HomeMy WebLinkAbout11-2179i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSY
I?
'AMA '' {
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WELLS FARGO BANK, N.A., CIVIL DIVISION cTa 'ar*i
Plaintiff, NO.:
vs. ?v T?w ca~*?
TYPE OF PLEADING
LESTER E. PARIS ?.
CIVIL ACTION - COMPLAINT - '
Defendant. IN MORTGAGE FORECLOSURE
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
525 Bosler Avenue
Lemoyne. PA 17043
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFE CTED BY THIS LIEN IS
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS
PARTY:
ZUCKER, GOLDBERG &
ACKERMAN, LLC
Scott A. Dietterick, Esquire
Pa. I.D. #55650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
Joel A. Ackerman, Esquire
Pa I.D. #202729
Ashleigh L. Levy, Esquire
Pa I.D. #306799
ATTY FILE NO.: XFP 149577
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldberg.com
File No.: XFP- 149577/rj
s ?a2:b° ?a any
C 1-7
Oa$?
Zucker, Goldberg & Ackerman, LLC
XFP-149577
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-149577
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.,
Plaintiff,
CIVIL DIVISION
NO.:
vs.
Lester E. Paris
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 LAWYER REFERRAL
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., : CIVIL DIVISION
Plaintiff, . NO.:
vs.
Lester E. Paris
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 notificacion 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 LAWYER REFERRAL
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
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., : CIVIL DIVISION
Plaintiff, : NO.:
vs.
LESTER E. PARIS
Defendant.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg &
Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Wells Fargo Bank, N.A., having its principal place of business at 3476
STATEVIEW BLVD., MAC # X7801-013, FT. MILL, SC 29715.
2. The Defendant, Lester E. Paris, is an individual whose last known address is 525
Bosler Avenue, Lemoyne, PA 17043.
3. On or about January 18, 2008, Lester E. Paris executed a Note in favor of Cardinal
Financial Company, LTD. in the original principal amount of $152,250.00.
4. On or about January 18, 2008, as security for payment of the aforesaid Note, Lester
E. Paris made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee
for Cardinal Financial Company, LTD. a Mortgage in the original principal amount of $152,250.00 on
the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder
of Deeds of Cumberland County on January 30, 2008, Instrument #200802972. 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 Cardinal Financial Company, LTD. to Wells Fargo Bank, N.A., plaintiff
herein, pursuant to an assignment of mortgage to be recorded.
6. Lester E. Paris, single person is the record and real owner of the aforesaid mortgaged
premises.
Zucker, Goldberg & Ackerman, LLC
XFP-149577
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. Plaintiff was not required to send Defendant(s) written Notice pursuant to 35 P.S.
§1680.403 (c) (Homeowners' Emergency Mortgage Assistance Act of 1983, - Act 91 of 1983), prior to
commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal
Housing Administration under Title II of the National Housing Act (12 U.S.C. §§1707 - 1715(z) - 18)
[35 P.S. §1680.401(x)(3).].
9. Plaintiff was not required to send Defendant(s) written notice of Plaintiffs intention to
foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this
action for the reason that the original principal balance of the aforesaid Mortgage is more than the
original principal balance threshold of the Act, and therefore:
(a) said Mortgage is not a "residential mortgage" as defined in 41 P.S. §101;
(b) the Defendant(s) is/are not "residential mortgage debtor(s)" as defined in 41 P.S. §101,
and;
(c) the mortgage premises is not "residential real property" as defined in 41 P.S. §101.
10. The amount due and owing Plaintiff by Defendant is as follows:
Principal $147,880.18
Interest through 03/01/2011 $7,394.00
Attorneys' Fees $1,250.00
Title Search & Costs $2,500.00
Late Charges $ 44.53
Escrow $ 55.40
Pro Rata $ 119.28
Other $ 50.50
Total $159,293.89
Zucker, Goldberg & Ackerman, LLC
XFP-149577
plus interest on the principal sum ($147,880.18) at the monthly interest rate of $739.40, 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 $159,293.89, with interest thereon at the monthly interest rate of $739.40 plus
additional late charges, and costs (including additional escrow advances), additional attorneys'
fees and costs and for foreclosure and sale of the mortgaged premises.
Zucker, Goldberg & Ackerman, LLC
XFP-149577
ZUCKER,GOLD
Dated: February O', 2011
BY:
Scott A.
Attorneys for Plainti
& ACKERMAN, LLC
PA I.D. #55650
Kimberly A. Bonner, Es i e; PA I.D. #89705
Joel A. Ackerman, Es ire. PA I.D. #202729
Ashleigh L. Levy, E uire PA I.D. #306799
XFP-149577/rj
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-149577
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP-149577
•? t 97,,
Pad By:
Lht wm H Z
444 JACKS s4VTLLt ROAD
UNINU !!t'IM, RR 19074
800-327-0080
Return To:
KcymwcCkwada scuuwem
Savior, t.LC
341 Sdmu Prrk ROW
Seto Co4m P 16M
FarCd Wt Ober 12-21-0265-204
Premises: 525 DWUM AV==
L8MXMM, Ph 17043
?/oa
ISpaw Cammanweaitb Of peaesytvardtt , This L ho 14? aasr?aa Dsty
,. rft
MORTGAGE L441-9147059-703
310019810 WN 100092200000175081
TIM MORTGAGE ("Saowrity Insduntrt") is giver an AM= 18TH, 2008
The Mas*pr is Ls8 1 R. pma
("DoWww"). This Security Instrument 1s given to Mortgage Ei Worjc Reg oadon Symems, Inc.
("MERE"). (soidy as nominee tbr I.enddw. as bereinafler ddlac t, and Landa'a sucsass0as nai assrgnns), as
mortgagee. MERS is one and existing under the taws of Dekv % and has on W&M and tetapbooo
mambos of P.O, Bova 2026, Flint, MI 48501.2026, ter. (888) MM Mt&
C71FDDUM !mPJKmm Comm=, I.'A'1r. v11tt'.F!Mt1;M =v
(""Landee) is organized and eatisft wxar the taws of Tt03 amocam I m or mawnv1 $, and
balm address of 444 JACKSON WA ROt4D, to MUBT8R, PA 18974
Waters Kkr^w Ruined ftMass
VMPS-+4NIPA) Ai Aftomk*LJM
ho.14110 .11.
Borrower owns Lander the principal sew of on P7y1's TWO %%DVX Z1A '8M
l htZD rxrzr AM tan/100. Doom (U.S. S 152,250.00
).
'this debt is evidenced by Bom Web's not bated do same date as this Security limnaneoot (Note"), which
provide fbr monthly payments, with the ibll dabs, if not paid earlier, due and payable an
rXXW MY IST, 2038 . This Security Instrument socuraa; to Lender: (a) the
rghaymaht of the debt cvaionved by the Note, with interest, and at renewals, anterior and modifications
of the Moto. (b) the payment of aft other sums, with int met, advanced under pamamph 7 to protect the
security of this Sea ity lastrunwrat; and (c) the pa 6tmance of Borrowers coverams and agreements
under this Security irattrumort and the Nate. For this purpose, Borrower don ban6y mortgage, gent and
cormy to IiMti (solely a no nine ftr Lander and Lando? a successors and assign) and to the atxcosaws
end assigns of MERS, On Mowing described property located in COMMA=
C.aa .I'eraeuyivanb;
s?1G tatriLls 7?L r?Litt:RIfS'2t7si
which bas the address of 538 8a'3t zxR AV7CtrtZ Puftol
('Property ") S.TiIOna PWJ, Pspnsylvan a 17043 JZ* OWL
TOMTHER WITH all the imprhvemenra now or hangar erodes! an the property, and all
eamets. appuctmaness and fixtures row or hereafter a pert of the ptopeety. All replacements and
additions abaft shp ye covered by this Security ha trumeut. All of die forsgoieg is of nud to in this
Sexuni(y Instrument es the'Ph4orly." Borrower understands and agrees !tree MM holds only bate the
to the snterctts aroused by Bummer in this Security Instrument: but if nay to comply with law or
cudom, MERE. (as nominee for leader aid Laahdw's succovan and assigns), bas this righk to wneviae
any at all of thaw intos shk including, but not liorited to. do right to foradara sad sail the Y, and
to take my notion rehired of Lender including, but not limited to. miessing or caroming this gnawky
Instrument,
BMOWER GOVENAM'S that Burrower is tow,louy mind or the estate hereby convoyed and has
the right to inahtgage, Want and can"# the Property and that Ibe Ptoperty is unencumbered. a mul t for
encumbrances of m oonk Borrower warrants and will defEtA generally the tide to the Prrparty agaim all
claim and demands, atrb* to any vocumbrances of vocas .
THIS SECURUY IMTRUM W comb no uniflmn cowa umtt fix national use and non-ura m.
covenants with limited variations by jtaisdlotion to constitute a unifbmr security instrument covering real
property-
VMP04N1PAt aosnnan as. a a to
Borrower and Lander eavenent and wpm as foilcws:
UNWRM COVENANTS.
1. Pmymemt of Priotdpad, Interest end Late Cl arga. Bormwer shell pay when duo the principal oL
and interest am the dudrt evidenced by the Nato and hda chasPS due urader tba Nab.
2. Monthly Peymsat of Taxes, Iammuce and Other Charges. Borrower abeal include in each
monthly payment, together wide the principal and interest asset forb in the Note and any lane dbw^ a
sum for (a) taxes and spacial assessments levied or to be levied sonst the Property, (b) lowhold
payments or ground rents an the Property, and (e) premiums :for insurance required under paragraph 4. In
any year in which the Larder a mst pay a mortgage iattrrpace pre, mium to the Secralaty of Homing and
Urban Development ("Secretary"). or in any year in which such premium would hsve boom nquirsd if
Lender still held the Security Instrument, each monthly payment shall also include ehber. (j) a =rn for the
annual mortgage insurance premium to la paid by Larder to the Sexotery, or (9) a monthly ebwp instead
of a nmrtgsge insunauee premium if this Security Instrummnt is held by the Saavtary, in a nameable
amount to be determined by the Secretary. Except for to monthly ebuV by the Secreisty, these items are
called "F,aeow Item" and do auras paid to Leader arc called "Eatwty Funds."
Lender may, at arty thee, collect and hold armor Rot Eaorow Items in an aggregate smtoaat am to
exceed the maximum amount that may be taqukW fbr Barnmeft -mcmw amt under the Real Essue
5cWmnr A Pmccdwo Act of 1974, 12 U.S.C. Section 260 t of nq, and imps a gated eft , 24 CFR
Part 3300, as they may be smanded fmm tuns to time ("RESPA•), except that the tuddon or reserve
permitted by RNPA fb r unanticipated disbutsemartts or dabuturrumls beftme the BwwwWs prtrmas are
¦vr Wk in the rcovat may not be based on muotants duce for the me ire premium,
If the amatumts held by Larder for Escrow Item eared the amounts peter to be held by RWA,
Lender *0 arc unt to Borrower lbr the excess fbad s sa respired by PMPA. If the amour of lands bald
by Loder at any time arc not sefflcient to pay the Baorow Items w1am due, Lender may notify the
Borrower and require Borrower to make up the shortage aspmmited by RESPA.
The P.retoar Funda ate phxtRedas elditionsl security for all sartn roomed by this Security Inwament.
If Bor mwet tenders to Lender the lbil payment of all snob stoma, Bonmwa a account :died be Grad rod with
the balance mminitl for ad installment itema (a), -(b), sand (c) and my marigage insentace pn=Wm
ixaftlimett that Leader bas not become obligated to pay to the Secretary, sad Lender sball promptly nAW
any exam Faris to Borrower. Immediately prior to a finclosam ae of the Pmpc* at its acquWdon by
Lender, Bwmwex4 account " be credited with airy balance remaining fur; all Inslailm ends for items (a),
(b), acrd (c).
3. AppQcadm of Payments. All paymmb under pvvAppiax I and 2 shall be applied by Leader as
follows:
First. to the rrm[tgage Insurance premium to be pail by Lender to the Seeretay or to do mamthly
cberge by the Secretary instead of the monthly mortgage insurance premium.,
Smand. to my tares, special asussmardt, loseWd payments or grnmtrd teens, and fire, flood and
other hasmd iaacnramao premiun* sa enquired;
WA to interest due under the Nola;
Pooch. to a of clot of the prinew of the Note; end
FlAh. to law charges doe under the Note.
