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HomeMy WebLinkAbout10-6618SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOiICItOr ~~~~titt, Jf v`rrrtit>~~~~~~ 4~~ -~ - Wells Fargo Bank, N.A., vs. Craig Danner Case Number 2010-6618 SHERIFF'S RETURN OF SERVICE 10/28/2010 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: Craig Danner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Craig Danner. Request for service at 745 Erford Road, Camp Hill, PA 17011 the defendant was not found. The Camp Hill Postmaster has confirmed, Craig Danner is not known at 745 Erford Road, Camp Hill, PA 17011. 10/29/2010 09:00 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 29, 2010 at 2100 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Holly Danner, by making known unto herself personally, current occupant of 118 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. l RO ERT THE ,D PU 11/01/2010 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: Craig Danner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Craig Danner. Deputies were advised, Craig Danner is thought to be residing in State College, Pennsylvania. SHERIFF COST: $100.00 November 01, 2010 SO ANSWERS, RON R ANDERSON, Skf R .,.~ -y ..w. ..._ ~ .: _.. r __ ~,~ , ~ . ,.. a_, .... _.. , __ ~.a (Gi Coii:i`yS~aile Sh2r:ff. Tr.!^,^s'o`t. In;;. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-6618 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NA Plaintiff (s) From CRAIG DANNER (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 $149,167.47 L.L.$.50 Interest from 2/6/2011 to date of sale $6,310.40 Atty's Comm % Due Prothy $2.00 Atty Paid $232.50 Other Costs Plaintiff Paid Date: 2/16/11 D. Buell, (Seal) By: REQUESTING PARTY: Name: ASHLEIGH L. LEVY, ESQUIRE Address: ZUCKER, GOLBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 306799 Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Wells Fargo Bank, N.A., File No. 10-6618 Amount Due $149,167.47 VS. Craig Danner Costs Defendant. C-) o C3 nCo -n - z? ? ca -C? > TO THE PROTHONOTARY OF THE SAID COURT: rr-? Cr" 4 ?c )>- ? 3a* C3 -n The undersigned hereby certifies that the below does not arise out of a retail installment safE n ? tr"t oJEF3 account based on a confession of judgment, but if it does, it is based on the appropriate original prce ing-file d- m pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. c? : a PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: Februa , 2011 Signature: © Print Name 9H. 00 b okkk? q a . oo `'/-' ?9. po // a? 1? CYZ a Plaintiff, Interest from 02/06/2011 to date of sale $6,310.40 s a.0o Da Co.. 4 5o LL C,? J`7o? 8 ?Z-? ssag?> Address: Attorney for: Telephone: Supreme Court ID No.: Scott A. Dietterick, Es ire Kimberly A. Bonner, squire Joel Ackerman, Esquire Ashleigh L. Levy, Esquire Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Plaintiff 908-233-8500 55650 89705 202567 306799 7ucki•r. 6oltbem & Ackerman. H ( X1'1'-1. 3718 Exhibit "A" LEGAL DESCRIPTION ALL THOSE TWO CERTAIN CONTIGUOUS LOTS OF GROUND SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO.1 BEGINNING AT A POINT 100.00 FEET, MEASURED IN A WESTERLY DIRECTION FROM THE SOUTHWEST CORNER OF FIRST STREET (FORMERLY BUCHER STREET), AND HERMAN AVENUE; THENCE EXTENDING ALONG THE SOUTHERN LINE OF HERMAN AVENUE IN A WESTERLY DIRECTION, 33 FEET 3 INCHES TO A POINT ON THE LINE OF LANDS FORMERLY OF GRACE B. NEWCOMER, NOW OR FORMERLY OF CALVIN R. STONER; THENCE ALONG THE LINE OF SAID LAND NOW OR FORMERLY OF CALVIN R. STONER IN A SOUTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT ON THE NORTHERN LINE OF PLUM ALLEY; THENCE ALONG SAID NORTHERN LINE OF PLUM ALLEY, AND LANDS NOW OR FORMERLY OF THE SOUTHERN PENNSYLVANIA RAILROAD COMPANY IN AN EASTERLY DIRECTION, 31 FEET 3 INCHES, MORE OR LESS, TO A POINT ON THE LINE OF LANDS FORMERLY OF GEORGE LEACH; THENCE ALONG THE LINE OF SAID LAST MENTIONED LANDS, AND AT RIGHT ANGLES TO THE SOUTHERN LINE OF HERMAN AVENUE IN A NORTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT IN THE SOUTHERN LINE OF HERMAN AVENUE, AFORESAID, AT THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY STONE AND FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 118 HERMAN AVENUE (FORMERLY 116 HERMAN