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HomeMy WebLinkAbout11-2900 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP- 149871/hp SO awe 'R C1 a. 00 ?d a? cv-* 0=3 v7a' as Lo 31(0 Ii IN THE COURT OF COMM(N PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, vs. BRIAN T. KEESEMAN; TINA L. KEESEMAN Defendants. TO. DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENA' (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: 16 Big Suring Terrace Newville. PA 17241-9468 CIVIL DIVISION NO.. 1 a q OO cl Y1 I c rfl _ TYPE OF PLEADING , v ? CIVIL ACTION - COMPLAIN*: -,- ra , IN IN MORTGAGE FORECLOSi*g 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 CER IF[C E L A I Kimberly A Bonner Es uir I HE Y CE F E LOCATION OF . , q e THE ES T FF D BY THIS IJEN IS Pa. I.D. #89705 08 N Roa e i 1241-9472 Munici I e wt Mu Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh L. Levy, Esquire ATT Y FOR PLA Pa I.D. #306799 AT Y FI NO.: XFP 149871 Zucker, Goldberg & Ackerman, LLC XFP-149871 i IF THIS IS THE FIRST N04E 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 DE ENDANT(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 REQYIRF, 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 TOIBE 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 ? OU 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 LITIG? TION 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-149871 IN T COURT OF COMMON PLEAS OF CU BERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., : CIVIL DIVISION Plaintiff, : NO.: vs. BRIAN T. KEESEMAN; TINA L. KEESEMAN Defendants. 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 wi>hin twenty (20) days after this complaint and notice are served, by entering a written appearande personally or by attorney and filing in writing with the court your defenses or objections to toe 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. Yo may lose money or property or other rights important to you. YOU SHOULD TAKE THIS ?APER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER ORS CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW !TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICEITO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Strut Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3106 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-149871 IN T COURT OF COMMON PLEAS OF CUMBIPRLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., : CIVIL DIVISION PlainO' : NO.: vs. BRIAN T. KEESEMAN; TINA L. KEESEMAN Defendants. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelant4 en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias des ues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de u abogado una comparecencia escrita y redicando en la Corte por escrito sus defensas de, y obje Tones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla tomar accion Como se describe anteriormente, el caso puede proceder sin usted y un fallo po cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio soli itado 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 Tb DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar A! 32 S. Bedford Stre( Carlisle, PA 1701: Phone (800) 990-91 (717) 249-31 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-149871 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION Plaintiff, vs. BRIAN T. KEESEMAN; TINA L. KEESEMAN Defendants. NO.: CIVIL ACTIO? - 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 # X7801013, FT. MILL, SC 29715. 2. The Defendants, ',BRIAN T. KEESEMAN and TINA L. KEESEMAN, are individuals whose last known address is 16 Big Spring Terrace, Newville, PA 17241-9468. 3. On or about March 6, 2009, Brian T. Keeseman and Tina L. Keeseman, his wife executed a Note in favor of New Pay Financial, LLC in the original principal amount of $163,444.00. 4. On or about Marich 6, 2009, as security for payment of the aforesaid Note, Brian T. Keeseman and Tina L. Keesemap, his wife made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as norn>inee for New Day Financial, LLC a Mortgage in the original principal amount of $163,444.00 on the promises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of ',Deeds of Cumberland County on March 17, 2009, Instrument #200907805. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. The aforesaid Systems, Inc. as nominee for N pursuant to an assignment of mor and Mortgage was assigned by Mortgage Electronic Registration Day Financial, LLC to Wells Fargo Bank, NA, plaintiff herein, to be recorded. Zucker, Goldberg & Ackerman, LLC XFP-149871 6. Brian T. Keeseman and Tina L. Keeseman, his wife as tenants by the entireties are record and real owners of the of resaid mortgaged premises. 7. Defendants are n default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. 8. Plaintiff was not required to send Defendant(s) written Notice pursuant to 35 P.S. §1680.403 (c) (Homeowners' Emergency Mortgage Assistance Act of 1983, - Act 91 of 1983), prior to commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. §§1707 - 1715(z) - 18) [35 P.S. §1680.401(a)(3).]. 9. Plaintiff was not required to send Defendant(s) written notice of Plaintiffs intention to foreclose said Moi gage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this action for the reason that the original principal balance of the aforesaid Mortgage is more than the original principal balance threshold of the Act, and therefore: (a) said Mortgage Is not a "residential mortgage" as defined in 41 P.S. §101; (b) the Defendant($) 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 Defendants is as follows: Principal $160,209.37 Interest though 02/13/2011 $4,005.25 Attorneys' Fees $1,250.00 Title Search & Costs $2,500.00 Late Charges $ 155.72 Suspense Balance (S-230.00) Pro Rata MIP / PMI $ 143.93 Other $ 90.50 Total $168124.77 plus interest on the principal sum ($160,209.37) at the monthly interest rate of , plus additional late charges, and cos 1s (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, Goldberg & Ackerman, LLC XFP-149871 I WHEREFORE, Plaint pff demands judgment in mortgage foreclosure for the amount due of $168,124.77, with int est thereon at the monthly interest rate of plus additional late charges, and costs (including dditional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, Goldberg & Ackerman, LLC XFP-149871 ZUCKER, KV7?ERM N, LLC BY: Dated: March 4, 2011 Scott ie Brick, Esquire; PA I.D. #55650 Kimb rl A. Bonner, Esquire; PA I.D. #89705 Joel A A kerman, Esquire; PA I.D. #202729 Ashlei . Levy, Esquire; PA I.D. 4306799 Attorneys for Plaintiff XFP-149871 /hp 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS IS AN ATTEMPT TO CG LLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-149871 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-149871 0008MII?p Prepared By: NEW DAY FINANCIAL, LLC [Name] 8171 MAPLE LAWN BLVD., SU?TE 300 [Street Address] FULTON, MD 20759 [City, State Zip Code] 877-423-1400 [Telephone Number] After Recording Please Return Ta: TSS, LLC [Name] [Attention] P O BOX 10550 73 (Street Address] MC LEAN, VA 22102 [City, State Zip Code] 240-294-1600 [Telephone Number] UM/PIN/Tax ID: 30-09-0513-023 ?J { SQ - [S,bace Above This Line For Recording Data] V O FliA Case No. 441-8886608-703 Loan Num: 446283 MIN: 100343000004462838 PENNSYLVANIA MORTGAGE T141S MORTGAGE ("Sec rity Instrument") is given on MARCH 6, 2009. The mortgagor is BRIAN 7'. KEESEMAN AND TINA L. K ESEMAN, HIS WIFE ("Borrower"). This Security instrument is given to NEW DAY FINANCIAL, LLC I which is organized and existing and r the laws of DELAWARE, and whose address is 8171 MAPLE LAWN BLVD, STE 300, FULTON, MD 2 759 FI1A MFRS Modified The Compliance Source, Inc. 'i.vir.compliancesource.corn uasm0 Pale 1 of 10 54301 FA 02/02 Rev. 02108 ®2002, The Compliance Source, Inc. 446283 ?t9?Ll s ("Lender"), Mortgage Electronic solely as a nominee for Lender Security Instrument. MERS is c telephone number of P.O. Box 2C principal sum of ONE HUNDRI AND 001100 Borrower's note dated the same payments, with the full debt, if Instrument secures to Lender: (a renewals, extensions and modifical under Paragraph 7 to protect the s covenants and agreements under th mortgage, grant and convey to ME to the successors and assigns of M Pennsylvania: SEE LEGAL DESCRIPTION XI which currently has the address of NEWVILLE [City] TOGETHER WITH all th appurtenances, and fixtures now or covered by this Security Instrumc "Property." Borrower understands Borrower in this Security Instrumc Lender and Lender's successors at but not limited to, the right to fc including, but not limited to, releas :gistration Systems, Inc. ("MFRS") is a separate corporation that is acting d Lender's successors and assigns. MERS is the mortgagee under this tnized and existing under the laws of Delaware, and has an address and Flint, MI 48541-2026, tel. (888) 679-MFRS. Borrower owes Lender the SIXTY THREE THOUSAND FOUR HUNDRED FORTY FOUR Dollars (U.S. $163,444.00). This debt is evidenced by date as this Security Instrument ("Note"), which provides for monthly lot paid earlier, due and payable on MARCH 1, 2039. This Security the repayment of the debt evidenced by the Note, with interest, and all Ions of the Note; (b) the payment of all other sums, with interest, advanced scurity of this Security instrument; and (c) the performance of Borrower's s Security Instrument and the Note. For this purpose, Borrower does hereby 2S (solely as nominee for Lender and Lender's successors and assigns) and -RS the following described property located in CUMBERLAND County, ACHED HERETO AND MADE A PART HERE OF. NEALY ROAD Pennsylvania 17241 - 9472 ("Property Address"): [Zip Code] improvements now or hereafter erected on the property, and all casements, tereafter a part of the property. Ali replacements and additions shall also be it. All of the foregoing is referred to in this Security instrument as the and agrees that MERS holds only legal title to the interests granted by it, but, if necessary to comply with law or custom, MERS (as nominee for I assigns) has the right: to exercise any or all of those interests, including, eclose and sell the Property; and to take any action required of Lender tg and canceling this Security Instrument. BORROWER COVENA TS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and onvey the Property and that the Property is unencumbered, except for encumbrances of record. Borrow r warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. Pcnnsylvenla Mortgage FIIA HERS Modified The Compliance Source, Inc. www.compl iancesou rce.co m Page 2 of 10 -losing 54301 PA 02/02 Rev. 02108 02002, The Compliance Source, Inc. 446283 THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessme is levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and () premiums for insurance required under Paragraph 4. In any year in which the Lender must pay a mortgage nsurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in whi h such premium would have been required if Lender still held the Security Instrument, each monthly paymen shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. § 2601 et sea. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Le der for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not suf3icie t to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are plc ged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the f 11 payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obliga ed to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately rior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of I'ayme its. All payments under Paragraphs I and 2 shall be applied by Lender as follows: First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of ill.- monthly mortgage insurance premium; Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; Fourth, to amortization oft a principal of the Note; and Pennsylvania Mortgage FHA HERS Modified The Compliance Source, Inc. www. co mp liancesou rce.com Closing Page 3 of 10 54301 PA 02/02 Rev. 02/08 02002, The Compliance Source, Inc. 446283 Fifth, to late charges due u der the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, gainst loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss dire tly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security instrument, first to any delinquent amounts applied in the order of Paragraph 3, and then to prepayment of principal or (b) to the restoration or repair of the damaged property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in Paragraph 2, or charge the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosur of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all ri ht, title and interest of Borrower in and to insurance policies in fbrce shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating ircumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear expected. Lender may inspect the Property if he Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect a preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the to application process, gave materially false or inaccurate information or statements to Lender (or failed to rovide Lender with any material information) in connection with the loan evidenced by the Note, including, ut not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. I this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrow r acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the erger in writing. 