4. Am Flood mad Other Hard Insurance. Borrower shall imsare all improvements on the
Property, whether now in existence or smbsegmcnntly erected, against any hato>ds, costudOes, rind
comtirW acies, including fin, Ibr which Lender ses}uires iatmurmoL We insurance shah be maintained in
T
" ,_
VMPOAW(PA) w a ins a . sw eo
the anwwttc and leer the perms that Lender mequbes.. Borrower dal alms iasum ag improvements on the
Prop M, wbedw now in eriance or sub iluenmdy csachd, against lost by floods to the eattant regained
by the Secretary. All iream ence doll be ;xmr cal with oaaapearhies opprov by Looder. The insurance
policies and any renewals sboll be held by Lander and shall iucludo loss payablo olso in favor of, and in
a lbnu acceptable to, Land.
ro do event of logs, Borrower fish give Lander immediate notice by nail. Lanier any make pro" of
ieass if not made promptly by Borrower. Each insurance company concamcd is hereby wtidmind and
directed to make payment for such toss dvacely to taodcr. irvdcad of to Borrower and to Lander jointly,
All or my part of the insurance proceeds may be applied by Lardor, at its opdor4 either (a) to the
reduction of the indebtedoom under the Note and this Security tr str rwk first In any dolhquent amounts
applied in the order in paragraph 3, and them to prepayment of principal, or (b) to the reaftntiun or repair
of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone as
due date of the monthly payments which are rofmcd to in paragraph 2, or change the amount of such
paym Cnk Any extxm instnurce proceeds over an amount required to pay all outstanding indebtedness
under the Note and this Sacterity Insbunsant shall be paid to to entity legally anddod thereto.
In the event of fbredossre of this Security Inst oment or other Water of tip to the Property that
extinguishes the iodefinodaass, all right, title and interest of Borrower in end to imam um policies in Amx
she, pass to the pardraser.
5. Occopmey, Pressrudea, Mabtananee sus Preteetbo of dw Properly; Borrower's Loco
? oWs. Sotrovrer alhath orxup}', es4hlish. and we tba "sorrorra4 principal
rpadanca wrthim slaty days afar rho esecnstion of this $eermity InaWmemt tbio oixw days of a later
snk or danathr o[ rho Proparty? arrd shell ooMinsna m ocarpy rho as Batroweea principal
fix at boat aria year afiecr the date of ocatrpanc?y, unbss Loader datsrtni a dW melulroment will
crtnse tnhdue batddrip fbr Bartower, unless eatanadng exist which ate bcymrd
Barwre['s ctartral. Bonnvrar ales, notify Lender of any cis . Borrower shall to
a?nrrit waala derdrny, damrhge or suDaluntirdhy the Amtparty or allow the hapedy to deteriorate,
rereasaeabhe weer and tear . Lc+Kter may imgrax the Prrrperty ii the Property is vacant or xboadomed
the east is in daAunit I?sadar may halos re>aonabkr action b psotect seal preserve such vacat or
ebaradorned PropmRy. Hotrawer sielt also be ire default i[ Barovver, timing the loam Applicalion p',
gave materially 5dra or inaccurate imtrrrnaton a to Lender (? gded to provide Leader with
arty rnattadah irhiEamation) in cxarmectiae wits the large ewidmgcad by fiat Note, but rat IWW to,
I a Soaowms shall with ssioas o asap tfam Wor sevires
es
the iroperty, the lld and tl eA trot bit tuttass Lert+er agree to the merger
in Mille%
IL Cbndemcsdem The proceeds of any sword or claim br damages, direct or consexpentiol, in
connection wilt any mxk m s*m or other taking of any pact of the Pm>pwtiy, or lbr conveyance in place
of caedamos30m, no hereby ndgned and wits, be paid to Landes' to ft este d of the lilt amount of the
proc cells to the reduction of do lnunder the Note and this Security debaa imsa made .tla Note and thislrahtro e m Inaba shit, apply such
dolimquont amounts applied in the order provided In ilk ft* to guy
paragraph 3, end Nma to prepayment of principal, Any
application of the proceeds to the principal shall not extend or padpooe tba due daft of the mton ty
payments, which are rcfamd to in paragraph 2, or ebsoge the amount of such payments. Any excess
pnoceods over an ammrmr t required to pay all outstanding lnddmodnsss ender the Note and this Security
lratrumcot shall be paid to the entity legally entitled thereto,
i
VMP6 4NtPAl tweet PW 4 a ra
Z Charge to Borrsrnrr and Pretwilet err Leader's Wgbts In then Property. Borrower shell pay all
govenunentai or mrtaicipa l cbargea, Runs and unposidama do are not included in paragraph 2. Borrower
dull pay thaw obiipotut on *Ae directly to the witty which is owed the payment. If tlhitae to pay mould
adversely affix* Landm% inherent In &a Prepmty, open Lender's nquad Harrower shall promptly ibmieh
to Lenten reaaipts rAlcuoing these payments.
If Bonawar tells to mate then: payments or the payments recptbed by pram 2, or fails to
art, ? tiara is a lalpti
tber caovmuttris and eonained in this leeteaity IrutranhE
may aigriSazaotly sfNrat Leoder'a tights in the (svc6 ss a praeieading
re darn or to enforce lawat tine tegutstiadt), gxtt Lethdx rosy do and psy whamva a
rotect He vahue of the Property utd Ltettdar's rights in tIs: Property, including payment of
curd Oder ttans mentioned in ph 2.
ff9ff2RR;WM
Any aatanm dlabvaaed by Lander under this parsgaph shall become an additional dada of Hdnrower
and be wa trod by this Seetnity lostrut cut. These etnotma gall brae Intarrau 9mm the data of
didausement, at the Note vx t, sad at do option of Leader, shalt be irmne diately dale and payable.
Bonewe' shall promptly discharge any Un which boa priority ewer this Security Instramgtt uneat
Borrows (a) vV= in writing to the psynrant of the ~on moved by the liar is a m aoaapfabfs
to Loder, (b) conksts to good to tb the lien by, or detects ageirut akwnent of the lien in, I%d
raccodings whiab in the Latdees opinion operate to prevent the mtibrostud of the lime; or (o) segues
firm the holder of the liar an.. ormoad eetieli terry to Larder sabrddbutiog the lien to this Security
butrwont. If Lardar detaa daim`d ua my part of 6* Property is sabject to a fiat which may attain pr1o ty
am this Security Ism. Leader may give Borrower a notice idattikyft thus live. Borrower droll
satisfy the ft or tare one or rmre of do adieus an theft above veltbhh 10 days of the giving of antlae
9. Yom Leader may collout f#x end d bargasttuftnind by the Seadary.
4. Grenada hr Aeadterattaa of Dobt.
(a)1Tat WL Lowder anryr except aalimited -fry rega a issued by the Sammy, in the case of
po<ymm defiatlet, require immediate payment in NO of alt alma secured by this Security
Instlum tttit
(i) Boeowerdefimlts by ttltog to pay to full any mondhty pyyment required by this Security
InsIrtm eat prior to or an de due date of the next monthly payeteen4 or
(it) Borrower debautg by fdihhg, the it pared of thirty days, to perkm any other ofts ions
contained to this Seerity Iasaumont.
(b) Bob VAdmut Credit Approval. Lander shall. if pormitted by applicable law (iaduding
Baction 34I(d) of the Cao,& Germain Depository lootiutions Act of 1492. 12 UAC.
1701]-s(4)) and with the prior appowal of the Saeemy, require ranoedim paynaot in full of all
sums Arad by ibis Security inanumant it
(t) All or rout of the PropoW, or it ho aaGcisi interest in a beat rah i ft aN or part of the
Prepetty, Is sold or odenwise traaafinrad (otber than by devise or descestj and
(ii) The Property Is not occupied by the purAie er at Statues as his or her principal residence
or the purchaser or View dome so oacopy the PropmW but Isla or her atroaNt bas not bow
rpprovad in eacordso a with deia ragttirogena of the Secretary.
(e) Ito Wstrer. It cirvamstancea oocur that would permit Lender to nxpuim immediaffi pays eut in
till, but Leader does not tequits such payn ents, Lender dotes not waive its rigits with respetx to
atbsequeW events.
VMPO-4NPV anw al Np 3.1 tO
(d) Regolatloax of MM Secretary. In many ameiaastaooec regabratan issued by dw $mobsq
w1i thstit I. d s shirts, in the am otpaya art dWWol t, to rogtdm inumm ere payment is Ibll
and lbr daft If not paid. 1U Stamity Instrtimreat does sat authorim accetwWon or foreclosure
if not permitud by mgukdons of the Secretary.
(a)1M artpge Not L9sarod. Btarower opm that If this Security Instrument grad the Note are not
dem mined to be crgpble for iasaura ce under the Nadonal Hand" Act widdn 60 days am me
dote beseof. Lawlor rmty, at its optictk rop#c kmoodiato payment in dull of all steps secured by
this Security bwtu sent. A written aunt of any sollsorLzed Mot of the Seorebry dated
subsequent to 60 days ilwn tba date bmarot; declining to Invare this Seetsrity bud ument and the
Note, sled be deemed canalosive proof of such IndigIbiiity. NctwkbsWmiag hiss S»+egoing, this
option may not be cxacmd by Leader whau doe un vellobilby of insu=res is solely due to
Lender's Blum to ra=fts mortgage insttretaae prernium to Its Secretary.
Int. ant Borrower has aright to be tebusteted if Lewder has requites immediate payrrteat
in fait beamass of Borrower': Whom to pay _an smound doe under the note or this Security losirgand. ibis
right applies; ever atler mutt VmcvodiW are irab uteri. To reline the Security lns ment,
Bummer stall tender in a hm* wars all amanurts required to bating Borrower's MCOURt conUd Including,
to the ode they are ob?igatim of Barmww odder this Seca ty Instrument, t tttt coats end
reasonable and custanmy altomeW ibex and expenem properly -a laled with dw tbredlown proaaedtpg.
Upon min memmd by Bonower, this Sw riW Irsrtrmomtf and the obKjdkm dud It seem= shall remain
in eflbot as it Leader bad not requirad inatatdiaac payment in MI. However, Louder is not regohed to
permit reinstetmwm ie (I) I.wAw leas accepted m mat atlsr that conancoccament of fuselosxae
proceedings widdo two years invoedlatety pteoeding the ocaummoccount of a aorvent finec?osue
Proceeding 00 anent will p echtde Itawk um an dill rom pounds in the llrttre, or (lit)
rninatatdnantwifl adversely atl6ct the prior* of the tan aaatel by this Security Iaarumcut.
I I. Borrower Not Relat Wl Forbearance By Lender Nit a Walm. Extoaaion of the time of
payment or modiecstion of anordestioo of tlia sons sommd by this Securby b3dmment J> by Lender
to any successor in Interest of Borrower shall ra tmanm to release die UA01ty of she o dOW Bwrower or
Bwsoww's successor in Iatuaest Leader stall not be ttgokW to communes prom ? against arty
atmcessor in interest or rrstim to contend thole lkw pgmmt at otbm^reise modify ammdaaition of the stuns
somired by thus Sm o ty Inshnnmsrt by reason of arty dehraiad rnedo by due orio* Bmt+ower or Donowe!:
su s In lommiz Amy fmbowv= by Lender In eaencidng any tight or n m* stall not be a waiver
of or preclude do exwcli m of any right or temody.
