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HomeMy WebLinkAbout11-0679 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, Plaintiff, VS. REBECCA A. STOCK Defendant. TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 STATEVIEW BLVD. MAC # X7801-013. FT. MILL. SC 29715 AND THE DEFENDANT: 150 Do¢wood Court New Oxford. PA 17350 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFE CTED BY THIS LIEN IS A ATTY FILE NO.: XFP 148131 CIVIL DIVISION NO.. / / 6 -/1 P ai'l TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF: Wells Fargo Bank, NA COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly.A. Bonner, Esquire Pa. I.D. #89705 n c Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh L. Levy, Esquire ,,y Pa I.D. #306799 200 Sheffield Street, Suite 101' ma Mountainside, NJ 07092 x. t (908) 233-8500 (908) 233-1390 FAX officenzuckereoldbere.com File No.: XFP- 148131/mme -v N ?O -4o x-n C3 C`' 0 -c ._c 09 Uvy C?? ?I S X31.0 C b3a Zucker, Goldberg & Ackerman, LLC XFP-148131 I . IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS ,AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Zucker, Goldberg & Ackerman, LLC XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, Plaintiff, : CIVIL DIVISION : NO.. vs. REBECCA A. STOCK Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, Plaintiff, : CIVIL DIVISION . NO.. VS. REBECCA A. STOCK Defendant. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notification de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y redicando en la Corte por escrito sus defensas de, y objeciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, Plaintiff, VS. REBECCA A. STOCK Defendant CIVIL DIVISION NO.. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, NA, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, NA, having its principal place of business at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Rebecca A. Stock, is an individual whose last known address is 150 Dogwood Court, New Oxford, PA 17350-. 3. On or about April 24, 2009, Rebecca A Stock executed a Note in favor of Oceanside Mortgage Company in the original principal amount of $169,911.00. 4. On or about April 24, 2009, as security for payment of the aforesaid Note, Rebecca A Stock, A Separated Woman made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Oceanside Mortgage Company a Mortgage in the original principal amount of $169,911.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on May 5, 2009, Instrument #200914550. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. The aforesaid Note and Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. as nominee for Oceanside Mortgage Company to Wells Fargo Bank, NA, plaintiff herein, pursuant to an assignment of mortgage to be recorded. Zucker, Goldberg & Ackerman, LLC XFP-148131 6. Rebecca A. Stock, adult individual is the record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. 8. On or about November 7, 2010, Defendant was mailed a combined Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 and Notice of Intention to Foreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. §101, et seq. 9. The amount due and owing Plaintiff by Defendant is as follows: Principal $166,754.51 Interest through 01/05/2011 $4,168.86 Attorneys' Fees $1,250.00 Title Search & Costs $2,500.00 Late Charges $ 188.72 Escrow $ 310.96 Pro Rata MIP/ PMI $ 150.10 Other $ 110.50 Total $175,433.65 plus interest on the principal sum ($166,754.51) at the monthly interest rate of $694.81 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $175,433.65, with interest thereon at the monthly interest rate of $694.81 and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, Goldberg & Ackerman, LLC XFP-148131 ZUCKER, GOLDBERG & ACWRMAN, LLC BY: Dated: January 18, 2011 Scott A. Dietterick, Esquird; PA-I.D-#. Kimberly A. Bonner, Esquire; PA I.D. Joel A. Ackerman, Esquire; PA I.D. #2 Ashleigh L. Levy, Esquire; PA I.D. #31 Attorneys for Plaintiff XFP-148131 /mme 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-148131 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-148131 lgc 6 After Recording Return To: Settlement Services F 401 Brkich Way Suite #1 Xi_FN: CUSTOMja SERVICE Bridgewater, PA 15009 (800) 955-8965 Prepared By: ELISE MINTZER OCEANSIDE MORTGAGE COMPANY 615 LACEY ROAD FORKED RIVER, NJ 08731 (800) 955-8965 Property Address: 1825 SHEEPFORD ROAD MECHANICS BURG, PA 17055-6737 PIN: 13-27-1877-019 [Space Above This Line For Recording Dam) MORTGAGE STOCK Loan #: 20090877 MIN:100572400000015493 Case #: 441-908197 0-703 THIS MORTGAGE ("Security Instrument") is given on APRIL 24, 2009. The mortgagor is REBECCA A STOCK, A SEPERATED WOMAN ("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. ("MFRS") (solely as nominee for Lender, as hereinafter defined, and Lender's successors and assigns), as mortgagee. MFRS is organized and existing under the laws of Delaware, and has an address and telephone number of 11.0. Box 2026, Flint, Ml 48501-2026, tel. (888) 679-MFRS. OCEANSIDE MORTGAGE COMPANY ("Lender") is organized and existing under the laws of NEW JERSEY, and has an address of 615 LACEY ROAD, FORKED RIVER, NJ 08731. Borrower owes Lender the principal sum of ONE HUNDRED SIXTY NINE THOUSAND NINE HUNDRED ELEVEN Dollars (U.S. $169,911.00). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on MAY 1, 2039. This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MrRS the following described property located in CUMBERLAND County, Pennsylvania: SEE PRELIMINARY TITLE REPORT which has the address of 1825 SHEEPFORD ROAD, MECHANICSBURG. Pennsylvania 17055-6737 ("Property Address"); t'HA 11PNNSYLVANIA MORTGAGr:-05MI qE) 400.22 Pagc I of 8 r i zo49aa77 TOGETHER WITH the improvements now or hereafter erected on the property, and all casements, appurtenances, and fixtures now or hereafter a part of the properly. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument; but, if necessary to comply with law or custom, MERS (as nominee for Lender and Lender's successors and assigns) has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfidly seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENAN'T'S. Borrower and Lender covenant agrec as follows: 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due tinder the Note. 2. Monthly Payment of Taxes, Insurance, and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest.as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either. (i) a sutra for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the. sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow items in an aggregate amount not to exceed the maximum amount that may be required for Dorrowees escrow account tinder the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 el seq. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mongage insurance premium. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not sufficieni to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RE SPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of alt such sutras, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments FHA PENNSYLVANIA MORTGAGE . 05108 444.12 Page 2 of a 20090877 for items (a), (b), and (c). 3. Application of Payments. All payments under Paragraphs I and 2 shall be applied by Lender as follows: First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; Fourth, to amortization of the principal of the Note; and Fifth, to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance, Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall be include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in Paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in Paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circurstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. 11' lorrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. FHA PCNNSYLVANIA MORTGAGE-03108 400.12 Yagc 3 of It 20090977 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the'Note and this Security Instrument, first to any delinquent amounts applied in the order provided in Paragraph 3, and then to prepayment of principal. Any application of the proceeds to (lie principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness tinder the hate and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in Paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by Paragraph 2, or tails to perl'ornn any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in Paragraph 2. Any amounts disbursed by Lender under this Paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement at the Noce rate, and at the option of Lender shall be itntnediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien, or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary in the case of payment defaults, require immediate payment in lull of all sums secured by this Security instrument if: (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn-St Germain Depository Institutions Act of 1982, 12 U.S.C. 1701 1j- 3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if: (i) All or part of the Property, or a beneficial interest in a trust owing all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by.the purchaser or grantee as his or her principal FHA PENNSYLVANIA MORTGAGE - 05/08 4031 400.12 Page 4 of 8 300901377 residence, or the purchaser or grantee does so occupy the Property, but his or her credit has not been approved in accordance with the requirements of the Secretary. (c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to subsequent events. (d) Regulations oi' IiUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance tinder the National Housing Act within 60 days from the date hereof, Leader may, at its option, require immediate payment in fiull of all sutras secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary: 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security instrument and the obligations that is secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the Liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise: modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any Forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Cu-Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Burrower, subject to the provisions of Paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co- signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sutras secured by this Security instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the tern of this Security Instrument or the Note without that Borrower's consent. 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to FHA PENNSYLVANIA MORTGAGE. - 05/08 ® 400.12 Page 5 or 8 20090677 Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security instrument shall be deemed to have been given to Borrower or Lender when given as provided itt this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrtment and the Note are declared to be severable. 15. Borrower's Cully. Borrower shall be given one conformed copy of the Note and of this Security Instnut:ent. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, ttor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are-generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private parry involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that nny removal or other remediation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used iii the paragraph 16. "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environnrerital protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the.Property; and (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights tinder this Paragraph 17, Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at utty time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other Pt IA r'ENNSYLVANIA MORTGAGE - 05/08 4W 400.12 Page 6 of 9 20090077 right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may initiate foreclose by judicial proceedings and/or invoke any other remedies permitted by applicable law. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not Iimited to, reasonable attorneys' fees and costs of title evidence to the extent permitted by applicable law. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3751 c1 seq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waiver. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy of sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a Sheriffs sale or other sale pursuant to this Security Instrument. 22. Purchase Motley Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security instrument shall be a purchase money mortgage. 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were in a part of this Security Instrument. The Following Rider(s) are to be executed by Borrower and are attached hereto and made a part thereof [check box as applicable): © Condominium Rider O Growing Equity Rider O Adjustable Rate Rider 0 Planned Unit Development Rider O Graduated Payment Rider O Other(s) [specify) BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in pages l through 5 of this Securi lnstnt nt and in any ride s) executed by Borrower and recorded with it. vg - BORROWER - REBECCA A STOCK - DATE - FHA PENNSYLVANIA MORTGAGE - 05/08 ?1 400.12 Pap 7 of 8 20090877 STATE OF Tv Q COUN'T'Y OF C uJ?K lo4#"' la'$"W ttcluw On this the ? day of ?A ?1L before me, the undersigned officer, personally appeared known to me (or satisfactorily proven to be the person(s) whose name(s) are subscribed to the within instrument and acknowledged that he she/they executed the same for the purposes therein contained, in witness whereof, I hereunto set my hand and official seal. Notary is seNetoN Io uogFP098V 0JUVAJAsuued 'jegwaW 1. u algruePn0a uotsaunw0Ayy My Commission Expires: ? ? ?` C° C3 lI roJ puvpe4u;n3 "dFALOX q"%tse3 M%AA40N'Wm8 UeW iBeS My" VINVAUSNN3d d0 WV3MNOWW00 CERTIFICATE OF RESIDENCE: I do certify that the precise t dress of the within nat ed Mortgagee is 3300 S.W. 34th Avenue, Suite 101, Ocala, FL 34474 or . . x 2026, F' t, MI 43 02 . Signature: COMMONWEIALTH OF Agent on behall'ofMortgagee NftW Seal _ East Pavuboro MYCl TIAV#'CurtaWw 8#1119 Jan. 16, 2011 Member, PennWvanla AssoWation of No tortes PHA PLNNSYLVANIA MORTGAGE -05/08 4? 400.12 Page 8 of 8 SCHEDULE C ! EXHIBIT A PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN lot of land situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a brad in the center of Sheepford Road and line of lands now or late of Pearl G. Kinter; thence along said lands now or late of Kinter, South one (1) degree East a distance of thirty- nine and eighty- six one-hundredths (39.86) feet to a stone in line of lands now or late of John Hertzler; thence along said lands now or late of Hertzler North sixty-six (66) degrees forty-five (45) minutes West a distance of one hundred fifty and nine one-hundredths (150.09) feet to a stake in line of other lands now or late of Robert E. and Hattie R. Cline; thence along said lands now or late of Cline, North one (1) degree West a distance of thirty-nine and sixty-one hundredths (39.61) feet to a brad in the center of Sheepford Road; thence continuing across Sheepford Road and along lands now or late of Cline by the same course a further distance of two hundred ninety-three and nine one-hundredths (293.09) feet to a stake; thence continuing along said land now or late of Cline North eighty (80) degrees forty-one (41) minutes East a distance of one hundred thirty-eight and thirty one-hundredths (138.30) feet to a stake in fine of lands now or late of Earl G. Kinter; thence along said lands of Kinter South one (1) degrees East a distance of fifty-six and eighteen