6. Condemnation. The roceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigne and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid tinder the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the ndebtedness under the Note and this Security Instrument, first to any Pconsviv 4nia Mortgage F1IA 1%tEkS Modified The Compliance Source, laic. www.comptiancesource.com Page 4 of 10 54301 PA 02/02 Rev. 02/08 02002, The Compliance Source, Inc. 446283 delinquent amounts applied in the rder provided in Paragraph 3, and then to prepayment of principal. Any application of the proceeds to the p incipal shall not extend or postpone the due date of the monthly payments, which are referred to in Paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstan ing indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in Paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest i the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by Paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in Paragraph 2. Any amounts disbursed b Lender under this Paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Under shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to he payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith tie lien by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate o prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Le ider subordinating the lien to this Security Instrument, If Lender determines that my part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender y give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actin s set forth above within 10 days of the giving of notice. 8. Fees. Lender may toll et fees and charges authorized by the Secretary. 9. Grounds for Accelerat on of Debt. (a) Default. Lender ay, except as limited by regulations issued by the Secretary in the case of payment defaults, require immediat payment in full of all sums secured by this Security Instrument if- (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior t or on the due date of the next monthly payment, or (ii) Borrower de aults by failing, for a period of thirty days, to perform any other obligations contained in th s Security Instrument. (b) Sale Without C edit Approval, Lender shall, if permitted by applicable law (including section 341(d) of the Gam-St Germain Depository Institutions Act of 1982, 12 U.S.C. § 1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all the sums secured by this Security Instrument if: (i) All or part of he Property, or a beneficial interest in a trust owning all or part of the Property, is sold or oth rwise transferred (other than by devise or descent), and rennsytvama mortgage Closing FHA MERS Modified The Compliance Source, Inc. Page 5 of 10 54301 PA 02/02 Rev. 02/0 Nviviv.compliancesource.com 02002, The Compliance Source, Inc. 446283 (ii) The Property residence, or the purchase not been approved in acco (c) No Waiver. If ci in full, but Lender does not require events. is not occupied by the purchaser or grantee as his or her principal or grantee does so occupy the Property, but his or her credit has lance with the requirements of the Secretary. cumstances occur that would permit Lender to require immediate payment such payments, Lender does not waive its rights with respect to subsequent (d) Regulations of 1 UA Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the ca ,,"e of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument oes not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not In ured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insur nce under the National Housing Act within 60 days from the date hereof, Lender may, at its option require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorize agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Ins rument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to r mit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borr wer has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failu a to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and a penses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the comme cement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in he future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance by Lender Not a Waiver. Extension of the time of payment or modification of amorti• ation of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of ny demand made by the original Borrower or Borrower's successors in interest- Any forbearance by Lend r in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Inst men[ shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of Paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co-sig s this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to in rigage, grant and convey that Borrower's interest in the Property under the rennsylvania Mortgage FHA NtERS Modified The Compliance Source, It,e. www.complinucesource.com Page 6 of 10 54301 PA 02102 Rev. 02/08 02002, The Compliance Source, Inc. 446283 terms of this Security Instrument; Instrument; and (c) agrees that Len any accommodations with regard t, consent. 13. Notices. Any notice delivering it or by mailing it by fi notice shall be directed to the Prop, Any notice to Lender shall be giver designates by notice to Borrower. i been given to Borrower or Lender v 14. Governing Law; Se-, the law of the jurisdiction in whicl Security Instrument or the Note cot this Security Instrument or the Note provisions of this Security Instrumc 15. Borrower's Copy. B (b) is not personally obligated to pay the sums secured by this Security ler and any other Borrower may agree to extend, modify, forbear or make the term of this Security Instrument or the Note without that Borrower's to Borrower provided for in this Security Instrument shall be given by st class mail unless applicable law requires use of another method. The rty Address or any other address Borrower designates by notice to Lender. by first class mail to Lender's address stated herein or any address Lender ,ny notice provided for in this Security Instrument shall be deemed to have hen given as provided in this Paragraph, arability. This Security Instrument shall be governed by Federal law and the Property is located. In the event that any provision or clause of this flicts with applicable law, such conflict shall not affect other provisions of which can be given effect without the conflicting provision. To this end the it and the Note are declared to be severable. rrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property hat is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appr priate to normal residential uses and to maintenance of the Property. Borrower shall promptly ive Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or r gulatory authority, that any removal or other remediation of any Hazardous Substances affecting the Property i necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental La . As used in this Paragrap 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environ ental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum prod cts, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this Paragraph 16, "Environmental Law" means federal laws and laws of th jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Bo ower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive a') rents and revenues of the Property as trustee for the benefit of Lender and Pennsylvania Mortgage FIIA HERS Modified "The Compliance Source, Inc. '%$V",.complianccso urce.co m Page 7 of 10 t-iosing 54301 PA 02/02 Rev. 02/08 02002, The Compliance Source, Inc. 446283 Borrower. This assignment of rem s constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of L nder only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all rents due and unpaid t Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not execute any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this Paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application f rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under Paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding and invoke any other remedies permitted by applicable law. Le der shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Paragraph 18, including, but not limited to, reasonable attorneys' fees and costs of title evidence to the extent per itted under applicable law. If Lender forecloses this ecurity Instrument, Lender shall give notice in the manner provided in Paragraph 13 and to Borrower a d any other persons prescribed by applicable law. Lender shall also publish and post the notice of s le, and the property shall be sold, as prescribed by applicable law. Lender or its designee may purch se the property at any sale. The proceeds of the sale shall be applied in the manner prescribed by applica le law. If the Lender's interest in is Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Pa agraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Fo closure Act of 1994 ("Act") (12 U.S.C. § 3751 et se .) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in t e preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payme t of all sums secured by this Security Instrument, this Security instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument. Bo .Tower shall pay any recordation costs. Lender may charge Borrower a The for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted unde applicable law. 20. Waivers. Borrower, t the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce is Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period Borrower's time to reinstate provided in Paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mo Ttgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Prop rty, this Security Instrument shall be a purchase money mortgage. F11A btERS Modired The Compliance Source, Inc. www.complinucesource.com Page 8 of 10 54301 PA 02102 Rev. 02108 02002, The Compliance Source, inc. 446283 23. Interest Rate After Judgement. Borrower agrees that the interest rate payable after a judgement is entered on the Note or in an actin of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [C eck applicable box (es)]. ? Condominium Rider ? Graduated Payment Rider ? Other [specify] ? Planned Unit Develop ent Rider (I Growing Equity Rider THIS IS A CONTRACT UNDER ?EAL AND MAY BE ENFORCED UNDER 42 PA.C.S. §5529(b). BY SIGNING BELOW, ?orrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any ride s) executed by Borrower and recorded with it. (Seal) 2(Seal) KEESEMAN -Borrower TINA L KEESEMAN -Borrower [Printed Name] [Printed Name] (Seal) -Borrower [Printed Name] (Seal) -Borrower [Printed Name] -.....,,.....,» ".U..gare FHA DIERS Moditted The Compliance Source, Inc. www.complia ncesource.co m Page 9 of 10 54301 PA 02102 Rev. 02/08 02002, The Compliance Source, Inc. 446283 Certificate of Residence: I/We do hereby certify that the pre interest is 3300 S. W. 34`1, Avenue, 2026, Flint, MI 48501-2026. address of the within named mortgagee, assignee or person entitled to 101, Ocala, FL 34474, and the Post Office Box address is P.O. Box NEW DAY FINANCIAL, LLC BY AjyA., NwIte Its: i / elile lt' ACKNOWLEDGMENT State of PA County of CUMBERLAND On this 6th day of ARCH, 2009, before me, the undersigned officer, personally appeared BRIAN T KEESEMAN AND TIN L KEESEMAN whose name is subscribed to the the purposes therein. In witness whereof, I UUMMONWEALTH OF PENNSYLVAI Notarial Seal learme L. Young Notary Pubic Penn TIP., Ctxnbertand County 1W COr=W n Explrm July 30, 2010 Member, Pennsylvania Association of Nola (Seal) z- 7 ?,? o?,,•... -0%0 N FICA XIERS 11todified The Compliance Source, Inc. Nutir.compliancesource.com , known to me (or satisfactorily proven) to be the person instrument, and acknowledged that he (or they) executed the same for set my hand and official seal. (arv (-? W, 4 44 f2 Qr- Notatk.ublic anne_ ?... ?u? Printe Name Title of Officer J My Commission Expires: Joy '3(} o0 /Q Page 10 of 10 54301 PA 02/02 Rev. 02/08 02002, The Compliance Source, Inc. 446283 SCHEDULE "A" ALL