IL Saecesems and Amalgam Rotund; "t and Several LWARty C*O pm The oovmw& and
agraw,ertto of Skis Security In hours st stall bind and bwwfd the sucommors stud ssa4m of Leader and
B , $**ct to due pnrA; orss of puvgmph 9(b) Boreonvice a aria mos. end agmements doll be jolat
and several. Any Harrower wbo cm-ribs this Smmty Iutrrsnont but sloes out vaccuto iho Note: (a) is
co-signing this Security IasEtrnriw only to motwim grant end convey *a Borrowws interest in tk
Property under doe thanes of this Security Instrument (b) is Out personally ahliSmed to pay the sums
secured by tbia Security Instrument; and (e) ai{rees thou herder and any other Borrower may agree to
extend. madilyr forbear or make any acaorrnaadatlwta whb segerd to the terms of this Smutty bwwnarrt
or the Note witrortthat BmrowcA consent
bftft Kul"
VMPSANIPA) rowm.oi rw a m 10
13. Notlew, Any notice to Borrower provided fbr in this Security brspvnrnt shall be glean by
delivering it or by nwvft it by first class mail unless applicable law ragnirea use of another enathod. The
notice sbail be directed to the Property Address or any other address Renewer designates by notice to
Lander. Any notice to Lander shall be given by first also mail to Gander's addtart owed bereht or any
address Lander designa by notice to Bolrowar. Anynodoe provided fbr in this Seaaft shall
be dexmed to bwm been given to iBeasowar or Lender when giver as provided in *6 paragraph;
14. Goverehtg Late, Seve rrbilky. This Sacruity I t shall be governed by Federal, low and
the lair of tha judadiation in which the Proparly Is located. Its the avant that any pmvWm or abous; of this
Security Ir sournant or the Note conflicts with applicable law, such coofilet shall not aftet other provisions
of this $conity Instrusnent. or the Note which can be given afhat without the conflicting preywoo, To this
and the provisions of this Security Instnnnant and the NOW are declared. tD be severable,
13. Barrewer's Copy. Bon:owee shall be given otne coofertned copy of the Now end of this Security
bxuw=L
A HisSardows Substances. Boneww shall no cam or parmit the presenink new, disposal, storage,
or raleess of any Musidow Substanoes on or In the Property. Borrower sball not do, tar allow anyone
else to do, anything affiedng alto Property tbet,is in violadon,of any RevIreseneeral Law. ra uatnipnacss?ng
two semances tail rho apply to the presence, UM or amp on tl o ?' of small qt W of
Haurdous Bubstahaas that are generally recognised to be appropreda to namal niskisaW was and to
maintenance of tie Propaty,
Renewer shall pmmpdy give Lander written notice of any investigation, cubit, demand, lawaait or
other nation by any govttsMCWAI ar regulatory ageaey er lx{tnsta patty involving the Froporty and any
Hasatdous Substance or Bnvis oruncrital Law of which Borrower has actual knowledge, it Stamm karm,
or is entitled by any govisrionatical or ragablGry, aulhoril% dial any renumal or other renseryiatian a any
Hazardous Substances affecting the Property is ruiaunry, Borrower shall promptly take all tamestry
reaudfai actim in accordance, with Buviromantal Law
As and hi this paragraph lb, "Haa?dos s Substances" are those substom defhoed as W,* or
lanudtwn snbatancas by Environmental Law and the fbilavwing substances: gawsotbne, kerosans, other
llarrimblo or mxic petrbeum products, bur pesticides and babicides, volatile aolvontst, matermh
containing asbersoa or fomadds hyde, and Tadlow0va mistaiais. As used in this paragraph 16,
'linvis'orunanal Law" mans Wend laws and kws of the jurisdiction whore the Property is located that
ralsto to beeilh, sate y ot'CnYlretltrMtnlal promotion.
NON41NffORM COVF1IATf'M Bonawat andLander Nrdw covering and agree a follows:
17. AmIganwat of Rents, Borrower unconditionally assig is and biuaafem to Lander an the mats and
revenues of the Pro". Borrower autb+aias Latter or Le nerlr *gob to uebaa the mab and mycouse
and hereby d Ws awb anew of to Property to pay the mots to Lander or Lenndsx'a ago" Howssm,
prior to Leaular's notice to Borrower of Borrowar't breach of any cavenanl or apeemsnt in flub 3atarity
Imo, Benowcr shall collet and rewtvc all rasa and reversese of the Property as trustee for the
benefit of Lender and Borsawer Ibis essigammht of ram constitutes an absohtte assignment and not an
a ORNA f'br additenai security only.
It Larder Sivas notice of breach to Borrower (a) all rents received by Borrower shall be hall by
Borrower as trufte for benefit of Lends only, to be applied to the summa secured by 4be Security
kwuntnant: (b) Lender shall he entitled to collect and receive all of the rents of the property, and (c) each
-.4-1
VMP04NO tWIMA% pop 7of to
tenant of on Ptepetty shell pay all rents due and unpaid to Lesade r or Leader's agent on hander's wriam
thermal to the Lanett.
Bonvww basaot executed any prior asaig mmmt of the rents and has not and wig not pufmm- any act
that would prevent Lender from t icing its rights under ibis pwovv* 17.
Loretta' shall no be required to eater upon, take control of or maintain the Property befhrt or altar
giving notice of branch to Burrower. How"Or. Lender er a judicially appointed ramah er mey do ma at any
time these is a breech. Any application of teats stall not cure or waive any de th ar invalidate any omen
right or remedy of Leader. ibis anhfgarneat or rents of the Property shall terminate when the debt secured
by the Security tushumeat is paid in fall.
IL Foreclosure Procedure if [seder require; Immediate payment In fall under paragraph 9.
Lender may foreclose this Security Instrument by judicial proceeding. Leader shall be a wed to
collect oil expaoasm incurred In purmirm the raaedles provided In this paragraph 1% including, but
not Nodled to, attorneys' ten and cub of title avi deam
11 the leader's lain In this Security instrument tr held by the Sep dary mad the Secretary
requires immeft a payment in doll under Paragraph 9, the Secretary mq isvobe ire noadted is al
powor of Nle provided to the eta Vandly Martpp Teredemare Act of 19114 ("Acel (12 UAC.
3751 et seq.) by requaft a foreclosure armumbdoaer deskas ed under the Act to commxaar
tbradesum mad to sell tba Property as provided to the Act. NothhaN In the precoding mentatat than
deprive the Secretary of any rights otherwise avmilable to a Lender under this Paregrapb 18 or
Applicable hew.
19. Room Upon payment of all suns secured by this Security lusow=4 Ibis Snatairy J=twummot
and the - conveyed sball tamiaadc and became void, Alter each occwrwv-t, Lander shall dbd *W
OW satiety this Security Ir»Wwnent without charge to Sommer. Sommer atmdt pay any low"Mon Dents.
M Wxhvm Bomwi;4 to the extort perrrritted by applicable law, valves and sahraam may onar or
defa m Its to Win this Saernity Insrun atet, and boreby waives the benefit of any ptresed or
Name laws pearklkbg for spay of execration, extension of titre, exemption ftm attachment, levy and atilt,
and bommumod etanpd w
21. Robutatemot Pedod. Sarawak time to reinstate provided in pwagmpb 18 shall extend to one
bow prior to the comet nceaaeat of bidding at a aberills agile or other sale pursued to this Snowily
losbutooL
12. Purtdtsse Money Marlgmge. If miry of the dabs secured by this Security Imtrumeat is lent to
Soaorm to sequins Lida m tae Ptxtltarty, dos S iqr bwkuntett dmW ba a pms>ma mamoy gtp?
33. tatersat Rata Attar ludg neat Bwtawox sormes that ttta h tetw rate payable aft ajudamw is
entered on the Note or in an action of mortgage thtedosum shall be the no payable Lima that to that
under the Note.
It Riders to MIA Security bsbvmmL If we or more rides are executed by Harrower and
recorded tegrther with We Saexity Ir au, the oovalan of each such melee shalt be leecrpandod into
and dull amend and supplonwat the cwnm m and agrecmaats of tbb Security Instrument as if to rider(s)
weer a part of this Security Instrument. [Check applicable box(er)).
? Coadominkaer Rider Growing Equity RW- 0 tithes [sptciiy)
L J Planned Unit Davelopmeant Rider Graduated Payment Rider
vmp,8 ;"Ipm s+eosbar ?,pr It M 14
'Phis is a =void undersea! and any be snforeW under 42 PA. C.S. Sued w 5529(b).
BY SIGNING BELOW, Bwowaa accepts sW arses to the tm= contained in this Security
Insdtumat =W in aiy rWw(s) wu=i tsd by Batowar and rocw*d with it.
MUM$ asc
LaeTM 8_ PAazB -Ba+o+
(em)
1awm wer
(SW) (smd)
Ann w er -Sommor
()
-acmWa
4k m+ m
_ (Seal)
-Ba ower
(Sat)
Bacm.r
VMPS 4WAt as mAi raps of to
COMMONWRALTH OF PtsiyNMVAMA, comwaaam Comiq w
On this, 18TH day of JAltpttlM 2008 . beibm mc. the undcnipptad offiocr,
personally eprpearad rze 2. P A=B
known to me (or sat skatodly prow to be the
parsa?whae twee( a subwrbed to the within Instrument sand acimowiedged
totes same for the purposes bwein contained,
1N VirP WESS 1VHMtEOP, I hereunto set my hand and official seat.
my commission }expires: T..•.. lk % 7L.- mic
lti OF PENN AM
noiridtied No t
AAeehs?iw , Gra?IEarhrfd TitW oCOttiaar
Canmisien Jan. 2a4 2M
CeAiliesta et' Rasideoco
Gi. Vt C trStrc^ , do hereby certify that
the correct sotm= oftlu within-nmod Mortgagee is PA. Box 244 Flint, N 49501-2026.
Witness my hand thin SB'L'N day of'J1t1it3 W 2008
Asaat or T+toegyr?ea
IV";
VtJ 6.4NIPAt wrawAi +*w roe 10
F?IBIT "A" LEGAL DESCRIPTION
All that certain parcel ofLmd and 0On?provements therein situate in the
Borough of Lemoyne, County of Cumberland, and Commoner of
Pennsylvania, and designated as Parcel No. 12-21-0265-204 and more
fully described in a Deed dated April 7, 2006 and recorded April 10,
2006 in Cumberland County in Deed Book 275, Page 4678, granted
and conveyed unto Lester E. Paris, a single person.
VERIFICATION
Esquire hereby states that he is attorney for Wells Fargo Bank,
N.A. in this matter, that Pl ' tiff 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 a
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 authorises.
Dated: \
Scott A`'Dietterick, Esquir ; PA I.D..455650
Kimberly A. Bonner, Esqu e; PA I.D. #89705
Joel A. Ackerman, Esquire PA I.D. 4202729
Ashleigh L. Levy, Esquire PA I.D. #306799
Attorneys for Plaints
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.,
Plaintiff,
vs.
LESTER E. PARIS
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:
525 Bosler Avenue
Lemoyne. PA 17043
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFE CTED BY THIS LIEN IS
CIVIL DIVISION
NO..
TYPE OF PLEADING
CIVIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS
PARTY:
ZUCKER, GOLDBERG &
ACKERMAN, LLC
Scott A. Dietterick, Esquire
Pa. I.D. #55650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
Joel A. Ackerman, Esquire
Pa I.D. #202729
Ashleigh L. Levy, Esquire
Pa I.D. #306799
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldberg.com
File No.: XFP- 149577/rj
Zucker, Goldberg & Ackerman, LLC
XFP-149577
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
FILED-OFFICE
2011 MAR 29 PM 1: E?
CUMBERLAND COUN ? Y
PENNSYLVANIA
Wells Fargo Bank NA
vs. Case Number
.
Lester E. Paris 2011-2179
SHERIFF'S RETURN OF SERVICE
03/28/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on March 28, 2011 at
0945 hours, he was unable to serve a true copy of the within Complaint In Mortgage Foreclosure, upon the
within named defendant, to wit: Lester E. Paris. After several attempts the Complaint in Mortgage
Foreclosure has expired. Request for service at 525 Bosler Avenue, Lemoyne, Pennsylvania 17043 is a
good address for Lester E. Paris. However, Deputies were unable to find him at the residence.
SHERIFF COST: $92.00
March 28, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
WELLS FARGO BANK, N.A.,
Plaintiff,
VS.
Lester E. Paris;
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 Stalavisw Blvd._ MAC # X7801-013. Ft. Mill. SC 29715
AND THE DEFENDANT:
525 Baler Ayg=
Lemoym, PA 17043
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
525 Boslor Avenue. Lemoyne PA 17043
MuniciWity: 14moy?ne
??
ATTORNEY FOR PLAINTIFF
ATTY FILE NO.: XFP 149577
C.
CIVIL DIVISION ='
cn ,,
NO.: 11-2179
TYPE OF PLEADING
CIVIL ACTION - AMENDED
COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
N
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
Ralph M. Salvia, Esquire
Pa I.D. #202946
Jaime R. Ackerman, Esquire
Pa I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldber& com
File No.: XFP- 149577/trk
Zucker, Goldberg & Ackerman, LLC
XFP-149577
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-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
NO.: 11-02179
VS.
Lester E. Paris;
Defendant(s).
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 Baler Association
32 S. Bedford Street
Carlisle, PA 1'013
Phone (800) 990-9108
(717) 249-3166
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
VS.
Lester E. Paris;
Defendant(s).
AVISO
NO.: 11-02179
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defender:se de la demanda
establecida en las
siguientes paginas, debe tomar accion dentro de los pr6ximos veinte (20) dins despuds de la
notificaci6n
de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una
comparecencia
esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas
en su
contra. Se Ie advierte de que si usted falla en tomar accion como se describe anteriormente, el
caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma d$ dinero reclamada
en la demanda 0 cua lquier otra reclamaci6n o remedio solicitado por el demandante, puede ser
dictado en contra suva por la Corte. Usted puede perder dinero o propiedade$ u otros derechos
importantes para
usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE UN
ABOGADO O NO PUEDE PAGAR UNO, LLAME O VAVA A LA SIGUEINTE OFICINA
PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Baer Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 1'013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
VS.
Lester E. Paris;
Defendant(s).
