Attorney for Plaintiff Cl) C 6119, G `n .0:Z Co Zfn =?v r +c Min =oo c D n ?' p.? XC) = n Zn y-C © °rn CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 10-6330 CIVIL TERM 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 DONALD L. MARTIN, JR, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 09/12/2010 to 11/22/2010 $103,178.97 $1,058.40 TOTAL $104,237.37 'ORP ot, ?D al?j Vk 46 Oe;to3 251162 *(L I hereby certify that (1) the Defendant's last known address is 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926, and (2) that notice has been given in accordance with Rule 237.1, copy attached. 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 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PHS # 251162 PROTHONOTAR 251162 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 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. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 VS. DONALD L. MARTIN, JR Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-6330 CIVIL TERM 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 DONALD L. MARTIN, JR is over 18 years of age and resides at 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926. 251162 This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. November 22, 2010 L'ILawrence 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 ourtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 Attorney for Plaintiff 251162 WELLS FARGO BANK, N.A. V Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-6330 CIVIL TERM DONALD L. MARTIN, JR Defendant(s) TO: DONALD L. MARTIN, JR 112 EAST ORANGE STREET SHEPPENSBURG, PA 17257-1926 DATE OF NOTICE:. November 1, 2010 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. Il1IPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN ' WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PHS # 251162 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 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 Shee 1 R. Shah-Jam, Esq., Id. No, 81760 Je a R. Davey, Esq., Id. No. 87077 auren R. Tabas, Esq., Id. No. 93337, Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos; Esq.; Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq'., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 251162 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO BANK, N.A. Plaintiff COURT OF COMMON PLEAS V DONALD L. MARTIN, JR Defendant(s) CIVIL DIVISION NO.: 10-6330 CIVIL TERM CUMBERLAND COUNTY To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 11/23/2010 to Date of Sale ($17.13 per diem) TOTAL Note: Please attach description of property. PHS # 251162 $104,237.37 C c $ 3,271.83 -o3 ao ° r ri c-a cry -<A ? rn x.107,509.20 D ° C') -a G D CC _7Z :- '- -? J1 Attorney for Plaintiff c 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 ? ourtenay R. Dunn, Esq., Id. No. 206779 (ndrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 * Oyu. oo l3rCcm vleH U. 00 d .50 C) n -orn ;:0? 2- O o-n X- Q 118.50 -PA A77Y 0,2•00 ove co so LL etlf Id3??7s l7 I iJ- 1,rl t-?S b a? ?o N N ? a? W [? ? aoao H z N ? o O ,? x a 0 O C1r w F ?r d z a, O A O w U w N O ? Oen 14T ON ? V1 O Ord 0M h 0 Rdsmg E. . C4 G Oz z000\ C4 t- Z O pr.i Oz.M ? z °z ;2;2, zZZ Z?;dW -d rx c3 vt-4 drn 3 ? ?'3w ti :???????????????? ? Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff V. DONALD L. MARTIN, JR Defendant(s) FILED-OFFICE OF TH ,DID DEC, 16 PM 1.35 CUMBE Y?VAN COUNTY PEN CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION NO.: 10-6330 CIVIL TERM : CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) 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 falsification to authorities. Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? enay 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. COURT OF COMMON PLEAS 41 Plaintiff FILED-OFFtC0 CIVIL DIVISION V. OF THE PROTHONOTARY NO.: 10-6330 CIVIL TERM DONALD L. MARTIN, JR 2010 DEC 16 PH 1: 35 : Defendant(s) CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY PHS # 251162 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DONALD L. MARTIN, JR 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 112 EAST ORANGE STREET SHIPPENSBURG, PA 17257-1926 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every m Name UNITED STATES OF AMERICA, ACTING THROUGH THE RURAL HOUSING SERVICE OR SUCCESSOR AGENCY, UNITED STATES DEPARTMENT OF AGRICULTURE ortgage of record: Address (if address cannot be reasonably ascertained, please indicate) P.O. BOX 66889 SAINT LOUIS, MO 63166 THE SHIPPENSBURG NON-PROFIT P.O. BOX 432 HOUSING CORPORATION SHIPPENSBURG, PA 1.7257 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. • 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANVOCCUPANT Domestic Relations of Cumberland County 112 EAST ORANGE STREET SHIPPENSBURG, PA 17257-1926 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA 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 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. Decembe .2010 By. _ -- . )7 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id.. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? ourtenay R. Dunn, Esq., Id. No. 206779 LI Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 , WELLS FARGO BANK, N.A. DONALD L. MARTIN, JR : COURT OF COMMON PLEAS is ILEp=Of RCE- Off' THE PROTHONOTIntiff CIVIL DIVISION VS. 2010 DEC 16 PH 1: 35 CUMBERLAND COUNTY PENNSYLVANIA Defendant(s) NO.: 10-6330 CIVIL TERM : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DONALD L. MARTIN, JR 112 EAST ORANGE STREET SHIPPENSBURG, PA 17257-1926 "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 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926 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 $104,237.37 obtained by WELLS FARGO BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain lot of land, together with improvements thereon lying and being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a drill hole at the edge of a concrete sidewalk abutting a Street known as East Orange Street at the line of Lot No. 2 on the hereinafter said draft of survey; thence along Lot No. 2, South 25 degrees 33 minutes 20 seconds East 220.86 feet to an iron pin at the line of any alley known as Lutz Avenue; thence along the alley known as Lutz Avenue, South 63 degrees 39 minutes 38 seconds West 14.76 feet to an iron pin at line of land now or formerly of Frank G. Walters; thence along land now or formerly of Frank G. Walters, North 26 degrees 20 minutes 22 seconds West 102.00 feet to an iron pin; thence along land of the same, South 63 degrees 39 minutes 38 seconds West 1.00 foot to an iron pin; thence along land of the same, North 26 degrees 20 minutes 22 seconds West 118.93 feet to a drill hole in a concrete sidewalk abutting a street known as East Orange Street; thence along the sidewalk that abuts the street known as East Orange Street, North 63 degrees 55 minutes 28 seconds East 18.78 feet to the place of BEGINNING. CONTAINING 3,713 square feet, more or less, according to the draft of survey of Carl D. Bert & Associates, professional surveyors and engineers dated April 14, 2002 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 89 at page 67. Being Lot No. 1 thereon and having the address of 112 East Orange Street, Shippensburg, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Donald L. Martin, .Jr., single, by Deed from Timothy J. Murphy and Sarah A. Murphy, h/w, dated 08/27/2009, recorded 09/04/2009 in Instrument Number 200931195. PREMISES BEING: 112 EAST ORANGE STREET, SE IPPENSBURG, PA 17257-1926 PARCEL NO. 33-34-2415-122. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6330 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From DONALD L. MARTIN, JR. (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 $104,237.37 L.L. $.50 Interest from 11/23/10 to Date of Sale ($17.13 per diem) -- $3,271.83 Atty's Comm % Due Prothy $2.00 Atty Paid $178.50 Other Costs Plaintiff Paid Date: 12/16/10 avid D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: ANDREW C. BRAMBLETT, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 208375 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY - WELLS FARGO BANK, N.A. .-) PHS # 251162 -? DEFENDANT SERVICE TEAM/ lixc fi ? f r; DONALD L. MARTIN, JR COURT NO.: 10-6330 CIVIL Tl? N ::Q SERVE DONALD L. MARTIN, JR AT: TYPE OF ACTION ' -<D C? N s Sale 112 EAST ORANGE STREET XX Notice of Sheriff .C 3::p CD -T1 - SHIPPENSBURG, PA 17257-1926 SALE DATE: 06/01/2011 =n - SERVED " Served and made known to DONALD L. MARTIN, JR , Defendant on the "day of , 20 , at o'clock ?. M., at I m E IFST OA"" STREET in the manner described below: Defendant personally served. SO-1 ppNS 16V& k PA- 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 II.,,O 5 Height , Weight 1 Race W Sex * Other I, /1?to t-(- , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed KIMBERLY CURTY before me this ;-;N0 day NOTARY PUBLIC lt,6 t of 2 R 4Ctt"O, / STATE OF NEW JERSEY Nota woAnsweron MY COMMISSION EXPIRES MARCH 7, 2013 NOT SERVED t20_, at o'clock _. M., Defenda nt NOT FOUND because: ot Exist Moved - Does Not Reside (Not Vacant) t , at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: 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. Taints, Esq., Id. No. 93337 Vivek Srivastava, Esq.. Id. No. 202331 Jay B. Jones, Esq, Id. No. 86657 Peter J. Muleahy, Esq., Id. No. 61791 Andrew I.. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Rakes, 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 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA rti WELLS FARGO BANK, N.A. CUMBERLAND COUNTY.