HomeMy WebLinkAbout11-3133lit°r?T
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cUPENN YLVAN A rY
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A. s/i/i/t Wachovia
Bank, N.A.
1 Home Campus
Des Moines, Iowa 50328
V.
Gretchen A. Drewett
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Harry C. Drewett
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Attorneys for Plaintiff
Cumberland County
Court of Common Pleas
Number 11 1 c 3 ? 1 YI
CIVIL ACTION/MORTGAGE FORECLOSURE
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NOTICE
You have been sued in court. If you wish to defend
against the claims set forth in the following pages, you
must take action within twenty (20) days after this
complaint and notice are served, by entering a written
appearance personally or by attorney and filing in
writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a
judgment may be entered against you by the court
without further notice for any money claimed in the
complaint or for any other claim or relief requested by
the plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO
YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A
LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT
AGENCIES THATMAY OFFERLEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR
NO FEE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere
defenderse de estas demandas ex-puestas en las paginas
siguientes, usted tiene veinte (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Hace falta
asentar una comparencia escrita o en persona o con un
abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de
su persona. Sea avisado que si usted no se defiende, la
corte tomara medidas y puede continuar la demands en
contra suya sin previo aviso o notificacion. Ademas, la
corte puede decidir a favor del demandante y requiere
que usted cumpla con todas las provisions de esta
demanda. Usted puede perder dinero o sus propiedades
u otros derechos importantes para usted.
USTED LE DEBE TOMAR ESTE PAPEL A
SU ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE A UN ABOGADO, VA A O TELEFONEA LA
OFICINA EXPUSO ABAJO. ESTA OFICINA LO
PUEDE PROPORCIONAR CON INFORMATION
ACERCA DE EMPLEAR A UN ABOGADO.
SI USTED NO PUEDE PROPORCIONAR
PARA EMPLEAR UN ABOGADO, ESTA OFICINA
PUEDE SER CAPAZ DE PROPORCIONARLO CON
INFORMACION ACERCA DE LAS AGENCIAS
QUE PUEDEN OFRECER LOS SERVICIOS
LEGALES A PERSONAS ELEGIBLES EN UN
HONORARIO REDUCIDO NI NINGUN
HONORARIO.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
CIVIL ACTION/MORTGAGE FORECLOSURE
1. Plaintiff is Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A., a corporation duly
organized and doing business at the above captioned address.
2. The Defendant is Gretchen A. Drewett, who is the mortgagor and real owner of the
mortgaged property hereinafter described, and his/her last-known address is 1205 Jerusalem Road,
Mechanicsburg, Pennsylvania 17050.
3. The Defendant is Harry C. Drewett, who is the mortgagor and real owner of the mortgaged
property hereinafter described, and his/her last-known address is 1205 Jerusalem Road, Mechanicsburg,
Pennsylvania 17050.
4. On November 2, 2007, mortgagors made, executed and delivered a mortgage upon the
premises hereinafter described to Wachovia Bank, National Association which mortgage is recorded in the
Office of the Recorder of Cumberland County in Mortgage Instrument Number 200742402.
5. The premises subject to said mortgage is described in the legal description attached as
Exhibit "A" and is known as 1205 Jerusalem Road, Mechanicsburg, Pennsylvania 17050.
6. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due October 1, 2010 and each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month, the entire principal balance and all
interest due thereon are collectible forthwith.
7. The following amounts are due on the mortgage:
Principal Balance $ 91,715.06
Interest through February 15, 2011 $ 2,306.32
(Plus $15.91 per diem thereafter)
Attorney's Fee $ 1,300.00
Late Charges $ 108.30
Corporate Advance $ 348.50
GRAND TOTAL $ 95,778.18
8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and
notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter
13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular
mail with a certificate of mailing and by certified mail, return receipt requested.
WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $95,778.18,
together with interest at the rate of $15.91 per diem and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgaged property.
McCABE, WEISBERG AND CONWAY,P.C.
BY: /
Attorneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
VERIFICATION
The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the
within action, and that he/she is authorized to make this verification and that the foregoing facts based on
the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this
verification at this time, and are true and correct to the best of his/her knowledge, information and belief
and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904
relating to unsworn falsification to authorities.
McCABE, WEISBERG AND CONWAY,P.C.