NO.: 11-02179
CIVIL ACTION - AMENDED COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg &
Ackerman, LLC, and files this Amended Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff') through its
servicing agent WELLS FARGO BANK, N.A. located at 3476 Stateview Blvd., MAC # X7801-
013, Ft. Mill, SC 29715.
II. Defendant, Lester E. Paris, is an individual whose last known address is 525
Bosler Avenue, Lemoyne, PA 17043.
III. On or about January 18, 2008, Lester E. Paris made, executed and delivered to
Mortgage Electronic Registration Systems, Inc. as nominee for Cardinal Financial Company,
LTD. Partnership a Mortgage in the original principal amount of $152,250.00 on the premises
hereinafter described in Exhibit "A", with said Mortgage being recorded in the Office of the
Recorder of Deeds of Cumberland County on January 30, 2008, Instrument #200802972. The
mortgage is a matter of public record and is incorporated herein by reference in accordance with
Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to
pleadings if those documents are of public record.
IV. Plaintiff is the current holder of the Mortgage. The Mortgage was assigned by
Mortgage Electronic Registration Systems, Inc. as nominee for Cardinal Financial Company,
LTD. to Wells Fargo Bank, N.A., plaintiff herein, pursuant to an assignment of mortgage dated
February 22, 2011 and recorded on March 10, 2011 in the Office of the Recorder of Deeds for
Cumberland County, Instrument #201107896. The Assignment is a matter of public record
and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule
Zucker, Goldberg & Ackerman, LLC
XFP-149577
relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are
of public record.
V. Lester E. Paris, single person is the record and real owner of the aforesaid
mortgaged premises.
VI. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest being contractually due for the
June 2010 payment.
VII. Plaintiff was not required to send Defendant(s) written notice of Plaintiffs
intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the
commencement of this action for the reason that the original principal balance of the aforesaid
Mortgage is more than the original principal balance threshold of the Act, and therefore:
(a) said Mortgage is not a "residential mortgage" as defined in 41 PAS. §101;
(b) the Defendant(s) is/are not "residential mortgage debtor(s)" as defined in 41 P.S.
§101, and;
(c) the mortgage premises is not "residential real property" as defined in 41 P.S.
§101.
VIII. Plaintiff was not required to send Defendant(s) written Notice pursuant to 35 P.S.
§1680.403 (c) (Homeowners' Emergency Mortgage Assistance Act of 1983, Act 91 of 1983),
prior to commencement of this action for the reason that the aforesaid Mortgage is insured by the
Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. §§1707 -
1715(z) - 18) [35 P.S. §1680.401(a)(3).].
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IX. As of March 8, 2012, the amount due and owing Plaintiff by Defendant(s) is as
follows:
Principal $147,880.18
Interest through 3/8/2012 $16,436.96
Escrow Advance $3,337.89
Escrow Balance ($0.00)
Suspense Balance ($1,115.00 )
Late Charges $44.53
Inspection Fees $250.00
Corporate Advance Credit ($8.00)
Total $166,826.56
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania
Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including
escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file
a motion in the above-captioned action to add such additional sums authorized under the
Mortgage and Pennsylvania Law to the above amount due and owing when incurred.
X. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff
is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to
do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of
personal liability under a bankruptcy proceeding, this action is in no way an attempt to re-
establish such liability.
Zucker, Goldberg & Ackerman, LLC
XFP-149577
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of $166,826.56, with interest thereon plus additional costs (including additional
escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the
mortgaged premises.
ZUCKER, GOLDBERG & ACKERMAN, LLC
BY:
4
Dated: S ?o ! Scott A. Dietterick, Esquire; PA I.D. #5650
Kimberly A. Bonner, Esquire; PA I.D.' #89705
Joel A. Ackerman, Esquire; PA I.D. #2102729
Ashleigh Levy Marin, Esquire; PA I.D #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-149577/trk
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
Alm
oast, _
Zucker, Goldberg & Ackerman, LLC
XFP-149577
VERIFICATION- AMENDED
hereby states that he/she is of
WELLS FARGO BANK, N.A., mortgage servicing agent for Plaintiff in this matter, that he/she
is authorized to make this Verification, and verify that the statements made in the foregoing
Amended Civil Action, in Mortgage Foreclosure are true and correct to the best of his/her
information and belief. The undersigned understands that this statement is made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities.
Further, due to its mortgage servicing agency relationship with plaintiff, WELLS
FARGO BANK, N.A. is in possession and control of all documents and records supporting the
statements in the foregoing pleading and, therefore, the undersigned, rather than an officer or
employee of plaintiff, is the appropriate individual to make this Verification pursuant to
Pa.R.C.P. 1024(c).
Name:
Title:
Date:
Atty File Number: XFP-149577
032-PA-V3
Zucker, Goldberg & Ackerman, LLC
XFP-149577
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP-149577
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VERIFICAIIQN - AMENDED
Samir Erian, hereby states that&he is Vice President Loan Documentation of WELLS
FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter,
thal9she is authorized to make this Verification, and verify that the statements made in
the foregoing Amended Complaint in Mortgage Foreclosure are true and correct to the
best of0hher information and belief. The undersigned understands that this statement is
made subject to the penalties of 18 Pa. C.S. Sec. 4404 relating to unsworn falsification to
authorities.
Name: Samir Erian
DATE: 04/05/2012
Title: Vice President Loan Documentation
054-PA-V2
Zucker, Goldberg & Ackerman,LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,,
NO.: 11-02179
vs.
Lester E. Paris;
Defendant(s).
ORDER OF COURT
ao
AND NOW, this 11 day of 13V%t. , 2012, upon consideration of Plaintiff's
Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its
Amended Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) Lester E.
Paris, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged
Premises, being 525 Bosler Avenue, Lemoyne PA 17043, and by mailing a copy, via Certified Mail, no
signature required and First Class U.S. Mail, Postage Prepaid with said service being valid and complete
upon such posting and mailing in accordance with Pa.R.C.P. 430.
BY THE COURT:
O? r%
J.
- „...d
75
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)
C
3> rv .
-
Zucker, Goldberg & Ackerman, LLC
XFP-149577
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson OF THE LP OTHOIJOT���°r'
Sheriff
Jody S Smith
2013 MAR 18 AM 9. 55
Chief Deputy
Richard W Stewart - CUMBERLAND COUNTY
Solicitor OFFICE QP THE SHERIFF PENNSYLVANIA
Wells Fargo Bank NA
vs. Case Number
Lester E. Paris 2011-2179
SHERIFF'S RETURN OF SERVICE
03/08/2013 04:26 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure upon the within named Defendant,to wit: Lester E. Paris, pursuant to Order of
Court by"Posting"the premises located at 525 Bosler Avenue, Lemoyne Borough, Lemoyne, PA 17043
with a true and correct copy according to law.
RYAN BURGEfT, OPEPUTY--
SHERIFF COST: $50.46 SO ANSWERS,
March 12, 2013 R_0N1irY R ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft.Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A., ISSUE NO.: 11-02179
Plaintiff, TYPE OF PLEADING
VS.
AFFIDAVIT OF SERVICE OF <
Lester E. Paris; COMPLAINT PURSUANT TO
Pa.R.C.P.,430 SPECIAL ORDER mw
Defendant. OF COURT
cn r-- t
-< C)
�, w o ,
�Ca
CODE: rco --1-C'5
rt
3>r> X-�
o o
FILED ON BEHALF OF: 5'� s-
Wells Fargo Bank, N.A. cr%
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
Ralph M.Salvia, Esquire-PA I.D.#202946
Jaime R.Ackerman, Esquire- PA I.D.#311032
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908)233-1390 FAX
office @zuckergoldberg.com
File No.:XFP- 149577/emed
4 •
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS.
NO.: 11-02179
Lester E. Paris;
Defendant.
AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE
FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT
I,Scott A. Dietterick, Esquire, Kimberly A. Bonner, Esquire, Joel Ackerman, Esquire,Ashleigh
Levy Marin, Esquire, Ralph M.Salvia, Esquire,Jaime R.Ackerman, Esquire,attorney for Plaintiff,Wells
Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding
the service of Plaintiffs Complaint in Mortgage Foreclosure on Defendant, Lester E. Paris, as follows:
1. On or about June 22, 2012,an Order of Court was entered granting Plaintiffs Motion for
Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct
copy of said Order is marked Exhibit"A",attached hereto and made a part hereof.
2. Pursuant to said Order,on or about March 14, 2013,Zucker, Goldberg&Ackerman, LLC,
the counsel for Plaintiff served Defendant, Lester E. Paris with a true and correct copy of Plaintiff's
Complaint in Mortgage Foreclosure,via First Class U.S. Mail and Certified Mail, Return Receipt
Requested to the defendant's last known address being 525 Bosler Avenue, Lemoyne, PA 17043. A true
and correct copy of said returned receipt and certificate of mailing are marked Exhibit"B", attached
hereto and made a part hereof.
3. Pursuant to said Order,on or about March 8, 2013,the Sheriff of Cumberland County
posted the property subject to the Mortgage, being 525 Bosler Avenue, Lemoyne, PA 17043 with a true
and correct copy of Plaintiff's Complaint in Mortgage Foreclosure. A true and correct copy of the Service
Form from the Cumberland County Sheriffs Office is marked Exhibit"C,attached hereto and made a
part hereof.
ZUCKER,GOLDBERG &ACKERMAN, LLC
Dated: 5�l f 13
BY:
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
Ralph M.Salvia; PA I.D.#202946
Jaime R.Ackerman, Esquire; PA I.D.#311032
200 Sheffield Street,Suite 301
Mountainside, NJ 07092
File No.:XFP-149577
(908) 233-8500; (908)233-1390 FAX
E-mail: Office @zuckergoldberg.com
Sworn to and subscribed before
me this ti day of ay ,2013
Notary P lic
MY COMMISSION EXPIRES:
Cheryl ,ebeneadto Notary Public
MY Comm.Expires Oct 16 2016
State of New Jersey,
EXHIBIT A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank,N.A. CIVIL.DIVISION
Plaintiff,
vs. NO.:11-02179
Lester E. Paris;
Defendant(s).
ORDER OF COURT
AND NOW,this ox�A ay of ,2012, upon consideration of Plaintiff's
Motion for Special Service,it is hereby O DERED,ADJUDGED AND DECREED that Plaintiff shall serve its
Amended Complaint in Mortgage Foreclosure and Notice of Sale, if necessary,on Defendant(s) Lester E.
Paris, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged
Premises, being 525 Bosler Avenue, Lemoyne PA 17043, and by mailing a copy, via Certified Mail, no
signature required and First Class U.S. Mail, Postage Prepaid with said service being valid and complete
upon such posting and mailing in accordance with.P.a.R.C.P.430.
BY TH E CO U RT:
CD
J.
d,
�-C3 -f
p C:� en,
T�
Zucker,Goldberg&Ackerman,LLC
XFP-149577
EXHIBIT B
..._... Z .rte
� prrtvetr aowFs
P+C�S ALSE�'e i{l `r ' �• 02 I M $ 01..200
This Cettifrcate of Mailing provides evidence that rnail has been presented to LISPS*for mailing.This form 6 0004282036 VAR 14 2013
and International mail. MAILED FROM ZIP GORE 07092
PrCm: Scott A.Dietterick,Esquire i
c/o Zucker,Goldberg&Ackerman, LLC
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
XFP-149577/cperTEAM B . Sds
T07 Lester E. Paris Postmark Here t�t,k
o h
525 Bosler Avenue ;
Lemoyne,PA 17043
County of P.Q.:CUMBERLAND rN(7-130
PS Form 3817,April 2007 PSN 7530-02-000-9065
Page 1 of 9
Zuolcer,Goldberg&Ackerman,LLC
PO Box 1219
Mountainside,NJ 07092-1219
7196 9006 9296 5973 6400
20130314.102
°il hhr 11 I I Ihul^ Ir°III^hlln°drud I1
Lester E.Paris
525 BOSLER AVE
LEMOYNE,PA 17043-1815
ISMTG
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EXHIBIT C
S.HERIFF'S OFFICE 0*CUMBERLAND .COUNTY
Ronny'tt Anderson
Sherrlf
of L(c�(�tr��
Jody s Smith
n
Chief.Deputy
Richard W Stewart
Solicitor oFf=OFTHE PIWF
Wells Fargo-Bank NA
Case Number
Lester E.Pads .201.1-2.179 .
SHERIFF'S RETURN OF SERVICE
03/01#/2013 04:26 PM Deputy Ryan Burgett,-being duly sworn according to la
w,.served the requested Complaint in
Mortgage Foreclosure upon:the.witi in named Defendant,.to.wit:Lester.E:Paris,pursuant to Order of
;Courtby"Posting the premises located at 525 Bbsler Avenue,.Lemoyne Borough,Lemoyne,PA 17043 . .
with a•true and'correct copy according to law.
