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HomeMy WebLinkAbout11-4357Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 R LED -OFF I CIE' 2011 HAY 16 AM 10: 37 CUMBERLAIID i,LiWI ! `a' PEEN 1SYLVANIA WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP1, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP 1 4600 Regent Blvd. Ste 200 Irving, TX 75603 Plaintiff V. ROSA LUCIDON AND JOHN LUCIDON OR OCCUPANTS 1910 Spring Road, Main Unit Carlisle, PA 17013 27669-CFC-EM Attorney for Plaintiff : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. // y?K7 &kq Defendant(s) : NOTICE ADVISO 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 THAT MAY OFFER LEGAL SERVICES TO ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar 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 a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda 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 provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 CIVIL ACTION - EJECTMENT od Aqa?? MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-OP 1 4600 Regent Blvd. Ste 200 Irving, TX 75603 Plaintiff V. ROSA LUCIDON AND JOHN LUCIDON OR OCCUPANTS 1910 Spring Road, Main Unit Carlisle, PA 17013 Defendant(s) 27669-CFC-EM COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY NO. CIVIL ACTION - EJECTMENT 1. Plaintiff, Wells Fargo Bank, N.A. as Trustee for SABR Trust 2004-OP1, Mortgage Pass-Through Certificates, Series 2004-OP I, is the owner of premises known as 1910 Spring Road, Main Unit, Carlisle, PA 17013, more fully described in the legal description, a true and correct copy is attached hereto, made part hereof and marked as Exhibit I. 2. Plaintiff claims title to the aforesaid property by virtue of a Sheriffs sale held on January 05, 2011, in the execution of a judgment in mortgage foreclosure obtained in the Court of Common Pleas of Cumberland County, Docket No. 2006-2390 where Plaintiff was the successful bidder. 3. The Plaintiff became the owner of the said property by a sheriff's deed recorded on January 27, 2011 in the Office of the Recorder of Cumberland County at Instrument No. 201103314. A true and correct copy is attached hereto, made part hereof and marked as Exhibit II. 4. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is entitled to possession thereof. The Defendants Rosa Lucidon and John Lucidon or Occupants are occupying the said premises without right, and so far as the Plaintiff is informed, without claim of title. WHEREFORE, plaintiff demands judgment for possession of 1910 Spring Road, Main Unit, Carlisle, PA 17013. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY: a a E. Von Rosenstiel, Es ire acqueline F. McNally, Esquire Attorneys for Plaintiff VERIFICATION I verify that the statements made in the foregoing documents are true and correct and are matters of public record. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BY. M a E. Von Rosenstie , E uire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: May 11, 2011 EXHIBIT I ALL THOSE TWO CERTAIN TRACTS OF LAND, TOGETHER WITH IMPROVEMENTS THEREON, ERECTED SITUATE IN NORTH MIDDLETON TOWNSF4P, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTIC ULARY BOUNDED AND DESCRIBED AS FOLLOWS TRACT NO.1 BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY ROUTE NO. 34 LEADING FROM THE BOROUGH OF CARLISLE TO THE BOROUGH OF NEW BLOOMFIELD, WHICH POINT IS IN THE NORTHERN LINE OF CARLISLE AVENUE (WHIC)H STREET LOCATED HAS BEEN CHANGED AND IS NOW CALLED WAGNER STREET), AS INDICATED ON THE PLAN OF LOTS ADOPTED BY