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HomeMy WebLinkAbout10-7382Phelan Hallinan &Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 ~~~-~~- 'Daniel G. Schmieg, Esq., Id. No. 62205 ~~ ~~~ P~~Q~(-~(~j~~ ~,,~~ Michele M. Bradford, Esq., Id. No. 69849 ~~ Z~1pN Judith T. Romano, Esq., Id. No. 58745 ~~ 3Q ~~ ~~Y Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ~(j pEN~$ ~~j) C~~~~ ~, Lauren R. Tabas, Esq., Id. No. 93337 ~~/A~jr~ Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 ATTORNEY FOR PLAINTIFF 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 257397 WELLS FARGO BANK, N.A 3476 STATEVIEW BOULEVARD COURT OF COMMON PLEAS FORT MILL, SC 29715 CIVIL DIVISION Plaintiff `'• TERM p DOUGLAS K. GAMBLE NO• `(~ _~ ~j' D JENNIFER D. GAMBLE 132 SOUTH EARL STREET CUMBERLAND COUNTY SHIPPENSBURG, PA 17257-1802 Defendants File #: 257397 ~~p © aa~ ~ ~k~ ~~~~, NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOU"1' AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS A I' A RF.,DUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL, CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE; CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 257397 1. Plaintiff is WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 132 SOUTH EARL STREET SHIPPENSBURG, PA 17257-1802 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 03/15/2007 DOUGLAS K. GAMBLE and JENNIFER D. GAMBLE made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book No. 1985, Page 3468. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 257397 t 6. The following amounts are due on the mortgage: Principal Balance $263,863.86 Interest $8,878.29 05/01/2010 through 11/15/2010 Late Charges through 11/15/2010 $249.78 Property Inspections/Property Preservations $205.00 Escrow Deficit , 729_fR TOTAL $273,926.61 7 8 Plaintiff is not seeking a judgment of personal liability (or an in ners~nam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. The mortgage premises are ya.cant and ahand~n~. File #: 257397 WHEREFORE, Plaintiff demands an in rim judgment against the Defendant(s) in the sum of $273,926.61, together with interest from 11/15/2010 at the rate of $45.18 per diem to the date of judgment, and other costs, fees and charges collectible under the mortgage, including but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALI,INAN & SCHMIEG, LLP .~- By: awrence "1'. 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. "I'abas, 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 I,. Spivack, Esq., Id. No. 84439 ^ Jaime McGuinness, Esq., Id. No. 90134 ^ Chrisovalante P. Fliakos, Esq., Id. No. 94620 ^ Joshua L Goldman, Esq., Id. No. 205047 ~Courtenay R. Dunn, Esq., Id. No. 206779 ^ Andrew C. Bramblett, Esq., Id. No. 208375 ^ Allison F. Wells, Esq., Id. No. 309519 Attorneys for Plaintiff File #: 257397 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern edge of William Drive at common corner of Lot 29 and Lot 30 as shown on subdivision plan of Hallwood Heights West, Phase III; thence along Lot 29, North 41 degrees 55 minutes 06 seconds East 121.00 feet to a point; thence along other lands now or formerly of G & C Associates, South 48 degrees 04 minutes 54 seconds East 106.25 feet to a point; thence along Lot 31, South 41 degrees 55 minutes 06 seconds West 121.00 feet to a point on the northern edge of William Drive; thence along the northern edge of William Drive, North 48 degrees 04 minutes 54 seconds West 106.25 feet to a point, the point and place of BEGINNING. BEING all of Lot 30 of Hallwood Heights West, Phase III, dated September 17, 1999 and recorded in the Recorder of Deeds Office, Cumberland County, Plan Book 80, Page 105. Consisting of .2951 acres, more or less. PROPERTY ADDRESS: 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173 PARCEL # 32-34-2413-309 File #: 257397 The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. ~~..~-- Attorney for Plaintiff DATE: ~ File #: 257397 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??ri?titp at 4n:r??frlT?b FtE..ED-OFF ICE o e 2011 J,4 -3 A 9: 2 9 C;th BEAD LAiiD o0Up,`T,., PENNSY! Wells Fargo Bank, N.A. , vs. Douglas K. Gamble (et al.) Case Number 2010-7382 SHERIFF'S RETURN OF SERVICE 12/01/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he rude a diligent search and inquiry for the within named defendant, to wit: Douglas K. Gamble, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 12/01/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he shade a diligent search and inquiry for the within named defendant, to wit: Jennifer D. Gamble, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 12/02/2010 12:16 PM - 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: Douglas K. Gam le, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage F reclosure as not found as to the defendant Douglas K. Gamble. Request for service at 407 William rive, Shippensburg, PA 17257 is vacant. WILLIAM CLINE; DEPUTY 12/02/2010 12:15 PM - 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: Douglas K. Gamble, 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 Douglas K. Gamble. Request for service at 407 William Drive, Shippensburg, PA 17257 is vacant. LIAM CLINE,'DEPUTY 12/03/2010 06:06 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 3, 2010 at 1806 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jennifer D. Gamble, by making known unto herself personally, at 132 S. Earl 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. NOAH CLINE, DE UTY 12/03/2010 06:06 PM - 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: Douglas K. Gamble, 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 Douglas K. Gamble. Jennifer D. Gamble advised Deputies, Douglas K. Gamble is thought to be residing in Franklin County, Pennsylvania. !c? Counr;E,a11, Shen<.I. f 0o lori. In;;. NOAH CLINE, DEPUTY 12/08/2010 12:15 PM - Franklin County Return: And now December 8, 2010 at 1215 hours I,',Dane Anthony, Sheriff of Franklin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Douglas K. Gamble by making known v/ unto himself personally, at The Franklin County Sheriffs Office, 157 Lincoln Way East, Chambersburg, Pennsylvania 17201 its contents and at the same time handing to him personally the said true and correct copy of the same. 12/13/2010 Franklin County Return: And now, December 13, 2010 I, Dane Anthony, Sheriff of Franklin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiryfor Jennifer D. Gamble the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in the County of Franklin and therefore return same NOT FOUND. Deputies were advised, Jennifer D. Gamble currently resides in Cumberland County. SHERIFF COST: $171.00 December 22, 2010 SO ANSWERS, -1?9 X? RON R AND RSON, SHERIFF CMMrTYSWte She,ff, T-'iPoOso f. In'- SHERIFF'S RETURN - NOT FOUND CASE NO: 2010-00295 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN WELLS FARGO BANK NA VS DOUGLAS K AND JENNIFER D GAMBL ROBERT K MARSHALL Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: GAMBLE JENNIFER D but was unable to locate Her in his bailiwick. He therefore returns the COMP MORT FORE the within named DEFENDANT 787 MEADOWBROOK LANE GAMBLE JENNIFER D (''F-TZkMnWDQMTTTJr± nT , " ^I DEFENDANT RESIDES IN CUMBERLAND COUNTY Sheriff's Costs: Docketing Service Affidavit Surcharge FOUND , as to So answers: .00 .00 , .00 ROBE AT SHALL .00 DANE M ANTHONY, Sheriff .00 .00 PHELAN HALLINAN AND SCHMIEG 12/13/2010 Sworn and subscribed to before me this day of CA e- - Ov A. D. JL.A- Notary RICHARD D. Mc(:A TY, Notary Yu Charribeisburg Boro., Franklin Co 1 i My (-ornmission boires 1an.29, SHERIFF'S RETURN - REGULAR CASE NO: 2010-00295 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN WELLS FARGO BANK NA VS DOUGLAS K AND JENNIFER D GAMBL I ROBERT K MARSHALL Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMP MORT FORE was served upon GAMBLE DOUGLAS K the DEFENDANT , at 1215:00 Hour, on the 8th day of December-, 2010 at FRANKLIN COUNTY SHERIFF'S OFFI 157 LINCOLN WAY EAST CHAMBERSBURG, PA 17201 by handing to DOUGLAS GAMBLE a true and attested copy of COMP MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 Sworn and Subscribed to before me this L13 day of A.D. Notary / ..