RYAN B
SHERIFF COST:$50.46 SO ANSWERS,
Match 12,2013 RON R ANDERSON;SHERIFF.-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAWA
rn
Wells Fargo Bank, N.A., CIVIL DIVISION rte- } ;:j1 "
t-.
Plaintiff No.: 11-02179
Er o c, C:
VS. ISSUE NUMBER: T'
Lester E. Paris; TYPE OF PLEADING:
Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT
(MORTGAGE FORECLOSURE)
Mortgaged Premises:
525 Bosler Avenue, Lemoyne, PA 17043 FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
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. Marin, Esquire-Pa I.D.#306799
Ralph M. Salvia, Esquire- Pa I.D.#202946
Jaime R.Ackerman, Esquire- Pa I.D.#311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
Atty File No.: XFP-149577
Praecipe for Entry of Judgment
Zucker,Goldberg&Ackerman, LLC
XFP-149577
7110 niaiied
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS. NO.: 11-02179
Lester E. Paris;
Defendant.
PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE)
TO: PROTHONOTARY
Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of
Plaintiff and against Defendant(s), for failure to file a response to Plaintiff's amended Complaint within
the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in amended
Complaint:
Amount as set forth in amended Complaint $166,826.56
plus interest on the judgment amount ($166,826.56)from March 9, 2012, at the statutory rate and for
foreclosure and sale of the mortgaged premises.
I hereby certify that the defendant's last known 525 Bosler Avenue
address is: Lemoyne, PA 17043
zUC R, G_OLBERG &ACKERMAN, LLC
Dated: ?/7 BY:
Joel A. ckerma , Esquire; I.D.#202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Jaime R.Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-149577
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office @zuckergoldberg.com
DAMAGES ARE HEREBY ASSESSED AS INDICATED
Date q 40
Prothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
vs. NO.: 11-02179
Lester E. Paris;
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF
NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT
STATE OF NEW JERSEY
SS:
COUNTY OF UNION
I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to
law, do hereby depose and say that the statements made herein are true in and correct to the best of
my knowledge, information, and that:
1) The Defendant is not in the military service of the United States of America to the best
of my knowledge, information and belief as evidenced by the attached copies;
2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P.
237.1 and that the time limits provided for that notice have expired.
ZUCLER OLBE G &ACKERMAN, LLC
Dated: t/7// ,5 BY:
Joel A. ckerman-, Esquire; PA I.D.#202729
VAshleigh L. Marin, Esquire; PA I.D. #306799
Jaime R.Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-149577
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office @zuckergoIdberg.com
Sworn to and subscr'bed before me
This I day of , 20 /3
(?Atv(-4s�� -
No ry Publ
My Commission Expires:
I Debeneadto Notary Public
y
Gomm.Expires Oct.16.2016
State of New Jersey
Zucker,Goldberg&Ackerman, LLC
XFP-149577
Department of Defense Manpower Data Center Results as of:Aug-05-2013 07:59:45
SCRA 3.0
Stem Report
Pursuant to Servicememben Civil Relief Act.
Last Name: PARIS
First Name: LESTER
Middle Name: E
Active Duty Status As Of: Aug-05-2013
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status service Component
NA NA NA
This response reflects the 14Adua—Isactive duty status based on the Active Duty.Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA 4A No NA
This response reflects where the individual left active duty,status vAth-in 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Component
NA '0'NA,' No' -11 y1 NA
This response rellects,whether the Individual or his/her unit has i; Ivodl early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data-Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY
ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY
IDENTIFY AN INDIVIDUAL.
16
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:http://www,defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or hislher unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: 03U9BD2F705B7B0
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS. NO.: 11-02179
Lester E. Paris;
Defendant.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Lester E. Paris
525 Bosler Avenue
Lemoyne, PA 17043
[ ] Plaintiff
[V] Defendant
[ ] Additional Defendant
You are hereby notified that an Or r, ecree or Judgment was entered in the above captioned
proceeding on �9 913
[ ] A copy of the Order or Decree is enclosed,
or
[V] The judgment is as follows: $166,826.56 Iplus cos A)
try,
�^ .04
Prothonotary
Zucker,Goldberg&Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS. NO.: 11-02179
Lester E. Paris
Defendant.
IMPORTANT NOTICE
TO: Lester E. Paris
525 Bosler Avenue
Lemoyne, PA 17043
DATE OF NOTICE: 4/8/2013
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
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
vs. NO.: 11-02179
Lester E. Paris
Defendant.
AVISO IMPORTANTE
TO: Lester E. Paris
525 Bosler Avenue
Lemoyne, PA 17043
FECHA DEL AVISOA/8/2013
USTED ESTA EN REBELDL4 PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD, Y OTROS DERECHOS DAPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO IN1vIEDLA.TA1VENTE A SU ABOGAD O. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND &.LAWYERREFERRA.L 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
ZUCKER,GOLDBERG &.ACKERMAN
BY: Scott A. D ietteridc
Scott A. Dietterick,Esquire
Attorneys for Plaintiff
PA I.D. # 55650
200 Sheffield Street, Suite 301
P.O. Box 1024
Mountainside,NJ 07092-0024
(717) 533-3560
FIRST CLASS U.S. MAIL, POSTAGE PREPAID 149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A., ISSUE NO.: 11-02179
Plaintiff, TYPE OF PLEADING
VS.
AFFIDAVIT OF SERVICE OF
Lester E. Paris; COMPLAINT PURSUANT TO
Pa.R.C.P.,430 SPECIAL ORDER
Defendant. OF COURT
CODE:
FILED ON BEHALF OF:
Wells Fargo Bank,N.A.
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER,GOLDBERG&ACKERMAN,LLC
Scott A.Dietterick, Esquire PA I.D.#55650
Kimberly A. Bonner,Esquire-PA I.D.#89705
Joel A.Ackerman, Esquire-PA I.D.#202729
Ashleigh Levy Marin, Esquire-PA I.D.#306799
Ralph M.Salvia,Esquire-PA I.D.#202946
Jaime R.Ackerman, Esquire-PA I.D.#311032
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
(908)233-8500
(908)233-1390 FAX
office@zuckergoldberg.com
File No.:XFP-149577/emed
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank,N.A. CIVIL DIVISION
Plaintiff,
NO.: 11-02179
VS.
Lester E.Paris;
Defendant.
AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE
FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT
I,Scott A.Dietterick, Esquire,Kimberly A.Bonner, Esquire, Joel Ackerman,Esquire,Ashleigh
Levy Marin, Esquire, Ralph M.Salvia, Esquire,Jaime R.Ackerman,Esquire,attorney for Plaintiff,Wells
Fargo Bank,N.A.,being duly sworn according to law depose and make the following Affidavit regarding
the service of Plaintiffs Complaint in Mortgage Foreclosure on Defendant, Lester E. Paris, as follows:
1. On or about June 22,2012,an Order of Court was entered granting Plaintiffs Motion for
Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct
copy of said Order is marked Exhibit"A",attached hereto and made a part hereof.
2. Pursuant to said Order,on or about March 14,2013,Zucker,Goldberg&Ackerman,LLC,
the counsel for Plaintiff served Defendant, Lester E.Paris with a true and correct copy of Plaintiffs
Complaint in Mortgage Foreclosure,via First Class U.S. Mail and Certified Mail, Return Receipt
Requested to the defendant's last known address being 525 Bosler Avenue,Lemoyne,PA 17043. A true
and correct copy of said returned receipt and certificate of mailing are marked Exhibit"B",attached
hereto and made a part hereof.
I
3. Pursuant to said Order,on or about March 8,2013,the Sheriff of Cumberland County
posted the property subject to the Mortgage,being 525 Bosler Avenue,Lemoyne, PA 17043 with a true
i and correct copy of Plaintiffs Complaint in Mortgage Foreclosure. A true and correct copy of the Service
Form from the Cumberland County Sheriffs Office is marked Exhibit"C,attached hereto and made a
part hereof.
ZUCKER,GOLDBERG&ACKERMAN, LLC
Dated:
'5/03
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
Ralph M.Salvia; PA I.D.#202946
Jaime R.Ackerman,Esquire;PA I.D.#311032
200 Sheffield Street,Suite 301
Mountainside, NJ 07092
File No.:XFP-149577
(908)233-8500, (908)233-1390 FAX
E-mail: Office @zuckergoldberg.com
Sworn to and subscribed before
me this r day of Pt 6VI ,2013
Notary P lic
MY COMMISSION EXPIRES:
Cheryl Debeneadto Notary Public
�Y t;olntn.Expires Oct 1$ 2016
State or New Jersey'
EXHIBIT A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
Wells l=argo Bank,N.A. CIVIL,DIVISION
Plaintiff,
vs. NO.:11-02179
'
Lester E.Paris,
Defendant(s).
ORDER OF COURT
nd .
AND NOW,this 5 day of 2012,upon consideration of Plaintiff's
Motion for Special Service,It is hereby O DERED,ADJUDGED AND DECREED that Plaintiff shall serve its
Amended Complaint in Mortgage Foreclosure and Notice of Sale,if necessary,on Defendant(s)Lester E.
Paris, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged
Premises, being 525 Bosler Avenue, Lemoyne PA 17043,and by mailing a copy, via Certified Mail,no
signature required and First Class U.S. Mail,Postage Prepaid with said service being valid and complete
upon such posting and mailing In accordance with.P.a.R.C.P.430.
BYTHEECOURT: '
J.
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C? -'A
C- M -
�yfrf c-
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"3 S1.
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C'>-'7
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Zucker,Goldberg&Ackerman,LLC
YFP-149577
I
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EXHIBIT B
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' . > 02 1M $ 01..20°
0004282036 M4R 14 2013 ,
•rldtWWwAttafM+lftProvWestvWer the nag hubesnDrwnwd tousPS'formaiG Thb form d,
and Wormitionalmall. MA[LEDFROM ZIPCODE 07092 '
Scott A.Dietterick, Esquire
Zucker,Goldberg&Ackerman,LLC
.200 Sheffield Street,Suite 101
Mountainside,N1 07092
XFP-149577/cperTEAM 8 �Q• SdS�
Lester E.Paris Ponmark Hem
525 Boster Avenue ,�r
Lemoyne,PA 17043 ��
County of P.Q.:CUMBERLAND ��(11IN
. i�wwar ter.nri ■r..�r�
j PS Form 3817,April 2007 PSN 7530-02-000-9065
i
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Page I of 1
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moxQ,cotdbory a Aa19111m,u.c
P08=1219
MaxdahrWo,NJ 07082-1218
7196 9006 9296 5973 6400
2013034-102
�"tl�hht^tl�t�l�thul^��ir��lll^IdhtNdrull�lrlll�l
Lester E.Paris
525 BOSLER AVE
LEMOYNE,PA 170431815
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EXHIBIT C
i
-.. . '.• : • . •. . , • • - . • •• ;� : . . , : . . -• ••.. . : .' . 1.
.S.HER.IFF`S OFFICE OF'CUMBERLAND.COUNTY
Ronny.R Anderson
• Sheriff f [J p� cam;"
4od y S Smith
Chiefoepury
Richard W Stewart
Solicitor oroFZxs sF
Webs Fargo.Bank NA.'
vs. Case Hamber
Lester E.Parts 2011-2179
SHERIFF'S-RETURN OF SERVICE
03106/2013 04:26 PM-Deputy Ryan Burgett,,being duly swom aocor0ing to law,.served the requested CoMolaint in
Mortgage Foreclosure upon-tile Within•named Defendant;to..wit:Laster:..Paris,pursuant to Order of
Court.by'"Posting":the premises located at 525 Bbsler Avenue,•Lerpoyne t30rough,Lemoyne,PA 11443 . .
with 6-true aiid'oorrect copy+aocording-to law.' .
RYAN BPRGM,CEPUry
SiiERIFF COST:$50.46 . SO ANSWERS,
Mucci 12,2013 •RON RANDERSON;SHERIFF,'
• - - •(�oounprsmw srtorp4 TaoesaF,ma
L,, •J'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
File No. 11-02179
Wells Fargo Bank, N.A. , Amount Due $166,826.56
Plaintiff, . Interest from 03/09/2012 to date of sale $22,686.32
vs.
Costs
Lester E. Paris;
Defendant. G
0- c) -
TO THE PROTHONOTARY OF THE SAID COURT: t�,p `.
2`" t
The undersigned hereby certifies that the below does not arise out of a retail installment sale contra of T.-'-
account based on a confession of judgment, but if it does, it is based on the appropriate original proceecTing filed
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 control of the said garnishee(s).
aig- 6 , 36 of
q) , bD cl?,t--
so, Lit, ,t t .