BY:
Attorneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. v. Gretchen A. Drewett and Harry C. Drewett
COMMITMENT FOR TITLE INSURANCE
SCHEDULE A
(continued)
File No. 2011-10345
LEGAL DESCRIPTION
ALL THOSE CERTAIN TWO tracts of land situate in the Township of Hampden, County of Cumberland and
Commonwealth of Pennsylvania. The first is bounded and described in accordance with a survey made by Michael C.
D'Angelo dated August 26, 1974, as follows, to wit:
TRACT NO. 1
BEGINNING at a stake on the west side of Jerusalem Road, said stake being located 104.15 feet south of the southwestern
intersection of a proposed 50 foot wide street and Jerusalem Road; thence by the same South 45 degrees 18 minutes East a
distance of 103.15 feet to the dividing line between Lots No. 10 and 11 on hereafter mentioned plan; thence by the same
South 44 degrees 42 minutes West a distance of 150.00 feet to a stake at other lands N/F of James E. Grandon; thence by the
same North 45 degrees 18 minutes West a distance of 103.15 feet to a stake at the dividing line between Lots No. 11 and 12;
thence by the same North 44 degrees 42 minutes East a distance of 150.00 feet to a stake, the point and place of
BEGINNING.
BEING Lot No. 11, Block C, Plan No. 1, Creekview, Plan Book 25, page 74.
HAVING thereon erected a dwelling house now known as 1205 Jerusalem Road.
TRACT NO.2
BEGINNING at a concrete monument located on the southern right-of-way line of Jerusalem Road and at the dividing line
between Lot No. 10 and lands now or formerly of Russell Braumwell; thence by lands N/F of Russell Braumwell, South 67
degrees 49 minutes 00 seconds West a distance of 13.54 feet to a concrete monument at the dividing line between Lot No. 10
and lands N/F of James E. Grandon, Jr.; thence by lands N/F of James E. Grandon, Jr., South 44 degrees 42 minutes 00
seconds West a distance of 137.54 feet to a concrete monument. Thence by the same, North 45 degrees 18 minutes 00
seconds West a distance of 99.83 feet to a point at the dividing line between Lot No. 10 and Lot No. 11. Thence by said
dividing line, North 44 degrees 42 minutes 00 seconds East a distance of 150.00 feet to a point on the southern right-of-way
line of Jerusalem Road. Thence by the same, South 45 degrees 18 minutes 00 seconds East a distance of 105.15 feet to a
concrete monument, the point and place of BEGINNING.
BEING Lot No. 10, Block C, and containing 15,007.72 square feet as shown on Final Subdivision Plan No. 1, Creekview
recorded in Plan Book 25, Page 74.
Being the same property acquired by Harry C. Drewett and Gretchen A. Drewett, by Deed recorded 06/16/1997, of record in
Deed Book 159, Page 428, in the Office of the Recorder of Cumberland County, Pennsylvania.
Elul
Schedule A - Page 2 of 2
File #: 2011-10345 - REO America Abstract Co.
ALTA Commitment (6-17-06) - TIRBOP & STG modifications (4-1-07) Ste V YOY t
r title guaranty company
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson PR?NONOTA
Sheriff T"E Jody S Smith
Chief Deputy
20t 1 MAR 28 m z' 18
Richard W Stewart
Solicitor CUMBER?.A vA? A i Y
PENHSYL
Wells Fargo Bank NA
vs.
Harry C. Drewett (et al.)
Case Number
2011-3133
SHERIFF'S RETURN OF SERVICE
03/24/2011 08:22 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 24,
2011 at 2022 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Harry C. Drewett, by making known unto Gretchen A. Drewett, Wife of
Defendant at 1205 Jerusalem Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its
contents and at the same time handing to her personally the said true and correct copy of the same.
_77'.5
RYAN BURGETT, DEPUTY
03/24/2011 08:22 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 24,
2011 at 2022 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Gretchen A. Drewett, by making known unto herself personally, at 1205
Jerusalem Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $54.00
March 25, 2011
RYAN BURGETT, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
icy Coimr,Su'a? S^erYi. Teie?.=,ofi. In.;.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-3133 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. S/I/I/T WACHOVIA
BANK, N.A. Plaintiff (s)
From GRETCHEN A. DREWETT AND HARRY C. DREWETT
(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 $96,891.88
L.L. $.50
Interest FROM 4/27/11 $2,134.62 AT $15.93
Atty's Comm %
Due Prothy $2.00
Atty Paid $186.50
Plaintiff Paid
Dale: 5/5/11
(Seal).