-z So Answers: ROBERT K MARSHALL By Depu y erif 12/13/2010 PHELAN HALLINAN AND EG .+WIT11.wnrrcru? n ur YENNSYLVA IA NOTARIAL SEAL RICHARD D. MCCARTY, Notary Pub is Chambersburg Boro., Franklin Cou ty My COiTlrrlissIon Ezpires Jan. 29, 20 1 t Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Attorney for Plaintiff 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 rng47,.., = ran r- -"gy Courtenay R. Dunn, Esq., Id. No. 206779 ; z? m ;BCD D Andrew C. Bramblett, Esq., Id. No. 208375 ? C -?o Allison F. Wells, Esq., Id. No. 309519 ?o s» William E. Miller, Esq., Id. No. 308951 =C' C) 1617 JFK Boulevard, Suite 1400 5 ? a One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS DOUGLAS K. GAMBLE CIVIL DIVISION JENNIFER D. GAMBLE No. 10-7382 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 DOUGLAS K. GAMBLE, and JENNIFER D. GAMBLE, 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: 6W+ V y,100 ?a1 a t? Ck?/bs'ya.?6 e?.as4g?? Yvvh-ce AA4;ied 257397 As set forth in Complaint $273,926.61 Interest -11/16/2010 to 02/08/2011 $3.840.30 TOTAL $277,766.91 I hereby certify that (1) the Defendant's last known addresses are 787 MEADOWBROOK LANE, CHAMBERSBURG, PA 17201-3851, and 132 SOUTH EARL STREET, SHIPPENSBURG, PA 17257-1802, and mortgaged premises located at 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173, and (2) that notice has been iven in accordance with Rule 237.1, copy attached. ? Lawr_ellhelan, Esq., Id. No. 3 ,2227 . 95 Q-Fraancis S. allinan, Esq., Id. ;:.622'05 ? Daniel G. Schmieg, Esq., Id. ? 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 ? Andr C. Bramblett, Esq., Id. No. 208375 lison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ?-?kjt PHS # 257397 PROTHONOTARY 257397 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-7382 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 DOUGLAS K. GAMBLE is over 18 years of age and last known addresses are 787 MEADOWBROOK LANE, CHAMBERSBURG, PA 17201-3851, and 132 SOUTH EARL STREET, SHIPPENSBURG, PA 17257-1802, and mortgaged premises located at 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173. 257397 (c) that defendant JENNIFER D. GAMBLE is over 18 years of age and last known address is 132 SOUTH EARL STREET, SHIPPENSBURG, PA 17257-1802, and mortgaged premises located at 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. February 8, 2011 LJJ.awren-ce T. Phelan, Esq., Id. No. 227 Francis S. Hallinan, Esq., Id. N . 62695 ? Daniel G. Schmieg, Esq., Id. o. 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 ? C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff 257397 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A. VS. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-7382 Notice is given that a Judgment in the above captioned matter has been entered against you on 6C -9-1 By: If you have any questions concerning this matter please ? Co ay R. Dunn, Esq., Id. No. 206779 ? ew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 [:1 Lawrence T. Phelan, Esq], Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 "THIS THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** 257397 WELLS FARGO BANK, N.A. V. Plaintiff COURT OF COMMON PLEAS CIVIL DIV] SON NO. 10-7382 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) TO: DOUGLAS K. GAMBLE 787 MEADOWBROOK LANE CHAMBERSBURG, PA 17201-3851 DATE OF NOTICE: January 26, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER 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 # 257397 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: 'Lawrence T. Phelan, Esq., Id. No. 227 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 She 1 R. Shah-Jani, Esq., Id. No. 81760 J me 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 Allison F. Wells, Esq., Id. No. 309519 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 257397 WELLS FARGO BANK, N.A. V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-73 82 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) TO: DOUGLAS K. GAMBLE 132 SOUTH EARL STREET SHIPPENSBURG, PA 17257-1802 DATE OF NOTICE: January 26, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER 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 # 257397 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 n (717) 249-3166 By: Lawrence T. Phelan, Esq., Ud%27 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 Sheeta ''R. Shah-Jani, Esq., Id. No. 81760 Jen' e R. Davey, Esq., Id. No. 87077 uren 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 257397 WELLS FARGO BANK, N.A. V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7382 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) TO: JENNIFER D. GAMBLE 132 SOUTH EARL STREET SHIPPENSBURG, PA 17257-1802 DATE OF NOTICE: January 26, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER 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 9 257397 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 n (717) 249-3166 Lawrence T. Phelan, Esq., Id. No-322' 7 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?al R. Shah-Jana, Esq., Id. No. 81760 Je ' e R. Davey, Esq., Id. No. 87077 wren 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plana. Philadelphia, PA 19103 PHS # 257397 WELLS FARGO BANK, N.A. V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7382 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) TO: JENNIFER D. GAMBLE 407 WILLIAM DRIVE SHIPPENSBURG, PA 17257-2173 DATE OF NOTICE: January 26, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER 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 # 257397 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 n (717) 249-3166 By: Lawrenc?Tft?elan, s q., Id. N . 