AVENUE), LEMOYNE. PENNSYLVANIA HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 118 HERMAN AVENUE, LEMOYNE, PA, 17043. BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 25, 2009 AND RECORDED JANUARY 12, 2010 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT #201001032, PAGE, GRANTED AND CONVEYED UNTO CRAIG DANNER, AN ADULT INDIVIDUAL. TAX MAP NO.: 12-21-0265-4'23. Tucker. (. oldherg & 1ckcrman, L.L(: XFII-14371 R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., vs. Craig Danner CIVIL DIVISION- LAW a n rn Plaintiff, NO.: 10-6618 r n re's- - -? m r -- i ? ??' a', to Ca-n -L -._ Defendant. p o PRAECIPE FOR DEFAULT JUDGMENT TO:PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant(s), Craig Danner, in the amount of $149„167.47 which is itemized as follows for failure to file an Answer: Principal $137,681.29 Interest through. 02/5/11 $6,310.40 Attorneys' Fees $1,250.00 Title Search & Costs $2,500.00 Late Charges $ 365.67 Escrow $ 456.65 Pro Rata MIP / PMI $ 123.96 Other $ 479.50 TOTAL $149,167.47 plus interest on the principal sum ($137,681.29) from February 6, 2011, at the rate of $631.04 per month, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale! of the mortgaged premises. ZUCKER, GOLDB G & ACKERMAN, LLC lq BY: Dated: February W, 2011 Scott A. etterick, Esquire; A I.D. #55650 Kimberly A. Bonner, Esqu' e PA I.D. #89705 Joel A. Ackerman, Esq . e; A I.D. #202729 Ashleigh L. Levy, Es ire; A LD. #306799 Attorneys for Plaintif XFP-143718/pn 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com } 14.oo Td (J ? C?,# 17D77 e? assa?9' I Zucker, Goldberg & Ackerman, LLC XFP-143 718 AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, Kimberly A. Bonner, Esquire, Joel A. Ackerman, Esquire, Ashleigh L. Levy, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his/her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. ZUCKER, GPLDIPRG & ACKERMAN, LLC By: Scott . i erick, Esqui , PA I.D. #55650 Kimberly A. Bonner, q ire; PA I.D. #89705 Joel A. Ackerman, squ' e; PA I.D. #202729 Ashleigh L. Levy, re; PA I.D. #306799 Atty File No.: XFP-143718 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX Sworn to and subscribed before me s ! S day of February, 20 H Not ublic My Commission Expires: EB A RD J_r,SGI?I?CHtiU Commission # 2383 9 Notary Publ.fc, State of.New Jersey My Commission Expires N?arch 09. 2014 Zucker, Goldberg & Ackerman, LLC XFP-143718 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 10-6618 VS. : Craig Danner Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Craig Danner 118 Herman Avenue Lemoyne, PA 17043 ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on . IQ, poll ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $149,167.47 plus interest on the principal sum ($137,681.29) from February 6, 2011, at the rate of $631.04 per month, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, Goldberg & Ackerman, LLC XFP-143718 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor x OFFICE OF THE St#ERIFF Wells Fargo Bank, N.A., vs. Craig Danner Case Number 2010-6618 SHERIFF'S RETURN OF SERVICE 1028/2010 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: Craig Danner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Craig Danner. Request for service at 745 Erford Road, Camp Hill, PA 17011 the defendant was not found. The Camp Hill Postmaster has confirmed, Craig Danner is not known at 745 Erford Road, Camp Hill, PA 17011. 10292010 09:00 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 29, 2010 at 2100 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Holly Danner, by making known unto herself personally, current occupant of 118 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. RO ERT N , D PRonny 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: Craig Danner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Craig Danner. Deputies were advised, Craig Danner is thought to be residing in State College, Pennsylvania. SHERIFF COST: $100.00 November 01, 2010 SO ANSWERS, RON R ANDERSON, S` RI - . ' t 4 -t 77 R] (C) CotultySuile Shenff. TeieosMl. Inr, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. VS. Craig Danner TO: Craig Danner 118 Herman Avenue Lemoyne, PA 17043 DATE OF NOTICE: 2/1/2011 