-, y Plaintiff, G COURT OF COMMON PS?v V. ON S 1 70C) CIVIL DIVI I 0 DONALD L. MARTIN, JR M r?- Defendant(s) No.: 10-6330 CIVIL TER p c7 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified MReturn Receipt stamped by the U.S. Postal Service is attached hereto Exh": Date: 22 ? Lawrence T. Phe sq., Id. No. 32227 ? Francis S. in , Esq., Id. No. 62695 ? Daniel c eg, Esq., Id. No. 62205 ? Mic e M radford, Esq., Id. No. 69849 ? Judi omano, 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 ? Pe ulcahy, Esq., Id. No. 61791 ndrew 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 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 # 251162 E o s 300 cPz WOW a3-Iirrw l n OWZ 9?330 ssZLCZtiooo oIFs Za VG z o I . J-1 I ?, ' T R N =WA NSOd i . O4 . ? 8 it O o a•C M b w w dA O? U 'W oG:. w C ? O •o o 1 w ~ q " PO C .-. F 2 04 ?^' C°n q L.Mw.Ci ??.qN o.+Orwl?f/?W Oi..7 .f?+ a. r U .. er .•r .O ..y y d h ° ?bv?? ?b rq.•r ? ova ;tea 14-1 -•.c w??° c8.wo a ?ppgoo ° Q yC 4 z Z.. al E 9.Z.C S. a??'a.F °r? ae o Ed :av?vi.'$°x$ OC..O. $ Chu.,.G?U4at?..?.,wp?wN?v?a:v?Fav, $ Z *. # kk V -cp b v?. a? cy d ?n SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Fff.-E3: ? 9 ID U T I `F i + t 20 ttl 13 AM 10: `' Richard W Stewart Solicitor OFF e -r- ; cHFF PE11HSYL'//, "IitA Wells Fargo Bank, NA vs. Donald L. Martin, Jr. Case Number 2010-6330 SHERIFF'S RETURN OF SERVICE 03/18/2011 01:28 PM - Deputy Dennis Fry, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 112 East Orange Street, Shippensburg, PA 17257, Cumberland County. 03/18/2011 01:28 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Travis Martin Brother, who accepted as "Adult Person in Charge" for Donald L. Martin, Jr. at 112 E. Orange Street, Shippensburg Borough, Shippensburg, PA 17257, Cumberland County. 06/01/2011 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/3/2011 06/10/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $897.21 SO ANSWERS, M June 10, 2011 RON R ANDERSON, SHERIFF Q -e0 fd , eeq, .Slo L-tlllad- !c; GountySulte She iff ieieosoft Ine WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 10-6330 CIVIL TERM DONALD L. MARTIN, JR Defendant(s) CUMBERLAND COUNTY PHS # 251162 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926. Name and address of Owner(s) or reputed Owner(s): Name DONALD L. MARTIN, JR 2. 4. 5. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 112 EAST ORANGE STREET SHIPPENSBURG, PA 17257-1926 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) UNITED STATES OF AMERICA, ACTING P.O. BOX 66889 THROUGH THE RURAL HOUSING SERVICE SAINT LOUIS, MO 63166 OR SUCCESSOR AGENCY, UNITED STATES DEPARTMENT OF AGRICULTURE THE SHH'PENSBURG NON-PROFIT P.O. BOX 432 HOUSING CORPORATION SHIPPENSBURG, PA 17257 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 112 EAST ORANGE STREET SHIPPENSBURG, PA 17257-1926 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 U.S. Department of Justice Federal Building, P.O. Box 11754 U.S. Attorney for the Middle District of PA 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. DecembeA 2010 By: Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? 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 ? ourtenay R. Dunn, Esq., Id. No. 206779 A Qv ndrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 WELLS FARGO BANK, N.A. : COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION VS. NO.: 10-6330 CIVIL TERM DONALD L. MARTIN, JR Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DONALD L. MARTIN, JR 112 EAST ORANGE STREET SHIPPENSBURG, PA 17257-1926 * *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 112 EAST ORANGE STREET,'SHIPPENSBURG, PA 17257-1926 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 courtjudgment of $104,237.37 obtained by WELLS FARGO BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL that certain lot of land, together with improvements thereon lying and being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a drill hole at the edge of a concrete sidewalk abutting a Street known as East Orange Street at the line of Lot No. 2 on the hereinafter said draft of survey; thence along Lot No. 2, South 25 degrees 33 minutes 20 seconds East 220.86 feet to an iron pin at the line of any alley known as Lutz Avenue; thence along the alley known as Lutz Avenue, South 63 degrees 39 minutes 38 seconds West 14.76 feet to an iron pin at line of land now or formerly of Frank G. Walters; thence along land now or formerly of Frank G. Walters, North 26 degrees 20 minutes 22 seconds West 102.00 feet to an iron pin; thence along land of the same, South 63 degrees 39 minutes 38 seconds West 1.00 foot to an iron pin; thence along land of the same, North 