THE CERTAIN IMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLkND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE, SR. AND H. DAVID MILLER, OR., AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 3, PAGE 19, AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD, TOWNSHIP ROAD T-353, AT THE NOR HWESTERN CORNER OF LOT NO. 4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN; THENCE BY SAID LOT NO. 4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN; THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE-DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT T SOUTHEASTERN CORNER OF LOT NO. 6 AS SHOWN ON THE ABOVE-DESCRIBED SUBDIVISION PLAN; THENCE BY SAID LOT NO. 6, NORTH 37 DEGREES 9 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN MEALY ROAD, TOWNSHIP ROAD T-353; THENCE IN SAID ROAD, SOUTH 2 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD, THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 OSS ACRES AND BEING DESIGNATED AS LOT NO. 5 AS SHOWN ON THE AB DESCRIBED SUBDIVISION PLAN. BEING THE SAME PR PERTY CONVEYED TO BRIAN T. KEESEMAN AND TINA L. KEESEVH N, HIS WI BY DEED FROM LEE D. KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WI RECORDED 12/21/1995 IN DEED BOOK 132 PAGE 1126, IN THE OFFICE OF HE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA. TAX ID#1 30-09-0513-023 ROBERT P. ZIl RECORDER OF CUMBERLAND I 1 COURTHOUSE CARLISLE, PA 717-240-63 Instrument Number - 200907805 Recorded On 3/17/2009 At 10:53:3 * Instrument Type - MORTGAGE Invoice Number - 39335 * Mortgagor - KEESEMAN, BRIAP * Mortgagee - MORTGAGE ELEC' * Customer - TSS LLC * FEES STATE WRIT TAX STATE JCS/ACCESS TO JUSTICE RECORDING FEES - ; RECORDER OF DEEDS PARCEL CERTIFICATION ; FEES AFFORDABLE HOUSING ti COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID ',GLER DEEDS 'OUNTY SQUARE 17013 AM User ID - AF T $0.50 10.00 25.50 10.00 11.50 $2.00 $3.00 62.50 * Total Pages - 12 REGISTRATION SYSTEMS INC Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA ce cups RECORDER O D EDS r?ao " - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. II?IIN 1111111141111111111 VERIFICATION Jak&Nq?- Esquire hereby states that he is attorney for Wells Fargo Bank, N.A. in this matter, that Plaintiff is outside the jurisdiction of the court and or the Verification could not be obtained within the time allowed for the filing of the pleading, that 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 u ersigned's mte ,to substitute a verification from Plaintiff ass on as it is received by ounrdel The undersigned understands that this statement i m (i(ttt t e enalties of 18 Pa. C.S. Sec. 4904 relating to unswor falsification to authoriti . Dated: 3 i Scott A.`Oi?tterick, Esquire; PA I.D..#55650 Kimberly A'. Bonner, Esquire; PA I.D. #89705 Joel A. ?ckerman, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 Attorneys for Plaintiff Zucker, Goldberg & Ackerman, LLC XFP-149871 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FILED-OFFIcc Sheriff OF THE PROTH0140TARY Jody S Smitho Chief Deputy 2011 APR I I PM 12: 58 Richard W Stewart CUMBERLAND COUNTY Solicitor OF' PENNSYLVANIA Wells Fargo Bank NA vs. Case Number Brian T. Keeseman (et al.) 2011-2900 SHERIFF'S RETURN OF SERVICE 03/15/2011 03:58 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Brian T. Keeseman, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Brian T. Keeseman. Request for service at 408 Nealy Road, T-353, Newville, Pennsylvania 17241 is vacant. Brian T. Keeseman currently resides at 16 Big Spring Terrace, Newville, Pennsylvania 17241. 03/15/2011 05:10 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 15, 2011 at 1710 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Brian T. Keeseman, by making known unto himself personally, at 16 Big Spring Terrace, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. I AEL BAR ICK, bEOUTY 03/16/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Brian T. Keeseman, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Brian T. Keeseman. Request for service at 60 N. East Street, Apartment 2, Carlisle, Pennsylvania 17013 the defendant was not found. Brian T. Keeseman currently resides at 16 Big Spring Terrace, Newville, Pennsylvania 17241. 03/21/2011 04:27 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Tina L. Keeseman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Tina L. Keeseman. Request for service at 408 Nealy Road, T-353, Newville, Pennsylvania 17241 is vacant. NOAH CLINE, DEPUTY 03/29/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Tina L. Keeseman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Tina L. Keeseman. Request for service at 16 Big Spring Terrace, Newville, Pennsylvania 17241 the defendant was not found. The Defendant's Son advised Deputies, Tina L. Keeseman moved to 65 N. East Street, Apartment 6, Carlisle, Pennsylvania. 03/29/2011 06:05 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on March 29, 2011 at 1805 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Tina L. Keeseman, by making known unto herself personally, at 60 N. East Street, Apartment 2, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. (?; CountySuite Shenff, Teleosoft. Inc. HA A L, Of!PUTY SHERIFF COST: $170.00 April 05, 2011 SO ANSWERS, T RON R ANDERSON, SHERIFF ici '_..OuM SU'.te Shenff TeIeeseft. Irc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 2011-2900 VS. j ra • c~ BRIAN T. KEESEMAN; TINA L. ~~ KEESEMAN; ~ Defendant(s). ~~ ~ <~ ~_~ ~. c v ~ U~ c~~ AMENDMENT TO MOTION FOR LEAVE TO AMEND COMPLAIN'T"`~ 1. No Judge has previously ruled on this matter. 2. Plaintiff attempted to reach concurrence of the Defendants, however, concurrence was could not obtained. ZUCKER, GOLDBERG & ACKERMAN ~~^ ~~ BY:~1, ~t~~ Scott A. Dietterick, Esquire PA LD. # 55650 Kimberly A. Bonner, Esquire PA LD.#89705 Joel A. Ackerman PA LD.#202729 Ashleigh L. Marin, Esquire PA I.D.#306799 Ralph M. Salvia, Esquire PA I.D. #202946 Jamie R. Ackerman, Esquire PA LD. #311032 Attorneys for Plaintiff 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 908-233-8500 FAX 908-233-1390 ,-4 ;i.;. J r..., J.J `{ ~ -) ~~.. ~ ~- ~~ LEONARD B. ZUCKER MICHAEL S. ACKERMAN JOELACKERMAN* RICHARD P. HABER** FRANCES GAMBARDELLA TANE[SHA J. INGRAM MILICA A.FATOVICH BRIAN C. NICHOLAS*** *ALSO MEMBER OF NY AND CA BAR **ALSO MEMBER OF PA BAR ***ALSO MEMBER OF NY A'VD ME BAR ****MEMEER OF PA BAR ONLY OF COUNSEL: SCOTT A. DIETTERICK, ESQ. **** KIMBERLY A. BONNER. ESQ.**** August 14, 2012 200 SHEFFIELD STREET- SUITE 301 P.O. BOX 1024 MOUNTAINSIDE, NJ 07092-0024 TELEPHONE: 908-233-8500 FACSIMILE: 908-233-1390 E-MAIL: officeCaazuckergoldberg_com For payoff/reinstatement figures Please send your request to: zuckergoldberg.com/pr REPLY TO NEW JERSEY ADDRESS Cumberland County Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Wells Fargo Bank vs. Brian T. Keeseman; Tina L. Keeseman Docket No.: 11-2900 Dear Sir or Madam: F )UNDED IN 1923 AS ZUCK R & GOLDBERG MAURICE J. ZU 'KER (1918-1979) LOU1S D. GOLD ERG (1923-1967) LEONARD H. GOLD ERG (1929-1979) BENJAMIN NEISS (1949-1981) Pennsylvania Office: P.O. Box 650 Hershey, PA 17033 717-533-3560 Fax: 717-533-3562 Enclosed, please find an original and one (1) copy of an Amendment to the Motion for Leave to Amend Complaint to be filed in the above-referenced matter. Please file upon receipt and time- the extra copy and return it to me in the attached self-addressed, stamped envelope. Should you have any further questions or require additional documentation, please feel free to our office. Sincerely, CKER GOMLDBERG & ACKERMAN ~' l~'~l` R 1 h .Salvia p RMS:mse Enclosures cc: Court Administrator (w/encl.) ZUCKER, GOLDBERG & ACKERMAN ATTORNEYS AT LAW WELLS FARGO BANK. N.A., Plaintiff v. BRIAN T. KEESEMAN; TINA L. KEESEMAN, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 11-2900 IN RE: PLAINTIFF' S MOTION AND AMENDED MOTION FOR LEAVE TO AMEND COMPLAINT ORDER OF COURT AND NOW, this 23rd day of August, 2012, upon consideration of Motion and Amended Motion for Leave To Amend Complaint, a Rule is hereby is upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Scott A. Dietterick, Esq. .~ Kimberly A. Bonner, Esq. Joel A. Ackerman, Esq. Ashleigh L. Marin, Esq. Ralph M. Salvia, Esq. Jamie R. Ackerman, Esq. 200 Sheffield Street Suite 301 Mountainside, NJ 07092 Attorneys for Plaintiff V Brian T. Keeseman ~ Tina L. Keeseman 408 Nealy Road T-353 Newville, PA 17241-9472 Defendants, pro Se ~,, ~~~ ~ c~ Christylee .Peck, J. ~; G'7 N r z• ru cx~ s c ~, r~ "'~ f,~1 ~~ --~a ~~, ~~, ..f ,~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ' Wells Fargo Bank, N.A. CIVIL DIVISION ~; ~ ~.~, ~ , ~ , ~ ..~. ~ , _~, Plaintiff, NO :2011-2900 ~`~'~ `_ -` `~`~ . vs. ~ ~ ~ ; - c:.~ ~~ BRIAN T. KEESEMAN; TINA L. ~~ ~~ Ln ~„ ~ ~-, KEESEMAN; ~~' r Defendant(s). =~' . ~.- --~ ~"' • "~ c MOTION TO MAKE RULE ABSOLUTE AND NOW, comes the Plaintiff, by and through their attorneys, Zucker Goldberg & Ackerman, and file this Motion to Make Rule Absolute as follows: 1. On or about August 7, 2012, Plaintiff filed its Motion for Leave to Amend Complaint ("Motion"). 2. On or about August 23, 2012, this Honorable Court issuing a Rule upon the Defendant(s) to show cause why the Motion should not be granted ("Rule"). A true and correct copy of said Rule is marked as Exhibit "A", attached hereto and made a part hereof. 3. On September 20, 2012, Defendant(s) was/were served with a true and correct copy of the Rule and Petition as evidenced by the Certificate of Service attached hereto as Exhibit "B." 4. The Rule required Defendant(s) to file an answer to the Petition twenty (20) days after service. 5. To date, no answer has been filed. WHEREFORE, Plaintiff respectfully requests that this Honorable Court make the Rule absolute by allowing Plaintiff to file an Amended Complaint in the same form as attached to its Motion as Exhibit "B." Respectfully Submitted: ZUCKER, GOLDBERG & ACKERMAN BY: Scott A. Dietterick, Esquire PA I.D. # SS6S0 Kimberly A. Bonner, Esquire PA I.D.#89705 Joel A. Ackerman PA I.D.#202729 Ashleigh L. Marin, Esquire PA I.D.#306799 Ralph M. Salvia, Esquire PA I.D. #202946 Jamie R. Ackerman, Esquire PA I.D. #311032 Attorneys for Plaintiff 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 908-233-8S00 FAX 908-233-1390 P :~ WELLS FARGO BANK. IN THE COURT OF COMMON PLEAS OF N.A., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL ACTION -LAW BRIAN T. KEESEMAN; TINA L. KEESEMAN, Defendants NO. 11-2900 IN RE: PLAINTIFF' S MOTION AND AMENDED MOTION FOR LEAVE TO AMEND COMPLAINT ORDER OF COURT AND NOW, this 23rd day of August, 2012, upon consideration of Plaintiff's Motion and Amended Motion for Leave To Amend Complaint, a Rule is hereby issued upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. Scott A. Dietterick, Esq. Kjr~iberly A. Bonner, Esq. oel A. Ackerman, Esq. Ashleigh L. Marin, Esq. Ralph M. Salvia, Esq. Jamie R. Ackerman, Esq. 200 Sheffield Street Suite 301 Mountainside, NJ 07092 Attorneys for Plaintiff Brian T. Keeseman Tina L. Keeseman 408 Nealy Road T-353 Newville, PA 17241-9472 Defendants, pro Se BY THE COURT, ~ s.. ~-, c '~'^- c-s Christylee .Peck, J. ~ i ~ ~x 7-"~ N -~ ~ -~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN~~.', ~ , PENNSYLVANIA ~ , ;:~ _: ~ Wells Fargo Bank, N.A. CIVIL DIVISION rrt~ ~ ~ cn 'r''~- ~ ~:;~~. . Plaintiff ' ~ ~ N ~ rw; , NO.: 2011-2900 ~ o ='''=-`' vs. ~ ~., ~ ~ --- BRIAN T. KEESEMAN; TINA L. ~ ~ -- _ KEESEMAN; ~' ~ - Defendant(s). CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Rule dated August 23, 2012 was served on the following 20th of September, 2012, via First Class U. S. Mail, Postage Pre-paid: BRIAN T. KEESEMAN TINA L. KEESEMAN 16 Big Spring Terrace 60 North East Street, Apt2 Newville, PA 17241-9468 Carlisle, PA 17013-2563 ZUCK~R~ (GOL ERG & ACKERMAN, LLC BY: ~~'". C" Dated: September 20, 2012 Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Ralph M. Salvia, Esquire; PA I.D. #202946 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 Attorneys for Plaintiff XFP-149871 /hp 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergol dberg. com Zucker, Goldberg & Ackerman, LLC XFP-149871 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. BRIAN T. KEESEMAN; TINA L. KEESEMAN; Plaintiff, Defendant(s). CIVIL DIVISION NO.: 2011-2900 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct co f the foregoing Motion o M Rule Absolute was served on the following this day of 2012, via First Class U. S. Mail, Postage Pre-paid: Brian Keeseman - 16 Big Spring Terrace, Newville, PA 17241-9468 Tina L. Keeseman - 60 North East Street, Apt2, Carlisle, PA 17013-2563 ZUCKER, GOLDBERG & ACKERMAN BY: /`~ "' Scott A. Dietterick, Esquire PA I.D. # 55650 Kimberly A. Bonner, Esquire PA I.D.