GEORGE H, SCMLUSSER AND DESIGNATED AS PLAN NO.1 OF SCHLVSSER VILLAGE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA. IN CLAN BOOK; 7„ PAGE S. THENCE ALONG THE NORTHERN SIDE OF SAID CARLISLE AVENUE, NORTH 84 DEGREES 45 MINUTES WEST, A DISTANCE OF 152.8 FEET TO A P094T IN LINE OF LAND NOW OR FORMERLY OF GEORGE H, SCHLUSSER; THENCE ALONG SAID LANDS NOW OR FORMERLY OF GEORGE H. SCHLUSSER, NORTH 5 DEGREES 15 MIINUTES EAST, A DISTANCE OF 254.6 FEET TO A POINT MJ LINE OF LOT NO.6 ON THE SAID PLAN OF LOTS: THENCE ALONG SAID LOT NO. $, SOUTH 84 DEGREES 45 MINUTES EAST. A DISTANCE OF 1$2,8 FEET' TO A POINT IN THE CENTER OF THE AFORESAID PENNSYLVANIA STATE HIGHWAY ROUTE 34; TI#NCE ALONG THE CENTER OF SAID PENNSYLVANIA STATE HIGHWAY ROUTE NO, X SOUTH 5 DEGREES 15 MINUTES WEST, A DISTANCE OF 299.5 FEET TO A POWT. THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TWO-STORY FRAM DWELLING HOUSE AND CONCRETE BLOCK GARAGE KNOWN AND NUMBERED AS 1910 SPRING ROAD, CARLISLE. PENNSYLVANIA. TRACT 140,2 OIN THE NORTH BY TRACT NO, i ABOVE DESCRIBED, ON THE E'AST BY THE CARLISLE-NEW BLOOMFIELD ROAD {KNOWN AS PENNSYLVANIA ROUTE 040. 341, ON THE SOUTH BY WA GNER STREET AS SHOWN ON THE REVISED PLAN OF FRY AVENUE LOTS ON PLAN NO.4 OF SCHLUSSER VILLAGE, WHI0i PLAN 15 RECORDED IN THE SAID RECORDER'S OFFICE IN PLAN 800K 7, PAGE 47; AND ON THE WEST BY LOT NOS. 67 AND 68 AS SHOWN ON SAID REVISED PLAN OF FRY AVENUE LOTS.. BEING A PORTION OF LOT NO.4 AND PART OF THE FORMER CARLMLE AVENUE (ERRONEOUSLY SAID IN PRIOR DEED BE PART OF LOT NO, 5) AS SHOWN ON PLAN NO, 1 OF SCHLUSSER VI LLAGE. WHICH PLAN IS RECORDED IN THE SAID RECORDERS OFFICE IN PLAN BOOK T, PAGE 5. CONTAINING 50 FEET MORE OR LESS, IN FRONT ON SAID ROUTE NO. 34 AND EXTENDING IN DEPTH AT AN INCREASING WIDTH OF 150 FEET, MORE OR LESS, AND HAVING A WIDTH IN THE REAR OF 55 FEET, MORE OR LESS. THE ABOVE TWO LOTS OF GROUND ARE CONVEYED SUBJECT TO THE BUILDING AND OTHER RMTRICTIONS AS SHOWN ON SAID PLAN OF LOTS RECORDED AS AFORESAID, BEING KNOWN AS, IS 10 Sprih9 ROW Cadi", PA 11'013 PROPERTY ID NO 29.16.1094,241 TITLE TO SAW) PREMISES 13 VESTED IN JOHN LUCIDON AND ROSE MARIA LMSON, HUSBAND AND WIFE BY° DEED FROM LEON C. MORPJSON AND JEANNETTE MORRISON. HUSBAND AND WIFE DATED 1 111 312 003 RECORDED 1111&2003 IN DEED SOOK 2$0 PAGE 26140. AND BEING the same premises which were sold to WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP1, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP 1, as Trustee by the Sheriff of CUMBERLAND County on January 05, 2011 in execution of a judgment in mortgage foreclosure entered in the Court of Common Pleas of CUMBERLAND County Docket No. 2006-2390. MARTHA E. VON ROSENSTIEL, P.C. 27669CFJ-EM Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE : COURT OF COMMON PLEAS FOR SABR TRUST 2004-OP I, MORTGAGE : CUMBERLAND COUNTY PASS-THROUGH CERTIFICATES, SERIES : 2004-OP I c= ?.y 4600 REGENT BLVD. STE 200 rriC =::_ ., IRVING TX 75603 CASE NO: 2011-4357 ? PLAINTIFF ?' rv u r, VS. ? ROSA LUCIDON OR OCCUPANTS ?. r_.. 1910 SPRING ROAD, MAIN UNIT = r- CARLISLE PA 17013 DEFENDANT(S) PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Enter judgment in the above captioned Ejectment action for failure of the above named defendants to file an answer within twenty days from date of service thereof. I hereby certify that Notice as provided in Rule 237.5 has been duly given, and that the time limits provided for in that notice have expired as evidenced by the attached Exhibit I. Property Address: 1910 SPRING ROAD, MAIN UNIT CARLISLE PA 17013 Dated: June 17, 2011 Respectfully Submitted, MARTHA E. VON ROSENSTTL. P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Pq- ap ?k y clew (14. 