°I . 00 " 61-
----bie
1 , . 1S i.D;aS
1lr?. spit it se.) 1.1,81
�� �f�}}/� Zucker,Goldberg&Ackerman,LLC
4 �c(). (- ( J`��/ FP-149577
-(*/-- --g6IFS Wh,---/- of g ._?.q.,e0/
(Indicate) Index this writ against the garnishees) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
DATE: 4111 *, € �� Signatures
Print Nam Cott A. Dietterick, Esquire
Kimberly A. Bonner, Esquire
Joel Ackerman, Esquire
Ashleigh L. Marin, Esquire
Ralph M.Salvia, Esquire
Jaime R.Ackerman, Esquire
Jana Fridfinnsdottir, Esquire
Brian Nicholas, Esquire
Denise Carlon, 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
202729
306799
202946
311032
315944
317240
317226
Zucker,Goldberg&Ackerman,LLC
XFP-149577
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF LEMOYNE. COUNTY OF CUMBERLAND
AND STATE OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS,
TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF BOSLER AVENUE AT THE DIVIDING LINE BETWEEN
LOTS NOS. 114 AND 115, BLOCK "D", AS SHOWN ON PLAN NO. 1 OF RIVERTON, PENNSYLVANIA, SAID
PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK"1", VOL.4,
PAGE 40; THENCE IN A NORTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE ONE HUNDRED
FIFTY(150) FEET TO RAILROAD ALLEY;THENCE IN A WESTERLY DIRECTION ALONG THE SOUTHERN LINE
OF RAILROAD ALLEY THIRTY(30) FEET SIX(6) INCHES TO A POINT; THENCE IN A SOUTHERLY DIRECTION
ALONG A LINE AT RIGHT ANGLES WITH BOSLER AVENUE ONE HUNDRED FIFTY(150) FEET TO BOSLER
AVENUE:THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN LINE OF BOSLER AVENUE THIRTY
(30) FEET SIX (6) INCHES TO THE POINT OR PLACE OF BEGINNING
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 525 BOSLER
AVENUE, LEMOYNE, PA, 17043.
BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND
WIFE, BY DEED DATED APRIL 7, 2006 AND RECORDED APRIL 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 273, PAGE 4679, GRANTED AND CONVEYED UNTO
LESTER E. PARIS, SINGLE PERSON.
TAX MAP NO.: 12-21-0265-204.
Zucker,Goldberg&Ackerman, LLC
XFP-149577
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 11-2179 Civil
COUNTY OF CUMBERLAND) 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 LESTER E.PARIS
(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: $166,826.56 L.L.: $.50
Interest from 3/9/2012 to Date of Sale -- $22,686.32
Atty's Comm: Due Prothy: $2.25
Any Paid: $291.21 Other Costs:
Plaintiff Paid:
Date: 2/20/2014
. s
David D.Buell,Prothonotary
(Seal) J - C
Deputy L
REQUESTING PARTY:
Name: 13ENISE CARLON,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.317226
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLII
NI
Wells Fargo Bank, N.A. , CIVIL DIVISION
0
Plaintiff, NO.: 11-02179
c1
vs.
Execution No.:
Lester E. Paris;
•
•
Defendant(s).
•
•
•
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., Plaintiff in the above action,sets forth as of the date the Praecipe for
Writ of Execution was filed the following information concerning the real property located at 525 Bosler
Avenue, Lemoyne, PA 17043.
1. Name and Address of Owner(s)or Reputed Owner(s):
LESTER E. PARIS,SINGLE PERSON
525 Bosler Avenue
Lemoyne, PA 17043
2. Name and Address of Defendant(s) in the Judgment:
LESTER E. PARIS
525 Bosler Avenue
Lemoyne, PA 17043
3. Name and Address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
WELLS FARGO BANK, N.A.
Plaintiff
4. Name and Address of the last record holder of every mortgage of record:
WELLS FARGO BANK, N.A.
Plaintiff
Zucker,Goldberg&Ackerman,LLC
XFP-149577
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR CARDINAL FINANCIAL
COMPANY, LTD. PARTNERSHIP
P.O. Box 2026
Flint, MI 48501-2026
AND
1901 E.Voorhees Street, Suite C
Danville, IL 61834
AND
444 Jacksonville Road
Warminster, PA 18974
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
525 Bosler Avenue
Lemoyne, PA 17043
UNKNOWN SPOUSE
525 Bosler Avenue
Lemoyne, PA 17043
Zucker,Goldberg&Ackerman,LLC
XFP-l49577
PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
I verify that the statements made in this Affidavit are true and correct to the best of my personal
knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
ZUCKER, GOLDBERG &ACKERMAN, LLC
Dated: k. l–i d'2')4 Bfb 0 ,1�. CA. I•• . –
Scott A. Dietterick, Esquire; PA I.D.#55650
q ,
Kimberly A. Bonner, Esquire; PA I.D.#89705
Joel A.Ackerman, Esquire; PA I.D.#202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D.#202946
Jaime R.Ackerman, Esquire; PA I.D.#311032
Jana Fridfinnsdottir, Esquire; PA I.D.#315944
Brian Nicholas, Esquire; PA I.D.#317240
—Denise Carlon, Esquire; PA I.D.#317226
Attorneys for Plaintiff
XFP-149577/11
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office @zuckergoldberg.com
Zucker,Goldberg&Ackerman,LLC
XFP-1 49577
Exhibit"A"
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF LEMOYNE.COUNTY OF CUMBERLAND
AND STATE OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS,
TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF BOSLER AVENUE AT THE DIVIDING LINE BETWEEN
LOTS NOS. 114 AND 115, BLOCK"D",AS SHOWN ON PLAN NO. 1 OF RIVERTON, PENNSYLVANIA, SAID
PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK "J",VOL.4,
PAGE 40;THENCE IN A NORTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE ONE HUNDRED
FIFTY(150) FEET TO RAILROAD ALLEY;THENCE IN A WESTERLY DIRECTION ALONG THE SOUTHERN LINE
OF RAILROAD ALLEY THIRTY(30) FEET SIX (6) INCHES TO A POINT;THENCE IN A SOUTHERLY DIRECTION
ALONG A LINE AT RIGHT ANGLES WITH BOSLER AVENUE ONE HUNDRED FIFTY(150) FEET TO BOSLER
AVENUE:THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN LINE OF BOSLER AVENUE THIRTY
(30) FEET SIX (6) INCHES TO THE POINT OR PLACE OF BEGINNING
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 525 BOSLER
AVENUE, LEMOYNE, PA, 17043.
BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND
WIFE, BY DEED DATED APRIL 7, 2006 AND RECORDED APRIL 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 273, PAGE 4679, GRANTED AND CONVEYED UNTO
LESTER E. PARIS,SINGLE PERSON.
TAX MAP NO.: 12-21-0265-204.
Zucker,Goldberg&Ackerman,LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
r i
Plaintiff,
. NO.: 11-02179 -
vs.Lester E. Paris; •
•
Defendant. t-
•
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Lester E. Paris
525 Bosler Avenue
Lemoyne, PA 17043
TAKE NOTICE:
That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 06/04/2014 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:
525 Bosler Avenue, Lemoyne, PA, 17043
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-02179
Zucker,Goldberg&Ackerman, LLC
XFP-149577
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S)OF THIS PROPERTY ARE:
Lester E. Paris,single person
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 Sheriff's 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 Sheriff's Deed is delivered.
Zucker,Goldberg&Ackerman, LLC
XFP-149577
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition must be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013-3387, before presentation of the petition to the Court.
ZUCKER, GOLDBERG &ACKERMAN, LLC
Dated: / --7(D--0� ' JZ.R� aJ .∎
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. Marin, Esquire; PA I.D.#306799
Ralph M.Salvia, Esquire; PA I.D.#202946
Jaime R.Ackerman, Esquire; PA I.D.#311032
Jana Fridfinnsdottir, Esquire; PA I.D.#315944
Brian Nicholas, Esquire; PA I.D.#317240
_Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFP-149577/11
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office @zuckergoldberg.com
VIA ORDER OF COURT
Zucker,Goldberg&Ackerman, LLC
XFP-149577
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF LEMOYNE. COUNTY OF CUMBERLAND
AND STATE OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS,
TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF BOSLER AVENUE AT THE DIVIDING LINE BETWEEN
LOTS NOS. 114 AND 115, BLOCK"D", AS SHOWN ON PLAN NO. 1 OF RIVERTON, PENNSYLVANIA, SAID
PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK"1", VOL.4,
PAGE 40; THENCE IN A NORTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE ONE HUNDRED
FIFTY(150) FEET TO RAILROAD ALLEY;THENCE IN A WESTERLY DIRECTION ALONG THE SOUTHERN LINE
OF RAILROAD ALLEY THIRTY(30) FEET SIX(6) INCHES TO A POINT;THENCE IN A SOUTHERLY DIRECTION
ALONG A LINE AT RIGHT ANGLES WITH BOSLER AVENUE ONE HUNDRED FIFTY(150) FEET TO BOSLER
AVENUE:THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN LINE OF BOSLER AVENUE THIRTY
(30) FEET SIX (6) INCHES TO THE POINT OR PLACE OF BEGINNING
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 525 BOSLER
AVENUE, LEMOYNE, PA, 17043.
BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND
WIFE, BY DEED DATED APRIL 7, 2006 AND RECORDED APRIL 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 273, PAGE 4679, GRANTED AND CONVEYED UNTO
LESTER E. PARIS,SINGLE PERSON.
TAX MAP NO.: 12-21-0265-204.
Zucker,Goldberg&Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff, •
vs. NO.: 11-02179
Lester E. Paris;
Defendant(s).
•
ORDER OF COURT
AND NOW,this ow day of ,2012,upon consideration of Plaintiff's
Motion for Special Service,it is hereby O DERED,ADJUDGED AND DECREED that Plaintiff shall serve its
Amended Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) Lester E.
Paris, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged
Premises, being 525 Bosler Avenue, Lemoyne PA 17043, and by mailing a copy, via Certified Mail, no
signature required and First Class U.S. Mail, Postage Prepaid with said service being valid and complete
upon such posting and mailing in accordance with.Pa.R.C.P.430.
BY THE COURT: •
151 /,l - v C Serir' 9_
J.
Y"1
�rt y y
,..., �ty P"7
tfl j" N)
' :.
c)
Zucker,Goldberg&Ackerman,LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. ,
vs.
Lester E. Paris;
Plaintiff,
Defendant(s).
. CIVIL DIVISION
NO.: 11-02179
: Execution No.:
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A. , Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of
Execution was filed the following information concerning the real property located at 525 Bosler Avenue,
Lemoyne, PA 17043.
1. Name and Address of Owner(s) or Reputed Owner(s):
LESTER E. PARIS, SINGLE PERSON
525 Bosler Avenue
Lemoyne, PA 17043
2. Name and Address of Defendant(s) in the Judgment:
LESTER E. PARIS
525 Bosler Avenue
Lemoyne, PA 17043
3. Name and Address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
WELLS FARGO BANK, N.A.
Plaintiff
4. Name and Address of the last record holder of every mortgage of record:
WELLS FARGO BANK, N.A.
Plaintiff
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR CARDINAL FINANCIAL
COMPANY, LTD. PARTNERSHIP
P.O. Box 2026
Flint, MI 48501-2026
AND
1901 E. Voorhees Street, Suite C
Danville, IL 61834
AND
444 Jacksonville Road
Warminster, PA 18974
AND
3300 SW 34th Ave, Ste 101
Ocala, FL 34474-4438
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
LEMOYNE BORO
510 HERMAN AVE
LEMOYNE, PA 17043-1822
ATTN: FAITH A NICOLA
WEST SHORE SCHOOL DISTRICT
507 Fishing Creek Rd
Lewisberry, PA 17339
AND
510 HERMAN AVE
LEMOYNE, PA 17043-1822
ATTN: FAITH A NICOLA
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
525 Bosler Avenue
Lemoyne, PA 17043
UNKNOWN SPOUSE
525 Bosler Avenue
Lemoyne, PA 17043
PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
LANCASTER COUNTY DOMESTIC RELATIONS OFFICE
Domestic Relations Section
PO Box 83479
Lancaster, PA 17608-3479
I verify that the statements made in this Amended Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Dated:
10-014
ZUCKER, GOLDBERG & ACKERMAN, LLC
B(»,(, _
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. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XCP-149577/nfe
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
4
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF LEMOYNE. COUNTY OF CUMBERLAND AND
STATE OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF BOSLER AVENUE AT THE DIVIDING LINE BETWEEN LOTS
NOS. 114 AND 115, BLOCK "D", AS SHOWN ON PLAN NO. 1 OF RIVERTON, PENNSYLVANIA, SAID PLAN BEING
RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK "J", VOL.4, PAGE 40; THENCE IN
A NORTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE ONE HUNDRED FIFTY (150) FEET TO RAILROAD
ALLEY; THENCE IN A WESTERLY DIRECTION ALONG THE SOUTHERN LINE OF RAILROAD ALLEY THIRTY (30) FEET
SIX (6) INCHES TO A POINT; THENCE IN A SOUTHERLY DIRECTION ALONG A LINE AT RIGHT ANGLES WITH
BOSLER AVENUE ONE HUNDRED FIFTY (150) FEET TO BOSLER AVENUE: THENCE IN AN EASTERLY DIRECTION
ALONG THE NORTHERN LINE OF BOSLER AVENUE THIRTY (30) FEET SIX (6) INCHES TO THE POINT OR PLACE OF
BEGINNING
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 525 BOSLER AVENUE,
LEMOYNE, PA, 17043.
BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND WIFE,
BY DEED DATED APRIL 7, 2006 AND RECORDED APRIL 10, 2006 IN AND FOR CUMBERLAND COUNTY,
PENNSYLVANIA, IN DEED BOOK VOLUME 273, PAGE 4679, GRANTED AND CONVEYED UNTO LESTER E. PARIS,
SINGLE PERSON.
TAX MAP NO.: 12-21-0265-204.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A., CIVIL DIVISION
Plaintiff No.: 11-02179
vs.
Lester E. Paris;
Defendant
TYPE OF PLEADING:
Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE
OF DEFENDANT/OWNER AND
OTHER PARTIES OF INTEREST
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
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 Levy Marin, Esquire -Pa I.D. #306799
Ralph M. Salvia, Esquire- Pa I.D. #202946
Jaime R. Ackerman, Esquire- Pa I.D. #311032
Jana Fridfinnsdottir, Esquire- PA I.D. #315944
Brian Nicholas, Esquire- PA I.D. #317240
Denise Carlon, Esquire- PA I.D. #317226
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
Atty File No.: XFP-149577
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Lester E. Paris;
Plaintiff,
Defendant.
CIVIL DIVISION
NO.: 11-02179
Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF
DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST
I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for
Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following
Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on
Defendant/Owner and Other Parties of Interest as follows:
1. Defendant(s) Lester E. Paris, single person, is/are the record owners of the real property.
2. Pursuant to the Order of Court dated June 22, 2012, the Sheriff of Cumberland County posted
Plaintiff's Notice of Sheriff's Sale, at the address of the mortgaged premises, being 525 Bosler Avenue,
Lemoyne, PA 17043, on or about March 28, 2014. A true and correct copy of said Order of Court and
Proof of Posting are marked Exhibit "A", attached hereto and made a part hereof.
3. Pursuant to the Order of Court dated June 22, 2012, Plaintiff's counsel served Defendant(s)
Lester E. Paris, with Plaintiff's Notice of Sheriff's Sale, via Certified Mail no signature required, at the
address of 525 Bosler Avenue, Lemoyne, PA 17043, on or about March 13, 2014. True and correct
copies of said Notices and Proofs of Mailing are marked Exhibit "B", attached hereto and made a part
hereof.
4. Pursuant to the Order of Court dated June 22, 2012, Plaintiff's counsel served Defendant(s)
Lester E. Paris, with Plaintiff's Notice of Sheriff's Sale, via First Class U.S. Mail, Postage Pre -Paid, with a
Certificate of Mailing, at the address of 525 Bosler Avenue, Lemoyne, PA 17043, on or about March 14,
2014. True and correct copies of said Certificate of Mailing is marked Exhibit "C", attached hereto and
made a part hereof.
Zucker, Goldberg & Ackerman, LLC
XFP-149577
5. On or about May 5, 2014, Plaintiff's counsel served all other parties in interest with Plaintiff's
Notice of Sheriff's Sale according to Plaintiff's Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail,
Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates
of Mailing are marked Exhibit "D", attached hereto and made a part hereof.
Finally, the undersigned deposes and says that the Defendants/Owners 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.
Dated: May 23, 2014
Sworn to and subscribed before me
r, r"
This
day of
, 2014
ZUCKER, GOLDBERG & ACKERMAN, LLC
Attorneys for Plaintiff
MARWrT AGYEPONG /7
Paralegal/Legal Assistant
Notary Pub is
MY COMMISSION EXPIRES:
PAUL C. NADRAT0WSK1
Notary Public of New Jersey
ID# 24078504J27�2016
My Commission Exp
ires
Zucker, Goldberg & Ackerman, LLC
XFP-149577
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
vs.
Lester E. Paris;
Defendant(s).
ORDER OF COURT
AND NOW, this day of .fie
for it is hereby O DERED
11-02179
, 2012, upon consideration of Plaintiff's
ADJUDGED
Motion Special Service, JUDGED AND DECREED that Plaintiff shall serve its
Amended Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) Lester E.
Paris, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged
Premises, being 525 Bosier Avenue, Lemoyne PA 17043, and by mailing a copy, via Certified Mail, no
signature required and First Class U.S. Mail, Postage Prepaid with said service being valid and complete
upon such posting and mailing in accordance with Pa.R.C.P. 430,
BY THE COURT:
/sr 5i1- '_geLed
J.
Zucker, Goldberg & Ackerman, LLC
XFP-149577
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
„0
0,0 of CAIRO),rl4rrb
;°4'ICE QF ThE SMERtFF
Wells Fargo Bank NA
vs.
Lester E. Paris
Case Number
2011-2179
SHERIFF'S RETURN OF SERVICE
03/28/2014 06:56 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 525 Bosler Avenue, Lemoyne - Borough, Lemoyne, PA
17043, Cumberland County.
03/28/2014 06:56 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ,
Notice and Description, in the above titled action, upon the within named Defendant, to wit: Lester E.
Paris, pursuant to Order of Court by "Posting" the premises located at 525 Bosler Avenue, Lemoyne
Borough, Lemoyne, PA 17043, Cumberland County with a true and correct copy according to law.
SHERIFF COST: $1,399.38 SO ANSWERS,
May 23, 2014 RONNY R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoft, Inc.
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP-149577
Zucker, Goldberg & Ackerman, LLC
PO Box 1219
Mountainside, NJ 07092-1219
7196 9006 9297 2962 4224
20140313-102
h1/1111101111111"InitIliliilhilid111r"lli1r11l11ll1nrl1
Lester E. Paris
525 BOSLER AVE
LEMOYNE, PA 17043-1815
PANOSS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
vs.
Lester E. Paris;
Defendant.
NO.: 11-02179
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CML PROCEDURE 3129
Lester E. Paris
525 Bosler Avenue
Lemoyne, PA 17043
TAKE NOTICE:
That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 06/04/2014 at 10:OOam
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:
525 Bosler Avenue, Lemoyne, PA, 17043
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-02179
Zucker, Goldberg & Ackerman, LLC
XFP-149577
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE:
Lester E. Paris, single person
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 5. 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 Sheriff's 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 Sheriff's Deed is delivered.
Zucker, Goldberg & Ackerman, LLC
XFP-149577
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition must be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013-3387, before presentation of the petition to the Court.
Dated:
‘,-1(az 2k-
ZUCKER, GOLDBERG & ACKERMAN, LLC
oat A. Dietterick, Esquire; PA 1.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.Q. #315944
Brian Nicholas, Esquire; PA I.D. #317240
......Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFP-149577/11
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
VIA ORDER OF COURT
Zucker, Goldberg & Ackerman, LLC
XFP-149577
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF LEMOYNE. COUNTY OF CUMBERLAND
AND STATE OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS,
TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF BOSLER AVENUE AT THE DIVIDING LINE BETWEEN
LOTS NOS. 114 AND 115, BLOCK "D", AS SHOWN ON PLAN NO. 1 OF RIVERTON, PENNSYLVANIA, SAID
PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN DEED BOOK "J", VOL.4,
PAGE 40; THENCE IN A NORTHERLY DIRECTION ALONG SAID LAST MENTIONED LINE ONE HUNDRED
FIFTY (150) FEET TO RAILROAD ALLEY; THENCE IN A WESTERLY DIRECTION ALONG THE SOUTHERN LINE
OF RAILROAD ALLEY THIRTY (30) FEET SIX (6) INCHES TO A POINT; THENCE IN A SOUTHERLY DIRECTION
ALONG A LINE AT RIGHT ANGLES WITH BOSLER AVENUE ONE HUNDRED FIFTY (150) FEET TO BOSLER
AVENUE: THENCE IN AN EASTERLY DIRECTION ALONG THE NORTHERN UNE OF BOSLER AVENUE THIRTY
(30) FEET SIX (6) INCHES TO THE POINT OR PLACE OF BEGINNING
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 525 BOSLER
AVENUE, LEMOYNE, PA, 17043.
BEING THE SAME PREMISES WHICH PATRICK A. MCCARTHY AND PAULA M. MCCARTHY, HUSBAND AND
WIFE, BY DEED DATED APRIL 7, 2006 AND RECORDED APRIL 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 273, PAGE 4679, GRANTED AND CONVEYED UNTO
LESTER E. PARIS, SINGLE PERSON.
TAX MAP NO.: 12-21-0265-204.
Zucker, Goldberg & Ackerman, LLC
XFP-149577
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A, CIVIL DIVISION
Plaintiff,
Defendant(s).
ORDER OF COURT
VS,
Lester E. Paris;
NO.; 11-02179
AND NOW, this orb -60-4 of 2012, upon consideration of Plaintiff's
MtSpecialo ion for hereby Service It is 0 'DEDJUDGED AND DECREED that Plaintiff shall serve its
Amended Complaint in Mortgage Foreclosure and Notice of Safe, if necessary, on Defendant(s) Lester E.
Paris, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged
Premises, being 525 Basler Avenue, Lemoyne PA 17043, and by mailing a copy, via Certified Mail, no
signature required and First Class U.S, Mail, Postage Prepaid with said service being valid and complete
upon such posting and mailing in accordance with,Pa,R,G.P, 430,
BYTIiE COURT: '
15( 51
J.
frM
-44471
.
14<i ZZ Ng Z16/
•
Zucker, Gotdberg & Ackerman, LLC
XFP-149577
EXHIBIT C
Zucker, Goldberg & Ackerman, LLC
XFP-149577
NOS CERT
�UNITED STATES
POSTAL SERVICE
Certificate
Mailing
U.S POSTAGE» PITNEY BOWES
This Certificate of Mailing provides evidence that mail has been presented to USPS' for mailing. This form may be used for domestic
and International mall.
Fr°' Denise Carlon, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/pn TEAM- PA - C
Tot Lester E. Paris
525 Bosler Avenue
Lemoyne, PA 17043
County of P.Q.: CUMBERLAND
P5 Form 3817, April 2007 PSN 7530-02-000-9065
,m WOr
.,
, ` 00t20°
0001387430 MAR 14 2014
To pay fee, affix stamps or meter postage
here.
FIELD
USPS
Postmark Here --
Page 1 of 1
EXHIBIT D
Zucker, Goldberg & Ackerman, LLC
XFP-149577
NTL Page 1 of 7
UNITED STATES
MilII POSTAL SERVICE®
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS for mailing. This form may ba used for domestic
and International mail.
From: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°' CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland COUhty Courthouse
One Courthouse Square
Carlisle, PA 17013
U.S. POSTAGE >> Prnv BOWES
ZIP 07090
02 Iry $ 001.2
0001387430 MAY 05 2014
To pay fee, affix stamps or meter postage
here.
Postmark Here
County of P.Q.: CUMBERLAND
P5 Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
POSTAL SERVICE®
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS* for mailing. Thls form may be used for domestic
and International mall.
f1om: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°` COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
P1OZ 90 AV10CPL9£1000
o0Z"�100 S l ZO
Z601LOd)Z
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here.
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J
NI U
NTL Page 2 of 7
UNITED STATES
POST/1L SERVICE
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic
and International mat.
From' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
To: UNKNOWN TENANT OR TENANTS
525 Bosler Avenue
Lemoyne, PA 17043
U.S. POSTAGE* PITNEY BOWES
ZIP °7°92 $ 001.20°
02 Irl
0001387430MAY 05 2014
To pay fee, affix stamps or meter postage
here,
Postmark Here
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
Pratt POSTAL SERVICE
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS* for malting. This form may be 'seed for domestic
and International mall.
Fr°m' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS
NOMINEE FOR CARDINAL FINANCIAL COMPANY, LTD.
PARTNERSHIP
P.O. Box 2026
Flint, MI 48501-2026
County of P.Q,: CUMBERLAND
P5 Form 3817, April 2007 PSN 7530-02-000-9065
1rIOZ SO AVL0CPL9EI000
°OZ OO $ Z60L0 dIZ
gaNCIe A3P4116 <<3OvLSOd s.n
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here.