#89705 Joel A. Ackerman PA I.D.#202729 Ashleigh L. Marin, Esquire PA I.D.#306799 Ralph M. Salvia, Esquire PA I.D. #202946 Jamie R. Ackerman, Esquire PA I.D. #311032 Attorneys for Plaintiff 200 Sheffield Street, Suite 301 Mountainside, NJ 07092 908-233-8500 FAX 908-233-1390 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION vs. BRIAN T. KEESEMAN; TINA L. KEESEMAN; Plaintiff, NO.: 2011-2900 Defendant(s). ORDER OF COURT AND NOW, this /5~~day of ~lrL~il~ct,1,,2012, upon consideration of Plaintiff s Motion to Make Rule Absolute, it is hereby ORDERED, ADJUDGED and DECREED that the Rule issued on August 23, 2012 is made absolute and Plaintiff is allowed to file an Amended Complaint in the same form as attached to its Motion as Exhibit "B." N ~' rn ~ o -c ~--- ~ N~ - a '''C, Z-' ~ CJ ~~ -.?~, ~..) ~ Q , ~ G7 ~"C W ~ -, ;'' __r 'r:> �*t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN$ rnC3 rrj— m Wells Fargo Bank, N.A., CIVIL DIVISION �r �U Eo Plaintiff No.: 2011-2900 Zc vs. ISSUE NUMBER: y O { BRIAN T. KEESEMAN; TINA L. KEESEMAN; TYPE OF PLEADING: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 408 Nealy Road, Newville, PA 17241-9472 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-149871 iZ� a g� 3a7 Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC j►/o�X�i 14�/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 2011-2900 BRIAN T. KEESEMAN; TINA L. KEESEMAN; Defendants. 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 Complaint within the appropriate time limits from service thereof, and assess Plaintiffs damages as set forth in Amended Complaint: Amount as set forth in Amended Complaint $182,106.01 plus interest on the judgment amount ($182,106.01) from May 11, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 16 Big Spring Terrace 60 North East Street, address is: Newville, PA 17241-9468 Apt 2 Carlisle, PA 17103 ZUCKER, GG A & A Dated: gy; Y/� Joel A. oerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-149871 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 3.0a WJ Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2011-2900 BRIAN T. KEESEMAN; TINA L. KEESEMAN; Defendants. 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 1, 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. ZUCKER, GOLBE G &ACKERM LLC Dated: ���I %y BY; �� � Joel AA. ckeftaan, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 ®/'Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-149871 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Sworn to and subscribed before me This ,{^ day of �� I 20 1 /> J PAUL C.NADRATOWSKI o n A/ Notary Public of New Jersey n ` ` } ID#2407850 Not ry Public My Commission Expires 4/27/2016 My Commission Expires: Zucker, Goldberg&Ackerman, LLC XFP-149871 Department of Defense Manpower Data Center aes ttaa,m:Ap."-�taazs$3.0 ` SCFA 3.a Status Report � t Pursuant to Servicemembers Civil Relief Act Last Name: KEESEMAN First Name: BRIAN Middle Name: T Active Duty Status As Of: Apr-11-2013 On Ache Duty on ACWW Duty stall Data Active Duty Stan Date Agave Duty EM Dato statue Sarvka Carnponeni NA NA No NA TWs Wo,onso meats the h9viduals'native duty statue based m 1W ANM Duty Status Date tuftA Duty WNtbr 3$7 Day,of Acwt,Duly$WoW Date Activo Duty Stan Dare AotM1 Duty amt Data $tatug $oMCO Componanl NA NA No NA Thls raSWW,maacts where the IWAI al Mn active duty status S42Wr 387 days proatlinp pre soeve Duly Status Date Ter McWWr oriila"m Vnit Was Natilled of o futom Csl p to ANve Duy an Ache Duty$iniva Date Draw NotHfmllon Start Date order NOdpcaWn EM Date Status sotsoo,Compatmt NA NA No NA TMs mEWrso ra%va,*WW a,We MMduel or lROW,uM hm racoNOli sally noucation to na on fm goo o 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,NOAH,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. At e r Mary M.Snavely-Dixon,Director Department of Defense•Manpower Data Center 48M Mark Center Drive,Suite 04E25 Arlington,VA 22350 Thebefense Manpower Date 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 core and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at sea,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 persons Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLOR.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 maybe 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 his/her 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 of xeir 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 parade. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many fimes 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: Q20CN6C8UOBAM00 Department of Defense Manpower Data Center Across as dt:Apr•11-24130237:46 SCRA 3.6 Status Report' K/ Pursuant to Serviceme nben Civil Relief Act Last Name: KEESEMAN First Name: TINA Middle Name: L Active Duty Status As Of: Apr-11-2013 On AWW bury On ACNo Duty slatus Dale Mlhe Duly Stan Date AGgvp Dory EM ads, stows sorvke cempommt NA NA No NA This rospoove ra600ts be IMivMuoh'edrvd duty ataws based oo the Active Ouy Slaws Dale the Moue Outyl4 M 367 Day9 or A Ouy sbtoS Dore Acihro Duty Start Dab ACNO Duty EN Oslo Sbtue some,canponont NA NA No NA Thh respaae mAects Mars be todMduot loft=M duty Lotus within 367 dare preceding oa ACNo Duty Shwa Oab The Member or HWHer Urdi was Nelaed of a Future Ca p b AcM Duty on Au"Duty Sirius Owe Ord.,NOddeolion Scot Dale Order Notification End Dab Status some,component NA NA No NA TNa neppnoa relloctr Maths,Po adM,dual a!defier evil has recabod Cray rwdrics3ari le topon la row-dory 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. 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 at 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:hftp://www.defenselink.mil/faq/pisIPC09SLDR.html. 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 his/her 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 consocutive 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 of 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),Metros 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: C22DO668YOBAF40 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 2011-2900 BRIAN T. KEESEMAN; TINA L. KEESEMAN; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Ord r, Decree or Judgment was entered in the above captioned proceeding on �111��j [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $182,106.01 plus sts. w'Z) rothon, Zucker, Goldberg&Ackerman, LLC XFP-149871 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 2011-2900 BRIAN T. KEESEMAN;TINA L. KEESEMAN; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: TINA L. KEESEMAN 60 North East Street,Apt 2 Carlisle, PA 17103 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an rd r, Decree or Judgment was entered in the above captioned proceeding on is [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $182,106.01 plus costs. a o honotary Zucker, Goldberg&Ackerman, LLC XFP-149871 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff �wu of G¢mLrt.4 Jody S Smith {� Chief Deputy F�i(G1 Richard W Stewart L1 Solicitor OFFIGE OF THE SHERIFF t Wells Fargo Bank NA Case Number vs. Brian T. Keeseman(at al.) 2011-2900 SHERIFF'S RETURN OF SERVICE 03/15/2011 03:58 PM-Ronny R.Anderson, Sheriff,who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Brian T. Keeseman, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Brian T. Keeseman. Request for service at 408 Neely Road,T-353, Newville, Pennsylvania 17241 is vacant. Brian T. Keeseman currently resides at 16 Big Spring Terrace, Newville, Pennsylvania 17241. 03/15/2011 05:10 PM-Michael Barrick, Deputy Sheriff,who being duly swom according to law, states that on March 15,2011 at 1710 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant,to wit: Brian T. Keeseman, by making known unto himself personally, at 16 Big Spring Terrace,.Newville,Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. I HAEL BAR ICK,DEPUTY 03/16/2011 Ronny R.Anderson, Sheriff,who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Brian T. Keeseman, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Brian T. Keeseman. Request for service at 60 N. East Street,Apartment 2, Carlisle, Pennsylvania 17013 the defendant was not found. Brian T. Keeseman currently resides at 16 Big Spring Terrace,Newville,Pennsylvania 17241. 03/21/2011 04:27 PM-Ronny R.Anderson, Sheriff,who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Tina L. Keeseman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Tina L. Keeseman. Request for service at 408 Neely Road, T-353, Newville, Pennsylvania 17241 is vacant. NOAH CLINE, DEPUTY 03t2912011 Ronny R.Anderson,Sheriff,who being duly swom according to law,states that he made a diligent search and inquiry for the within named defendant to wit: Tina L. Keeseman, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Tina L. Keeseman. Request for service at 16 Big Spring Terrace, Newville, Pennsylvania 17241 the defendant was not found. The Defendant's San advised Deputies, Tina L. Keeseman moved to 65 N. East Street,Apartment 6, Carlisle, Pennsylvania. 03/29/2011 06:05 PM-Shawn Gutshall, Deputy Sheriff,who being duly sworn according to law, states that on March 29, 2011 at 1805 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant,to wit:Tina L. Keeseman,by making known unto herself personally, at 60 N. East Street,Apartment 2,Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. (C)G tyWle SheNI.Tel..,Irc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2011-2900 BRIAN T. KEESEMAN TINA L. KEESEMAN Defendant. IMPORTANT NOTICE TO: BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 DATE OF NOTICE: 5/6/2011 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.: 2011-2900 BRIAN T. KEESEMAN TINA L. KEESEMAN Defendant. ATTSOEIWCllZTAIV'LE TO: BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 FECHA DEL AVISO:5/6/2011 L==A IN IMM rxA PC RQ E HA FAT I Am>-E TQWAR LA ACC[CI'N IN I= CASO A Ala'q 5 QL.E LMM TaVIE ACCICN EE\TIM 1E LOS PREDMVIDS PIFZ(KC ERAS ICE LA FECHA EEFSTE AN=, SE PCE1--E E 1CTAR UNFJ4-L0H'1TCCNI ASUYASNLLEUAR SEACABOUNANISTAYLMMFL=E FERCEP, SU PPCFEEEAD Y OIRCS 11ad3CIIDS EVPClUANDES LT= !E� LLEUAR EKIE DO DLWEN D E% L'IATAIMIENM A SU ABOCzd,DO S[ LMM NC TI ENM LN ABOGADO O NO PLFSE PAGAR LNQ UAYA O LLAA E LA ORCINA AE000 ENT_dCADA PARA QUE LE IINICE04EN DaNLE PUSS CCNSEQLIR AlYULAl I133Ad. r4MCETODIUE D&I-AWVER13EFFIRAT.S99MCE 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 ZUCKEB, GOLDBERG&ACICERIAN BY s�rA Dieffeick Soott A Diettmdc,EscWe Attu neys for 0 ainuff PA ID.# 55650 200 Sheffield Street,Siute301 P.O. B�1024 Nl atwnside,N7 07092-0024 (717) 533-3560 FIRST CLASS U S, MAIL,PCISTAGE PREPAID 149871 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2011-2900 BRIAN T. KEESEMAN TINA L. KEESEMAN Defendant. IMPORTANT NOTICE TO: TINA L. KEESEMAN 60 North East Street,Apt 2 Carlisle, PA 17103 DATE OF NOTICE: 5/6/2011 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.: 2011-2900 BRIAN T. KEESEMAN TINA L. KEESEMAN Defendant. AVb5OIl►�i�TANIE TO: TINA L. KEESEMAN 60 North East Street,Apt 2 Carlisle, PA 17103 FECHA DEL AVISO:5/6/2011 L=ESTA FNREE TxA PCRQL E HA FAUADD LE Ta1AR LA ACCICI\ EN ESIE CASQ A 11ENU� QUE LKM TQ\4E ACCICN IEV= DE LOG FR DXRv 1S DdE?(Ko DIAS DE LA FECI-IA EEESIE Xvb , SE PUEEE LFCFAR U N FALLO E N CCD I SOYASENUF-VARSEAC_ADDLU\AVLSTAYLMMP[JECF PEI . SU PPCFEEEAD Y CTRCIS I %7S IlVFK)RrATTIES LS= 1 LLEVAR ME DO 3-W NM R TAIMI NM A SU ABC 3ADQ SI LMM NC TIENIE LN ABOC.a.DO O ND PILE CE PAGAR U\K)� VAYA O LLAIVE LA CHCINA ARAJO PCICADA PARA CXU LE Il N DCI\EE PCELE CCNSEQiAZ AYUL74 IE r4MCETODIIIIMD&I-ANNYIR13MTFEF1A][ SER%4CE 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 ZUC3U2.GOLDBERG&AC CE[n4AN BY S3dtA- Ditttaick Scott A 1hetteric1c,E--zWe Attorneys for Pl airmff PAID. # 55650 200 Sheffie[dStreet,Suite 301 P.O. Bcx 1024 Moru>tai =c1—,M 07092-0024 (717)533-3560 FIRST CLASS U.S.MAIL,PCSTAGE PREPAID 149871 IN TI3E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 2011-2900 vs. BRIAN T.KEESEMAN; TINA L. ICEESEMAN Defendants. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Amended Complaint in Mortgage Foreclosure was served on the following 30th of January, 2013, via First Class U. S. Mail, Postage Pre-paid: BRIAN T. KEESEMAN TINA L. KEESEMAN 16 Big Spring Terrace 60 North East Street,Apt2 Newville, PA 17241-9468 Carlisle, PA 17013-2563 ZUCKhR, GO7/t BERG & ACKERMAN, LLC BY: (�j'.)I , Dated: January 30, 2013 Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Ralph M. Salvia, Esquire; PA I.D. #202946 Joel A. Ackerman, Esquire; PA LD. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 Attorneys for Plaintiff XFP-149871/hp 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Off?ce @zuckergoldberg,corn Zucker, Goldberg&Ackerman,LLC XFP-149871 %pa57� vrcE• certificate Of Mailing Tbrs G�ili de of Melr 99paom 4i�lYJ�Aammelblle�birel0een orespnt to U5P5'a n9 0r E � TTk tam mo-y bo uae4Pta t.!r.r.a( .i i r 3 - Zucker, Goldberg&Ackerman, LLC AAA_ 200 Sheffield Street, Suite 301 .. Mountainside, NJ 07092 BRIAN T. KEESEMAN m� 16 Big Spring Terrace _ Q Newville, PA 17241-9468 ^ PS Farm 3817,April 2007 PSN 7530-02-0009065 �UNITED STATES `•"�'``"' " pD$TAL SERVICE• Certificate Of MalliTC 'c __' TfiS CeRlficOte p!MaPnp Wafitles pm6arCe Nel lbeS Ceen pmsBnteO tO U$P:.:®lor maileNj T' � Thrs 1c meY ba:5c01or0dnYAic rtMlMertwlbatl m5l. ;• N t From: ❑: . . r Zucker,Goldberg&Ackerman, LLC — z — 200 Sheffield Street, Suite 301 .. -- WN Mountainside,NJ 07092 R�,..,�. Vf TINA L. KEESEMAN ---o N p 60 North East Street, Apt2 Carlisle, PA 17013-2563 PS Farm 3817.APril 007 PSN 530-02-0 0906 Oder_)e� N �� � X7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Wells Fargo Bank, N.A., File No. 2011-2900 Plaintiff, Amount Due $182,106.01 vs. Interest from 5/11/2012 to date of sale c$14&19.-M BRIAN T. KEESEMAN; TINA L. KEESEMAN; rrnW Costs Defendants. —i =K C?-n TO THE PROTHONOTARY OF THE SAID COURT: ?c ro o� 5;.z D "a O 7.7 The undersigned hereby certifies that the below does not arise out of a retail installment salcT5conf�ract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding 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). (Indicate) Index this writ against the garnishee(s) as a lis p/�q insttr real�estate of the d^�efe�nJ�dant(s) describeQ the attached exhibit.ATE: L! I ') Signature: Print Name: Scott , Esuire Kimberly A. Bonner, Esquire Joel A. Ackerman, Esquire Ashleigh L. Marin, Esquire bO Ralph M. Salvia, Esquire V t�U Jaime R. Ackerman, Esquire(d, �� It �I Address: Zucker, Goldberg&Ackerman, LLC Lk 200 Sheffield Street,Suite 101 ..Solt Mountainside, NJ 07092 oo Attorney tor: Plaintiff s r`- Telephone: 908-233-8500 Supreme Court ID No.: 55650 89705 202729 306799 311032 d oC l.0 311032 . SO LL CF---# /ud.er (­1dh<n,4 nckcmnm I I C X1 '_14981 1 Exhibit"A° LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR.AND H. DAVID MILLER,JR.,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN;THENCE BY LOT NO. I AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO.6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO, 6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD, SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING, CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO.5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D. KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126,GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.: 30-09-0513-023. ltzl;ci,(h9Ahl:fc&AekcrinAi_LtC: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION n rag n c c.a = Plaintiff, NO.: 2011-2900 mm vs. Z� "°r" Execution No.: Nt� —4o BRIAN T. KEESEMAN; TINA L. KEESEMAN; Defendant(s). bs N Drs, —i o 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 408 Nealy Road, Newville, PA 17241-9472. 1. Name and Address of Owner(s) or Reputed Owner(s): BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE, AS TENANTS BY THE ENTIRETIES 16 Big Spring Terrace Newville, PA 17241-9468 AND 60 North East Street, Apt 2 Carlisle, PA 17103 2. Name and Address of Defendant(s) in the Judgment: BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 TINA L. KEESEMAN 60 North East Street, Apt 2 Carlisle, PA 17103 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 luc6rr.(inlchere.k nckcnn:m. IJS X1 11-1 198?1 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff EQUITY ONE, INCORPORATED, A PENNSYLVANIA CORPORATION 400 Lippincott Drive Marlton, NJ 08053 EQUITY ONE, INCORPORATED, D/B/A POPULAR FINANCIAL SERVICES, A PENNSYLVANIA CORPORATION ("BENEFICIARY"), EQUITY ONE ABS, INC. 400 Lippincott Drive Marlton, NJ 08053 THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-1, A BANKING CORPORATION 450 West 33`d Street, 151h Floor New York, NY 10001 EQUITY ONE, INCORPORATED ('BENEFICIARY"), EQUITY ONE ABS, INC., A DELAWARE CORPORATION 400 Lippincott Drive Marlton, NJ 08053 THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-2, A BANKING CORPORATION 450 West 33`d Street, 151h Floor New York, NY 10001 ALLFIRST BANK 25 South Charles Street Baltimore, MD 21201 MANUFACTURERS AND TRADERS TRUST COMPANY One M&T Plaza Buffalo, NY 14240 /uckar Ooldbeu k nckcrman. LL(' X1 P-1 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR NEW DAY FINANCIAL, LLC P.O. Box 2026 Flint, M148501-2026 AND 1901 E. Voorhees Street, Suite C Danville, IL 61834 AND 8171 Maple Lawn Boulevard, Suite 300 Fulton, MD 20759 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 408 Nealy Road Newville, PA 17241-9472 UNKNOWN SPOUSE 16 Big Spring Terrace Newville, PA 17241-9468 /u,k,r Guidbcw,k Ackerma, I.I XYP-119971 UNKNOWN SPOUSE 60 North East Street, Apt 2 Carlisle, PA 17103 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 1 verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. 1 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: �2 By; Scott A. D�tterick, 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 File No.: XFP-149871 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com /aL ko G)Idb¢re.&Ackcamm. I I(' XFP-119871 r ' Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR.AND H. DAVID MILLER,JR.,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353, AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN; THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO.6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN; THENCE BY SAID LOT NO. 6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEETTO A PARKER KALON NAIL IN NEALY ROAD, TOWNSHIP ROAD T-353; THENCE IN SAID ROAD, SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO.5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWViLLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D. KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126, GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES, TAX MAP NO.: 30-09-0513-023, rc(.u_i lotdhce fi Ack��mw�.[Lt: tit-id<s;zt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 2011-2900 BRIAN T. KEESEMAN;TINA L. KEESEMAN; c-) a �,� c Defendants. .rn ' r- srr � n = I cD rx s-n NOTICE OF SHERIFF'S SALE y N fir" OF REAL PROPERTY PURSUANT TO C-) ;a PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 AND 408 Nealy Road Newville, PA 17241-9472 AND 60 North East Street,Apt 2 Carlisle, PA 17103 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 9/4/2013 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: 408 Mealy Road,Newville,PA,17241-9472 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No.2011-2900 Zucker,Goldberg&Ackerman,LLC XFP-149871 THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: BRIAN T. KEESEMAN AND TINA L. KEESEMAN,HIS WIFE,AS TENANTS BY THE ENTIRETIES 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-149871 1 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: / BY: zzv A��4_ �/ b Scott A. D' tterick, 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, N1 07092 File No.:XFP-149871 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker,Goldberg&Ackerman,LLC XFP-149871 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR,AND H.DAVID MILLER,JR.,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEETTO AN IRON PIN; THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO.6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD,SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO. 5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D.KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126,GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.: 30-09-0513-023. 7nrl<ti.twldhop$Arkotmn.I.Lt: VIT-1ON71 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION O Plaintiff, C n VS. NO.: 2011-2900 -03 x.rt rnco M. BRIAN T. KEESEMAN;TINA L. KEESEMAN; Nf -Orn Defendants. DC7 Z- Z N --4msy Fa NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TINA L. KEESEMAN 60 North East Street, Apt 2 Carlisle, PA 17103-2563 AND 408 Nealy Road Newville, PA 17241-9472 AND 16 Big Spring Terrace Newville, PA 17241-9468 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, l Courthouse Square, Carlisle, PA 17013 on 9/4/2013 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: 408 Nealy Road, Newville,PA, 17241-9472 Zucker,Goldberg&Ackerman, LLC XFP-149871 _ t The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2011-2900 THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: BRIAN T. KEESEMAN AND TINA L.KEESEMAN,HIS WIFE,AS TENANTS BY THE ENTIRETIES 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 sate, 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. Zucker,Goldberg&Ackerman,LLC XFP-149871 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 Sheriffs Deed is delivered. 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:i//I� BY; i + Scott A, /ietteric , re 0 Kimberly A. Bonner, Esquire; PA.I.D.#89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA LD.#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 File No.: XFP-149871 (908)233-8500; (908)233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker,Goldberg&Ackerman,LLC XFP-149871 ' Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR.AND H. DAVID MILLER,JR,,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN; THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEETTO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO. 6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD, SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO. 5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D. KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126, GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.: 30-09-0513-023. t;,,Idbo K Ackamin.IJ.0 XPI'-1 V9R?i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-2900 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 BRIAN T. KEESEMAN; TINA L. KEESEMAN (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 gamishee(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: $182,106.01 L.L.: $.50 Interest FROM 5/11/2012 TO DATE OF SALE-$14,419.20 Atty's Comm: Due Prothy:$2.25 Arty Paid: $307.00 Other Costs: Plaintiff Paid: Date: 4/17/13 ��- David D. Buell,Prothonota\onola[rJ��') C� 7 (Seal) his, �" /7 Deputy REQUESTING PARTY: Name:JAIME R. ACKERMAN,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.311032 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO VS. .: 2011-2900 r7l C!: ;,r Execution No.: o cs� S'BRIAN T. KEESEMAN;TINA L. KEESEMAN; -� Z�z CD Defendant(s). 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 408 Nealy Road, Newville, PA 17241-9472. 1. Name and Address of Owner(s)or Reputed Owner(s): BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE,AS TENANTS BY THE ENTIRETIES 16 Big Spring Terrace Newville, PA 17241-9468 AND 60 North East Street,Apt 2 Carlisle, PA 17103 2. Name and Address of Defendants) in the Judgment: BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 TINA L. KEESEMAN 60 North East Street,Apt 2 Carlisle, PA 17103 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 d EQUITY ONE, INCORPORATED,A PENNSYLVANIA CORPORATION 400 Lippincott Drive Marlton, NJ 08053 EQUITY ONE, INCORPORATED, D/B/A POPULAR FINANCIAL SERVICES,A PENNSYLVANIA CORPORATION("BENEFICIARY"), EQUITY ONE ABS, INC. 400 Lippincott Drive Marlton, NJ 08053 THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-1,A BANKING CORPORATION 450 West 33`d Street, 15th Floor New York, NY 10001 EQUITY ONE, INCORPORATED('BENEFICIARY"), EQUITY ONE ABS, INC.,A DELAWARE CORPORATION 400 Lippincott Drive Marlton, NJ 08053 THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-2,A BANKING CORPORATION 450 West 33 d Street, 15th Floor New York, NY 10001 ALLFIRST BANK 25 South Charles Street Baltimore, MD 21201 MANUFACTURERS AND TRADERS TRUST COMPANY One M&T Plaza Buffalo, NY 14240 NEW DAY FINANICAL, LLC 1901 E.Voorhees Street, Suite C Danville IL 61834 MANUFACTURERS AND TRADERS TRUST COMPANY S/B/M TO ALLFIRST BANK One Fountain Plaza,4th Floor Buffalo, NY 14203 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR NEW DAY FINANCIAL, LLC P.O. Box 2026 Flint, MI 48501-2026 AND 1901 E.Voorhees Street, Suite C Danville, IL 61834 AND 8171 Maple Lawn Boulevard,Suite 300 Fulton, MD 20759 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 NORTH NEWTON TWP 433 Oakville Road Shippensburg, PA 17257 DARLENE PITTMAN 903 Big Spring Rd, Shippensburg, PA 17257 BIG SPRING SCHOOL DISTRICT 45 Mount Rock Road, Newville, PA 17241 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 408 Nealy Road Newville, PA 17241-9472 UNKNOWN SPOUSE 16 Big Spring Terrace Newville, PA 17241-9468 UNKNOWN SPOUSE 60 North East Street,Apt 2 Carlisle, PA 17103 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 1 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. ZUCKER GOLDBERG &ACKERMAN, LLC Dated: 10\4415 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 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 File No.: XFP-149871 (908) 233-8500; (908)233-1390 FAX E-mail: Office @zuckergoldberg.com Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR.AND H. DAVID MILLER,JR.,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN;THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO.6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER.KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD,SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO.5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D.KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126,GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.:30-09-0513-023. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 2011-2900 VS. TYPE OF PLEADING Brian T. Keeseman;Tina L. Keeseman; Pa. R.C.P. RULE 3129.2(C)AFFIDAVIT OF SERVICE Defendants. OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire- PA I.D.#202729 Ashleigh L. 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 r:T File No.:XFP- 149871/dsc _ CD P C Zucker, Goldberg&Ackerman, LLC XFP-149871 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. ' NO.: 2011-2900 Brian T. Keeseman;Tina L. Keeseman; Defendants. Pa.R.C.P. RULE 3129(c)AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendants, Brian T. Keeseman and Tina L. Keeseman, his wife as tenants by the entireties, are the record owners of the real property. 2. On or about May 4, 2013 and May 13, 2013, Defendants Brian T. Keeseman and Tina L. Keeseman were served with Plaintiff's Notice of Sheriff's Sale of Real Property Pursuant to Pa. R.C.P. 3129, via Certified Mail, return receipt requested at the addresses of 16 Big Spring Terrace, Newville, PA 17241 and 46 Marilyn Drive, Carlisle, PA 17013. True and correct copies of said Notices and Proofs of Service are marked Exhibit"A", attached hereto and made a part hereof. 3. On or about July 26, 2013, Plaintiff's counsel served all other parties in interest with Plaintiff's Notice of Sheriff's Sale according to Plaintiff's Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of Zucker, Goldberg&Ackerman, LLC XFP-149871 Interest were served with Plaintiffs Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG &ACKERMAN, LLC Attorneys for Plaintiff Dated: August , 2013 DANIELS Paralegal/Legal Assistant Sworn to and subscribed before met day of A gust, 2013 J Not ry Public MY COMMISSION EXPIRES: PAUL C.%ADRAT0WSK1 Notary Public Of Nof Jersey My Commission Exp►res 4/27/2016 Zucker, Goldberg&Ackerman, LLC XFP-149871 EXHIBIT A Zucker, Goldberg&Ackerman, LLC XFP-149871 Zucker,Goldberg&Ackerman,LLC PO Box 1219 Mountainside,NJ 07092-1219 7196 9006 9296 6812 1181 20130425-102 BRIAN T. KEESEMAN 16 BIG SPRING TER NEWVILLE, PA 17241-9468 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.:2011-2900 VS. BRIAN T. KEESEMAN;TINA L. KEESEMAN; Defendants. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 BRIAN T. KEESEMAN 16 Big Spring Terrace Newville,PA 17241-9468 AND 408 Nealy Road Newville,PA 17241-9472 AND 60 North East Street,Apt 2 Carlisle,PA 17103 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 9/4/2013 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: 408 Nealy Road, Newville,PA,17241-9472 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No.2011-2900 y Zucker,Goldberg&Ackerman,LLC XFP-149871 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.:2011-2900 VS. BRIAN T. KEESEMAN;TINA L. KEESEMAN; is Defendants. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 AND 408 Nealy Road Newville,PA 17241-9472 AND 60 North East Street,Apt 2 Carlisle, PA 17103 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 9/4/2013 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: 408 Nealy Road, Newville,PA,17241-9472 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No.2011-2900 Zucker,Goldberg&Ackerman,LLC XFP-149871 THE NAMES)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: BRIAN T. KEESEMAN AND TINA L.KEESEMAN,HIS WIFE,AS TENANTS BY THE ENTIRETIES 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 LIM XFP-149871 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: �,((� BY: Scott A. D' tterick, 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 File No.:XFP-149871 (908)233-8500; (908)233-1390 FAX E-mail: Office @zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. i Zucker,Goldberg&Ackerman, LLC XFP-149871 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND. COUNTY,PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E.FOOTE,SR.AND H.DAVID MILLER,JR.,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63,PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN;THENCE BY LOT NO.1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO.6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.6,NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD,SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEETTO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO.5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D.KEESEMAN AND CHARLOTTE K.KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21,1995 AND RECORDED DECEMBER 21,1995 IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA, IN DEED BOOK VOLUME 132,PAGE 1126,GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN,HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.:30-09-0513-023. tS, /aAm Cioldhcrg&Ackerman,H.C. UNITED STATES POSTAL SERVICE First-Class Mail Postage& Fees Paid LISPS Permit No. G-10 , 1 IElitEl�l llE 1 11111i�t1�E�il �tlEllIII tills 1 11111 r Zucker, Goldberg & Ackerman, LLC PO Box 90 76 -90?G Temecula, CA 92559 j �4 , 2. Article number COMPLETE • ON DELIVERY r ! A Received (Please Print Clearly) B. pate of efivery . s«,lnature r ! 1196 9006 9296 68112 118 Agent R• ..-�,.�_ _ Addressee * -D-_!*ee5ierya0fss different from item 1? Yes 3 J If YES, er delivery address below. bNo Z O 3. Service Type CERTIFIED MAIL ;. t 4. Restricted Delivery? (Extra Pee) UYes 1. Article*Addressed to: CL BRIAN T. KEESEMAN Reference Information f 16 BIG SPRING TER 149871 p NEMILLE, PA 17241-94£8 PANOSS Ll 4/2512013 7]96 9006 9291 6812 1181-102 PS Form 3811,January 2005 Domestic Retum Receipt Zucker,Goldberg&Ackerman,LLC PO Box 1219 Mountainside,NJ 07092-1219 7196 9006 9296 6812 1303 20130425-102 III-Ill.11,lll1ln11.+11l�l�i Tina L. Keeseman 46 Marilyn Dr Carlisle, PA 17013-8885 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.:2011-2900 VS. . BRIAN T. KEESEMAN;TINA L.KEESEMAN; Defendants. Y NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TINA L. KEESEMAN 60 North East Street,Apt 2 Carlisle, PA 17103-2563 AND 408 Nealy Road Newville, PA 17241-9472 AND 16 Big Spring Terrace i Newville,PA 17241-9468 I' 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 9/4/2013 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: 408 Nealy Road,Newville,PA,17241-9472 Zucker,Goldberg&Ackerman,LLC RN. XFP-149871 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No.2011-2900 THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: BRIAN T. KEESEMAN AND TINA L.KEESEMAN,HIS WIFE,AS TENANTS BY THE ENTIRETIES 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 n; 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. i k Zucker,Goldberg&Ackerman,LLC IN XFP-149871 2. After the Sheriffs Sale,you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 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: BY: r 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 File No.:XFP-149871 i (908)233-8500; (908)233-1390 FAX E-mail: Office @zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. l i Zucker,Goldberg&Ackerman,LLC . XFP-149871 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E.FOOTE,SR.AND H. DAVID MILLER,JR.,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63,PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT N0.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN;THENCE BY LOT NO.1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEETTO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO.6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEETTO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD,SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO.5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D.KEESEMAN AND CHARLOTTE K.KEESEMAN, HIS WIFE,BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132,PAGE 1126,GRANTED AND CONVEYED UNTO BRIAN T.KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. i TAX MAP NO.:30-09-0513-023. ;. USE ta: 7urkcr.6oldhcr,�d Ackerman,I.I.C. XI'P•l41;c?1 2._Article.Number COMPLETE THIS SECTION ON DELIVERY � A. Received by(Please Print Clearly) B. Date of Delivery C. signature 7196 9006 9296 :681,2 1303 ! - EAddr Addressee it I� D, fs delivery address different from item 17 Yes X111111 If YES,enter delivery address below. No . J Z O 3. Service Type CERTIFIED MAIL N 4. Restricted Delivery? (Extra Fee) UYes y1. Article Addressed to: CL O Tina L. Keeseman i. Reference Information 46 Marilyn Dr I 149871 I Carlisle, PA 1701 -8885 o � PANOSS I 4/2512013 I. 7196 9006 9296 6812 1303-102 I ... h PS Form 3811,January 2005 Domestic Retum ReceiAt 1 v UNITED STATES POSTAL PERVICE First-Class Mail Ui.v p `-w�. P_ostage&Fees Paid `r� {'` USPS v _. Permit Igo.G-10 � 1-11,1111 { 11111 if fill 1 [lilt11111111111111111111111till Zucker, Goldberg & Ackerman, LLC -PO Box 9076 - Temecula, CA 92589-9076 EXHIBIT 6 Zucker, Goldberg&Ackerman, LLC XFP-149871 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, VS. NO.:2011-2900 BRIAN T. KEESEMAN;TINA L.KEESEMAN; Defendants. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P.3129(b) TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 408 Nealy Road 16 Big Spring Terrace Newville,PA 17241-9472 Newville,PA 17241-9468 COMMONWEALTH OF PENNSYLVANIA PA DEPT.OF REVENUE-INHERITANCE TAX DEPARTMENT OF WELFARE DIVISION P.O.Box 2675 Dept.280601 Harrisburg, PA 17105 Harrisburg,PA 17128-0601 CUMBERLAND COUNTY TAX CLAIM BUREAU CUMBERLAND COUNTY DOMESTIC RELATIONS Cumberland County Courthouse OFFICE One Courthouse Square Domestic Relations Section Carlisle,PA 17013 13 N.Hanover Street PO Box 320 UNKNOWN SPOUSE Carlisle,PA 17013 60 North East Street,Apt 2 Carlisle,PA 17103 NORTH NEWTON TWP 433 Oakville Road MANUFACTURERS AND TRADERS TRUST Shippensburg,PA 17257 COMPANY One M&T Plaza DARLENE PITTMAN Buffalo, NY 14240 903 Big Spring Rd, Shippensburg, PA 17257 NEW DAY FINANICAL,LLC 1901 E.Voorhees Street,Suite C BIG SPRING SCHOOL DISTRICT Danville IL 61834 45 Mount Rock Road, Newville,PA 17241 MANUFACTURERS AND TRADERS TRUST COMPANY S/B/M TO ALLFIRST BANK ALLFIRST BANK One Fountain Plaza,4th Floor 25 South Charles Street Buffalo,NY 14203 Baltimore,MD 21201 Zucker,Goldberg&Ackerman,LLC NFP-149871 14987 ID1004CO7232013PI MORTGAGE ELECTRONIC REGISTRATION EQUITY ONE,INCORPORATED, D/B/A POPULAR SYSTEMS, INC.,AS NOMINEE FOR NEW DAY FINANCIAL SERVICES,A PENNSYLVANIA FINANCIAL,LLC CORPORATION("BENEFICIARY"), EQUITY ONE P.O. Box 2026 ABS, INC. Flint, Ml 48501-2026 400 Lippincott Drive Marlton, NJ 08053 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR NEW DAY THE CHASE MANHATTAN BANK AS TRUSTEE FINANCIAL, LLC FOR THE BENEFIT OF EQUITY ONE ABS INC., 1901 E.Voorhees Street,Suite C MORTGAGE PASS-THROUGH CERTIFICATE Danville, IL 61834 SERIES 2001-1,A BANKING CORPORATION MORTGAGE ELECTRONIC REGISTRATION 450 West 33rd Street,15th Floor SYSTEMS, INC.,AS NOMINEE FOR NEW DAY New York,NY 10001 FINANCIAL, LLC 8171 Maple Lawn Boulevard,Suite 300 EQUITY ONE,INCORPORATED("BENEFICIARY"), Fulton, MD 20759 EQUITY ONE ABS, INC.,A DELAWARE CORPORATION EQUITY ONE, INCORPORATED,A PENNSYLVANIA 400 Lippincott Drive CORPORATION Marlton, NJ 08053 400 Lippincott Drive Marlton, NJ 08053 THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-2,A BANKING CORPORATION }. 