Other Costs
Did D. Buell, Prothonotary
By:
Deputy
REQUESTI'NQ PARTY:
Name: MARC S. WEISBERG, ESQUIRE
Address: MCCABE, WEISBERG AND CONWAY
123 S. BROAD STREET, SUITE 2080
Attorney for: PLAINTIFF
Telephone: 215-790-1010
i
Supreme Court ID No. 17616
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A.
V.
Gretchen A. Drewett and Harry C. Drewett
FILE NO.: 11-3133 civil Civil Term
.`? na
AMOUNT DUE: $96,891.88
-p ? =
rrim -X
INTEREST: from 04/27/11 ? -
$2,134.62 at $15.93
ATTY' S COMM.:
2. cry
COSTS:
TO THE PROTHONOTARY OF SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account
based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant tc
Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue writ or 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)
1205 Jerusalem Road Mechanicsburg, Penns lvania 17050
(More fully described as 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 personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s)
described in the attached exhibit.
DATE: Mav 3, 2011
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Signature:
Print Name: MCCABE, WEISBERG AND ONWAY
Address:123 S. Broad Street Suite 2080
Philadelphia. PA 19109
Attorney for: Plaintiff
Telephone: (215) 790 1010
Supreme Court ID No. _
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tlict a:
4ca GL
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
215 790-1010
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. CUMBERLAND COUNTY COURT O F COMMON
PLEAS
Plaintiff
v. NO: 11-3133 civil - -i
--?-
-•?
Gretchen A. Drewett and Harry C. Drewett r-
,
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Defendants -rj
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C)
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AFFIDAVIT PURSUANT TO RULE 3129 - i
The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning
the real property located at: 1205 Jerusalem Road, Mechanicsburg, Pennsylvania 17050, as of the date the Praecipe
for the Writ of Execution was filed. A copy of the description of said property being attached hereto.
1. Name and address of Owners or Reputed Owners
Name
2.
3
Harry C. Drewett
Gretchen A. Drewett
Address
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Name and address of Defendants in the judgment:
Name
Gretchen A. Drewett
Harry C. Drewett
Address
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name Address
Plaintiff herein
4
5
Name and address of the last recorded holder of every mortgage of record:
Name
Address
Wavhovia Bank, National Association 301 South College Street
VA 0343
Charlotte, North Carolina 28288
Name and address of every other person who has any record lien on the property:
Name
Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name
Address
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest
in the property which may be affected by the sale:
Name
Tenants/Occupants
Commonwealth of Pennsylvania
Commonwealth of Pennsylvania
Inheritance Tax Office
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Department of Public Welfare
TPL Casualty Unit Estate
Recovery Program
PA Department of Revenue
Commonwealth of Pennsylvania
Department of Revenue Bureau of
Compliance
Address
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105
ATTN: Dan Richard
110 North 8`h Street
Suite #204
Philadelphia, PA 19107
6th Floor, Strawberry Square
Department #280601
Harrisburg, PA 17128
Willow Oak Building
P.O. Box 8486
Harrisburg, PA 17105-8486
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Clearance Support Department 281230
Harrisburg, PA 17128-1230
ATTN: Sheriff's Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
Domestic Relations P.O. Box 320
Cumberland County Carlisle, PA 17013
United States of America c/o United States Attorney for the
Middle District of PA
William J. Nealon Federal Bldg.