CIVIL DIVISION NO.: 10-6618 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) 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 notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. VS. Craig Danner TO: Plaintiff, Defendant. Craig Danner 118 Herman Avenue Lemoyne, PA 17043 CIVIL DIVISION NO.: 10-6618 FECHA DEL AVISO:2/1/2011 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IN`N1DIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAIO INDICADA PARA QUE LE 1NFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. r4MCET0DEEFJ.1Ll &1ANVVM SEITS1ICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 ZUCRER, GOIDBERG & ACIKEEUVL4N BY # A. Moo do Scott A Dietterick, Esquire Attomeys for Plairkff PAID. # 55650 200 Sheffiel d Street, Suite 301 P. 0- Box 1024 Mbumainside; M 07092-0024 (717) 533-3560 FIRST C3ASS U .S. MAU, PCEMAGE. PREPAID 143718 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs Craig Danner Defendant. CIVIL DIVISION NO.: 10-6618 -;c* { TYPE OF PLEADING S rn Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT ZWCSERV -R E C) OF DEFENDANT/OWNER AND -c . c.? ca OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh L. Levy, Esquire- PA I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckerp,oldbere.com File No.: XFP- 143718/dsc Zucker, Goldberg & Ackerman, LLC XFP-143718 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., : CIVIL DIVISION Plaintiff, . NO.: 10-6618 VS. Craig Danner Defendant. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Craig Danner, an adult individual, is the record owner of the real property. 2. On or about March 18, 2011, Craig Danner, an adult individual was served with Plaintiff's Notice of Sheriff's Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at the address of the mortgaged premises, being 118 Herman Avenue, Lemoyne PA 17043. A true and correct copy of said Notice and Proof of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about April 7, 2011, Plaintiff's counsel served all other parties in interest with Plaintiff's Notice of Sheriff's Sale according to Plaintiff's Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, LLC XFP-143718 Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Interest were served with Plaintiff's Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Dated: May 5, 2011 DAN LESINGER S o to and subscribed before me hi S day of May, 2011 Notary f lic MY COMMISSION EXPIRES: Paralegal/Legal Assistant EDVYARO J. SCHWAHL II Commission # 2383239 Notary Public, State of New Jersey My Commission Expires Morch 09, 2014 Zucker, Goldberg & Ackerman, LLC XFP-143718 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs. Craig Danner Defendant. CIVIL DIVISION : NO.: 10-6618 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Craig Danner 118 Herman Avenue Lemoyne, PA 17043 AND 745 Erford Road Camp Hill, PA 17011-1126 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 06/01/2011 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 118 Herman Avenue, Lemoyne, PA, 17043 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 10-6618 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Craig Danner Zucker, Goldberg & Ackerman, LLC XFP-143718 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you, You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker, Goldberg & Ackerman, LLC XFP-143718 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. i Dated: February,, 2011 ZUCKER GOLDBERG & ACKERMAN, LLC BY: .. Scott A. Di tterick, Esquire;, P I.D. #55650 Kimberly A. Bonner, Esqui A.I.D. #89705 Joel A. Ackerman, Esquire; V_X 1. D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-143718 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldbcrg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XFP-143718 EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-143718 r. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., VS. Plaintiff, CIVIL DIVISION NO.: 10-6618 Craig Danner Defendant. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P 3129(b) TO: CUMBERLAND COUNTY TAX CLAIM BUREAU UNKNOWN SPOUSE Cumberland County Courthouse 118 Herman Avenue One Courthouse Square Lemoyne, PA 17043 Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 UNKNOWN TENANT OR TENANTS 118 Herman Avenue Lemoyne, PA 17043 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in: the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 On 06/01/2011 at 10:00am, the following described real estate which Craig Danner, an adult individual are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: 118 Herman Avenue, Lemoyne, PA 17043 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). Zucker, Goldberg & Ackerman, LLC XFP-143718 143718DIO04CO4042011P1 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank, N.A. vs. Craig Danner, et al Plaintiff Defendant(s) at EX. NO, 10-6618 in the amount of $149167.47 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments wi regard to should contact your attorney as soon as possible. /) , Dated: ZUCKER GO eriff's Sale or this Notice, you AN, LLC BY: U _ Scott A Die terick, Esquire; PA 1. D. #55650 Kimber A Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; Pa I.D. #306799 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.: XFP-143718 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-143718 1437 18r) 1 004C040420 I I P2 Exhibit "A" LEGAL DESCRIPTION ALL THOSE TWO CERTAIN CONTIGUOUS LOTS OF GROUND SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO. I BEGINNING AT A POINT 100.00 FEET, MEASURED IN A WESTERLY DIRECTION FROM TI IE SOUTHWEST CORNER OF FIRST STREET (FORMERLY BUCHER STREET), AND HERMAN AVENUE; THENCE EXTENDING ALONG THE SOUTHERN LINE OF HERMAN AVENUE IN A WESTERLY DIRECTION, 33 FEET 3 INCHES TO A POINT ON THE LINE OF LANDS FORMERLY OF GRACE B. NEWCOMER, NOW OR FORMERLY OF CALVIN R. STONER; THENCE ALONG THE LINE OF SAID LAND NOW OR FORMERLY OF CALVIN R. STONER IN A SOUTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT ON THE NORTHERN LINE OF PLUM ALLEY; THENCE ALONG SAID NORTHERN LINE OF PLUM ALLEY, AND LANDS NOW OR FORMERLY OF THE SOUTHERN PENNSYLVANIA RAILROAD COMPANY IN AN EASTERLY DIRECTION, 31 FEET 3 INCHES, MORE OR LESS, TO A POINT ON THE LINE OF LANDS FORMERLY OF GEORGE LEACH; THENCE ALONG THE LINE OF SAID LAST MENTIONED LANDS, AND AT RIGHT ANGLES TO THE SOUTHERN LINE OF HERMAN AVENUE IN A NORTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT IN THE SOUTHERN LINE OF HERMAN AVENUE, AFORESAID, AT THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY STONE AND FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 118 HERMAN AVENUE (FORMERLY 116 HERMAN AVENUE), LEMOYNE. PENNSYLVANIA HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 118 HERMAN AVENUE, LEMOYNE, PA, 17043. BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 25, 2009 AND RECORDED JANUARY 12, 2010 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT #201001032, PAGE , GRANTED AND CONVEYED UNTO CRAIG DANNER, AN ADULT INDIVIDUAL. TAX MAP NO.: 12-21-0265-423. Zucker, Goldberg & Ackerman, LLC «Field2»-aField1» ((Field I )D 1004C02/ 12/200BP3 t? a Page 1 of 3 ! , C,i, a.tt.- w , 102 im UNITED STATES ' 0004282036 $ 01.150 MAILED FROM ZIP ODE7 2011 p 70 9 POST11t SERVICE This Certificate of Meiling provides evidence that mall has been presented to USPSe for milling. This form maybe used for domestic and international mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-143718/sde TEAM C To' CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 NO nowv" .02 1M 01.15 UNITE? ST13TES 0004282038 APR 0 7 2011 l i., MAILED FROM WCODE 0 7092 POSTAL S?gg?a te!7 VICEe here. This Grtgkate of Marling provides evidence that mail has been presemed to USPSe for mailing. This form may be used for domestic and international mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-143718/sde TEAM C To' COMMONWEALTH OF PENNSYLVANIA Postmark DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q : CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ;i Here J/C,rJr^ POSTAL CERT OF MAILING: NOTICE TO LIEN HOLDERS Page 2 of 3 UNITED 02 1M 01.150 0004282036 ST13TES .. ,.. MAILEDFRL3MZA?CAPR0 2011 ODE707092 PSERVICE here. This Certificate of Mailing provides evidence that mail has been presented to IAPSe for maitln. This form maybe used for domestic and international mall. "om` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, N1 07092 XFP-143718/sde TEAM C TO: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 --County of P.Q.: CUMBERLAND ??