Postmark Here
NTL Page 3 of 7
UNITED STATES
grafi POSTAL SERVICE
Certificate 0
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS for mailing. This form may be used for domestk
and international mall.
From` Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
U.S. POSTAGE )) PITNEY BOWES
r''g�e.. ramie.✓
aL, f�llr
ZIP 07092 $ 001.200
02 11Y
0001387430 MAY 05 2014
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here.
To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS Postmark Here
NOMINEE FOR CARDINAL FINANCIAL COMPANY, LTD.
PARTNERSHIP
1901 E. Voorhees Street, Suite C
Danville, IL 61834
County of P.Q.: CUMBERLAND
P5 Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
Mit POSTAL SERVICE
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic
and International mall.
ffem' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
Tei MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS
NOMINEE FOR CARDINAL FINANCIAL COMPANY, LTD.
PARTNERSHIP
444 Jacksonville Road
Warminster, PA 18974
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
O1 OZ SO AV1t10CPL9C1000
00Z100 $ Z60L0 dI�
o�a411111111W- %I
S3M0e A3lu f K30VISOd s n
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here.
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NTL Page 4 of 7
UNITED STATES
Cita POSTAL SERVICE?,
U.S. POSTAGE »> PITNEY BOWES
Certificate Of
Mailing
willala
..r.r.r m -
.ww..a.«..nn�..
�► 02 07092 $ 001 200
0001387430 MAY 05 2014
This Certificate of Melling provides evidence that map has been presented to USPS for mailing. Thls form may be used for domestic
and International mall.
From: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°` MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS
NOMINEE FOR CARDINAL FINANCIAL COMPANY, LTD.
PARTNERSHIP
3300 SW 34th Ave, Ste 101
Ocala, FL 34474-4438
County of P.Q,: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED ST/]TES
P::;POSTiL SERVICE,
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestk
and international mall,
From' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°t WEST SHORE SCHOOL DISTRICT
510 HERMAN AVE
LEMOYNE, PA 17043-1822
ATTN: FAITH A NICOLA
County of P.Q.: CUMBERLAND
P5 Form 3817, April 2007 PSN 7530-02-000-9065
To pay fee, affix stamps or meter postage
hare.
To pay fee, affix stamps or meter postage
here.
Postmark tic
�Rt
NTL Page 5of7
j UNITED STATES
Ma POSTAL SERVI EI -
Certificate 0
Mailing
This Certificate of Melling provides evidence that mall has been presented to USPS for milling. This fom, may be used for domestic
and international mail.
Frt,m: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°' WEST SHORE SCHOOL DISTRICT_
507 Fishing Creek Rd
Lewisberry, PA 17339
County of P.Q.: CUMBERLAND
P5 Form 3817, April 2007 PSN 7530-02-000-9065
�unnrEosrnrEs
POST/1L SERVICER
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mail has been presented to USPS• for mailing. This form may be used for domestic
and international marl.
ffOm' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°' LEMOYNE BORO
510 HERMAN AVE
LEMOYNE, PA 17043-1822
ATTN: FAITH A NICOLA
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
OZ SO AMOYOEtL8CI000
I 10
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0001387430 MAY 05 2014
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�S.a C1r j
To pay fee, affix stamps or meter postage
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Postmark H
NTL Page 6 of 7
UNITED STATES
Frail POST/1L SERViCEt
Certificate Of
Mailing
This Certificate of Mailing provMes evidence that mall has been presented to USPS• for mailing, This form may be used for domestic
and International malt.
From: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°' LANCASTER COUNTY DOMESTIC RELAIiONS OEEiCE-------- ---
-Section
SectioLL n
PO Box 83479
Lancaster, PA 17608-3479
U.S. POSTAGE }» PIT rscl 5 s
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7)P °7°92 $'-"'' 1
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0001387430 MAY 05 2014
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....•Postmark Her@
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
grallir POSTAL SERVICE
Certificate Of
Mailing
This Certificate of Melling provides evidence that nail hu been presented to USPS• for mailing, This form may be used for domestic
and International mall.
from: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
T°' CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
(Ji: So AvwO£hL8E1o00
C, Oa $ z60µ0 di?
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here.
Postmark iter
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\:\t,),\
NTL Page 7of7
UN/TEDST13TE5
POSTAL SERV10E4
Certificate
Mailing
U.S. POSTAGE»PrTNEv®owES
ZIP 07092 $ 00120•
02 1r4
0001387430 MAY. 05 2014
This Certificate of Mailing provides evidence that moll has been presented to USPS• for mailing. This form may be used for domestic
and international mall.
From' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-149577/nfe TEAM- C
PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
County of P.O.: CUMBERLAND
To pay fee, affix stamps or meter postage
here.
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
„Praia POST4L SERVICE
Certificate Of
Mailing
This Certificate of Mailing provides evidence that mall has been presented to USPS. for mailing. Thla form may be used for domestic
and International mall.
From: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
To pay fee, affix stamps or meter postage
here.
0,4J I
XFP-149577/nfe TEAM- C t
Ty: UNKNOWN SPOUSE
525 Bosier Avenue
Lemoyne, PA 17043
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
IrtOZ SO AVW0EPL8E1.000
0OrIf00 $ zoo tOdeZAmminamwAsonew 110)
490109 A3NIId «39V1SOd S fl
Postmark Here
•R
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
E La -GFF ICE
(iF THE PROTHONO IAR'
201', OCT 21 PM 2: 51
CUMBERLAND COWRY
PENNSYLVANIA
OrmE og ESE ,SKER Fr.
Wells Fargo Bank NA
vs.
Lester E. Paris
Case Number
2011-2179
SHERIFF'S RETURN OF SERVICE
03/28/2014 06:56 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 525 Bosler Avenue, Lemoyne - Borough, Lemoyne, PA
17043, Cumberland County.
03/28/2014 06:56 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ,
Notice and Description, in the above titled action, upon the within named Defendant, to wit: Lester E.
Paris, pursuant to Order of Court by "Posting" the premises located at 525 Bosler Avenue, Lemoyne
Borough, Lemoyne, PA 17043, Cumberland County with a true and correct copy according to law.
06/04/2014 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 1 Courthouse Square Carlisle Pa, 17013 at 1000 am on June 4, 2014.
He sold the same for the sum of $1.00 to Attorney Jaime Ackerman, on behalf of Wells Fargo Bank, N.A.,
being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $1,057.11 SO ANSWERS,
September 16, 2014 RON R ANDERSON, SHERIFF
(c) (curtySL.te :i,heriff. i'eleosaft. Inc.
c9 d•ea
gV
9-93 9
On March 3, 2014 the Sheriff levied upon the
defendant's interest in the real property situated in
Lemoyne Borough, Cumberland County, PA,
`Z Known and numbered as 525 Bosler Avenue,
N
Lemoyne, as Exhibit "A" filed with this
Writ and by this Reference incorporated herein.
Date: March 3, 2014
By:
���� IL)
eal Estate Coordinator
LXIII 16 .CUMBERLAND LAW JOURNAL 04/18/14
Writ No. 2011-2179 Civil Term
Wells Fargo Bank N.A.
vs.
Lester E. Paris
Atty.: Jaime R. Ackerman
ALL THAT CERTAIN lot of land
situate in the Borough of Lemoyne
County of Cumberland and State of
Pennsylvania, being more particu-
larly bounded and described as follo.
ws, to wit:
BEGINNING at a point on the
northern line of Bosler Avenue at
the dividing line between Lots Nos
114 and 115, Block "D", as shown
on Plan No.1 of Riverton, Pennsyl-
vania, said plan being recorded in
the Cumberland County Recorder's
Office in Deed Book "J", Vol. 4, Page
40; thence in a northerly direction
along said last mentioned line one
hundred fifty (150) feet to. Railroad
Alley; thence in a westerly direction
along the southern line of Railroad
Alley thirty (30) feet six (6) inches to.
a point; thence in a southerly direc-
tion along a line at right angles with
Bosler Avenue one hundred fifty (150)
feet to Bosler Avenue: thence in an
easterly direction along the northern
line of Bosler Avenue thirty (30) feet
six (6) inches to the point or place of
BEGINNING
HAVING THEREON ERECTED
a dwelling house being known and
numbered as 525 Bosler Avenue,
Lemoyne, PA, 17043.
BEING the same premises which
Patrick A. McCarthy and Paula
M. McCarthy, husband and wife,
by Deed dated April 7, 2006 and
recorded April 10, 2006 in and for
Cumberland County, Pennsylvania,
in Deed Book Volume 273, Page
4679, granted and conveyed unto
Lester E. Paris, Single Person.
TAX MAP No.12-21-0265-204.
90
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CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
Ani..ici.r_-_
2011-2179 CMI Term
Wells Fargo Bank NA
Vs
Lester E. Paris
Atty: Jaime R Ackerman
ALL THAT CERTAIN LOT
OF LAND SITUATE IN THE
BOROUGH OF LEMOYNE
COUNTY OF CUMBERLAND
AND STATE OF PENNSYLVANIA,
BEING MORE PARTICULARLY
BOUNDED AND DESCRIBED AS
FOLLOWS, TO WIT:
BEGINNING AT A POINT ON
THE NORTHERN LINE OF
BOSLER AVENUE AT THE
DIVIDING LINE BETWEEN LOTS
Nos 114 AND 115, BLOCK "D",
AS SHOWN ON PLAN NO.1 OF
RIVERTON, PENNSYLVANIA,
SAID PLAN BEING RECORDED
IN THE CUMBERLAND COUNTY
RECORDER'S OFFICE IN DEED
BOOK "J", VOL. 4,PAGE40;THENCE
IN A NORTHERLY DIRECTION
ALONG SAID LAST MENTIONED
LINE ONE HUNDRED FIFTY
(150) FEET 10. RAILROAD
ALLEY; THENCE IN A WESTERLY
DIRECTION ALONG THE
SOUTHERN LINE OF RAILROAD
ALLEY THIRTY (30) FEET SIX (6)
INCHES TO. A POINT, THENCE
IN A SOUTHERLY DIRECTION
ALONG A LINE AT RIGHT
ANGLES WITH BOSLER AVENUE
ONE HUNDRED FIFTY (150) FEET
TO BOSLER AVENUE: THENCE
IN AN EASTERLY DIRECTION
ALONG THE NORTHERN LINE
OF BOSLER AVENUE THIRTY
(30) FEET SIX (6) INCHES TO THE
POINT OR PLACE OF BEGINNING
HAVING THEREON EREC:1'ED
A DWELLING HOUSE BEING
KNOWN AND NUMBERED AS 525
BOSLER AVENUE, LEMOYNE, PA,
17043.
BEING THE SAME PREMISES
WHICH PATRICK A. MCCARTHY
AND PAULA M. MCCARTHY,
HUSBAND AND WIFE, BY
DEED DATED APRIL 7, 2006
AND RECORDED APRIL 10, 2006
IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA,
IN DEED BOOK VOLUME 273,
PAGE 4679, GRANTED AND
CONVEYED UNTO LESTER E.
PARIS, SINGLE PERSON. •
TAX MAP No.12-21-0265-204
PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
ig duly sworn according to law, deposes and says:
;tant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
ania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Tty of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
2ws and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949,
an continuously published ever since;
or publication which is securely attached hereto is exactly as printed and published in their regular
inity Weekly editions which appeared on the date(s) indicated below. That neither she nor said
subject matter of said printed notice or advertising, and that all of the allegations of this statement as
:ter of publication are true; and
al knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
:o. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
rectors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
iphin in Miscellaneous Book "M", Volume 14, Page 317.
This ad ran on the date(s) shown below:
04/13/14
04/20/14
04/27/14
Sw rn to and subscribed before 0 ay of May, 2014 A.D.
Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Holy Lynn W"'arfei, Notary Pubic
Washington Tulp., Dauphin County
My Commission Exp" res Dec. 12, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
} SS:
I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the
Sheriff's Deed in which Wells Fargo Bank, NA is the grantee the same having been sold to said grantee
on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 20th day of
February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number
2179, at the suit of Wells Fargo Bank, NA against Lester E. Paris is duly recorded as Instrument
Number 201424035.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this / day of
(9 -e -t -4-4-"L , A.D. p 7 /9'
()J
Recorder of Deeds
�� rder o ds, Cumberland County, Carlisle, PA
My Comm' ston Expires the First Monday of Jan. 2018
t r'
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
: ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 18, April 25 and May 2, 2014
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.
Lisa Marie Coyne, itor
SWORN TO AND SUBSCRIBED before me this
2 da of May, 2014
Notary
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE 80RO., CUMBERLAND CNTY
My Commission Expires Apr 28, 2018