235 North Washington Avenue, Ste. 311
Scranton, PA 18503
and
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108-1754
United States of America c/o
Atty General of the United States
United States of America c/o
Atty General of the United States
Name and address of Attorney of record:
Name
U.S. Dept of Justice, Room 5111
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
U.S. Dept of Justice, Room 4400
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
Address
None
I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge
or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
May 3.2011
DATE
V/1? A ? ??M
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
CIVIL ACTION LAW
Cs 1
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. COURT OF COMMON PLEAS
v. CUMBERLAND COUNTY -C rr, 33. r
Gretchen A. Drewett and Harry C. Drewett
°'
zs
Number 11-3133 civil r
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY :
To: Gretchen A. Drewett Harry C. Drewett
1205 Jerusalem Road 1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050 Mechanicsburg, Pennsylvania 17050
Your house (real estate) at 1205 Jerusalem Road, Mechanicsburg, Pennsylvania 17050 is scheduled to
be sold at Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the
2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the
court judgment of $96,891.88 obtained by Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be canceled if you pay to Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. the
back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you
must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of
stopping the sale. (See the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find
out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your real estate. A schedule of
distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days
of the sale. This schedule will state who will be receiving that money. The money will be paid out
in accordance with this schedule unless exceptions (reasons why the proposed schedule of
distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the
schedule of distribution.
7. You may also have other rights and defenses, or ways of getting your real estate back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A.
Plaintiff
V.
Gretchen A. Drewett and Harry C. Drewett
Defendants
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 11-3133 civil
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF PHILADELPHIA:
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Z7.
The undersigned, being duly sworn according to law, deposes and says that the Defendants, Gretchen A.
Drewett and Harry C. Drewett, are not in the Military or Naval Service of the United States or its Allies, or otherwise
within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the
Defendants, Gretchen A. Drewett and Harry C. Drewett, are over eighteen (18) years of age, and reside as follows:
Gretchen A. Drewett
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
SWORN AND SUBS -D
BEF RE E THIS AY
OF Ifa(I(--: .2011
NOTARY PUBLIC
UMr1 Ll i?••-^--
NOTARIAL SEA
Barbara I Moyer-Notary Public
MYyCOMMISSIONhIEMKSJAN.12, 20!14
Harry C. Drewett
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Z?10? ? ? LA
?TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A.
Plaintiff
V.
Gretchen A. Drewett and Harry C. Drewett
Defendants
Attorneys for Plaintiff
COURT OF COMMON PLEAS
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rri
CUMBERLAND COUNTY co
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Number 11-3133 civil -<>
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AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS
tom.:
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C1i
ss
The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby
depose and say that the last-known mailing addresses of the Defendants are:
Gretchen A. Drewett Harry C. Drewett
1205 Jerusalem Road 1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050 Mechanicsburg, Pennsylvania 17050
SWORN AND SUBS D
BEF E THISaAY
OF _? 4,/ J---- . 20 Ll
NOTARY PUBLIC (/
COMMONWEALTH F PENNSYLVANIA
NOTARIAL eEAL
6ubara J. Moyer-Notary Public
Qb d ftkdelphia, Philadelphia Cawdy
W ION EmfiE i% 12, 2014
TERRE CE J. McCAB t , ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorneys for Plaintiff
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LEGAL DESCRIPTION
ALL THOSE CERTAIN TWO tracts of land situate in the Township of Hampden, County of Cumberland and
Commonwealth of Pennsylvania. The first is bounded and described in accordance with a survey made by Michael C
D'Angelo dated August 26, 1974, as follows, to wit:
TRACT NO. 1
BEGINNING at a stake on the west side of Jerusalem Road, said stake being located 104.15 feet south of the
southwestern intersection of a proposed 50 foot wide street and Jerusalem Road; thence by the same South 45 degrees
18 minutes East a distance of 103.15 feet to the dividing line between Lots No. 10 and 11 on hereafter mentioned
plan; thence by the same South 44 degrees 42 minutes West a distance of 150.00 feet to a stake at other lands N/F of
James E. Grandon; thence by the same North 45 degrees 18 minutes West a distance of 103.15 feet to a stake at the
dividing line between Lots No. 11 and 12; thence by the same North 44 degrees 42 minutes East a distance of 150.00
feet to a stake, the point and place of BEGINNING.
BEING Lot No. 11, Block C, Plan No. 1, Creekview, Plan Book 25, page 74.