227 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?pl R. Shah-Jani, Esq., Id. No. 81760 Je ' e 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 Allison F. Wells, Esq., Id. No. 309519 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 257397 WELLS FARGO BANK, N.A. V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-7382 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) TO: DOUGLAS K. GAMBLE 407 WILLIAM DRIVE SHIPPENSBURG, PA 17257-2173 DATE OF NOTICE: January 26, 2011 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER 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 # 257397 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 n (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 "l R. Shah-Jani, Esq., Id. No. 81760 J ne R. Davey, Esq., Id. No. 87077 VLauren 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 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 257397 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-7382 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 DOUGLAS K. GAMBLE and JENNIFER D. GAMBLE (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 $277,766.91 L.L. $.50 Interest from 02/09/2011 to Date of Sale ($45.66 per diem) - - $5,159.58 Atty's Comm % Due Prothy $2.00 Atty Paid $303.50 Other Costs Plaintiff Paid Date: 3/1/11 , David D. B 11, Prothonot (Seal) By: Deputy REQUESTING PARTY: Name.: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD., SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 10-7382 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) CUMBERLAND COUNTY To the Prothonotary: C-) Issue writ of execution in the above matter: c'j r ?.,?. Amount Due $277,766.91 cn? X" _n ° Interest from 02/09/2011 to Date of Sale C-) $5,159.58 3`-' ($45.66 per diem) C ? --ir='r =4 CD :; TOTAL $ $282_9269-_- X tomey for Plaintiff Phelan Halligan eg, LLP © awrence T. helan, Esq., d. No. 32227 ? Francis S. Hallinan, Esq., I . No. 62695 do r] LiPd (? ?t O' I ? Daniel G. Schmieg, Esq., No. 62205 El Michele M. Bradford, E ., Id. No. 69849 QQ ?(= ? Judith T. Romano, Esq., Id. No. 58745 019 0 O ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 D O ? Jenine R. Davey, Esq., Id. No. 87077 . ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 El Jay B. Jones, Esq., Id. No. 86657 1 30 3 , D?a Q [] 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 ew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Note: Please attach description of property. PHS # 257397 'ea as ?Ua Co. . So LL ?U? 5 16S? og b 00 vW "" cC W a ~ ? ? a a4 ? ? 3 ¢?`? axe ca7?? a a? ? d Zia Q ABU ??? w z 09 W ? %n %n 0020 c, fr- ? w M EN.,`oc or- MM o?vzcco, 00 N 00 N ? OMO .-r N GOO` Z w p OZ?n ONI??p Cb OZOM oA4 W aZZZ - ozooa, c? cZ "z Z.6 6 '00 FSbSi z a?•?b?z--zzzcczb z as 8wwr W ?w"z~ y o y c" ., A 5r .6 :, 5r- .4 4A g O O ?` O ?." ~ W " H q i"N to W 5r 43 ?A w Hx? ?cnAH > 64 ??' ??aa3 A CA CA P. 0 J2 w awA Zvi °"' >tiad`U"UO Q3 a A a w a ??????????????a? ? LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern edge of William Drive at common corner of Lot 29 and Lot 30 as shown on subdivision plan of Hallwood Heights West, Phase III; thence along Lot 29, North 41 degrees 55 minutes 06 seconds East 121.00 feet to a point; thence along other lands now or formerly of G & C Associates, South 48 degrees 04 minutes 54 seconds East 106.25 feet to a point; thence along Lot 31, South 41 degrees 55 minutes 06 seconds West 121.00 feet to a point on the northern edge of William Drive; thence along the northern edge of William Drive, North 48 degrees 04 minutes 54 seconds West 106.25 feet to a point, the point and place of BEGINNING. BEING all of Lot 30 of Hallwood Heights West, Phase III, dated September 17, 1999 and recorded in the Recorder of Deeds Office, Cumberland County, Plan Book 80, Page 105. Consisting of .2951 acres, more or less. SUBJECT, however, to all existing rights of way, conditions, easements, restrictions, reservations, rights, agreements, notes and other matters of record to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PREMISES VESTED IN Douglas K. Gamble and Jennifer D. Gamble, his wife, by Deed from Paul Dinda and Mary M. Dinda, his wife, dated 03/07/2007, recorded 03/20/2007 in Book 279, Page 916. PREMISES BEING: 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173 PARCEL NO. 32-34-2413-309 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. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) S t; {((}}vim [ Attorneys for Plaintiff C1JIMBERLARD COUNT`.' PENW4SYLWANIA CERTIFICATION : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 10-7382 : 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. PhelaTrtf~ & Schmieg, LLP 7 ? Lawrence T. Phelan, Esq., Id. No)695 ? Francis S. Hallinan, Esq., Id. No. Daniel G. Schmieg, Esq., Id. No. ? 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 ? Aadre-w C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 WELLS FARGO BANK, N.A. Plaintiff v. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) THo?JOWI 2 1 t - 11G J CliMBERLAND COUNT" COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-7382 • CUMBERLAND COUNTY PHS # 257397 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 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173. Name and address of Owner(s) or reputed Owner(s): Name DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 787 MEADOWBROOK LANE CHAMBERSBURG, PA 17201-3851 132 SOUTH EARL STREET SHIPPENSBURG, PA 17257-1802 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) WELLS FARGO BANK, NA 101 NORTH PHILLIPS AVENUE SIOUX FALLS, SD 57104 Wells Fargo Bank, N.A. Attn: Document Management Wells Fargo Bank, N.A. Attn: Katherine Tuazon Document Preparation P.O. Box 31557 MAC B6955-015 Billings, MT 59107-9900 526 Chapel Hills Drive Colorado Springs, CO 80920 Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 407 WILLIAM DRIVE SHIPPENSBURG, PA 17257-2173 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 unsworn falsification to authorities. Date: I 't Attorney-<r-Plaintiff Phelan Hallinan & Jeg, LLP awrence T. elan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62611,95 ? Daniel G. Schmieg, Esq., Id. No. 622 ? 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 ? Court ay R. Dunn, Esq., Id. No. 206779 ? ew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 WELLS FARGO BANK, N.A. D _ 0 s F C 4 : COURT OF COMMON PLEAS E1080TAR Plai iff CIVIL DIVISION VS. ?RS NNO.:10-7382 ? P?VA?IA ?Y DOUGLAS K. GAMBLE JENNIFER D. GAMBLE CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 787 MEADOWBROOK LANE 132 SOUTH EARL STREET CHAMBERSBURG, PA 17201 SHIPPENSBURG, PA 17257-1802 **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 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173 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 $277,766.91 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 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-7382 WELLS FARGO BANK, N.A. vs. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE owner(s) of property situate in the BOROUGH OF SHIPPENSBURG, Cumberland County, Pennsylvania, being (Municipality) 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173 Parcel No. 32-34-2413-309 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $277,766.91 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the northern edge of William Drive at common corner of Lot 29 and Lot 30 as shown on subdivision plan of Hallwood Heights West, Phase III; thence along Lot 29, North 41 degrees 55 minutes 06 seconds East 121.00 feet to a point; thence along other lands now or formerly of G & C Associates, South 48 degrees 04 minutes 54 seconds East 106.25 feet to a point; thence along Lot 31, South 41 degrees 55 minutes 06 seconds West 121.00 feet to a point on the northern edge of William Drive; thence along the northern edge of William Drive, North 48 degrees 04 minutes 54 seconds West 106.25 feet to a point, the point and place of BEGINNING. BEING all of Lot 30 of Hallwood Heights West, Phase III, dated September 17, 1999 and recorded in the Recorder of Deeds Office, Cumberland County, Plan Book 80, Page 105. Consisting of .2951 acres, more or less. SUBJECT, however, to all existing rights of way, conditions, easements, restrictions, reservations, rights, agreements, notes and other matters of record to the extent valid and enforceable and still applicable to the above-described premises. TITLE TO SAID PREMISES VESTED W Douglas K. Gamble and Jennifer D. Gamble, his wife, by Deed from Paul Dinda and Mary M. Dinda, his wife, dated 03/07/2007, recorded 03/20/2007 in Book 279, Page 916. PREMISES BEING: 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173 PARCEL NO. 32-34-2413-309 .M AFFIDAVIT OF SERVICE (FHLMC) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, N.A. PHS # 257397 DEFENDANT SERVICE TEAM/ kxc 1 a - .. DOUGLAS K. GAMBLE COURT NO.: 10-7382 r JENNIFER D. GAMBLE SERVE JENNIFER D. GAMBLE AT: TYPE OF ACTION e 132 SOUTH EARL STREET XX Notice of Sheriffs Sal t SHIPPENSBURG, PA 17257-1802 SALE DATE: 06/01/2011 ?Q TP SERVED 12744 1 ZQ % p , Served and made known to JENNIFE D. GAMBLE , Defendant on the day of 20 ?St ?; 0 ! o'clock /4 M. ate- t,¢it L r- J4 .4yA /tr4. in the manner described below: ? - , X Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is - Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging In which Defendant(s) reside(s). Agent or person in charge of Defennfs office or usual place of business. _ an officer of said Defendant's company. Other: Description: Age Height Weight / 7f'? Race W Sex /" Other 1, 141<< , 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 Kenneth W. Baker before me this ;-3? day 19 Bisbee Drive Burlington,NJ 08016. of , 20i?. Ph. 609-526-423 N By: NOT SERVED , On e . of 20-, at o'clock _. M., Defendant NOT FOUND because: L _ Does Not Exist _ Moved _ Does Not Reside (Not Vacan No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: KIMBERLY CT' N? ;?' r'U13?.1C %TA14 C, t4EY 'MY COMMISS!(,1 ' l MARCH j7, 2013 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, Fsq, 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., fit. No. 93337 Vivck Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq, Id. No. 86657 Peter J. Mukahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., fit. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblety Esq., Id. No. 208375 Allison F. Wells, Esq, Id. No. 309519 William E. Miller, Esq Id. No. 308951 One Penn Center at SuKi6l Station 1617 John F. Kennedy Blvd, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 r PLAINTIFF WELLS FARGO BANK, N.A. AFFIDAVIT OF SERVICE (FHLMC) CUMBERLAND COUNTY PHS # 257397 DEFENDANT DOUGLAS K. GAMBLE JENNIFER D. GAMBLE SERVE DOUGLAS K. GAMBLE AT: i 787 MEADOWBROOK LANE CHAMBERSBURG, PA 17201-3851 SERVICE TEAM/ lac COURT NO.: 10-7382 TYPE OF ACTION XX Notice of Sheriffs Sale SALE DATE: 06/01/2011 C) = --n r-n Fz --! CS C) -r? A C-) C "L3= tzlM <CD 3>C--) Zp --I A r.a 117 SERVED Ri Served and made known to DOUGL . G BL Defendant on the 3 day of 20? , at o o?r~ in a manner d bed be?o *Defendant o clock M., at z a W Too,, personally s rved. ?.l (/.gar 1 Y??S UR - Adult family member with whom lefendant(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 sad Defendant's company. Other: L Weight Race " V 4 Sex 41- Other d ?SSL° S t Sult, being duly sworn according to law, depose and state that I personally e if Sheriffs Sale in the manner as set forth herein, issued in the captioned J above. he - day of 20 , at Vacant _ Does Not E?ist _ No Answer on at Service Refused Other: Sworn to and subscribed before me this day of -? By: Notary: NOTARIAL SEAL LUCILLE H. CARTY Notary Public ?O LETTERKENNY TWP, FRANKLIN COUNTY ?C My Commission Expires Nov 10, 2C 1 1 !NOT o'clnt NOT FOUN D because: _ Moved _ Does Not Reside (Not Vacant) at ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq, Id. No. 32227 Francis S. Haltinmy Esq., Id. No.62695 Daniel G. Sd,mieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Rommm, Esq., Id. No. 58745 Shm4al R. Shah-Jana, Esq., Id. No. 81760 Jendne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq, Id. No. 93337 V ivek 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 C.'hrisovalante P. Flialim, 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 One Penn Center at Sufi i6n Station 1617 John F. Kennedy Blvd, Suite 1400 Phgadelphia,PA 19103.1814 (215)563.7000 Descr, tion: Age elg C?tteNCe L-. 6 handed a true and correct copy of the case on the date and at the address ind ..?0,-OF °I L -ti 'P0TH0H01:x;r 2011 MAR 25 APB 10: 08 CUMBERLAND COUNT'Y' PENNSYLVANIA Phelan Hallinan & Schmieg, LL By: Lawrence T. Phelan, Esq., I c' . No. 32227 Francis S. Hallinan, Esq., Id. No 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. o. 69849 Judith T. Romano, Esq., Id. No. 8745 Sheetal R. Shah-Jani, Esq., Id. N ). 81760 Jenine R. Davey, Esq., Id. No. 8 077 Lauren R. Tabas, Esq., Id. No. 9' 337 Vivek Srivastava, Esq., Id. No. 2 )2331 Jay B. Jones, Esq., Id. No. 8665 Peter J. Mulcahy, Esq., Id. No. 6 -791 Andrew L. Spivack, Esq., Id. No 84439 Chrisovalante P. Fliakos, Esq., I c . No. 94620 Joshua I. Goldman, Esq., Id. No. 05047 Courtenay R. Dunn, Esq., Id. No 206779 Andrew C. Bramblett, Esq., Id. N o. 208375 Allison F. Wells, Esq., Id. No. 30 9519 William E. Miller, Esq., Id. No. 08951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff V. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-7382 257397 Plaintiff, by its 'helan Hallinan & Schmieg, LLP, moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. Plaintiff comme4ed this foreclosure action by filing a Complaint on November 30, 2010. 2. Judgment was entered on February 9, 2011 in the amount of $277,766.91. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit "A". 3. Pursuant to Penns lvania Rule of Civil Procedure 1037(b)(1), a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item which can be calculated from the omplaint, i.e. bringing the interest current. However, new items cannot be added at the time of en of the judgment. 4. The Property is lis ed for Sheriffs Sale on June 1, 2011. 5. Additional sums h ive been incurred or expended on Defendants' behalf since the Complaint was filed and Defend is have been given credit for any payments that have been made since the judgment. The amount f damages should now read as follows: Principal Balance $263,863.86 Interest Through June 1, 2011 $17,899.47 Per Diem $45.18 Late Charges $249.78 Legal fees $1,325.00 Cost of Suit and Title $1,346.00 Sheriffs Sale Costs $0.00 Property Inspections/ Pro perty Preservation $281.43 Appraisal/Brokers Price pinion $0.00 Mortgage Insurance Pre ium / $0.00 Private Mortgage Insura ce Non Sufficient Funds C rge $0.00 Suspense/Misc. Credits ($0.00) Escrow Deficit d"711n LO TOTAL $285,695.22 257397 6. The judgment fo*erly entered is insufficient to satisfy the amounts due on the Mortgage. 