one- hundredths (56.18) feet to a stake; thence by the same lands now or late of Kinter South one (1) degrees East a distance of fifty-six and eighteen one-hundredths (56.18) feet to a stake; thence by the same lands and on the same course a distance of three hundred eighteen and thirty-one one- hundredths (318.31) feet to a brad in the center of Sheepford Road, the place of BEGINNING. The distance along the center of Sheepford Road, measured from brad to brad, measures a distance of 150 feet. The road mentioned in the foregoing description as Sheepford Road is also sometimes known as Sheep's Fording Road. 1 Being designated as parcel number 13-27-1877-019 VERIFICATION Esquire hereby states that he is attorney for Wells Fargo Bank, NA in this matter, ,it 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 he is authorized to make this verification pursuant to Pa. R. C. P. 1024 (c) and that the statements made in the foregoing pleading in the Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is the undersigned's intention to substitute verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Scott A. D''Ytterick, Esquire; Kimberly A. Bonner, Esquir Joel A. Ackerman, Esquire; Ashleigh L. Levy, F,squire? Attorneys for Plaintiff Dated: A I.D. #55650 PA I.D. #89705 A I.D. #202729 A I.D. #306799 Zucker, Goldberg & Ackerman, LLC XFP-148131 SHERIFF'S OFFICE OF CUMBERLAND COUNTY F_F? ?- Ronny R Anderson ?? Sheriff Jody S Smith FF ' 8 Chief Deputy -" ? ,"i Richard W Stewart ; ? kj is 11" Solicitor Wells Fargo Bank NA I Case Number vs. 2011-679 Rebecca A. Stock SHERIFF'S RETURN OF SERVICE 01/24/2011 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: Rebecca A. Stock, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Adams County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 01/28/2011 06:00 PM - Adams County Return: And now January 28, 2011 at 1800 hours I, James W. Muller, Sheriff of Adams 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: Rebecca A. Stock by making known unto Bruce Stock, Husband of defendant at 150 Dogwood Court, New Oxford, Pennsylvania 17350 its contents and at the same time handing to him personally the said true and correct copy of the same. 02/04/2011 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: Rebecca A. Stock, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Rebecca A. Stock. Request for service at 1825 Sheepford Road, Mechanicsburg, Pennsylvania 17055 is vacant. SHERIFF COST: $67.00 February 04, 2011 SO ANSWERS, RdddON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, , n - PENNSYLVANIA Wells Fargo Bank, NA, CIVIL DIVISION Plaintiff No.: 11-679-CIVIL VS. ISSUE NUMBER: 7. i Rebecca A. Stock TYPE OF PLEADING: Defendant(s). I Hereby certify that the last known address of Defendant(s) is/are: PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF: 150 Dogwood Court New Oxford, PA17350 J?td 4.. 4(a~ra`s Attorney for Plaintiff Wells Fargo Bank, NA Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa I.D.# 55650 Kimberly A. Bonner, Esquire Pa I.D. #89705 Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh L. Levy, Esquire Pa I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA Plaintiff, VS. Rebecca A. Stock Defendant(s). TO: PROTHONOTARY SIR/MADAM: CIVIL DIVISION NO.: 11-679-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant(s), Rebecca A. Stock, in the amount of $176,917.63 which is itemized as follows for failure to file an Answer: Principal $166,754.51 Interest through 03/05/11 $5,558.48 Attorneys' Fees $1,250.00 Title Search & Costs $2,500.00 Late Charges $ 283.08 Escrow $ 310.96 Pro Rata MIP/ PMI $ 150.10 Other $ 110.50 Total $176,917.63 plus interest on the principal sum ($166,754.51) from March 6, 2011, at the rate of $694.81 per month, plus additional late charges, and costs (including additional escrow a"ces), additional attorneys' fees and costs and for foreclosure and sale of the mort2aAd premises. _.C i ZUCKER, G BE C AN, LLC Dated: By: Scott A. D e erick? E P I.D. #55650 Kimberly . onner, Esquire; PA I.D. #89705 i Joel A. Ac an, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 pel. 14111. Gl) ? IGI rrvlGr ?? Atty File No.: XFP-148131 200 Sheffield Street, Suite 101 11t il lal C. J 7 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX ?, j n c?i ' ?1UT iV& Q Zucker, Goldberg & Ackerman, LLC XFP 148131 - AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, Kimberly A. Bonner, Esquire, Joel Ackerman, Esquire, Ashleigh L. Levy, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his/her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by?he attache. ZUCKER, By: Scott A. i ric , squ PA I.D. #55650 Kimberly, . Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 Atty File No.: XFP-148131 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX to and subscribed before me S day of March, 2011 is My Commission Expires: EDWJtRD J. $CHWAHt II Commission # 2383239 Notary Public, State of New Jersey My Commission Expires L4crrch 09, ZO1 4 Zucker. Goldberg & Ackerman, LLC XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, NO.: 11-679-CIVIL VS. Rebecca A. Stock Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Rebecca A. Stock 150 Dogwood Court New Oxford, PA17350 ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on Iy it h /7t di / l ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $176,917.63 plus interest on the principal sum ($166,754.51) from March 6, 2011, at the rate of $694.81 per month, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. onotary "Zucker, Goldberg & Ackerman, LLC XFP-148131 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff `?wtY ct Luinbcr Jody S Smith Chief Deputy ? ?4 , ,? \ 7 b Richard W Stewart Solicitor OFFICE OF THE VERIFF Wells Fargo Bank NA vs. Rebecca A. Stock Case Number 2011-679 SHERIFF'S RETURN OF SERVICE 01/24/2011 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: Rebecca A. Stock, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Adams County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 01/28/2011 06;00 PM'- Adams County Return: And now January 28, 2011 at 1800 hours I, James W. Muller, Sheriff of Adams 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: Rebecca A. Stock by making known unto. Bruce Stock, Husband of defendant at 150 Dogwood Court, New Oxford, Pennsylvania 17350 its contents and at the same time handing to him personally the said true and correct copy of the same. 02/04/2011 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: Rebecca A. Stock, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Rebecca A. Stock. Request for service at 1825 Sheepford Road, Mechanicsburg, Pennsylvania 17055 is vacant. SHERIFF COST: $67.00 SO ANSWERS, ZOO February 04, 2011 RONKW? R ANDERSON, SHERIFF (c) County5we Spent Teleoaon. Int. DATE RECEIVED DATE PROCESSED SHERIFF'S DEPARTMENTA ADAMS COUNTY, PENNSYLVANIA. .` COURTHOUSE, GETTYSBURG, PA 17325 NlsiTi!<ICTIOIISZ: Sea 'INSTRUCTIONS` FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF' on the revarw a ate lest (No. a of thi.•1orm..Pleaee PROCESS RECEIPT,, and AFFIDAVIT OF RETURN M" er a'"t1eg'*,k"ur'"g of °N 4P)W Do root detach any ooples. ACED BiV.r t. PLAINTIFFS/ 2. COURT NUMBER WELLS FARGO BANK N.A 2011-679 3. DEFENDANTS/ TYPE OF WRIT OR COMPLAINT: REBECCA A. SMCK 4.Taint in Mortgage Foreclosure $11111m 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO. SERVICE OR DESCRIPTION OF` PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Rebecca A. Stock 6. ADDRESS (Street or RFD, Apartment. No.. City, Boro, Twp., State and ZIP CODE) 150 Dog(ood Court; Nt3ta•'0Xford, "PA 7. INDICATE UNUSUAL SERVICE: O :PERSONAL O PERSON IN CHARGE O DEPUTIZE O CERT. MAIL O REGISTERED MAIL 0 POSTED O OTHER NOW, , I, SHERIFF OF ADAMS COUNTY; PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk-of the plaintiff. laHIEWF OF ADAMS COUNTY S. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any do" sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever Is found In possession, after notifying person of levy or attachment, without liability on the pan of such deputy or the sheriff to any plaiMMt herein for any lees, destruction or removal of any such property before sheriff's sale thereof. g. SIGNATURE of ATTORNEY or other ORKNNATOR requesting service on betak Of. 10. TELEPHONE NUMBER 11.. DATE ?I PLAINTIFF Scott A. Dietterick, Esq. ? DEFENDANT (717) 533-3280 FOR F.. R F _... .Y_., .: 12. h admowledge receipt a the writ SIGNATURE of Authorized ACSO Deputy or Clerk and Tito' 13.: Date fleoshred 14. Expiration / Hearing date or complaint as indicated above. 1/25/2011 15. 1 hereby CERTIFY and RETURN that 111 have personally served, 0. have, served person in charge, O have legal evidence of service as shown in "Remarks" (on reverse) 0 have pooled the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the indhridual, company, corporation, etc., at the address Inserted below by handing/or Posting a TRUE snd ATTESTED COPY therd. 10. O 1 hereby certify and return a NOT FOUND because I am. unable to Wale the individual, company, corporation. etc., named above. (See remarks below) 17. Name and tole of individual served pIrL A ps,sq d .wt?blr, OP end dk?ion Read Order Zld" er,,,; the dd?n0 8 UKW ? Bruce Stock, husband of Rebecca A. Stock 19. Address Of where served (001111114144 only If different than shown above) (Street or RFD. Apartment No., City. Boro, Twp., State and ZIP CODE) 20. Date of Service 21. Time 1/28/11 6:OOPM 22. ATTEMPTS I Dole I MNss I De h* I Dab MINs ?Dep.l"t. Date M. Advance Costa 24. 1 25. -1 26. Mite I DWIO. I Deb I W" I DRIP-ML I Data I 111111103 27. Toth Cops 29.70 Pd. 2/1/11 AFFIRMED and subaxbed to before me day " one S tz w PrW JAMES Wes. MULLER S FF OF ADAMS COUNTY 111114411111WR[ REFUND - .30 Ck. #26810 %28/2011 Deals 1/28/2011 I ACKNOM UMM RECEIPT OF THE sNI 111111 S rArrU N SGNATURE 39. Dab Received OF AUT HORIM MSUSIG AUTHORITY AND TITLE. PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA Plaintiff, CIVIL DIVISION vs Rebecca A. Stock TO: Rebecca A. Stock 150 Dogwood Court New Oxford, PA 17350 DATE OF NOTICE: 2/25/2011 NO.: 11-679-CIVIL IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA VS. Rebecca A. Stock Plaintiff, Defendant. TO: Rebecca A. Stock 150 Dogwood Court New Oxford, PA17350 CIVIL DIVISION NO.: 11-679-CIVIL I A;I K-':*] 1 T % ze Z' 4 : C U FECHA DEL AVISO:2/25/2011 LB= =A EN REBaELA PCRQUE; HA FALLADO M TCM4R LA ACCICIN F FU AA FN E= CASO A XEI ? QL.E LE= TCW ACICICN DE141M EE LUIS PREDMADS Lt¢ (K( ETAS I:E LA FDCIHA DE ESIE AVLSO, SE RJ E I[CTAR UNFALL ENCCNIRASCJYASNLLEVARSEACABDUI\iAVISTAYLMMPLUF PEK:ER SU MCFEECAD Y C URCS TES RVP=ANI& U= L? LLEVAR. E= DOCXAEN M EWMATAMENM A SU A13OC3ADQ S[ LMM NC IIENIE LN AEK)GADJ O NO PLEEE PAGAR L1VQ VAYA O LLAAC LA C HC H, A ABAJO P?EKCADA PARR CXIE LE IfgffC4V DCINLE PLEEE C7CI M AY -IDA T F1aq r4MCE-FODEME DBiLAVVVM SEEMGE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 ZUC1:4EP, GOLDBERG & ACXETC N BY Salt A Dlstbaidc Soon A Diextcrick Esquire Attameys far PI airmiff PA ID- # 55650 200 Shed d Street, Suite 301 P_ O Bcm 1024 Maurtaumde, M 07092-0024 (717) 533-3560 F= CIASS U. S- NfAIL, POSTAGE PREPAID 148131 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-679 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 REBECCA A. STOCK (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 $176,917.63 L.L.$.50 Interest 03/05/2011 TO DATE OF SALE $4,863.67 Atty's Comm % Atty Paid $199.50 Plaintiff Paid Date: 03117/2011 (Seas) REQUESTING PARTY: Name: JOEL ACKERMAN, ESQUIRE Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Due Prothy $2.00 Other Costs avid D. Buell, rothonotary By: Deputy Supreme Court ID No. 202567 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Wells Fargo Bank, NA, vs Rebecca A. Stock File No. 11-679-CIVIL Amount Due $176,917.63 Plaintiff, Interest from 03/05/2011 to date of sale $4,863.67 Costs Defendant. `? - "-j;" co • .. ;-ya rte, TO THE PROTHONOTARY OF THE SAID COURT: - M2• W T! The undersigned hereby certifies that the below does not arise out of a retail installment s ?7coni?ct of account based on a confession of judgment, but if it does, it is based on the appropriate original prsckding`]file pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or corkrol oftfiVsWga0r%e(s). ( (Indicate) Index this writ against the garnishee(s) as a lis pe?de?s t t/stk_t e fthe defendants) described in the attached exhibit. II V / DATE: March 14.2011 'V-7- G 0 ?/8G A ICJ. v o rl ?Ytt says Fc4i -7i-7 TI jL? Signature: v" Print Name: ScottlA. Esquire Kimb ly . Bonner, Esquire Joel Ac an, Esquire Ashleigh L. Levy, Esquire Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650 89705 202567 306799 dw & &W / L Lucker. 6A)bcm V Ackcrm,an. I.LC' XHP-1-18131 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A BRAD IN THE CENTER OF SHEEPFORD ROAD AND LINE OF LANDS NOW OR LATE OF PEARL G. KINTER; THENCE ALONG SAID LANDS NOW OR LATE OF KINTER, SOUTH ONE (1) DEGREE EAST A DISTANCE OF THIRTY-NINE AND EIGHTY-SIX ONE-HUNDREDTHS (39.86) FEET TO A STONE IN LINE OF LANDS NOW OR LATE OF JOHN HERTZLER; THENCE ALONG SAID LANDS NOW OR LATE OF HERTZLER NORTH SIXTY-SIX (66) DEGREES FORTY-FIVE (45) MINUTES WEST A DISTANCE OF ONE HUNDRED FIFTY AND NINE ONE-HUNDREDTHS (150.09) FEET TO A STAKE IN LINE OF OTHER LANDS NOW OR LATE OF ROBERT E. AND HATTIE R. CLINE; THENCE ALONG SAID LANDS NOW OR LATE OF CLINE, NORTH ONE (1) DEGREE WEST A DISTANCE OF THIRTY-NINE AND SIXTY-ONE HUNDREDTHS (39.61) FEET TO A BRAD IN THE CENTER OF SHEEPFORD ROAD; THENCE CONTINUING ACROSS SHEEPFORD ROAD AND ALONG LANDS NOW OR LATE OF CLINE BY THE SAME COURSE A FURTHER DISTANCE OF TWO HUNDRED NINETY- THREE AND NINE ONE-HUNDREDTHS (293.09) FEET TO A STAKE; THENCE CONTINUING ALONG SAID LAND NOW OR LATE OF CLINE NORTH EIGHTY (80) DEGREES FORTY-ONE (41) MINUTES EAST A DISTANCE OF ONE HUNDRED THIRTY-EIGHT AND THIRTY ONE-HUNDREDTHS (138.30) FEET TO A STAKE IN LINE OF LANDS NOW OR LATE OF EARL G. KINTER; THENCE ALONG SAID LANDS OF KINTER SOUTH ONE (1) DEGREES EAST A DISTANCE OF FIFTY-SIX AND EIGHTEEN ONE-HUNDREDTHS (56.18) FEET TO A STAKE; THENCE BY THE SAME LANDS NOW OR LATE OF KINTER SOUTH ONE (1) DEGREES EAST A DISTANCE OF FIFTYSIX AND EIGHTEEN ONE- HUNDREDTHS (56.18) FEET TO A STAKE; THENCE BY THE SAME LANDS AND ON THE SAME COURSE A DISTANCE OF THREE HUNDRED EIGHTEEN AND THIRTY-ONE ONE-HUNDREDTHS (318.31) FEET TO A BRAD IN THE CENTER OF SHEEPFORD ROAD, THE PLACE OF BEGINNING. CONTAINING 1.05 ACRES ON THE NORTH SIDE OF SHEEPFORD ROAD AND 0.12 ACRES ON THE SOUTH SIDE OF SHEEPFORD ROAD, THE ENTIRE TRACT CONTAINING 1.17 ACRES. THE DISTANCE ALONG THE CENTER OF SHEEPFORD ROAD, MEASURED FROM BRAD TO BRAD, MEASURES A DISTANCE OF 150 FEET. THE ROAD MENTIONED IN THE FOREGOING DESCRIPTION AS SHEEPFORD ROAD IS ALSO SOMETIMES KNOWN AS SHEEP'S FORDING ROAD. THIS DESCRIPTION IS MADE ACCORDING TO A SURVEY BY D. P. RAFFENSBERGER, REGISTERED SURVEYOR, ON MAY 29, 1956. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1825 SHEEPFORD ROAD, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH ESTHER L. SCHAMBACH, SINGLE PERSON„ BY DEED DATED AUGUST 28, 2008 AND RECORDED OCTOBER 31, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT# 200835658, PAGE, GRANTED AND CONVEYED UNTO REBECCA A. STOCK, ADULT INDIVIDUAL. TAX MAP NO.: 13-27-1877-019. Zucker, Goldberg & Ackerman. LLC XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, CIVIL DIVISION - -'= =::?: 7Z Plaintiff, NO.: 11-679-CIVIL vs. Rebecca A. Stock `- Defendant. ° -.? AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, NA, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 1825 Sheepford Road, Mechanicsburg, PA 17055. 