HAVING thereon erected a dwelling house now known as 1205 Jerusalem Road
TRACT NO. 2
BEGINNING at a concrete monument located on the southern right-of-way line of Jerusalem Road and at the dividing
line between Lot No. 10 and lands now or formerly of Russell Braumwell; thence by lands N/F of Russell Braumwell,
South 67 degrees 49 minutes 00 seconds West a distance of 13.54 feet to a concrete monument at the dividing line
between Lot No. 10 and lands N/F of James E. Grandon, Jr.; thence by lands N/F of James E. Grandon, Jr., South 44
degrees 42 minutes 00 seconds West a distance of 137.54 feet to a concrete monument. Thence by the same, North 45
degrees 18 minutes 00 seconds West a distance of 99.83 feet to a point at the dividing line between Lot No. 10 and
Lot No. 11. Thence by said dividing line, North 44 degrees 42 minutes 00 seconds East a distance of 150.00 feet to a
point on the southern right-of-way line of Jerusalem Road. Thence by the same, South 45 degrees 18 minutes 00
seconds East a distance of 105.15 feet to a concrete monument, the point and place of BEGINNING.
BEING Lot No. 10, Block C, and containing 15,007.72 square feet as shown on Final Subdivision Plan No. 1,
Creekview recorded in Plan Book 25, Page 74.
1205 Jerusalem Road, Mechanicsburg, Pennsylvania 17050
BEING the same premises which DENNIS E. HELMAN AND BRENDA HELMAN, HUSBAND AND WIFE by
deed dated June 13, 1997 and recorded June 16, 1997 in the office of the Recorder in and for Cumberland County in
Deed Book 159, Page 428, granted and conveyed to Gretchen A. Drewett and Harry C. Drewett, husband and wife, in
fee.
TAX MAP PARCEL NUMBER: 10-16-1060-026
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
P-SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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Wells Fargo Bank NA
vs. Case Number
Harry C. Drewett (et al.) 2011-3133
SHERIFF'S RETURN OF SERVICE
06/15/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $166.20 SO ANSWERS,
June 15, 2011 RON R ANDERSON, SHERIFF
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II
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A.
Plaintiff
V.
Gretchen A. Drewett and Harry C. Drewett
Defendants
AFFIDAVIT PURSUANT TO RULE 3129
The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning
the real property located at: 1205 Jerusalem Road, Mechanicsburg, Pennsylvania 17050, as of the date the Praecipe
for the Writ of Execution was filed. A copy of the description of said property being attached hereto.
1. Name and address of Owners or Reputed Owners
Name Address
Harry C. Drewett 1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF COMMON
PLEAS
NO: 11-3133 civil
Gretchen A. Drewett
2.
3
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Name and address of Defendants in the judgment:
Name
Gretchen A. Drewett
Harry C. Drewett
Address
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name Address
Plaintiff herein
4
5
Name and address of the last recorded holder of every mortgage of record:
Name
Address
Wavhovia Bank, National Association 301 South College Street
VA 0343
Charlotte, North Carolina 28288
Name and address of every other person who has any record lien on the property:
Name Address
None
6. Name and address of every other person who has any record interest in the property which may be
affected by the sale:
Name Address
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest
in the property which may be affected by the sale:
Name
Tenants/Occupants
Commonwealth of Pennsylvania
Commonwealth of Pennsylvania
Inheritance Tax Office
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Department of Public Welfare
TPL Casualty Unit Estate
Recovery Program
PA Department of Revenue
Commonwealth of Pennsylvania
Department of Revenue Bureau of
Compliance
Address
1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050
Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105
ATTN: Dan Richard
110 North 8`h Street
Suite #204
Philadelphia, PA 19107
6th Floor, Strawberry Square
Department #280601
Harrisburg, PA 17128
Willow Oak Building
P.O. Box 8486
Harrisburg, PA 17105-8486
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Clearance Support Department 281230
Harrisburg, PA 17128-1230
ATTN: Sheriffs Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
Domestic Relations P.O. Box 320
Cumberland County Carlisle, PA 17013
United States of America c/o United States Attorney for the
Middle District of PA
William J. Nealon Federal Bldg.
235 North Washington Avenue, Ste. 311
Scranton, PA 18503
and
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108-1754
United States of America c/o U.S. Dept of Justice, Room 5111
Atty General of the United States 950 Pennsylvania Avenue NW
Washington, DC 20530-0001
United States of America c/o U.S. Dept of Justice, Room 4400
Atty General of the United States 950 Pennsylvania Avenue NW
Washington, DC 20530-0001
8. Name and address of Attorney of record:
Name Address
None
I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge
or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904 relating to unsworn falsification to authorities.