-_-_??_?--------- PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here ySosp%? .....e, neNE,r teowsEs 02 1M $ 01.150 UNITED STATES '0004282036 APR 0 7 2011 OOnCTAI sERVrcEt? MAILED FROM ZIPCODE 0 7092 This Certificate of Mailing provides evidence that mail has been presented to USPSe for malling. This form may be used for domestk and International mall. Preen: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-143718/sde TEAM C T°` PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 POSTAL CERT OF MAILING: NOTICE: TO LIEN HOLDERS A ra Page 3 of 3 l m 11 sees, 3 .?v .r..star, e,!-Ea sown UNITED STATES 00042 N! ° 2 42 $ 01.150 82036 AFRO) 2011 MAILED FROM ZIP CODE 0 70 92 . POSTAL SERVICEe - This Certificate of Mailing provides evidence that mail has been presented to USPSe for mailing. This form maybe used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-143718/sde TEAM C To: UNKNOWN TENANT OR TENANTS Postmark Here 118 Herman Avenue Lemoyne, PA 17043 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ..e.v UNI TED STATES ? 021M $ 01.150 0004282036 APR 0 7 2011 V..?POSTAL SERVICEe MAILED FROM ZIPCODE 07092 This Certiflcale of Mailing provides evidence that mail hu been presented to USPSe for making. TENS form n.., w emu mr uumesvc and international mail. From: Scott A. Dietterick, Esquire ---?.., Ov?? ?t f? ?L,`` ,? c/a Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 tt{ XFP-143718/sde TEAM C .7 - •r i TO: UNKNOWN SPOUSE PostmarkH 118 Herman Avenue ?`.. ?... - Lemoyne, PA 17043 County of P.Q.: CUMBERLAND PS Form 3827, April 2007 PSN 7530-02-000-9065 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff T:-'E sry TH, n p t?i1 PEINNSY', V' A,triA Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, N.A Case Number vs. Craig Danner 2010-6618 SHERIFF'S RETURN OF SERVICE 03/17/2011 08:42 PM - Deputy Michael Barrick, 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 118 Herman Avenue, Lemoyne, PA 17043, Cumberland County. 03/18/2011 06:34 PM - Deputy Michael Barrick, 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 the Defendant, to wit: Craig Danner at 756 Erford Road, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County. 06/01/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County, Courthouse, Carlisle, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Atty Scott Dietterick, being the buyer in this execution, paid to the Sheriff the sum of $ 07/08/2011 Deed recorded on 7/8/11 SHERIFF COST: $955.35 July 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith V Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, N.A. vs. Craig Danner Case Number 2010-6618 SHERIFF'S RETURN OF SERVICE 03/17/2011 08:42 PM - Deputy Michael Barrick, 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 118 Herman Avenue, Lemoyne, PA 17043, Cumberland County. 03/18/2011 06:34 PM - Deputy Michael Barrick, 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 the Defendant, to wit: Craig Danner at 756 Erford Road, East Pennsboro Township, Camp Hill, PA 17011, Cumberland County. 06/01/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County, Courthouse, Carlisle, PA on June 1, 2011 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Atty Scott Dietterick, being the buyer in this execution, paid to the Sheriff the sum of $ 07/08/2011 Deed recorded on 7/8/11 SHERIFF COST: $955.35 July 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 10-6618 vs. t? N - , Craig Danner Defendant. U) D C) AFFIDAVIT PURSUANT TO RULE 3129.1 5c= : --? Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 118 Herman Avenue, Lemoyne, PA 17043. Name and Address of Owner(s) or Reputed Owner(s): CRAIG DANNER, AN ADULT INDIVIDUAL 118 Herman Avenue Lemoyne, PA 17043 2. Name and Address of Defendant(s) in the Judgment: CRAIG DANNER 118 Herman Avenue Lemoyne, PA 17043 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 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: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 1 l 8 Herman Avenue Lemoyne, PA 17043 UNKNOWN SPOUSE 1 18 Herman Avenue Lemoyne, PA 17043 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER GOLDBERG & ACKERMAN, LLC Dated: February 1,4, 2011 BY: ?.. Scott A. Dietterick, Esquire; P I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. 