26 degrees 20 minutes 22 seconds West 118.93 feet to a drill hole in a concrete sidewalk abutting a street known as East Orange Street; thence along the sidewalk that abuts the street known as East Orange Street, North 63 degrees 55 minutes 28 seconds East 18.78 feet to the place of BEGINNING. CONTAINING 3,713 square feet, more or less, according to the draft of survey of Carl D. Bert & Associates, professional surveyors and engineers dated April 14, 2002 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 89 at page 67. Being Lot No. 1 thereon and having the address of 112 East Orange Street, Shippensburg, Pennsylvania. TITLE TO SAID PREMISES IS VESTED IN Donald L. Martin, Jr., single, by. Deed from Timothy J. Murphy and Sarah A. Murphy, h/w, dated 08/27/2009, recorded 09/04/2009 in Instrument Number 200931195. PREMISES BEING: 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926 PARCEL NO. 33-34-2415-122. SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-6330 CIVIL TERM WELLS FARGO BANK, N.A. VS. DONALD L. MARTIN, JR owner(s) of property situate in the BOROUGH OF SHIPPENSBURG, Cumberland County, Pennsylvania, being (Municipality) 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926 Parcel No. 33-34-2415-122. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $104,237.37 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6330 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From DONALD L. MARTIN, JR. (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 $104,237.37 L.L. $.50 Interest from 11/23/10 to Date of Sale ($17.13 per diem) -- $3,271.83 Atty's Comm % Atty Paid $178.50 Plaintiff Paid Date: 12/16/10 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs ---r-v Name: ANDREW C. BRAMBLETT, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 TRUE COPY FROM RECORD In Testimony whereof. l hero unto set my hand and the seal of said at Cadisle, Pa. T?ft _L day of C ....• 20/0 `Qp prothonotary Supreme Court ID No. 208375 On March 3, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Borough, Cumberland County, PA, Known and numbered as, 112 East Orange Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: - I'D k-,-I'D eal Estate Coordinator s ii :Z ci Z Z 330 610Z CUMBERLAND LAW JOURNAL Writ No. 2010-6330 Civil Wells Fargo Bank, NA VS. Donald L. Martin, Jr. Atty.: Daniel J. Schmieg By virtue of a Writ of Execution NO. 10-6330 CIVIL TERM, WELLS FARGO BANK, N.A. vs. DONALD L. MARTIN, JR., owner(s) of property situate in the BOROUGH OF SHIP- PENSBURG, Cumberland County, Pennsylvania, being 112 EAST OR- ANGE STREET, SHIPPENSBURG, PA 17257-1926. Parcel No. 33-34-2415-122.. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $104,237- .37. 51 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 22, April 29, and May 6, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this =do 2011 ary F ARIL SEAL RAH A COLLINS tary Public GH, CUMBERLAND COUNTY on Expires Apr 28, 2014 The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Z4e Patti* ot New Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid-, that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since- That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement aE to the time, place and character of publication are true-, and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement or behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 04/29/11 20104= Chill Term 05/06/11 wells Fargo Bank, NA Vs t Donald L. Marlin, Jr. 1 ?,? ? Any: Daniel J.8chm1e9 .... .. .: :.... . : G• By virtue of a Writ of Execution 10- VII TERM 6330 N A 2011 A Sworn to and s?bscribed before me this h 08Y of May D WELLS . . BANI{ F GO , WELL , . . VS. DONALD . MARTIN, JR .. _: _ owner(s) property situate in the ,.. BORG HOFSHIPPENSBURG, Cumberland county, Pennsylvania, being Notary Public (Municipality) 112 EAST ORANGE STREET, SHIPPENSBURG, PA 17257-1926 Parcel No. 33-34-2415-122. COMMONWEALTI.1 OF PENNSYLVANIA (Acreage or street address) Improvements thereon: RESIDENTIAL Sh m DWELLING JUDGMENT AMOUNT. $104,237.37 = e e Klsner, Y Pubik T1vp,; Uauphln County n i*eS Nov. 26, 2011 Member, Pennsylvania Association of Notaries Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff WELLS FARGO BANK, N.A. Plaintiff vs DONALD L. MARTIN, JR Defendant Court of Common Pleas : I Civil Division CUMBERLAND County M MM No. 10-6330 CIVIL TERM ..o r' c.? r7i PRAECIPE' TO THE PROTHONOTARY: Please vacate the judgment(s) entered and mark the action discontinued and ended PHE N ALLINAN & SCHMIEG, LLP By: Lawrence T. Phe an, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. ,Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 PHS# 251 162 A,ttorneys for Plaintiff ?- r without pr jud'ce Date: S Ir ad f.4 ,it ('ed10919"3j