Ma 3. 2011 TERRENCE J. McCAB , ESQUIRE
DATE MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET CAIRO, ESQUIRE
Attorneys for Plaintiff
to
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
CIVIL ACTION LAW
Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A.
COURT OF COMMON PLEAS
V.
CUMBERLAND COUNTY
Gretchen A. Drewett and Harry C. Drewett
Number 11-3133 civil
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Gretchen A. Drewett Harry C. Drewett
1205 Jerusalem Road 1205 Jerusalem Road
Mechanicsburg, Pennsylvania 17050 Mechanicsburg, Pennsylvania 17050
Your house (real estate) at 1205 Jerusalem Road, Mechanicsburg, Pennsylvania 17050 is scheduled to
be sold at Sheriffs Sale on September 7, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the
2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the
court judgment of $96,891.88 obtained by Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be canceled if you pay to Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. the
back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you
must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of
stopping the sale. (See the following notice on how to obtain an attorney.)
a
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find
out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your real estate. A schedule of
distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days
of the sale. This schedule will state who will be receiving that money. The money will be paid out
in accordance with this schedule unless exceptions (reasons why the proposed schedule of
distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the
schedule of distribution.
7. You may also have other rights and defenses, or ways of getting your real estate back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(800) 990-9108
LEGAL DESCRIPTION
ALL THOSE CERTAIN TWO tracts of land situate in the Township of Hampden, County of Cumberland and
Commonwealth of Pennsylvania. The first is bounded and described in accordance with a survey made by Michael C.
D'Angelo dated August 26, 1974, as follows, to wit:
TRACT NO. 1
BEGINNING at a stake on the west side of Jerusalem Road, said stake being located 104.15 feet south of the
southwestern intersection of a proposed 50 foot wide street and Jerusalem Road; thence by the same South 45 degrees
18 minutes East a distance of 103.15 feet to the dividing line between Lots No. 10 and 11 on hereafter mentioned
plan; thence by the same South 44 degrees 42 minutes West a distance of 150.00 feet to a stake at other lands N/F of
James E. Grandon; thence by the same North 45 degrees 18 minutes West a distance of 103.15 feet to a stake at the
dividing line between Lots No. 11 and 12; thence by the same North 44 degrees 42 minutes East a distance of 150.00
feet to a stake, the point and place of BEGINNING.
BEING Lot No. 11, Block C, Plan No. 1, Creekview, Plan Book 25, page 74.
HAVING thereon erected a dwelling house now known as 1205 Jerusalem Road.
TRACT NO.2
BEGINNING at a concrete monument located on the southern right-of-way line of Jerusalem Road and at the dividing
line between Lot No. 10 and lands now or formerly of Russell Braumwell; thence by lands N/F of Russell Braumwell,
South 67 degrees 49 minutes 00 seconds West a distance of 13.54 feet to a concrete monument at the dividing line
between Lot No. 10 and lands N/F of James E. Grandon, Jr.; thence by lands N/F of James E. Grandon, Jr., South 44
degrees 42 minutes 00 seconds West a distance of 137.54 feet to a concrete monument. Thence by the same, North 45
degrees 18 minutes 00 seconds West a distance of 99.83 feet to a point at the dividing line between Lot No. 10 and
Lot No. 11. Thence by said dividing line, North 44 degrees 42 minutes 00 seconds East a distance of 150.00 feet to a
point on the southern right-of-way line of Jerusalem Road. Thence by the same, South 45 degrees 18 minutes 00
seconds East a distance of 105.15 feet to a concrete monument, the point and place of BEGINNING.
BEING Lot No. 10, Block C, and containing 15,007.72 square feet as shown on Final Subdivision Plan No. 1,
Creekview recorded in Plan Book 25, Page 74.
1205 Jerusalem Road, Mechanicsburg, Pennsylvania 17050.
BEING the same premises which DENNIS E. HELMAN AND BRENDA HELMAN, HUSBAND AND WIFE by
deed dated June 13, 1997 and recorded June 16, 1997 in the office of the Recorder in and for Cumberland County in
Deed Book 159, Page 428, granted and conveyed to Gretchen A. Drewett and Harry C. Drewett, husband and wife, in
fee.