1. Name and Address of Owner(s) or Reputed Owner(s): REBECCA A. STOCK, ADULT INDIVIDUAL 150 Dogwood Court New Oxford, PA 17350 2. Name and Address of Defendant(s) in the Judgment: REBECCA A. STOCK 150 Dogwood Court New Oxford, PA 17350 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, NA Plaintiff /.uckix GOldhi-rs+ & Ackerman. H (' XI P-I4NI')I 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, NA Plaintiff MERS AS A NOMINEE FOR OCEANSIDE MORTGAGE COMPANY PO Box 2026 Flint, MI 48501-2026 AND 615 Lacey Road Forked River, NJ 08731 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 1825 Sheepford Road Mechanicsburg, PA 17055 UNKNOWN SPOUSE 150 Dogwood Court New Oxford, PA 17350 Zucker. Goldberg & \c:kcrmaji. LLC XIT-1-48131 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and co ect to the best of my personal knowledge, information and belief. I under and th a s is herein are made subject to the penalties of 18 Pa.C.S. §4904 relating .Ian o 1 i to authorities. ZUCKER L B AN, LC Dated: ` BY: Scott A. ettick, Esquire, P I.D. #55650 Kimberly nner, Esquire; PA.I.D. #89705 Joel A. Ac an, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-148131 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com /ut;kix, (?olcll7trsz & Rckcrm3n, I I (' X1 N-1-4N131 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A BRAD IN THE CENTER OF SHEEPFORD ROAD AND LINE OF LANDS NOW OR LATE OF PEARL G. KINTER; THENCE ALONG SAID LANDS NOW OR LATE OF KINTER, SOUTH ONE (1) DEGREE EAST A DISTANCE OF THIRTY-NINE AND EIGHTY-SIX ONE-HUNDREDTHS (39.86) FEET TO A STONE IN LINE OF LANDS NOW OR LATE OF JOHN HERTZLER; THENCE ALONG SAID LANDS NOW OR LATE OF HERTZLER NORTH SIXTY-SIX (66) DEGREES FORTY-FIVE (45) MINUTES WEST A DISTANCE OF ONE HUNDRED FIFTY AND NINE ONE-HUNDREDTHS (150.09) FEET TO A STAKE IN LINE OF OTHER LANDS NOW OR LATE OF ROBERT E. AND HATTIE R. CLINE; THENCE ALONG SAID LANDS NOW OR LATE OF CLINE, NORTH ONE (1) DEGREE WEST A DISTANCE OF THIRTY-NINE AND SIXTY-ONE HUNDREDTHS (39.61) FEET TO A BRAD IN THE CENTER OF SHEEPFORD ROAD; THENCE CONTINUING ACROSS SHEEPFORD ROAD AND ALONG LANDS NOW OR LATE OF CLINE BY THE SAME COURSE A FURTHER DISTANCE OF TWO HUNDRED NINETY- THREE AND NINE ONE-HUNDREDTHS (293.09) FEET TO A STAKE; THENCE CONTINUING ALONG SAID LAND NOW OR LATE OF CLINE NORTH EIGHTY (80) DEGREES FORTY-ONE (41) MINUTES EAST A DISTANCE OF ONE HUNDRED THIRTY-EIGHT AND THIRTY ONE-HUNDREDTHS (138.30) FEET TO A STAKE IN LINE OF LANDS NOW OR LATE OF EARL G. KINTER; THENCE ALONG SAID LANDS OF KINTER SOUTH ONE (1) DEGREES EAST A DISTANCE OF FIFTY-SIX AND EIGHTEEN ONE-HUNDREDTHS (56.18) FEET TO A STAKE; THENCE BY THE SAME LANDS NOW OR LATE OF KINTER SOUTH ONE (1) DEGREES EAST A DISTANCE OF FIFTYSIX AND EIGHTEEN ONE- HUNDREDTHS (56.18) FEET TO A STAKE; THENCE BY THE SAME LANDS AND ON THE SAME COURSE A DISTANCE OF THREE HUNDRED EIGHTEEN AND THIRTY-ONE ONE-HUNDREDTHS (318.31) FEET TO A BRAD IN THE CENTER OF SHEEPFORD ROAD, THE PLACE OF BEGINNING. CONTAINING 1.05 ACRES ON THE NORTH SIDE OF SHEEPFORD ROAD AND 0.12 ACRES ON THE SOUTH SIDE OF SHEEPFORD ROAD, THE ENTIRE TRACT CONTAINING 1.17 ACRES. THE DISTANCE ALONG THE CENTER OF SHEEPFORD ROAD, MEASURED FROM BRAD TO BRAD, MEASURES A DISTANCE OF 150 FEET. THE ROAD MENTIONED IN THE FOREGOING DESCRIPTION AS SHEEPFORD ROAD IS ALSO SOMETIMES KNOWN AS SHEEP'S FORDING ROAD. THIS DESCRIPTION IS MADE ACCORDING TO A SURVEY BY D. P. RAFFENSBERGER, REGISTERED SURVEYOR, ON MAY 29, 1956. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1825 SHEEPFORD ROAD, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH ESTHER L. SCHAMBACH, SINGLE PERSON„ BY DEED DATED AUGUST 28, 2008 AND RECORDED OCTOBER 31, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT# 200835658, PAGE, GRANTED AND CONVEYED UNTO REBECCA A. STOCK, ADULT INDIVIDUAL. TAX MAP NO.: 13-27-1877-019. Zucker. Goldberg & Ackerman, L.L:C XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, vs. Rebecca A. Stock Plaintiff, Defendant. CIVIL DIVISION NO.: 11-679-CIVIL J '? -' Ctr .. . i a 13 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Rebecca A. Stock 150 Dogwood Court New Oxford, PA 17350 AND 1825 Sheepford Road Mechanicsburg, PA 17055 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 09/07/2011 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 1825 Sheepford Road, Mechanicsburg, PA, 17055 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-679-CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Rebecca A. Stock Zucker, Goldberg & Ackerman, LLC XFP-148131 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker, Goldberg & Ackerman, LLC XFP-148131 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberlapd-.,County Courthouse, One Courthouse Square, Carlisle, PA 13-3387, petition to the Court. I I Dated: c.3 S 1 6 ZUCKER on of the LLC BY: Scott A. tt , Esquire; A I.D. #55650 Kimberly onner, Esquire; PA.I.D. #89705 Joel A. Ac an, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-148131 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XFP-148131 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A BRAD IN THE CENTER OF SHEEPFORD ROAD AND LINE OF LANDS NOW OR LATE OF PEARL G. KINTER; THENCE ALONG SAID LANDS NOW OR LATE OF KINTER, SOUTH ONE (1) DEGREE EAST A DISTANCE OF THIRTY-NINE AND EIGHTY-SIX ONE-HUNDREDTHS (39.86) FEET TO A STONE IN LINE OF LANDS NOW OR LATE OF JOHN HERTZLER; THENCE ALONG SAID LANDS NOW OR LATE OF HERTZLER NORTH SIXTY-SIX (66) DEGREES FORTY-FIVE (45) MINUTES WEST A DISTANCE OF ONE HUNDRED FIFTY AND NINE ONE-HUNDREDTHS (150.09) FEET TO A STAKE IN LINE OF OTHER LANDS NOW OR LATE OF ROBERT E. AND HATTIE R. CLINE; THENCE ALONG SAID LANDS NOW OR LATE OF CLINE, NORTH ONE (1) DEGREE WEST A DISTANCE OF THIRTY-NINE AND SIXTY-ONE HUNDREDTHS (39.61) FEET TO A BRAD IN THE CENTER OF SHEEPFORD ROAD; THENCE CONTINUING ACROSS SHEEPFORD ROAD AND ALONG LANDS NOW OR LATE OF CLINE BY THE SAME COURSE A FURTHER DISTANCE OF TWO HUNDRED NINETY- THREE AND NINE ONE-HUNDREDTHS (293.09) FEET TO A STAKE; THENCE CONTINUING ALONG SAID LAND NOW OR LATE OF CLINE NORTH EIGHTY (80) DEGREES FORTY-ONE (41) MINUTES EAST A DISTANCE OF ONE HUNDRED THIRTY-EIGHT AND THIRTY ONE-HUNDREDTHS (138.30) FEET TO A STAKE IN LINE OF LANDS NOW OR LATE OF EARL G. KINTER; THENCE ALONG SAID LANDS OF KINTER SOUTH ONE (1) DEGREES EAST A DISTANCE OF FIFTY-SIX AND EIGHTEEN ONE-HUNDREDTHS (56.18) FEET TO A STAKE; THENCE BY THE SAME LANDS NOW OR LATE OF KINTER SOUTH ONE (1) DEGREES EAST A DISTANCE OF FIFTYSIX AND EIGHTEEN ONE- HUNDREDTHS (56.18) FEET TO A STAKE; THENCE BY THE SAME LANDS AND ON THE SAME COURSE A DISTANCE OF THREE HUNDRED EIGHTEEN AND THIRTY-ONE ONE-HUNDREDTHS (318.31) FEET TO A BRAD IN THE CENTER OF SHEEPFORD ROAD, THE PLACE OF BEGINNING. CONTAINING 1.05 ACRES ON THE NORTH SIDE OF SHEEPFORD ROAD AND 0.12 ACRES ON THE SOUTH SIDE OF SHEEPFORD ROAD, THE ENTIRE TRACT CONTAINING 1.17 ACRES. THE DISTANCE ALONG THE CENTER OF SHEEPFORD ROAD, MEASURED FROM BRAD TO BRAD, MEASURES A DISTANCE OF 150 FEET. THE ROAD MENTIONED IN THE FOREGOING DESCRIPTION AS SHEEPFORD ROAD IS ALSO SOMETIMES KNOWN AS SHEEP'S FORDING ROAD. THIS DESCRIPTION IS MADE ACCORDING TO A SURVEY BY D. P. RAFFENSBERGER, REGISTERED SURVEYOR, ON MAY 29, 1956. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1825 SHEEPFORD ROAD, MECHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH ESTHER L. SCHAMBACH, SINGLE PERSON„ BY DEED DATED AUGUST 28, 2008 AND RECORDED OCTOBER 31, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT# 200835658, PAGE, GRANTED AND CONVEYED UNTO REBECCA A. STOCK, ADULT INDIVIDUAL. TAX MAP NO.: 13-27-1877-019. Zucker, Goldberg & Ackerman. LLC XFP-1 38131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA,', jPlaintiff, vs Rebecca A. Stock CIVIL DIVISION NO.: 11-679-CIVIL TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE Defendant. OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, NA COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh Levy Marin, Esquire- PA I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoIdberg.com C:- File No.: XFP- 148131/dsc -0 1 Ua rr ?