489705 Joel A. Ackerman, Esquire; P I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-143718 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THOSE TWO CERTAIN CONTIGUOUS LOTS OF GROUND SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO.I BEGINNING AT A POINT 100.00 FEET, MEASURED IN A WESTERLY DIRECTION FROM THE SOUTHWEST CORNER OF FIRST STREET (FORMERLY BUCHER STREET), AND HERMAN AVENUE; THENCE EXTENDING ALONG THE SOUTHERN LINE OF HERMAN AVENUE IN A WESTERLY DIRECTION, 33 FEET 3 INCHES TO A POINT ON THE LINE OF LANDS FORMERLY OF GRACE B. NEWCOMER, NOW OR FORMERLY OF CALVIN R. STONER; THENCE ALONG THE LINE OF SAID LAND NOW OR FORMERLY OF CALVIN R. STONER IN A SOUTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT ON THE NORTHERN LINE OF PLUM ALLEY; THENCE ALONG SAID NORTHERN LINE OF PLUM ALLEY, AND LANDS NOW OR FORMERLY OF THE SOUTHERN PENNSYLVANIA RAILROAD COMPANY IN AN EASTERLY DIRECTION, 31 FEET 3 INCHES, MORE OR LESS, TO A POINT ON THE LINE OF LANDS FORMERLY OF GEORGE LEACH; THENCE ALONG THE LINE OF SAID LAST MENTIONED LANDS, AND AT RIGHT ANGLES TO THE SOUTHERN LINE OF HERMAN AVENUE IN A NORTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT IN THE SOUTHERN LINE OF HERMAN AVENUE, AFORESAID, AT THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY STONE AND FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 118 HERMAN AVENUE (FORMERLY 116 HERMAN AVENUE), LEMOYNE. PENNSYLVANIA HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 118 HERMAN AVENUE, LEMOYNE, PA, 17043. BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 25, 2009 AND RECORDED JANUARY 12, 2010 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT #201001032, PAGE, GRANTED AND CONVEYED UNTO CRAIG DANNER, AN ADULT INDIVIDUAL. TAX MAP NO.: 12-21-0265-423. /uck,^r 6oldhcri, c Ackcrnnan 1.1 (' XFP-1-0718 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, ; vs. NO.: 10-6618 Craig Danner t:-7 rv C':? Defendant. rr7 rn ? ?> rn o NOTICE OF SHERIFF'S SALE ) "-" OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Craig Danner 118 Herman Avenue Lemoyne, PA 17043 AND 745 Erford Road Camp Hill, PA 17011-1126 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013 on 06/01/2011 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") The LOCATION of your property to be sold is: 118 Herman Avenue, Lemoyne, PA, 17043 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 10-6618 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Craig Danner Zucker, Goldberg & Ackerman, LLC XFP-143718 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker, Goldberg & Ackerman, LLC XFP-143718 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. l Dated: February ; 2011 ZUCKER GOLDBERG & ACKERMAN, LLC BY: L Scott A. Di tterick, Esquire; P I.D. #55650 Kimberly A. Bonner, Esqui e; PA.I.D. #89705 Joel A. Ackerman, Esquire; I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D, #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-143718 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XFP-143718 Exhibit "A" LEGAL DESCRIPTION ALL, THOSE TWO CERTAIN CONTIGUOUS LOTS OF GROUND SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO. I BEGINNING AT A POINT 100.00 FEET, MEASURED IN A WESTERLY DIRECTION FROM THE SOUTHWEST CORNER OF FIRST STREET (FORMERLY BUCHER STREET), AND HERMAN AVENUE; THENCE EXTENDING ALONG THE SOUTHERN LINE OF HERMAN AVENUE IN A WESTERLY DIRECTION, 33 FEET 3 INCHES TO A POINT ON THE LINE OF LANDS FORMERLY OF GRACE B. NEWCOMER, NOW OR FORMERLY OF CALVIN R. STONER; THENCE ALONG THE LINE OF SAID LAND NOW OR FORMERLY OF CALVIN R. STONER IN A SOUTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT ON THE NORTHERN LINE OF PLUM ALLEY; THENCE ALONG SAID NORTHERN LINE OF PLUM ALLEY, AND LANDS NOW OR FORMERLY OF THE SOUTHERN PENNSYLVANIA RAILROAD COMPANY IN AN EASTERLY DIRECTION, 31 FEET 3 INCHES, MORE OR LESS, TO A POINT ON THE LINE OF LANDS FORMERLY OF GEORGE LEACH; THENCE ALONG THE LINE OF SAID LAST MENTIONED LANDS, AND AT RIGHT ANGLES TO THE SOUTHERN LINE OF HERMAN AVENUE IN A NORTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT IN THE SOUTHERN LINE OF HERMAN AVENUE, AFORESAID, AT THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY STONE AND FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 118 HERMAN AVENUE (FORMERLY 116 HERMAN AVENUE), LEMOYNE. PENNSYLVANIA HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 118 HERMAN AVENUE, LEMOYNE, PA, 17043. BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 25, 2009 AND RECORDED JANUARY 12, 2010 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT #201001032, PAGE, GRANTED AND CONVEYED UNTO CRAIG DANNER, AN ADULT INDIVIDUAL. TAX MAP NO.: 12-21-0265-423. hicker. Goldhcrg & Ackerman. LLCM XFl'-143718 Exhibit "A" LEGAL DESCRIPTION ALL. THOSE TWO CERTAIN CONTIGUOUS LOTS OF GROUND SITUATED IN THE BOROUGH OF LEMOYNE, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: TRACT NO. I BEGINNING AT A POINT 100.00 FEET, MEASURED IN A WESTERLY DIRECTION FROM THE SOUTHWEST CORNER OF FIRST STREET (FORMERLY BUCHER STREET), AND HERMAN AVENUE; THENCE EXTENDING ALONG THE SOUTHERN LINE OF HERMAN AVENUE IN A WESTERLY DIRECTION, 33 FEET 3 INCHES TO A POINT ON THE LINE OF LANDS FORMERLY OF GRACE B. NEWCOMER, NOW OR FORMERLY OF CALVIN R. STONER; THENCE ALONG THE LINE OF SAID LAND NOW OR FORMERLY OF CALVIN R. STONER IN A SOUTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT ON THE NORTHERN LINE OF PLUM ALLEY; THENCE ALONG SAID NORTHERN LINE OF PLUM ALLEY, AND LANDS NOW OR FORMERLY OF THE SOUTHERN PENNSYLVANIA RAILROAD COMPANY IN AN EASTERLY DIRECTION, 31 FEET 3 INCHES, MORE OR LESS, TO A POINT ON THE LINE OF LANDS FORMERLY OF GEORGE LEACH; THENCE ALONG THE LINE OF SAID LAST MENTIONED LANDS, AND AT RIGHT ANGLES TO THE SOUTHERN LINE OF HERMAN AVENUE IN A NORTHERLY DIRECTION, 75.00 FEET, MORE OR LESS, TO A POINT IN THE SOUTHERN LINE OF HERMAN AVENUE, AFORESAID, AT THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY STONE AND FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 118 HERMAN AVENUE (FORMERLY 116 HERMAN AVENUE), LEMOYNE. PENNSYLVANIA HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 118 HERMAN AVENUE, LEMOYNE, PA, 17043. BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND WIFE, BY DEED DATED NOVEMBER 25, 2009 AND RECORDED JANUARY 12, 2010 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT #201001032, PAGE, GRANTED AND CONVEYED UNTO CRAIG DANNER, AN ADULT INDIVIDUAL. TAX MAP NO.: 12-21-0265-423. /uckei (;oldh,?w & ,,\c:kcrman. L! _C XIT-l43718 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6618 Civil CIVIL. ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NA Plaintiff (s) From CRAIG DANNER (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 5149,167.47 L.L.S.50 Interest from 2/6/2011 to date of sale $6,310.40 Atty's Comm % Due Prothy 52.00 Atty Paid $232.50 Other Costs Plaintiff Paid !! Date: 2/16/11 ` Dav' D. Buell, Prothono?ry (Seal) By: Deputy REQUESTING PARTY: Name: ASHLEIGH L. LEVY, ESQUIRE; Address: ZUCKER, GOLBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF TRUE COPY FROM RECORD In Testimony whereo,`, I here unto set my hand and the seal of said Court at ^arlis:e, Pa. This 146 day of ' 7 , ?Q 1 ?J'??y' onotG:y Telephone: 908-233-8500 Supreme Court ID No. 306799 t )11 March 1, 201 1 the S1ientl levied upon the defendant's interest iii the real property situated in Lemoyne Borough, Cumberland County, PA, K,-nown and numbered as, i 18 Herman Avenue, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein Date; Marc1i 3.. 20 Bva ., l fJ o f ?t? l 1 JD Real Estate- Coordinator CUMBERLAND LAW JOURNAL Writ No. 2010-6618 Civil Wells Fargo Bank, N.A VS. Craig Danner Atty.: Scott A. Dietterick ALL THOSE TWO CERTAIN con- tiguous lots of ground situated in the Borough of Lemoyne, County of Cumberland, and State of Penn- sylvania, bounded and described as follows, to wit: TRACT NO.I BEGINNING at a point 100.00 feet, measured in a westerly direction from the southwest corner of First Street (formerly Bucher Street), and Herman Avenue; thence extending along the southern line of Herman Avenue in a westerly direction, 33 feet 3 inches to a point on the line of lands formerly of Grace B. New- comer, now or formerly of Calvin R. Stoner; thence along the line of said land now or formerly of Calvin R. Stoner in a southerly direction, 75.00 feet, more or less, to a point