7. Under the terms o the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth wove in the amount of judgment against the Defendants. 8. Plaintiff's foreclo ure judgment is in rem only and does not include personal liability, as addressed in Plaintiffs attached brief. 9. In accordance with C berland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess D ages and Order to the Defendant on March 16, 2011 and requested the Defendants' Conc ence. Plaintiff did not receive any response from the Defendants. A true and correct copy of Plainti s letter pursuant to Local Rule 208.3(9) and certification of mailing are attached hereto, mad part hereof, and marked as Exhibit "B". 10. No judge has y entered a ruling in this case. 257397 WHEREFORE, Plaintiff #espectfully requests that this Honorable Court amend the judgment as requested. DATE: 5/2 -( Phelan Hallinan & B tOFrancis r sq., . o. 32227 S. Hallinan, Esq., Id. No 62695 ? Daniel G. Schmieg, Esq., Id. N .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 ? C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ATTORNEY FOR PLAINTIFF 257397 Phelan Hallinan & Schmieg, LL By: Lawrence T. Phelan, Esq., Id . No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No 62695 Daniel G. Schmieg, Esq., Id. No 62205 Michele M. Bradford, Esq., Id. N o. 69849 Judith T. Romano, Esq., Id. No. 8745 Sheetal R. Shah-Jani, Esq., Id. N ). 81760 Jenine R. Davey, Esq., Id. No. 8 077 Lauren R. Tabas, Esq., Id. No. 9 337 Vivek Srivastava, Esq., Id. No. 2 )2331 Jay B. Jones, Esq., Id. No. 8665 Peter J. Mulcahy, Esq., Id. No. 6 .791 Andrew L. Spivack, Esq., Id. No 84439 Chrisovalante P. Fliakos, Esq., IC .. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No 206779 Andrew C. Bramblett, Esq., Id. o. 208375 Allison F. Wells, Esq., Id. No. 3( 9519 William E. Miller, Esq., Id. No. 08951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County DOUGLAS K. GAMBLE JENNIFER D. GAMBLE T _l___ t No.: 10-7382 OF LAW IN SUPPORT OF 257397 I. DOUGLAS K. GAMBLIf and JENNIFER D. GAMBLE executed a Promissory Note agreeing to pay principal, intere+, late charges, real estate taxes, hazard insurance premiums, and mortgage insurance premiums a these sums became due. Plaintiffs Note was secured by a Mortgage on the Property locate at 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257- 2173. The Mortgage indicates tliat in the event of a default in the mortgage, Plaintiff may advance any necessary sums, inc uding taxes, insurance, and other items, in order to protect the security of the Mortgage. In the instant case, Defen4ants defaulted under the Mortgage by failing to tender numerous, promised monthly mortgage payments. Accordingly, after it was clear that the default would not be cured, Plaintiff commenced the i stant mortgage foreclosure action. Judgment was subsequently entered by the Court, and the Property is currently scheduled for Sheriffs Sale. Because of the excessive eriod of time between the initiation of the mortgage foreclosure action, the entry of judgment d the Sheriffs Sale date, damages as previously assessed are outdated and need to be adjusted o include current interest, real estate taxes, insurance premiums, costs of collection, and other expe ses which Plaintiff has been obligated to pay under the Mortgage in order to protect its interests. It is also appropriate to give Defendants credit for monthly payments tendered through bankn tcy, if any. II. It is settled law in Pennsyl ania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments § 191. Stephenson v. tts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase 257397 Home Mortgage Corporation of the Southwest v Good, 537 A.2d 22, 24 (Pa. Super. 1988). The Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its judgment prior to the Sheriffs sal. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489 (Pa.Super. 2003). Morgan Guara}Zty Trust Co. ofN.Y. v Mowl, 705 A.2d 923 (Pa. Super. 1998). National Bank of Pittsbur v. Ciongoli, 407 Pa.Super. 171, 595 A.2d 179 (1991). The Supreme Court of Pennsylvania recognized in Landau v. Western Pa. Nat. Bank 445 Pa. 117, 282 A.2d 335 (1971), that the debt owed on a Mortgage is subject to change and, in fact, can be expected to change from day to day because the bank must advance sums in order to protect its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must protect its collateral up until the dite of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d 826 (1939). Because a judgment In mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts e pended by the Plaintiff in protecting the property. Meco Reality Company v. Burns, 414 Pa. 495, 00 A.2d 335 (1971). Plaintiff submits that if it goes to sale without the requested amended ju gment, and if there is competitive bidding for the Property, Plaintiff will suffer a significant 1 ss in that it would not be able to recoup monies it advanced to protect its interests. Conversely, amending the in rem judgment will not be detrimental to Defendants as it imputes no perso?al liability. In B.C.Y. v. Bukovich, th? Pennsylvania Superior Court reiterated its long standing rule that a Court has the inherent power to 4orrect a judgment to conform to the facts of a case. 257 Pa. Super. 157, 390 A.2d 276 (1978). In the within case, the amount of the original judgment does not adequately reflect the additional s s due on the Mortgage due to Defendants' failure to tender payments during the foreclosure p ceeding and the advances made by the mortgage company. The Mortgage plainly requires the mo agors to tender to the mortgagee monthly payments of principal 257397 and interest until the Promissory are also required to remit to the premiums, fire insurance premi mortgagor s have breached the accompanying the Mortgage is paid in full. The mortgagors igee sufficient sums to pay monthly mortgage insurance taxes and other assessments relating to the Property. The of the Mortgage, and Plaintiff has been forced to incur significant unjust financial losses ?on this loan. III. THE The within case is a mortgaged property to Sheriffs foreclosure is strictly in rem and Partnership v. Kimmel, 424 Pa. IS IN REM ONLY foreclosure action, the sole purpose of which is to take the Pennsylvania law makes clear that an action in mortgage not include any personal liability. Newtown Village 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer Discount Company v. Babuscio, 157 Pa. Super 101, 109,390 A.2d 266,270 (1978). Pennsylvania Rule of Civil Procedure 1141(a). However, Pennsylvania lal requires that the foreclosure action demand judgment for the amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for bidding at the Sheriffs Sale. In thle event that a third party real estate speculator were to bid on the mortgaged property at the Sheriff Sale and become the successful purchaser, Plaintiff would receive the amount of the in rem j IV. INTEREST The Mortgage clearly req principal and interest due on the from the Sheriff. that the