450 West 33rd Street,15th Floor New York, NY 10001 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania,and to the Sheriff of Cumberland County,directed,there will be exposed to Public Sale in: the Cumberland County Courthouse, 1 Courthouse Square,Carlisle, PA 17013 On 9/4/2013 at 10:00am,the following described real estate which Brian T.Keeseman and Tina L. Keeseman, his wife as tenants by the entireties are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: 408 Nealy Road, Newville,PA 17241-9472 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). Zucker,Goldberg&Ackerman,LLC XFP-149871 149871D1004C07232013P2 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank,N.A. Plaintiff VS. BRIAN T. KEESEMAN,et al Defendant(s) at EX. NO.2011-2900 in the amount of$182106.01 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty(30)days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten(10)days from the date when Schedule of Distribution is filed in the Office of the Sheriff. i If you have any questions or comments with regard to the Sheriff's Sale or this Notice,you should contact your attorney as soon as possible. ZUCKER,GOLDBERG&ACKERMAN,LLC Dated: /y� f 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 PF 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-149871 (908)233-8500;(908)233-1390 FAX E-mail: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-149871 149871D1004C07232013P3 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E.FOOTE,SR.AND H.DAVID MILLER,JR.,AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,ATTHE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEETTO AN IRON PIN;THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO.6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.6,NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD,SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO.5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE,PA, 17241-9472. i BEING THE SAME PREMISES WHICH LEE D.KEESEMAN AND CHARLOTTE K.KEESEMAN,HIS WIFE, BY DEED DATED DECEMBER 21,1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126,GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.:30-09-0513-023. Zucker,Goldberg&Ackerman,LLC XFP-149871 f Page 1 of ii NOTICE TO LIENHOLDERS 1 5 %� ,SE12V1. ��IEr 021M $ 01-200 This Certificate of Malling provides evidence that mail has been prese USPS for mating. 0004282036 JUL 26 3 and international mall d.,a Fro MAILED FROM ZIP CODE 0 7092 m: Scott A. Dietterick,Esquire .��/ c/o Zucker,Goldberg&Acker an,LLC 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 SpS XFP-1 sde TEAM C To' UNKNOWN TENANT OR TENANTS Postmark Here 408 Nealy Road Newville,PA 17241-9472 i County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-00D-9065 UNIT FnsT rES awns_% This Certificate of Malling pno idas evidence that mall has been presented to USPS'for mailing.This form m e20' and International mail. y�Fll± — 02 1M ",UL�6 2p13 from' Scott A. Dietterick, Esquire �� 000428203 MAILED FROM ZIP CODE 0 70 92 c/o Zucker,Goldberg&Ackerman,LLC i n f 200 Sheffield Street,Suite 101 I i Mountainside, NJ 07092 9871/sd COMMONWEALTH OF PENNSYLVANIA mart Here 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 Page 2 of 11 NOTICE TO LIENHOLDERS WT EQ57/1TF _ t AU TIJL.SE If!_CE P"N This cert ificate of Mailing provides evidence that mall has been presented to Usp aifing.T� 02 1M $ 01.200 and lntemationalmail. 0004282036 JUL 26 2013 } From: Scott A. Dietterick,Esquire MAILED FROM ZIPCODE 07092 f c/o Zucker,Goldberg&Ackerman, 4Lc le6 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 GSP XFP-1498 M C To` CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 P�T,Qk N1-7 t UST/JL SE-RVL E� �� ®ps Ev Bow" 02 IM $ 01.200 ThdInte International IIing.This jp� 0004282036 JUL 26 2013 andlnternatlonalmail. f((// [LED FROM ZIP CODE 07092 from: Scott A. Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, LLC ��13 200 Sheffield Street,Suite 101 ASP l: i Mountainside, NJ 07092 XFP-149871/sde TEAM C To` UNKNOWN SPOUSE Postmark Here 60 North East Street,Apt 2 Carlisle, PA 17103 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 3 of 11 NOTICE TO LIENHOLDERS U11:1.ITE�_STdT�s` � _ �rH This Certificate of Mailing provides evidence that mail has been presented to USPSe for i s'HE .02 1 M 200 and International mail. 000, JUL 26 2013 From: MAILED FROM ZIP CODE 0 70 92 Scott A.Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 v 149871/S e C TO: MANUFACTURERS AND TRADERS TRUST COMPANY Postmark Here One M&T Plaza Buffalo,NY 14240 j.: i County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i unrtrFaSrrES 0 n�osrt,sEnv� Fl � �MW /®HTWEV 0AXAMS This Certificate of Mailing provides evidence that mail has been presented to USPSa f This �` and international mail. .Sl 02 1M el+ 01 e20a i From: Scott A. Dietterick, Esquire ! 4282036 JUL 26 2013 c/o Zucker,Goldberg Ackerman,LL � LEDFROM ZiPGODE 07092 g 6 201,E 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 PS ZAZZilm XFP-149871/sde TZM C !' Tot NEW DAY FINANICAL, LLC Postmark Here 1901 E.Voorhees Street,Suite C Danville IL 61834 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 4 of II NOTICE TO LIENHOLDERS 9. •t�NITE>t?� �1T�ES_ �� � This Certificate ofMailingprovdesevdence that mag has been presented toUSPSefo a 4Thuf 0`2 ? p0, 00 and From:mattonalmatl, jot � MA QED ROB/►z1���s�" '� Scott A. Dietterick,Esquire COD 0 7032 c/o Zucker,Goldberg&Ackerman, LLC Q 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 PS XFP-149871/sde T C MANUFACTURERS AND TRADERS TRUST COMPANY S/B/M TO Postmark Here ALLFIRST BANK One Fountain Plaza,4th Floor Buffalo, NY 14203 • i County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 j ypos PO4- PQSrIlLaFRVX& 1M This CertifiuteofMaUinaprovdes evidence that mail his been preso oU n (�t 1e2 00 andintemationatmall. � �pF �b 6 2013 Fr°m` Scott A. Dietterick, Esquire � Rom ZfPO 07092 c/o Zucker,Goldberg&Ackerma LLC 200 Sheffield Street,Suite 101 pS Mountainside, NJ 07092 d XFP-149871/sde TEAM C TO' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.,AS Postmark Here NOMINEE FOR NEW DAY FINANCIAL, LLC P.O. Box 2026 Flint, MI 48501-2026 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 5 of 11 NOTICE TO LIENHOLDERS nQST/lL.SFfl `E LUMP - - TFI u2 h Thts CertHkate of Mailbq provides evidence that man has been presented to USP mating V �� 01.2$� aFrOm:mational man. I MA 1ED�036 JUL 26 2013 Scott A. Dietterick,Esquire .��� RAM ZIPGODE 0 7092 c/o Zucker,Goldberg&Ackerman,L C 6' 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 SpS XFP-1498 EAM C To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS Postmark Here NOMINEE FOR NEW DAY FINANCIAL, LLC 1901 E.Voorhees Street,Suite C Danville, IL 61834 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 LlNITED:S.T/.lTIES ��yT F IE y'��`��'r �QS7%!L SEn�lICF� ThlsCerttlkateofMalnngprovldesw1dence that man has been presented to SPS•formalP ' IM � and internatlonal mail From: Scott A. Dietterick, Esquire ��D RQMZ�$ 010 200 c/o Zucker,Goldberg&Ackerman, LLC S s coD�0 7o 92 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-149871/sde TEAM C TO: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS Postmark Here NOMINEE FOR NEW DAY FINANCIAL, LLC 8171 Maple Lawn Boulevard,Suite 300 Fulton, MD 20759 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 I Page 6 of 11 NOTICE TO LIENHOLDERS POML.SER IC e I I This Cartif sate of Malang providas evidence that mall has been presented to USPSa for mailir /� and International mall, 02 1M $ 01.200 From: 9j FIB 0004282036 JUL 26 2018 Scott A.Dietterick,Esquire �� ® MAILED FROM ZIPCODE 0 7692 c/o Zucker,Goldberg&Ackerman, LC -�,,a„_ 200 Sheffield Street,Suite 101 .. Mountainside, NJ 07092 3 XFP-1 98 EAM C To: EQUITY ONE, INCORPORATED,A PENNSYLV A CO ON Postmark Here 400 Lippincott Drive Marlton, NJ 08053 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 tIJ}VITEDST/lTJ�S POML:SE�i VICEa . , , A>HE This Certificate of Mailing provides widence that mall has been presented to SPs•fer `:0 2 IM Qom` end intematlonal mail. �• W 01.200 From: � 82036 JUL 26 Scott A. Dietterick,Esquire t 3 ,uA ° onrt zracoD�0 7os2 i. c/o Zucker,Goldberg&Ackerman, L 200 Sheffield Street,Suite 101 S'Pg j Mountainside,NJ 07092 XFP-149871/sde TEAM C To: THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF Postmark Here EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-2,A BANKING CORPORATION 450 West 33rd Street, 15th Floor New York,NY 10001 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 7 of 11 NOTICE TO LIEN HOLDERS - ' UNlTEa5T11TES_ � � ; � d This Certificate of Mailing provides evidence that mall has been Presented to USPSe for 7:* 02 IM $ 01-200 and International mail. 0004282036 JUL 26 2013 Fsom: Scott A. Dietterick, Esquire � MAILED FROM ZIPCODE 0 7092 c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 ' A' Mountainside, NJ 07092 XFP-149871 de 7O: EQUITY ONE, INCORPORATED("BENEFICIARY"), ITY O Postmark Here INC.,A DELAWARE CORPORATION 400 Lippincott Drive Marlton, NJ 08053 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i y� POS7*. UNITE =ST/1TE z �TM PQST/�L-SfVICF� S F I EL 0 y 02 1N( �°�+��° ThkCertificateofMailingproiidesevidencethatmallhasbeenpresentedtoUSPS•for aiong.Thisformr 0004282036 JUL 26 2013 andinternationalmall. AILED FROM ZIPCODE 07092 . From: Scott A. Dietterick, Esquire Jul r•' '9 , c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 V Mountainside, NJ 07092 XFP-149871/sde TEAM C TO: THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF Postmark Here EQUITY ONE ABS INC.,MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-1,A BANKING CORPORATION 450 West 33rd Street,15th Floor New York, NY 10001 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7$30-02-000-9065 i Page 8 of 11 NOTICE TO LIENHOLDERS AP Alf F ..- - - a dam PMEV 60WES AC?-AL:. ERSI/ >f� . . 021 + $ 01.20° 0004282036 JUL 26 2013 This Certificate of Mailing prwldes avidencs that mall has been presented to USPSe formail3 MAILED FROM ZIP CODE 0 70 92 and International mall. a` "or": Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman,LLC ---4. ° 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 1 c To: EQUITY ONE, INCORPORATED,D/B/A POPULAR FINANCIAL FostmarkHere SERVICES,A PENNSYLVANIA CORPORATION("BENEFICIARY"), EQUITY ONE ABS,INC. 400 Lippincott Drive Marlton, NJ 08053 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 tJNI�ED-SfiJSTES`_ a�gesP%: n+aST/lL:5E1 /ICE a'rrtvEY ROWES This Certificate of Malting provides evidence that mall has bean presented to US for malt - $ 01-200 and Internationalmaa. 0 36 JUL 26 2013 ``°m` Scott A. Dietterick,Esquire FROM ZIP CODE 0 7082 c/o Zucker,Goldberg&Ackerman, LLCM,_ 200 Sheffield Street,Suite 101 3 i Mountainside, NJ 07092 XFP-149871/sde TEAM C TD: ALLFIRST BANK Postmark Here 25 South Charles Street Baltimore,MD 21201 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i Page 9 of 11 NOTICE TO LIENHOLDERS 'rhis Certificate o(Mailing provides evidence that rnall has been presented to USPSo for maltiny"rhisfo d� ����� and international moil. 02 1M W 0 prom �I1 I� 0004282036 JUL 26 2013 Scott A.Dietterick, Esquire �� v MAILED FROM ZIP CODE 070_.92 c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 "2 I. Mountainside,NJ 07092 U XFP-149871 de To' BIG SPRING SCHOOL DISTRICT Postmark Here 45 Mount Rock Road, Newville, PA 17241 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i 6e tJ1111 TED S.7l.lTES. a d t '. SMAKS-E 01.2ao f andtntarnautbmatmaH,rgprovWeswidencethatmal t has been presented toUSPS'for mal >I<V . 000 282038 JUL 26 7082 Scott A. Dietterick, Esquire LED FF;ann Zip CODE c c/o Zucker Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 C/ XFP-149871/sde TEAM DARLENE PITTMAN Postmark Here 903 Big Spring Rd, Shippensburg,PA 17257 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 3 i Page 10 of 11 NOTICE TO LIENHOLDERS VA IC This Certlrrate or Mailing provWes evidence that mall has been presents oUSPSefor ma and international mail. It 00042820-36 Ev Fr°m: Scott A. Dietterick,Esquire `lC`, MA1l,Fp JU®'j p R01y21Pcol)" 2013 c/o Zucker,Goldberg&Ackerma , LLC 0.7092 200 Sheffield Street,Suite 101 ' {: Mountainside, NJ 07092 S I XFP- sde TEAM C TO' NORTH NEWTON TWP Postmark Here 433 Oakville Road Shippensburg, PA 17257 , 5 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 : i Ba I ►JUITEQ ST-T .. ��s� �tNEY�, r 02 1M $ 01.200 f PGM- LSE V X& �f 0004282036 JUL 26 2013 This Certificate of Mailing providesevidence that mall has peen presented toUSFS aformalrn DFROM ZIPCODE 07092 and International mall. From: Scott A. Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, LLC Sp 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-149871/sde TEAM C To: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here 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 Page 11 of 11 NOTICE TO LIENHOLDERS UMT. S7J�F�S`.. N • � This Certificate of Wiling provides evidence that mail has been presented to USP5e for mailfng.Thli _ e and International fig. �LO �'pltrvty 60tn1F5 From: Scott A. Dietterick, Esquire �� 02 1M $ 01-200 0004282036 JUL 26 2013 c/o Zucker,Goldberg&Ackerman, LC r MAILED FROM ZEPCODE 0 7092 . 200 Sheffield Street,Suite 101 r`� V : Mountainside,NJ 07092 t GS XFP-1 871 M C To: PA DEPT.OF REVENUE-INHERITANCE TAX DIVISION Postmark Here Dept.280601 Harrisburg, PA 17128-0601 County of P.Q.:CUMBERLAND f° PS Form 3817,April 2007 PSN 7530-02-000-9065 UNITUI ST/1TE5 . I�Fl $ 0,�_20° 02 1M This Certificate of Mailing provides evidence that mall has been presented to LISPS•for ailing. � 0 428 20 3 6 J U L 2 6 201 3 and International mall DFROM ZIPCODE 07092 From: Scott A.Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 3 Mountainside, NJ 07092 XFP-149871/sde TEAM C I° To' UNKNOWN SPOUSE Postmark Here 16 Big Spring Terrace Newville,PA 17241-9468 I County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i k i i SHERIFF'S OFFICE OF CUMBERLAND COUNTY- Ronny R Anderson Sheriff ��t0,01+Cnrnt�,er, , ...' t ' '. " Jody S Smith Chief Deputy h 5 �.a��l ..� :�� "' Ail 0 n Richard W Stewart Solicitor QFF rE OF rt,E SHERIFF PENNSYLVANIA Wells Fargo Bank NA vs. Case Number Brian T. Keeseman (et al.) 2011-2900 SHERIFF'S RETURN OF SERVICE 06/27/2013 03:07 PM - Deputy Tim Black, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Tina L. Keeseman at Penn's Woods Physical Therapy, 419 Village Drive, South Middleton Township, Carlisle, PA 17015, Cumberland County. 06/27/2013 06:57 PM-Deputy Jason Kinsler, 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 408 Nealy Road, North Newton Township, Newville, PA 17241, Cumberland County. 07/02/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Brian T. Kesseman, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 16 Big Spring Terrace, Newville, PA 17241, property is vacant, no longer a trailer located on this lot. 07/05/2013 07:25 PM -Deputy William Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Brian T. Keeseman at 20 Hosfeld Road, Carlisle, PA 17013, Cumberland County. 09/04/2013 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, on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Scott Dietterick on behalf of Wells Fargo Bank, NA, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,079.87 SO ANSWERS, November 21, 2013 RONNK ANDERSON, SHERIFF W.00 pi, ad. aS sv II". �i3 ft/ ,cj CountySuite Sheriff Teleosoft.Inc. 306693 r • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 2011-2900 vs. : Execution No.: BRIAN T. KEESEMAN;TINA L. KEESEMAN; • 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 408 Nealy Road, Newville, PA 17241-9472. 1. Name and Address of Owner(s)or Reputed Owner(s): BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE,AS TENANTS BY THE ENTIRETIES 16 Big Spring Terrace Newville, PA 17241-9468 AND 60 North East Street,Apt 2 Carlisle, PA 17103 2. Name and Address of Defendant(s) in the Judgment: BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 TINA L. KEESEMAN 60 North East Street,Apt 2 Carlisle, PA 17103 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 \ckcrman. I.I C' Yi i'-I-19Ri! • 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff EQUITY ONE, INCORPORATED,A PENNSYLVANIA CORPORATION 400 Lippincott Drive Marlton, NJ 08053 EQUITY ONE, INCORPORATED, D/B/A POPULAR FINANCIAL SERVICES, A PENNSYLVANIA CORPORATION ("BENEFICIARY"), EQUITY ONE ABSII INC. 400 Lippincott Drive Marlton, NJ 08053 THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-1, A BANKING CORPORATION 450 West 33rd Street, 15th Floor New York, NY 10001 EQUITY ONE, INCORPORATED ("BENEFICIARY"), EQUITY ONE ABS, INC.,A DELAWARE CORPORATION 400 Lippincott Drive Marlton, NJ 08053 THE CHASE MANHATTAN BANK AS TRUSTEE FOR THE BENEFIT OF EQUITY ONE ABS INC., MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2001-2,A BANKING CORPORATION 450 West 33rd Street, 15th Floor New York, NY 10001 ALLFIRST BANK 25 South Charles Street Baltimore, MD 21201 MANUFACTURERS AND TRADERS TRUST COMPANY One M&T Plaza Buffalo, NY 14240 �_ i;�.i(dh r. .�. .1d:kennan.I I( XIP-l49R?I MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR NEW DAY FINANCIAL, LLC P.O. Box 2026 Flint, MI 48501-2026 AND 1901 E.Voorhees Street, Suite C Danville, IL 61834 AND 8171 Maple Lawn Boulevard, Suite 300 Fulton, MD 20759 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 408 Nealy Road Newville, PA 17241-9472 UNKNOWN SPOUSE 16 Big Spring Terrace Newville, PA 17241-9468 ^,tkcr,,,,,, t i c \I P-1 r ' UNKNOWN SPOUSE 60 North East Street,Apt 2 Carlisle, PA 17103 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: �/ BY: =AO Scott A. 11;%-tterick, 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 File No.: XFP-149871 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com cl;r ( ahll7er+, 1Lkernian.I.1 XI I'-I-1987I Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR.AND H. DAVID MILLER,JR., AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN;THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO. 6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO.6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD,SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO.5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D. KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126, GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.: 30-09-0513-023. o idh�re& 'Viso man.I.I.0 XI P-I49X7I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • vs. NO.: 2011-2900 BRIAN T. KEESEMAN;TINA L. KEESEMAN; Defendants. • • • NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 BRIAN T. KEESEMAN 16 Big Spring Terrace Newville, PA 17241-9468 AND 408 Nealy Road Newville, PA 17241-9472 AND 60 North East Street,Apt 2 Carlisle, PA 17103 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 9/4/2013 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: 408 Nealy Road, Newville, PA, 17241-9472 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2011-2900 Zucker, Goldberg&Ackerman, LLC XFP-149871 • THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: BRIAN T. KEESEMAN AND TINA L. KEESEMAN , HIS WIFE,AS TENANTS BY THE ENTIRETIES 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-149871 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: BY: t� �3 Scott A. D. tterick, 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. #31103247 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-149871 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg&Ackerman, LLC XFP-149871 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR.AND H. DAVID MILLER,JR., AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN; THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN; THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO. 6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO. 6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353; THENCE IN SAID ROAD, SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO. 5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D. KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126, GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.: 30-09-0513-023. h Idhrre&.-�ckofnaH. P-14,o-1 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, •vs. NO.: 2011-2900 BRIAN T. KEESEMAN; TINA L. KEESEMAN; • Defendants. • • • NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TINA L. KEESEMAN 60 North East Street, Apt 2 Carlisle, PA 17103-2563 AND 408 Nealy Road Newville, PA 17241-9472 AND 16 Big Spring Terrace Newville, PA 17241-9468 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 9/4/2013 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: 408 Nealy Road, Newville, PA, 17241-9472 Zucker, Goldberg&Ackerman, LLC XFP-149871 • The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2011-2900 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE,AS TENANTS BY THE ENTIRETIES 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. Zucker, Goldberg&Ackerman, LLC XFP-149871 • 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. 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: 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 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 File No.: XFP-149871 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg&Ackerman, LLC XFP-149871 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN UNIMPROVED TRACT OF LAND SITUATE IN NORTH NEWTON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED PURSUANT TO A SUBDIVISION PLAN FOR LARRY E. FOOTE,SR.AND H. DAVID MILLER,JR., AS RECORDED IN CUMBERLAND COUNTY PLAN BOOK 63, PAGE 19,AS FOLLOWS: BEGINNING AT A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353,AT THE NORTHWESTERN CORNER OF LOT NO.4 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN; THENCE BY SAID LOT NO.4, SOUTH 37 DEGREES 29 MINUTES 47 SECONDS WEST 585.00 FEET TO AN IRON PIN;THENCE BY LOT NO. 1 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN, NORTH 52 DEGREES 30 MINUTES 13 SECONDS WEST 150.00 FEET TO AN IRON PIN AT THE SOUTHEASTERN CORNER OF LOT NO. 6 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN;THENCE BY SAID LOT NO. 6, NORTH 37 DEGREES 29 MINUTES 47 SECONDS EAST 585.00 FEET TO A PARKER KALON NAIL IN NEALY ROAD,TOWNSHIP ROAD T-353;THENCE IN SAID ROAD, SOUTH 52 DEGREES 30 MINUTES 13 SECONDS EAST 150.00 FEET TO A PARKER KALON NAIL IN SAID ROAD,THE POINT AND PLACE OF BEGINNING. CONTAINING 2.01 GROSS ACRES AND BEING DESIGNATED AS LOT NO. 5 AS SHOWN ON THE ABOVE DESCRIBED SUBDIVISION PLAN. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 408 NEALY ROAD, NEWVILLE, PA, 17241-9472. BEING THE SAME PREMISES WHICH LEE D. KEESEMAN AND CHARLOTTE K. KEESEMAN, HIS WIFE, BY DEED DATED DECEMBER 21, 1995 AND RECORDED DECEMBER 21, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 132, PAGE 1126, GRANTED AND CONVEYED UNTO BRIAN T. KEESEMAN AND TINA L. KEESEMAN, HIS WIFE AS TENANTS BY THE ENTIRETIES. TAX MAP NO.: 30-09-0513-023. 1 ih.:r t A.-\ckL'nnan_l.l.(' \FP-1•,);< WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-2900 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 BRIAN T. KEESEMAN; TINA L. KEESEMAN (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: $182,106.01 L.L.: $.50 Interest FROM 5/11/2012 TO DATE OF SALE-$14,419.20 Atty's Comm: Due Prothy: $2.25 Atty Paid: $307.00 Other Costs: Plaintiff Paid: Date: 4/17/13 David D.B ell,Prothonotary (Seal) = : / /i _ Deputy REQUESTING PARTY: Name: JAIME R.ACKERMAN,ESQUIRE Address: ZUCKER, GOLDBERG&ACKERMAN, LLC 200 SHEFFIELD STREET,SUITE 101 MOUNTAINSIDE,NJ 07092 Attorney for: PLAINTIFF s.E007D TRUE COPY F ROM„° �— hand Telephone: 908-233-8500 whereof, t here unto set my In Testimony Supreme Court ID No.311032 and the seal of said Court at Car�si 20 This day of Prothonotary 1,1tld � 1 • LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2011-2900 Civil Term corded December 21, 1995 in and for Cumberland County, Pennsyl- WELLS FARGO BANK NA vania, in Deed Book Volume 132, vs. Page 1126, granted and conveyed BRIAN T. KEESEMAN, unto Brian T. Keeseman and Tina Tina L. Keeseman L. Keeseman,his wife as tenants by the entireties. Atty.: Scott Dietterick TAX MAP NO.: 30-09-0513-023. ALL THAT CERTAIN unimproved tract of land situate in North New- ton Township, Cumberland County, Pennsylvania, more particularly bounded and described pursuant to a subdivision plan for Larry E. Foote, Sr. and H. David Miller, Jr., as recorded in Cumberland County Plan Book 63,Page 19,as follows: BEGINNING at a Parker Kalon nail in Nealy Road, Township Road T-353, at the northwestern corner of Lot No. 4 as shown on the above described subdivision plan; thence by said Lot No. 4, South 37 degrees 29 minutes 47 seconds West 585.00 feet to an iron pin;thence by Lot No. 1 as shown on the above described subdivision plan, North 52 degrees 30 minutes 13 seconds West 150.00 feet to an iron pin at the southeastern corner of Lot No. 6 as shown on the above described subdivision plan; thence by said Lot No. 6, North 37 degrees 29 minutes 47 seconds East 585.00 feet to a Parker Kalon nail in Nealy Road, Township Road T-353; thence in said road, South 52 degrees 30 minutes 13 seconds East 150.00 feet to a Parker Kalon Nail in said road,the point and place of BEGINNING. CONTAINING 2.01 gross acres and being designated as Lot No. 5 as shown on the above described subdivision plan. HAVING THEREON ERECTED a dwelling house being known and numbered as 408 Nealy Road, Newville,PA, 17241-9472. BEING THE SAME PREMISES which Lee D. Keeseman and Char- lotte K.Keeseman,his wife,by deed dated December 21, 1995 and re- 67 L PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. isa Marhoyne, E itor SWORN TO AND SUBSCRIBED before me this 9 da of Au.ust 2013 d . J'/d I. '�. , Notary NOTARIAL SEAL DE.BURAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Bank,NA is the grantee the same having been sold to said grantee on the 4th day of September A.D., 2013, under and by virtue of a writ Execution issued on the 17th day of April, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 2900, at the suit of Wells Fargo Bank,NA against Brian T. Keeseman& Linda Keeseman is duly recorded as Instrument Number 201400297. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of 1 ..,_____ , A.D. 070 i 1 Recorder of Deeds 1M.. Deeds,Cumberland County,Carlisle,PA My Co ission Expires the First Monday of Jan.2018