on the northern line of Plum Alley; thence along said northern line of Plum Ailey, and lands now or formerly of the Southern Pennsylvania Railroad Company in an easterly direction, 31 feet 3 inches, more or less, to a point on the line of lands formerly of George Leach; thence along the line of said last mentioned lands, and at right angles to the southern line of Herman Avenue in a northerly di- rection, 75.00 feet, more or less, to a point in the southern line of Her- man Avenue, aforesaid, at the place of BEGINNING. HAVING thereon erected a dwell- ing known and numbered as 118 Herman Avenue (formerly 116 Her- man Avenue), Lemoyne, Pennsyl- vania. HAVING thereon erected a dwell- ing house being known and num- bered as 118 Herman Avenue, Le- moyne, PA, 17043. BEING the same premises which Patrick A. McCarthy and Paula M. McCarthy, husband and wife, by deed dated November 25, 2009 and recorded January 12, 2010 in and for Cumberland County, Pennsylvania, in Deed Book Volume Instrument #201001032, Page , granted and conveyed unto Craig Danner, an adult individual. TAX MAP NO.: 12-21-0265-423. 15 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. ! <sa Marie Coyne, E for SWORN TO AND SUBSCRIBED before me this of May, 2011 GC Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission 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 Z4fPNow 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 as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 04/29/11 -) 05/06/11 Sworn to and sukribed befog me this 23,day ©f.* ay, 2011 A. D. Notary Public COMMONWEALTH OF PENNSYLVANLA I Notarial Seal ` Sherrie L. Kisner, Notary Publi i Lower Paxton Twp,, Dauphin County Mer My Cc) en l%10n Ekplres Nov. 25, 2011 svivanla Association of Not-ert 2010.64118 Civil Vyells Fargo Bank, N.A. Vs Craig Danner Any; scM A pietterick Ali Those Two Certain Contiguous Lots of Ground Situated In The Borough Of Lemoyne, County Of Cumberland, And State of Pennsylvania, Bounded And Described AS F0117, To Wit: No Tract Beginning At A Point 100.00 Feet, Measured In A Westerly Direction From The Southwest Comes of First Street (Formerly Bucher Street), And Herman Avenue; Thence Emending, Along The Southern Line Of Herman Avenue In A Westerly Direction, 33 Feet 3 Inches To A Point On The Line Of Lands Formerly Of Grace B. Newcomer, Now Or Formerly of Calvin. R. Stoner; Thence Along The Line of Said Land Now Or Formerly Of Calvin R. Stoner In A Southerly Direction, 75.00 Feet, More Or Less, To A Point On The Northern Line Of Plum Alley; Thence Along Said Northern Line Of Plum Alley, And Lands Now Or Formerly Of The Southern Pennsylvania Railroad Company In An Easterly Direction, 31 Feet 3 Inches, More Or Less, To A Point On The Line of Lands Formerly Of George Leach; Thence Along The Line Of Said Last Mentioned Lands, And At Right Angles To The Southern Line Of Herman Avenue In A Northerly Direction, 75.00 Feet, More Or Less, To A Point In The Southern Line of Herman Avenue. Aforesaid, At The Place Of Beginning. Having Thereon Erected A Two- Story Stone And Frame Dwelling House Known And Numbered As 118 Herman Avenue (Formerly 116 Herman .!Venue), Lemoyne. Pennsylvania Having Thereon Erected A Dwelling House Being Known And Numbered As 118 Herman Avenue, Lemoyne, Pa, 17043. Being The Same Pm `uses Which Patrick A. Mccarthy And Paula M. Mccarthy, Husband And Wife, By Deed Dated November 20 02I 2004 And Recorded January Pennsylvania, And For Cumberland County, Penny In Deed Book Volume Instrument #201001032, Page , Granted And Conveyed Unto Craig Danner, An Adult individual. Tare Map No.: 12.21-OW-423. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND f SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Wells Fargo Bank NA is the grantee the same having been sold to said grantee on the 1 day of June A.D., 202011, under and by virtue of a writ Execution issued on the 16 day of February, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6618, at the suit of Wells Fargo Bank N.A. against Craig Danner is duly recorded as Instrument Number 201119107. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of i 2-A.D. of Deeds PAW(* Of *ft Offl Wd Cm My, Cadift PA My C*rnm"On Monda1l of Jan. 2014