58 A_)oittc_^&tL( a. MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE FOR COURT OF COMMON PLEAS SABR TRUST 2004-OPI, MORTGAGE PASS- CUMBERLAND COUNTY THROUGH CERTIFICATES, SERIES 2004-OP1 PLAINTIFF VS. ROSA LUCIDON OR OCCUPANTS CASE NO: 2011-4357 1910 SPRING ROAD, MAIN UNIT CARLISLE, PA 17013 DEFENDANT TO: Rosa Lucidon or Occupants 1910 Spring Road, Main Unit Carlisle, PA 17013 IMPORTANT NOTICE 27669CFJ-EM 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 AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Dated: June 07, 2011 Respectfully Submitted, MARTHA E. VON ROSEN 7L, .C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE : COURT OF COMMON PLEAS FOR SABR TRUST 2004-OP1, MORTGAGE : CUMBERLAND COUNTY PASS-THROUGH CERTIFICATES, SERIES : 2004-OP I 4600 REGENT BLVD. STE 200 IRVING TX 75603 CASE NO: 2011-4357 PLAINTIFF VS. ROSA LUCIDON OR OCCUPANTS 1910 SPRING ROAD, MAIN UNIT CARLISLE PA 17013 DEFENDANT(S) AFFIDAVIT OF NON MILITARY SERVICE 27669CFJ-EM MARTHA E. VON ROSENSTIEL, being duly sworn according to law deposes and says that she is the attorney for the plaintiff herein; that she is duly authorized to take this affidavit in behalf of the plaintiff, and that the defendants 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; That Rosa Lucidon or Occupants, Defendant(s) is/are over 21 years old and reside(s) at 1910 Spring Road, Main Unit Carlisle PA 17013. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEf, P.C. BY: Marty E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: June 17, 2011 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE : COURT OF COMMON PLEAS FOR SABR TRUST 2004-OP1, MORTGAGE : CUMBERLAND COUNTY PASS-THROUGH CERTIFICATES, SERIES : 2004-OP 1 _ Plaintiff : No: 2011-4357 VS. ROSA LUCIDON OR OCCUPANTS Defendants CERTIFICATE OF SERVICE 27669CFJ-EM Martha E. Von Rosenstiel, Esquire hereby certifies that she is the attorney for the Plaintiff herein, and that service of the praecipe to enter judgment in the above matter was made upon the following: ROSA LUCIDON OR OCCUPANTS 1910 Spring Road, Main Unit Carlisle, PA 17013 by regular first class mail, postage prepaid, deposited with the United States Postal Service on 6/17/2011. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully MARTHA E. VON ROSENSTIL. P.C. BY: Dated: 6/17/2011 Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 Prothonotary Rosa Lucidon or Occupants 1910 Spring Road, Main Unit Carlisle, PA 17013 WELLS FARGO BANK, N.A. AS TRUSTEE : COURT OF COMMON PLEAS FOR SABR TRUST 2004-OP1, MORTGAGE : CUMBERLAND COUNTY PASS-THROUGH CERTIFICATES, SERIES : 2004-OP 1 PLAINTIFF VS. : ROSA LUCIDON OR OCCUPANTS DEFENDANT(S) NO: 2011-4357 Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment for possession has been entered against you in the above proceeding as indicated below: Prothonotary Judgment by Default F-1 Money Judgment F1 Judgment in Replevin Judgment for Possession F1 Judgment on Award of Arbitration D Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Martha E. Von Rosenstiel, Esquire at this telephone number: 610-328-2887. 27669CFJ-EM 27669CPG-EM Praecipe for Writ of Possession (Pa.R. C.P. 3160-3165) COUNTY OF CUMBERLAND WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST COURT OF COMMON PLEAS 2004-OP1, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP1 DOCKET NO. 2011-4357 V. ROSA LUCIDON OR OCCUPANTS TO THE PROTHONOTARY: ATTORNEY I.D. #56,34 M C :) y C- ID Kindly issue Writ of Possession in the above Ejectment matter. , . 