TAX MAP PARCEL NUMBER: 10-16-1060-026
MCCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830 sue,
KEVIN T.MCQUAIL,ESQUIRE-ID#307169 C=
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201926 r i r4s
JOSEPH F.RIGA,ESQUIRE-ID#57716 -<> -i C-D
JOSEPH I.FOLEY,ESQUIRE-ID#314675 !Zo -
1.23 South Broad Street,Suite 1400 J>o =,
Philadelphia,Pennsylvania 19109 c ""
(215)790-101.0
Wells Fargo Bank,N.A.s/i/i/t Wachovia Bank,N.A. CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V. No. I1-3133 civil
Gretchen A.Drewett and Harry C.Drewett
Defendants
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate,upon payment of your costs only,the default judgment entered in the above-captioned matter
against defendants GRETCHEN A.DREWETT and HARRY C.DREWETT on May 2,2011.This praecipe to vacate
is filed without prejudice to plaintiff s rights in this matter and is without prejudice to plaintiff s right of recovery against
defendants on the underlying obligation.
DATE: J 1�I 113 McCABE,WEISB ,P.C.
BY:
[ ] Terrence .Mc ,Esquire [ ]Marc S.Weisberg,Esquire
[ ]Edward b-C-ot1way,Esquire [ ]Margaret Gairo,Esquire
[ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire
[ ]Marisa J.Cohen,Esquire [ ] evm T.McQuail,Esquire
[ ]Christine L.Graham,Esquire [ j Brian T.LaManna,Esquire
[ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire
[ ]Joseph I.Foley,Esquire
Attorneys for Plaintiff
9k_' IRa3�a
0 IL A6
on
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff
MARC S. WEISBERG,ESQUIRE-ID#17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.MCQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E. SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
(215)790-1.010
Wells Fargo Bank,N.A. s/i/i/t Wachovia Bank,N.A. CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V. No. 11-3133 civil
Gretchen A.Drewett and Harry C.Drewett
Defendants
CERTIFICATE OF SERVICE
The undersigned Attorney for Plaintiff,hereby certifies that a true and correct copy of the within Praecipe to
Discontinue and End,as well as Praecipe to Vacate Judgment,was served on the below persons by regular first class
mail,postage prepaid,on the3lf+day of May,2013.
Gretchen A.Drewett
Harry C.Drewett
1205 Jerusalem Road
Mechanicsburg,Pennsylvania 17050
DATE: S-131113 McCABE,WEISBERG C .C.
BY:
[ ]Terrence J. cca s ire [ ]Marc S.Weisberg,Esquire
[ ]Edward D. ay, squire [ ]Margaret Gairo,Esquire
[ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire
[ ]Marisa J.Cohen,Esquire [ m T.McQuail,Esquire
[ ]Christine L.Graham,Esquire Brian T.LaManna,Esquire
[ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire
[ ]Joseph I.Foley,Esquire
Attorneys for Plaintiff
McCABE,WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID#17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.MCQUAIL,ESQUIRE-ID#307169 rnco cam.
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321 cnr ter. ;
ANN E.SWARTZ,ESQUIRE-ID#201926 —<> C3
JOSEPH F.RIGA,ESQUIRE-ID#57716 �
JOSEPH I.FOLEY,ESQUIRE-ID#314675
1.23 South Broad Street,Suite 1400 =C:)
Philadelphia,Pennsylvania 19109 ..
(215)790-1010 < c n "v
Wells Fargo Bank,N.A.s/i/i/t Wachovia Bank,N.A. CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V. No. 11-3133 civil
Gretchen A.Drewett and Harry C.Drewett
Defendants
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above-captioned matter as Discontinued and Ended,without prejudice,upon
payment of your costs only.
DATE: lJ 1 13 McCABE,WEISBER ,P.C.
BY: �'-
[ ]Terrence J Mcc quire [ ]Marc S.Weisberg,Esquire
[ ]Edward w squire [ ]Margaret Gairo,Esquire
[ ]Andrew L.Ma owitz,Esquire [ ]Heidi R. Spivak,Esquire
[ ]Marisa J.Cohen,Esquire [ ]6owmi T.McQuail,Esquire
[ ]Christine L.Graham,Esquire [ 'Brian T.LaManna,Esquire
[ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire
[ ]Joseph I.Foley,Esquire
Attorneys for Plaintiff