Defendants shall promptly pay when due the nding debt. In addition, the Note specifies the rate of interest 257397 to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days prior to the date of default throug the date of the impending Sheriff's sale has been requested. V. If Plaintiff had not adva4d monies for taxes and insurance throughout the foreclosure proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale, Plaintiffs interest very well may qe divested, and Plaintiff would sustain a complete loss on the outstanding balance due on the loo. If the Property were damaged in a fire, Plaintiff would not be able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums. Most importantly, the monies for taxes and insurance simply seeking to have the Court VI. ATTORNEY'S FEES The amount of attorney's f with the loan documents and concluded that a request of five enforceable as an attorney's fee. specifically provides that the mortgagee may advance the charge these payments against the escrow account. Plaintiff is the terms of the Mortgage. requested in the Motion to Reassess Damages is in accordance law. Pennsylvania Courts have long and repeatedly of the outstanding principal balance is reasonable and v. Loomis, 51 Pa. 78 (1865); First Federal Savings an d 68 D&C 2d 751, 755 (1974). In F of ten percent of the original 1979). Recently, the Superior included in the judgment in v. Fetner, the Superior Court held that an attorney's fee amount is not unconscionable. 410 A.2d 344 (Pa. Super. cited Fetner in confirming that an attorney's fee of ten percent foreclosure action was reasonable. Citicorp v. Morrisville 257397 Hampton Realty, 662 A.2d 1120 Court's equitable authority to set VII. COST OF SUIT Super. 1995). Importantly, Plaintiff recognizes this Honorable ney's fees and costs as it deems reasonable. Pursuant to the terms of e mortgage, Plaintiff is entitled to recover all expenses incurred in the foreclosure action. The amo it claimed for the costs of suit and title are the expenses Plaintiff paid to date as a result of the mortkage default. The title report is necessa?y to determine the record owners of the property, as Pa.R.C.P. 1144 requires all record owners tb be named as Defendants in the foreclosure action. It is also necessary to determine whether :property. re are any prior liens to be cleared, so that the Sheriff's sale purchaser acquires clear title toIt is necessary to determine if there are IRS liens on the property, whether the Defi complaint), and numerous other 1 new liens on the property or new date. The Freedom of whereabouts are necessary to sale on the Defendant. The n and 3129.2 to notify all lienholde their interests will be divested by Accordingly, the modest its are divorced (which could affect service of the issues. The title bringdown is necessary to identify any ors between the time of filing and complaint and the writ Act inquiries and the investigation into Defendants' tively attempt personal service of the complaint and notice of of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1 owners, and interested persons of the Sheriff's sale date, as le Sheriff's sale. Plaintiff has incurred for the costs of suit and title were necessary pursuant to Pennsylvj1w'permit aw. The amounts were reasonable and actually incurred. The mortgage and PennsylvaniPlaintiff to recover these sums through its 257397 foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from the sale of the property, not out 4f the Defendant's pockets. Plaintiff should recover the costs of suit and title in their entirety, wh?ch will not cause harm to the Defendants. VIII. CONCLUSION Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by legal proceedings, and such delay require the mortgagee to expend additional sums provided for by the Mortgage, then the expenses necessarily become part of the mortgagee's lien and should be included in the judgment. Plaintiff respectfully requ4sts that this Honorable Court grant its Motion to Reassess Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance with the Mortgage, and has relied l n terms of the Mortgage with the understanding that it would recover the monies it expended to protect its collateral. 257397 WHEREFORE, Plaintiff judgment as requested. DATE: requests that this Honorable Court amend the Phelan Hallinan & L an, sq., .32227 Francis S. Hallinan, Esq., Id. No. 95 ? Daniel G. Schmieg, Esq., Id. No. 6 05 ? Michele M. Bradford, Esq., Id. N .69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? E. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff 257397 xhibit "A" 257397 Phelan Hallinan & Schmieg, LI P By: Lawrence T. Phelan, Esq., t . No. 32227 Attorney for Plaintiff Francis S. Hallinan, Esq., I c . 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., d. No. 81760 Jenine R. Davey, Esq., Id. o. 87077 Lauren R. Tabas, Esq., Id. o. 93337 Vivek Srivastava, Esq., Id. o. 202331 Jay B. Jones, Esq., Id. No. 6657 Peter J. Mulcahy, Esq., Id. o. 61791 Andrew L. Spivack, Esq., I . No. 84439 Chrisovalante P. Fliakos, E q., Id. No. 94620 Joshua I. Goldman, Esq., Id No. 205047 rn ?,.? rn- Courtenay R. Dunn, Esq., la . No. 206779 rn z? °a ?rn Andrew C. Bramblett, Esq., Id. No. 208375 ) Allison F. Wells, Esq., Id. o. 309519 {o p. ? William E. Miller, Esq., Id. No. 308951 sn ?_ ?cz 1617 JFK Boulevard, Suite 140 y ? ° --4 One Penn Center Plaza --+ ° Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE PRAECIPE TO THE PROTHONOTARY: : CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION No. 10-7382 IN REM JUDGMENT FOR FAILURE TO Kindly enter judgment in favor of the Plaintiff and against DOUGLAS K. GAMBLE. and JENNIFER D. GAMBLE Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from s rvice thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs dunages as follows: offi+01DDNoM? yVVh-c,r 257397 As set forth in Complaii Interest -11/16/2010 to $273,926.61 $3,840.30 TOTAL $277,766.91 I hereby certify that (1) a Defendant's last known addresses are 787 MEADOWBROOK LANE, C ERSBURG, PA 17201-3851, and 132 SOUTH EARL STREET, SHIPPENSBURG, P) L 17257-1802, and mortgaged premises located at 407 WILLIAM DRIVE, SHIPPENS URG, PA 17257-2173, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. LJ Lawre elan, Esq., Id. No. 3 227 rancis S. allinan, Esq., Id. No. 695 ? Daniel G. Schmieg, Esq., Id. . 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 ? Andr .C. Bramblett, Esq., Id. No. 208375 O-Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff DAMAGES ARE HEREBY DATE: -1 PHS # 257397 SED AS INDICATED. PROTHONOTARY 257397 xhibit "B" 257397 N J W v g i? w c oo o? v, A W N r. r to c. ? ° x ? ? x ? a r n i v y N N N N n ? W W W W 4 J J CD ?t ' `? = O O xO xC Al H b? O ton cn V5 rA rA a z> p> Pa 4 P b4 b4 C tz a a? a rz ? -4 a m ? 00 W Z N Z v d ~ Z o. Oil lyl o w v t7 v O o a a > S z a rm 7y c 5' '-1 o?? ° m n -4 00 J A ~ N y EL c y d '= a h•? a r Q Cr . d r c tz o o _ ? z ° ? w ? o N ID c ? r d Y oy. c 'fl ?' 3 ti a m Q _ - y 5. c n 4 w. o a a. ?Pses paS'l ` ti 5 n a ??09 ° 02 1M 0004277256 M4 ' y ' MAILED FROM ZIpCC 5 o ?y . rn tD T y, 3 `D m . 