~- i M _- r Ar -- ?, r CD C7 "^w -?- -T7 C*) ? C C= b -i r, - Zucker, Goldberg & Ackerman, LLC XFP-148131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, CIVIL DIVISION Plaintiff, : NO.: 11-679-CIVIL vs. Rebecca A. Stock Defendant. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, NA, being duly sworn according to law depose and make the following Affidavit regarding he service of Plaintiffs Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Rebecca A. Stock, adult individual, is the record owner of the real property. 2. On 'pr about May 26, 2011, Rebecca A. Stock, adult individual was served with Plaintiffs Notice of Sheriff's (Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at 150 Dogwood Court, New Oxford, PA 17350. A true and correct copy of said Notice and Proof oflService are marked Exhibit "A", attached hereto and made a part hereof. 3. On for about July 22, 2011, Plaintiff's counsel served all other parties in interest with Plaintiff's Notice oflSheriff's Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage ?re-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, LLC XFP-148131 Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of interest were served with Plaintiff's Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG & ACKERMAN, LLC Dated: July 28, 201 Sworn o nd subscribed before meths day of July, 2011 i? Ntsfary Pub c MY COMMISSION E*PIRES: 8HEREZA DEMARINI Nolary Pub0c of Now J41 D# 240 261 My Commisision Expires V Zucker, Goldberg & Ackerman, LLC XFP-148131 Paralegal/Legal Assistant EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-148131 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??u? of Eanrbrr?y? OFFMIE OF THE SWRIFF ----- -- - I Wells Fargo Bank NA i,lf Case Number vs. Rebecca A. Stock 2011-679 05126/2011 Ronny R. Ande inquiry for the u in his bailiwick. Notice and Des 05/2612011 The requested Adams County Answers: Jerer SHERIFF COST: $907.94 May 26, 2011 SHERIFF'S RETURN OF SERVICE son, Sheriff, being duly sworn according to law, states that he made a diligent search and thin named Defendant, to wit: Rebecca A. Stock, but was unable to locate the Defendant le therefore deputized the Sheriff of Adams County to serve the within Real Estate Writ, ription, in the above titled action, according to law. teal Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of )pon Rebecca A. Stock, personally, at 150 Dogwood Court, New Oxford, PA 17350. So y Becker, Deputy, Sheriff. SO ANSWERS, RON R ANDERSON, SHERIFF 4 _ (c) CountySuite SherM, TeI903M, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Banks NA, Plaintiff, vs. : CIVIL DIVISION NO.: 11-679-CIVIL Rebecca A. Stock Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO YLVANIA RULE OF CIVIL PROCEDUI Rebecca A. St k 150 Dogwood C ourt New Oxford, P 17350 AND 1825 Sheepford oad Mechanicsburg, A 17055 TAKE NOTICE;: That e Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 09/07/2011 at 0:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of statement of the measured boundaries of the property, together with a brief mention Of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A") LOCATION of your property to be sold is: 1825 Sheepford Road, Mechanicsburg, PA, 17055 The JI DGMENT under or pursuant to which your property is being sold is docketed to: No. 11 THE ?AME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY RE: Rebecca A. Zucker, Goldberg & Ackerman, LLC XFP-148131 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the! sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthous Square, Carlisle, PA 17013-3387. It has b en issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. if you wish to exercise your rights, you must act promptly. SP Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: GO TO I. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered, Zucker, Goldberg & Ackerman, LLC XFP-148131 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of CumberlanCounty. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached t the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberl County Courthouse, One Courthouse Square, Carlisle, PA I 13-33.187, ore resentation of the petition to he Court. I l Dated: V ZUCKER BY: X k6w) Scott A. tt , Esquire; A I.D. #55650 Kimberly . onner, Esquire; PA.I.D. #89705 Joel A. Ac an, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-148131 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg. com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND 1 PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. , LLC Zucker, Goldberg & Ackerman, LLC XFP-148131 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT, OR LATE OF PEARL G.1 ONE (1) DEGREE EAST, FEET TO A STONE IN Ll LANDS NOW OR LATE WEST A DISTANCE OF STAKE IN LINE OF OTE ALONG SAID LANDS N, THIRTY-NINE AND SIX SHEEPFORD ROAD; TH OR LATE OF CLINE BY THREE AND NINE ONE, SAID LAND NOW OR L, EAST A DISTANCE OF ( FEET TO A STAKE IN L LANDS OF KINTER SOI ONE-HUNDREDTHS Of KINTER SOUTH ONE (1 HUNDREDTHS (56.18) F COURSE A DISTANCE ( (318.31) FEET TO A BR7 BRAD IN THE CENTER OF SHEEPFORD ROAD AND LINE OF LANDS NOW INTER; THENCE ALONG SAID LANDS NOW OR LATE OF KINTER, SOUTH DISTANCE OF THIRTY-NINE AND EIGHTY-SIX ONE-HUNDREDTHS (39.86) 4E OF LANDS NOW OR LATE OF JOHN HERTZLER; THENCE ALONG SAID ?F HERTZLER NORTH SIXTY-SIX (66) DEGREES FORTY-FIVE (45) MINUTES ?NE HUNDRED FIFTY AND NINE ONE-HUNDREDTHS (150.09) FEET TO A ER LANDS NOW OR LATE OF ROBERT E. AND HATTIE R. CLINE; THENCE ?W OR LATE OF CLINE, NORTH ONE (1) DEGREE WEST A DISTANCE OF `Y-ONE HUNDREDTHS (39.61) FEET TO A BRAD IN THE CENTER OF NCE CONTINUING ACROSS SHEEPFORD ROAD AND ALONG LANDS NOW SHE SAME COURSE A FURTHER DISTANCE OF TWO HUNDRED NINETY- HUNDREDTHS (293.09) FEET TO A STAKE; THENCE CONTINUING ALONG TE OF CLINE NORTH EIGHTY (80) DEGREES FORTY-ONE (41) MINUTES NE HUNDRED THIRTY-EIGHT AND THIRTY ONE-HUNDREDTHS (138.30) NE OF LANDS NOW OR LATE OF EARL G. KINTER; THENCE ALONG SAID TH ONE (1) DEGREES EAST A DISTANCE OF FIFTY-SIX AND EIGHTEEN 18) FEET TO A STAKE; THENCE BY THE SAME LANDS NOW OR LATE OF DEGREES EAST A DISTANCE OF FIFTYSIX AND EIGHTEEN ONE- EET TO A STAKE; THENCE BY THE SAME LANDS AND ON THE SAME F THREE HUNDRED EIGHTEEN AND THIRTY-ONE ONE-HUNDREDTHS D IN THE CENTER OF SHEEPFORD ROAD, THE PLACE OF BEGINNING. CONTAINING 1.05 AC S ON THE NORTH SIDE OF SHEEPFORD ROAD AND 0.12 ACRES ON THE SOUTH SIDE OF SHEEP FORD ROAD, THE ENTIRE TRACT CONTAINING 1.17 ACRES. THE DISTANCE ALONG THE CENTER F SHEEPFORD ROAD, MEASURED FROM BRAD TO BRAD, MEASURES A DISTANCE OF 150 FEET . THE ROAD MENTIONED IN THE FO REGOING DESCRIPTION AS SHEEPFORD ROAD IS ALSO SOMETIMES KNOWN AS SHEEP'S F RDING ROAD. THIS DESCRIPTION IS DE ACCORDING TO A SURVEY BY D. P. RAFFENSBERGER, REGISTERED SURVEYOR, ON MAY 2 , 1956. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1825 SHEEPFORD ROAD, M CHANICSBURG, PA, 17055. BEING THE SAME PREMISES WHICH ESTHER L. SCHAMBACH, SINGLE PERSON„ BY DEED DATED AUGUST 28, 2008 AND RECORDED OCTOBER 31, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT# 200835658, PAGE, GRANTED AND CONVEYED UNTO REBECCA A. STOCK, ADULT INDIVIDUAL. TAX MAP NO.: 113-27-1877-019. Zucker, Goldberg & Ackenim, LLC XFP-113131 EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-148131 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, CIVIL DIVISION vs. Rebecca A. Stock TO: UNKNOWN TENANT I 1825 Sheepford Road Mechanicsburg, PA 1 COMMONWEALTH O DEPARTMENT OF WE P.O. Box 2675 Harrisburg, PA 1710E Plaintiff, Defendant(s). NO.; 11-679-CIVIL NOTICE TO LIENHOL ERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) 1R TENANTS UNKNOWN SPOUSE 150 Dogwood Court 7055 New Oxford, PA 17350 PENNSYLVANIA PA DEPT. OF REVENUE- INHERITANCE TAX .FARE DIVISION Dept. 280601 Harrisburg, PA 17128-0601 CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County ourthouse One Courthouse Squ re Carlisle, PA 17013 MERS AS A NOMINEE FOR OCEANSIDE MORTGAGE COMPA Y PO Box 2026 Flint, M148501-2026 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 MERS AS A NOMINEE FOR OCEANSIDE MORTGAGE COMPANY 615 Lacey Road Forked River, NJ 08731 TAKE NOTICE hat by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public ale in: the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 On 09/07/2011 at 10: am, the following described real estate which Rebecca A. Stock, adult individual are the owners or rep ted owners and on which you may hold a lien or have an interest which could be affected by the sale o 1825 Sheepford Road, Mechanicsburg, PA 17055 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"), Zucker, Goldberg & Ackerman, LLC XFP-148p] 1 148131DI004CO713201iPI s The said Writlof Execution has been issued on a judgment in the action of Wells Fargo Bank, NAI Plaintiff Rebecca A. Stock, et vs. Defendant(s) at EX. NO, 11-679-ClV IL in the amount of $176917.63 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to pro?eeds must be made with the office of the Sheriff before distribution, l Schedule of istribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date, i Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments wit regard tot heriff's Sale or this Notice, you should contact your attorney as soon as possible. ZUCKER, GO B WC ,LLC Dated U BY: Scott A. Di t Brick, uir P I.D. #55650 Kimberly nner, Esquire; PA I.D. #89705 Joel A. Ack Varin, an, Esquire; PA I.D. #202729 Ashleigh L. Esquire; Pa I.D. #306799 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 File No.. XFP-148131 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-148131 148131D1004C07132011P2 Exhibit "A" LEGAL DESCRIPTION ALL THAT ERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING LANDS NOW OR Li OF KINTER, SOUTI ONE-HUNDREDTH HERTZLER; THEN( (66) DEGREES FOR AND NINE ONE-HL OR LATE OF ROBE LATE OF CLINE, Nt ONE HUNDREDTH! THENCE CONTINU CLINE BY THE SAb AND NINE ONE-14L SAID LAND NOW C MINUTES EAST A I 1UNDREDTHS (13 E KINTER; THENCE f DISTANCE OF FIFT THENCE BY THE S, A DISTANCE OF FE THENCE BY THE S. HUNDRED EIGHTE THE CENTER OF ST AT A BRAD IN THE CENTER OF SHEEPFORD ROAD AND LINE OF .TE OF PEARL G. KINTER; THENCE ALONG SAID LANDS NOW OR LATE ONE (1) DEGREE EAST A DISTANCE OF THIRTY-NINE AND EIGHTY-SIX (39.86) FEET TO A STONE IN LINE OF LANDS NOW OR LATE OF JOHN E ALONG SAID LANDS NOW OR LATE OF HERTZLER NORTH SIXTY-SIX "Y-FIVE (45) MINUTES WEST A DISTANCE OF ONE HUNDRED FIFTY VDREDTHS (150.09) FEET TO A STAKE IN LINE OF OTHER LANDS NOW .T E. AND HATTIE R. CLINE; THENCE ALONG SAID LANDS NOW OR ?RTH ONE (1) DEGREE WEST A DISTANCE OF THIRTY-NINE AND SIXTY- (39.6 1) FEET TO A BRAD IN THE CENTER OF SHEEPFORD ROAD; NG ACROSS SHEEPFORD ROAD AND ALONG LANDS NOW OR LATE OF IE COURSE A FURTHER DIS'T'ANCE OF TWO HUNDRED NINETY-THREE NDREDTHS (293.09) FEET TO A STAKE; THENCE CONTINUING ALONG R LATE OF CLINE NORTH EIGHTY (80) DEGREES FORTY-ONE (41) ISTANCE OF ONE HUNDRED THIRTY-EIGHT AND THIRTY ONE- 30) FEET TO A STAKE IN LINE OF LANDS NOW OR LATE OF EARL G. LONG SAID LANDS OF KINTER SOUTH ONE (1) DEGREES EAST A ?'-SIX AND EIGHTEEN ONE-HUNDREDTHS (56.18) FEET TO A STAKE; kME LANDS NOW OR LATE OF KINTER SOUTH ONE (1) DEGREES EAST TYSIX AND EIGHTEEN ONE-HUNDREDTHS (56.18) FEET TO A STAKE; MME LANDS AND ON THE SAME COURSE A DISTANCE OF THREE ,N AND THIRTY-ONE ONE-HUNDREDTHS (318.31) FEET TO A BRAD IN EEPFORD ROAD, THE PLACE OF BEGINNING. CONTAINING 1.05 CRES ON THE NORTH SIDE OF SHEEPFORD ROAD AND 0.12 ACRES ON THE SOUTH SIDE F SHEEPFORD ROAD, THE ENTIRE TRACT CONTAINING 1.17 ACRES. THE DISTANCE ALONG THE CENTER OF SHEEPFORD ROAD, MEASURED FROM BRAD TO BRAD, MEASURES DISTANCE OF 150 FEET. THE ROAD MENTIONED IN THE FOREGOING DESCRIPTION AS SHEEPFORD ROAD IS ALSO SOMETIMES KNOWN AS SHEEP'S FORDING ROAD. THIS DESCRIPTION IS MADE ACCORDING TO A SURVEY BY D. P. RAFFENSBERGER, REGISTERED SURVEYOR, ON MAY 29, 1956. HAVING THERIEON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1825 SHEEPFORD ROAD, MECHANICSBURG, PA, 17055. BEING T DATED AUGUST 28, i PENNSYLVANIA, IN D UNTO REBECCA A. S1 TAX MAP NO. E SAME PREMISES WHICH ESTHER L. SCHAMBACH, SINGLE PERSON„ BY DEED 08 AND RECORDED OCTOBER 31, 2008 IN AND FOR CUMBERLAND COUNTY, =D BOOK VOLUME INSTRUMENT# 200835658, PAGE, GRANTED AND CONVEYED ADULT INDIVIDUAL. 13-27-1877-019. Zucker, Goldberg & Ackerman, LLC «Field2»-<< Field 1» Field 1)0 1004C02/ 12/2008P3 Page 1 of 4 NOTICE TO LIENHOLDERS UNI Pt?S ED STATES AL SERVICE. This Certificate of huring provl and International mail. Fr°m, Scott A. Die evidence that mall has been presented to USPSa for mailing. This terick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffiel d Street, Suite 101 Mountainsi de, NJ 07092 XFP-148131/sde TEAM C To: UNKNOWN 1825 Sheep Mechanicsb TENANT OR TENANTS ford Road urg, PA 17055 County o P.Q.: CUMBERLAND PS Farm 3817, ill I??I UNI V??A AVS This Certificate of Mailing provk and international mail. From: Scott A. Die pril 2007 PSN 7530-02-000-9065 ED, STATES /JL ERVICE4 - s evidence that mall has been presented to USPSa for mailing. This form maybe used for domestic terick, Esquire c/o Zucker, oldberg & Ackerman, LLC 200 Sheffiel d Street, Suite 101 Mountainsid e, NJ 07092 XFP-14813 1/sde TEAM C TO; COMMONW DEPARTME P.O. Box 267 Harrisburg, - EALTH OF PENNSYLVANIA T OF WELFARE 5 A 17105 I _ County of P.Q.: CUMBERLAND PS Form 3817, A II I I I li pril 2007 PSN 7530-02-000-9065 P F`04S7' . zw...?s..? 42genowne, pffw*. BMW" 02 1M $ 01.150 0004282036 JUL22 2011 MAILED FROM ZIPCODE 07092 Postmark Here OS Kok ? :¦aIM??o°o?mv Prasurv -vvtz 02 1M 0004282036 ? 072 1O 0 MAILED FROM ZIPCODE 0 7092 .? ?? p,1NStp? 1y ? 6 Here 41 Page 2 of 4 NOTICE TO LIENHOLDERS 4;-0 PN' AMMOMM-OW UNI V POs Thfc Certificate of Mailing prwM and irtarnatbnal mail. Scott A. Die ED STATES L SERVICES s evidence that mall has been presented to LISPS- for mailing: terick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffiel d Street, Suite 101 Mountainsi de, NJ 07092 XFP-148131/sde TEAM C T°` CUMBERLA Cumberland One Courth Carlisle, PA ND COUNTY TAX CLAIM BUREAU County Courthouse use Square 17013 County o P.Q.: CUMBERLAND PS Form 3817, ; I UNI POS .. V?a %pril 2007 PSN 7530-02-000-9065 ED STATES raw, ZL SERVICES This Con1 iab of Malting prov' and international mall. From: Scott A. Die s evidence that mall has been presented to USPS- for mailing. This form may ba used for domestic terick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffiel d Street, Suite 101 Mountainsi e, NJ 07092 XFP-148131/sde TEAM C TO: MERS AS A PO Box 202 Flint, MI 48 NOMINEE FOR OCEANSIDE MORTGAGE COMPANY 01-2026 1 County o P.Q.: CUMBERLAND PS Form 3817, 'I 11 I I pril 2007 PSN 7530-02-000-9065 ?aaaaaaaanIw PIAafY WrAEs 02 1M $ 01-150 0004282036 JUL22 2011 MAILED FROM ZIPCODE 0 7092 Postmark Here rtseW r ?r MWEY twvoFs )2 1M $ 01.150 )004282036 JUL 22 2011 NAILED FROM ZIPCODE 0 7092 pJNSlD i Here JUL 2 2 2011 ?"pS - 0`70 I ,• Page 3 of 4 NOTICk TO LIENHOLDERS UNI ,. V?w cos ED STATES aL SERVrCEa Thls Cartificata of MaNing prov s evidence that mail has been presented to USPse for madins, Thu form maybe used for domesti, and international ma H. hom; Scott A. Die terick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffiel d Street, Suite 101 Mountainsi e, NJ 07092 XFP-148131/sde TEAM C T°` MERS AS A NOMINEE FOR OCEANSIDE MORTGAGE COMPANY 615 Lacey R oad Forked Rive r, NJ 08731 County o P.Q.: CUMBERLAND PS Form 3817, I Il pril 2007 P5N 7530-02-000-9065 i UNI ED STATES C AO L SERVICES A This Conifloate of Malin` prow es evldenp that mail has been pmsented to USPSa for mailing, una iv-, nvy .. w.? ?, wmw,a and Internatlonal me 1. Pr°m` Scott A. Di terick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffiel d Street, Suite 101 Mountainsi e, NJ 07092 XFP-148131/sde TEAM C To: CUMBERLA D COUNTY DOMESTIC RELATIONS OFFICE Domestic R lations Section 13 N. Hano ver Street PO Box 320 Carlisle, PA 17013 County o P.Q.: CUMBERLAND PS Form 3817, I pril 2007 PSN 7530-02-000-9065 aF 02 1M $ 01.150 0004282035 JUL 22 2011 MAILED FROM ZIPCODE 0 70 92 Postmark Here 9?P PC% O 5 smear OKYrm l2 1M $ 01.150 004282036 JUL 22 2011 RAILED FROM ZIPGODE 0 7092 ,/ jPJNS/p 11, 2 2 2011 \s-07% . -1 Page 4 of 4 NOTICE TO LIENHOLDERS UNI V,?,POS 'w. 7i? ED STATES ? ,. 