0 9 S w oa?z A ag A •, a 2 N con A C b z r a z x Cr1 C) r r -0 IEY ROVI ES .680 216 2011 IDE 19103 PHEL Phelan Hallinan & Schmieg, March 16, 2011 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 132 SOUTH EARL STREET HALLINAN & SCHMIEG, LLP 517 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Representing Lenders in Pennsylvania and New Jersey RE: WELLS FARGO BANK, N.A. v. DOUGLAS K. GAMBLE and JENNIFER D. GAMBLE Premises Address: 407 WILLIAM DRIVE SHIPPENSBURG, PA 17257 CUMBERLAND Coun CCP, No. 10-7382 Dear Defendants, Enclosed please find a e and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with C berland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is, increasing the amount of the judgment. Please respond to me within 5 days, by arch 22, 2011. Should you have further uesti Otherwise, please be guided acc rding Very truly yours,-I Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire or concerns, please do not hesitate to contact me. Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Chrisovalante P. Fliakos, Esqu Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Allison F. Wells, Esquire William E. Miller, Esquire Enclosure VERIFICATION I hereby state that I am make this verification, and that Damages are true and correct to undersigned understands that Pa.C.S. §4904 relating to the attorney for Plaintiff in this action, that I am authorized to statements made in the foregoing Motion to Reassess best of my knowledge, information and belief. The statement herein is made subject to the sworn penalties of 18 falsification of authorities. Phelan Hallinan & DATE: U Lawrence T. P halan- Es ., Id. N0.32227 ranallinan, Esq., . 62695 ? Daniel G. Schmieg, Esq., Id. o'62205 ? Michele M. Bradford, Esq., Id. o. 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 rew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ATTORNEY FOR PLAINTIFF 257397 Phelan Hallinan & Schmieg, LL 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. o. 69849 Judith T. Romano, Esq., Id. No. 8745 Sheetal R. Shah-Jani, Esq., Id. N :). 81760 Jenine R. Davey, Esq., Id. No. 8 077 Lauren R. Tabas, Esq., Id. No. 9 337 Vivek Srivastava, Esq., Id. No. 2 )2331 Jay B. Jones, Esq., Id. No. 8665 Peter J. Mulcahy, Esq., Id. No. 6 .791 Andrew L. Spivack, Esq., Id. No 84439 Chrisovalante P. Fliakos, Esq., IQ . No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No 206779 Andrew C. Bramblett, Esq., Id. o. 208375 Allison F. Wells, Esq., Id. No. 3 9519 William E. Miller, Esq., Id. No. 08951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff V. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE CA ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 10-7382 257397 I hereby certify that true correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, wee sent to the following individuals on the date indicated below. DOUGLAS K. GAMBLE DOUGLAS K. GAMBLE JENNIFER D. GAMBLE JENNIFER D. GAMBLE 132 SOUTH EARL STREET 407 WILLIAM DRIVE SHIPPENSBURG, PA 17257-1 02 SHIPPENSBURG, PA 17257-2173 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 787 MEADOWBROOK LANE CHAMBERSBURG, PA 172013851 Phelan Hallinan & Schmieg, LLP DATE: LJ Lawrence T. P o. 32227 llinan, Esq., Id. No. 95 ? Daniel G. Schmieg, Esq., Id. No. 622 5 ? Michele M. Bradford, Esq., Id. No. 849 ? 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 ? Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ATTORNEY FOR PLAINTIFF 257397 WELLS FARGO BANK, N.A., PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS K. GAMBLE, JENNIFER D. GAMBLE, DEFENDANTS NO. 10-7382 CIVIL ORDER OF COURT c7 N ? rn v a ? l- r Z -vim ao a > . Cam AND NOW, this 29th day of March, 2011, upon consideration of the Plaintiff's Motion to Reassess Damages, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendants to show cause why the relief requested should not be granted; 2. The Defendants will file an answer on or before April 19, 2011; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendants file an answer to this Rule to Show Cause, the Court will determine if further Order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, 'Allison F. Wells, Esquire Attorney for Plaintiff '".Douglas K. Gamble Jennifer D. Gamble Defendants ' -A, M. L. Ebert, Jr., J. 100 Abas FILED-OFFICE:- 1l _ ,'i O MONO T?^-,Id"` 2011 APR -6 AM 10: 0 CUMBERLAND COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County DOUGLAS K. GAMBLE JENNIFER D. GAMBLE No.: 10-7382 Defendants CERTIFICATION OF SERVICE 257397 I hereby certify that a true and correct copy the Court's Rule dated March 29, 2011, was sent to the following individuals on the date indicated below. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 132 SOUTH EARL STREET SHIPPENSBURG, PA 17257-1802 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 407 WILLIAM DRIVE SHIPPENSBURG, PA 17257-2173 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 787 MEADOWBROOK LANE CHAMBERSBURG, PA 17201-3851 By? DATE: A-01 t-, I Phelan Hallinan & S an, Esq., Id. io 22' n, Esq., Id. No. 62 *5 H Daniel G. Schmieg, Esq., Id. No. 62105 ? Michele M. Bradford, Esq., Id. N9/69849 ? 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 ? Andr w C. Bramblett, Esq., Id. No. 208375 lison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 ATTORNEY FOR PLAINTIFF 257397 C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff, V. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PL;kS,.a C °- CIVIL DIVISION cc No.:10-7382 p AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 (r COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY 1 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 C i it Return Receipt stamped by the U.S. Postal Service is attached her iibit "A". Date: ?. an, sg2227 ? Francis S. Hallinan, Esq., Id. No. 695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? An . Bramblett, Esq., Id. No. 208375 llison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorney for Plaintiff IMPORTANT N TICE: 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 # 257397 M s 3U( LLOZ 9Lb 089' tt Saff-08 A31 -=Mll g a ?o U d ?0. U G a?a r 8o`v? z?O a 8 v 2,x )0dlz WOaj 037?VW 9sUlztooo [ g a N :9 o ? w n Q $ = o 5 fps ? a o ? g gc w x ? ? ?a 3 ? ? w bR S°o?a g.?. N a W a a a e ? as oa co a d d Q p .? a ? G7 G7 C9 OoG ? w w 3 PC LTO z z? C2 GN P n°O N N ?? W r W r W a W cn 4-4 ? Da D? OD D r, 7W Z o 8 8 $ u z M M kn N N N N o a a a a `??; a z ••] ^' N M et v'1 ? O l ? 00 0, N M v'f A o . E- a r- C% M tn N I. i i s ao a ,oa ob - s h c N ? ? a o c -ca•°- c x0. -Cc ate.=0o t C?C N N N ?g zap, w g-am w Z 0 L 6 4 3000 dIZ W OH:J 03 1VW 13. •a w . LLOz ZOavw 9 9ZLLzb000 sEy ooz,vo $ WL ZO E :3 e uwtia Oooka gE2p; Z 't w o C 24 d M : E? °$ x ? N ` . _ a? ° E W ?g > x a M ? z u _ 1 o p w 0 V ??' e O N ? T o •?a A? ?s ? ?II ? ?, V? ?r W ^i ? a 'O t? O y W G? ? VJ ' ?` ? pp 0 a ? 41.. .a7GU e n u`? o ? ty uvNi .°?a'`•."r Ci 96 z ma Q x s 3Ir EAU e s. a UV U OSrn ? o=U a°°? paGax< 0. = ov+o<, ?oe?$ Y ?°+« y s ? a+ vv. ?< ??a; e O in GU??vVii ? ? 0 ? ? < W) at- 0% ° ? a a- a .a ? e „ , ? o L= ? ?a $ ? , a ' g, GO a ¦ ` °' e- Gy Oen Q ? "L u ? ? M? wC' w'? e?o w a ., e a z . z3o: w x Fv? 0 eez o °„? w GU..0 ef = eg t o ?? 