1 , L SERVICEin Th Is Certificate of Malang proof and international rfall. rrom: Scott A. Die es ed me that mail has been presented to U595e for mailing. This form may be used for domestic terick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffie ld Street, Suite 101 Mountainsi de, NJ 07092 _ XFP-14813 1/sde TEAM C To: PA DEPT. O Dept., 2806 Harrisburg, F REVENUE- INHERITANCE TAX DIVISION 01 PA 17128-0601 County o P.Q.; CUMBERLAND PS Form 3817, II! UN POS April 2007 PSN 7530-02-000-9065 ti TED STATES f /1L SERVICES This Certificate of Maliing or- and international mail From: Scott A. Di des evidence that mail has been presented to US9Se for mailing. This form may be used for domestic tterick, Esquire c/o Zucker Goldberg & Ackerman, LLC 200 Sheffie ld Street, Suite 101 Mountains ide, NJ 07092 XFP-148131/sde TEAM C To: UNKNOWN 150 Dogwo New Oxfor SPOUSE od Court d, PA 17350 County o f P.Q.: CUMBERLAND PS Form 3817 i , April 2007 PSN 7530-02-000-9065 g?pS PIN, _i PITNEY BOWES 02 1M $0 1.150 0004282036 JUL 22 2011 i MAILED FROM ZIP CODE 0 70 92 'ostmark Mere N 0110S P ru as , .ae®as1-w 9 vnv ? ?s ? nre+Ev 02 W $ 01.15° 0004282036 JUL 22 2011 MAILED FROM ZIP CODE 0 7082 AIN Postmark ere J IL, 2 2 2011 JSf'S _ 07 a% a y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriffakttttp at tua,Gi?r,?? Jody S Smith Chief Deputy' 2 M '0J Richard W Stewart Solicitor F?E? e?Pt'a?35`f" Wells Fargo Bank NA Case Number vs. 2011-679 Rebecca A. Stock SHERIFF'S RETURN OF SERVICE 05/26/2011 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: Rebecca A. Stock, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Adams County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 05/26/2011 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Adams County upon Rebecca A. Stock, personally, at 150 Dogwood Court, New Oxford, PA 17350. So Answers: Jeremy Becker, Deputy, Sheriff. 06/23/2011 06:11 PM - Deputy Shawn Gutshall, 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 1825 Sheepford Road, Mechanicsburg, PA 17055, Cumberland County. 09/08/2011 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, Cumberland County, PA on September 7, 2011 at 10:00 a.m.. He sold the same for the sum of $1.00 to Attorney Joel Ackerman, on behalf of, Wells Fargo Bank, N.A., of, 3476 Stateview Blvd, Fort Mill, SC 29715, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,208.23 October 21, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ?/? ?? P ? • act. j - coo 'f"4 - C&, C 39 5,7s -)- G, 6,t// y ci Coun ySui[o hen'f. Teeosof,. In::. On May 11, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 1825 Sheepford Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 11, 2011 By: Real Estate Coordinator -?iL . CUMBERLAND LAW JOURNAL Writ No. 2011-679 Civil Wells Fargo Bank NA . vs. Rebecca A. Stock Atty.: Joel A. Ackerman ALL THAT CERTAIN lot of land situate in the Township of Lower Al- len, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a brad in the center of Sheepford Road and line of lands now or late of Pearl G. Kinter; thence along said lands now or late of Kinter, South one (1) degree East a distance of thirty-nine and eighty- six one-hundredths (39.86) feet to a stone in line of lands now or late of John Hertzler; thence along said lands now or late of Hertzler North sixty-six (66) degrees forty-five (45) minutes West a distance of one hun- dred fifty and nine one-hundredths (150.09) feet to a stake in line of other lands now or late of Robert E. and Hattie R. Cline; thence along said lands now or late of Cline, North one (1) degree West a distance of thirty-nine and sixty-one hundredths (39.61) feet to a brad in the center of Sheepford Road; thence continuing across Sheepford Road and along lands now or late of Cline by the same course a further distance of two hundred ninety- three and nine one- hundredths (293.09) feet to a stake; thence continuing along said land now or late of Cline North eighty (80) degrees forty-one (41) minutes East a distance of one hundred thirty-eight and thirty one-hundredths (138.30) feet to a stake in line of lands now or late of Earl U. Kinter; thence along said lands of Kinter South one (1) degrees East a distance of fifty-six and eighteen one-hundredths (56.18) feet to a stake; thence by the same lands now or late of Kinter South one (1) degrees East a distance of fiftysix and eighteen one hundredths (56.18) feet to a stake; thence by the same lands and on the same course a dis- tance of three hundred eighteen and thirty-one one-hundredths (318.31) feet to a brad inthe center of Sheep- ford Road, the place of beginning, Containing 1.05 acres on the north side of Sheepford Road and 0.12 acres on the south side of Sheepford Road, the entire tract containing 1.17 acres. The distance along the center of Sheepford Road, measured from brad to brad, measures a distance of 150 feet. The road mentioned in the foregoing description as Sheepford Road is also sometimes known as Sheep's Fording Road. THIS DESCRIPTION IS MADE ACCORDING TO A SURVEY BY D. P. RAFFENSBERGER, REGISTERED SURVEYOR, ON MAY 29, 1956. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1825 SHEEP- FORD ROAD, MECHANICSBURG, PA, 17055. BEING the same premises which Esther L. Schambach, single person, by deed dated August 28, 2008 and recorded October 31, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume Instrument* 200835658, Page, granted and con- veyed unto Rebecca A. Stock, adult individual. TAX MAP NO.: 13-27-1877-019. 63 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: July 15, July 22 and July 29, 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 Coyn , Editor SWORN TO AND SUBSCRIBED before me this 9 da of Jul 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 CARLISLE PA 17013 t4t Patti* ot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement 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 uehaii 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. This ad ran on the date(s) shown below: 07/15/11 07/22/11 07/29/11 n Sworn to and s ribed befor me this 8 y August, 2011 A.D. C, _ Notary P`` lic COMMONWEALTH OF PENNSYLVANIA Al Notarial seal Sherrie L Klsner, iNotary Public LLower Paxton T ' Dauphin t I e Commission County Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries 11 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 Wells Fargo Bank N.A. is the grantee the same having been sold to said grantee on the 7 day of September A.D., 2011, under and by virtue of a writ Execution issued on the 17 day of March, A.D., 2011, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 679, at the suit of Wells Fargo Bank N.A. against Rebecca A. Stock is duly recorded as Instrument Number 201129283. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this r9C day of A.D. L? `/Recorder of Deeds *GWAWM 6*nft tkltU=hro1Jn=4