00ax a. a ,s aa a L ^ C? ?3? p+°sw DD Dl? o a a°oU? W ps `? W C es 0" 3 p4? ?Q ?_ 3e p m 8 _ ° '? 3lC ° .... wi3x m U v i o , wU fY, ? C c7 w h O? 'O y C .1 r N M1 1 !1 b h e o ° , N en gym x n 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division n vs. --4 CUMBERLAND Coin M- DOUGLAS K. GAMBLE ?r- -urn JENNIFER D. GAMBLE No.: 10-7382 a Cq ?M = -n Defendants =C) a -q c') ORDER A AND NOW, this 11 day of --t M&y , 2011, upon consideration of Plaintiff's s? Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendants shall be and is hereby made absolute and Plaintiff s Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $263,863.86 Interest Through June 1, 2011 $17,899.47 Per Diem $45.18 Late Charges $249.78 Legal fees $1,325.00 Cost of Suit and Title $1,346.00 Property Inspections/ Property Preservation $281.43 Escrow Deficit $729.68 TOTAL $285,695.22 Plus interest from June 1, 2011 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. IPS ?( Mew F W&&' r?oghs k Gamble P V Jemt9er Q . &a" le BY THE COURT: - ?% 'I J. 257397 Soft HERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson IL ??--0 f' I(. Sheriff { = F i _ ry Jody S Smith C hief Deputy Ptj Richard W Stewart ?1Ut hL A Solicitor Wells Fargo Bank, N.A. vs. Case Number Douglas K. Gamble (et al.) 2010-7382 SHERIFF'S RETURN OF SERVICE 03/18/2011 02:40 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 407 Wililam Drive, Shippensburg, PA 17257, Cumberland County. 03/18/2011 01:20 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 John Tamayo boyfriend, who accepted as "Adult Person in Charge" for Jennifer D. Gamble at 132 S. Earl Street, Shippensburg Borough, Shippensburg, PA 17257, Cumberland County. 04/06/2011 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Douglas K. Gamble, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Franklin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 04/06/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Franklin County upon Douglas K. Gamble, personally, at 787 Meadowbrook Lane, Chambersburg, PA 17201. So Answers: Michael Harris, Deputy Sheriff. 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 Daniel Schmieg, on behalf of Federal Home Loan Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $787.26 August 01, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF oo Pd Co M COUntySUi!r Sner_ff. 7F??eo ,oft. Ire. WELLS FARQ0 W.NK, NAIL. Plaintiff V. DOUGLAS K. GAMBLE JENNIFER D. GAMBLE Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-7382 CUMBERLAND COUNTY PHS # 257397 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 F,xecution was filed, the following information concerning the real property located at 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) DOUGLAS K. GAMBLE JENNIFER D. GAMBLE 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 787 MEADOWBROOK LANE CHAMBERSBURG, PA 17201-3851 132 SOUTH EARL STREET SHIPPENSBURG, PA 17257-1802 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) WELLS FARGO BANK, NA 101 NORTH PHILLIPS AVENUE SIOUX FALLS, SD 57104 Wells Fargo Bank, N.A. P.O. Box 31557 Attn: Document Management MAC B6955-015 Billings, MT 59107-9900 Wells Fargo Bank, N.A. 526 Chapel Hills Drive Attn: Katherine Tuazon Colorado Springs, CO 80920 Document Preparation 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and, addreJ,,? of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA 407 WILLIAM DRIVE SHIPPENSBURG, PA 17257-2173 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: 1/95 11 1- 1-7 Attorneyor Plaintiff Phelan Hallinan & ieg, LLP awrence T. P elan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 622 ? Michele M. Bradford, Esq., Id. No: 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Court ay R. Dunn, Esq., Id. No. 206779 rew C. Bramblett, Esq., Id. No. 208375 R'AIl'son F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. NO.: 10-7382 DOUGLAS K. GAMBLE JENNIFER D. GAMBLE : CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DOUGLAS K. GAMBLE 787 MEADOWBROOK LANE CHAMBERSBURG, PA 17201 JENNIFER D. GAMBLE 132 SOUTH EARL STREET SHIPPENSBURG, PA 17257-1802 * *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 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173 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 $277,766.91 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-7382 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 DOUGLAS K. GAMBLE and JENNIFER D. GAMBLE (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 $277,766.91 L.L. $.50 Interest from 02/09/2011 to Date of Sale ($45.66 per diem) - - $5,159.58 Atty's Comm % Due Prothy $2.00 Atty Paid $303.50 Other Costs Plaintiff Paid Date: 3/1/11 David D. B 1, Prothono -} (Seal) Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD., SUITE 1400 TRUE COPY FROM RECORD PHILADELPHIA, PA 19103 In Testimony whereof, I here unto set my hand Attorney for: PLAINTIFF and the seal of said C{p urt at Carlisle, Pa. This.-?._._day of _.! W&I - , 2011- Telephone: 215-563-7000 v, P roth ion ?; t _i ry Supreme Court ID No. 309519 C( zf?hjv 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, 407 William Drive, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: Real Estate Coordinator 4/ I CUMBERLAND LAW JOURNAL Writ No. 2010-7382 Civil Wells Fargo Bank, N.A. vs. Douglas K. Gamble Jennifer D. Gamble Atty.: Daniel Schmieg By virtue of a Writ of Execution NO. 10-7382, WELLS FARGO BANK, N.A. vs. DOUGLAS K. GAMBLE, JENNIFER D. GAMBLE, owner(s) of property situate in the BOROUGH OF SHIPPENSBURG, Cumberland County, Pennsylvania, being 407 WILLIAM DRIVE, SHIPPENSBURG, PA 17257-2173. Parcel No. 32-34-2413-309. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $277,766- .91. 25 a 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 Coy e, Editor SWORN TO AND SUBSCRIBED before me this da of May. 2011 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 the Patr1*0t'WXfW5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/22/11 Mulls l?r?r>MrM+ M?. 04/29/11 Vs- 0041100"1MMnrW?n jeawkr 0. eon+b1s' 05/06/11 '? 10 ' N ? r - q? of Execution 0. Byviriae of a .\. J 7382 `? 7382 4'co>;ANK NA lorer" Sworn to and ut?scribed 1) me h, day of May 2011 A D Dt?UGLAS IC GAMBLE , . . i 7ENNTM D. CxAMBLF anvaer(s) of Property situate in floe 1 - f G- ` - BOROUGH OF 5f1,iF)'M9 tO, omkriandCountS',?5 bem8 __- -' Notary Public d07 wffLLVA DRIVE, SHIIIFENSBURi3 FA17257-2173 pa=1No.32-34-2413-309 COMMONWEALTH OF PENNSYLVANIA (AaeaV or user ad*=0 Notarial Seal *°W& N Sherrie L Kism, Notary Public DWEUJNG JUDGMENT AioLR` . !277,766.91 Lower Paxton 1WP., DavPhln County My Exom Nov. 26, 2011 Member, PennsAvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Home Loan Mortgage Corporation 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 1 day of March, A.D., 202011, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 7382, at the suit of Wells Fargo Bank N.A. against Douglas K. Gamble and Jennifer D. Gamble is duly recorded as Instrument Number 201121373. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this A.D. 4-0 day of It-Y ecord r of D ds pAwdm of Deeds, Cw bedand Courtly, Carlisle, PA My Comm "m E*es the Frst Monday of Jan. 2014