1910 Spring Road, Main Unit Carlisle, PA 17013 42Y. do ?dL. 7! . O u e r-1` !? o 9,2 cj -".2. od (?46 Respectfully Submitted, MARTHA E. VON ROSENSTIE , P.C. BY: artha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff CK-4 1W.-T197 k4i- .2 L61190 2 W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP1 VS. No. 2011-4357 Civil Term ROSA LUCIDON OR OCCUPANTS Costs Attorney's $ 201.00 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP 1 being: (Premises as follows): 1910 SPRING ROAD, MAIN UNIT CARLISLE, PA 17013 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. David D. Buell, Prothonotary, Common Pleas Court of Cumberland County A Date JUNE 2p_.20 11 (Sea1? p ? 2of2 No 11-4357 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP 1 VS. ROSA LUCIDON OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 201.00 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 649 SOUTH AVENUE, UNIT #7 SECANE, PA 19018 610-328-2887 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the named appurtenances, and day of , . I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , C7 '. , ?tiffs, o IllNf Pr C Cy p r7 Jody S Smith ? 4? `a3 - ` --r ChiefDeputy - W Stewart Richard (n C Solicito ?? r F ) --I A a' q -r T1 q- z kO - C552 Wells Fargo Bank NA Case N6rhbe vs. Rosa Lucidon (et al.) 2011-4357 4 SHERIFF'S RETURN OF SERVICE 06/30/2011 07:28 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Rosa Lucidon at 1910 Spring Road, Main Unit, North Middleton Township, Carlisle, PA 17013, Cumberland County, informed Defendant of contents of same and posted Sheriffs Notice on premises. 07/01/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupants, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1910 Spring Road, Main Unit, North Middleton Township, Carlisle, PA 17013. Rosa Lucidon is the only occupant of 1910 Spring Road, Main Unit, Carlisle, Pennsylvania, 17013. July 01, 2011 !c; CounfySuite Sherft TeleorsofT Inc SO ANSWERS, 0A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE rTHE PROTH0No 1A k,, 2011 JUL 22 QM 8: 4 3 CUMBERLAND COUNTY Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank NA vs. Rosa Lucidon (et al.) Case Number 2011-4357 SHERIFF'S RETURN OF SERVICE 06/30/2011 07:28 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Writ of Possession by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Rosa Lucidon at 1910 Spring Road, Main Unit, North Middleton Township, Carlisle, PA 17013, Cumberland County, informed Defendant of contents of same and posted Sheriffs Notice on premises. 07/01/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Occupants, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1910 Spring Road, Main Unit, North Middleton Township, Carlisle, PA 17013. Rosa Lucidon is the only occupant of 1910 Spring Road, Main Unit, Carlisle, Pennsylvania, 17013. 07/21/2011 By virtue of this writ, Ronny R. Anderson, Sheriff caused the within named Plaintiff to have possession of the premises described as 1910 Spring Road, Main Unit, Carlisle, PA 17013. Possession given to Ron Goldberg of Keller Williams Realty. SHERIFF COST: $82.00 July 22, 2011 SO ANSWERS, RON r R ANDERSON, SHERIFF 1-fi- i (, Ccu?iySuite henf_ reieosott, ir: 27669- CPG -EM (disc & end) Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610 328-2887 Attorney I.D. # 52634 Attorney for Plaintiff : COURT OF COMMON PLEAS WELLS FARGO BANK, N.A. AS TRUSTEE : CUMBERLAND COUNTY FOR SABR TRUST 2004-OP I, MORTGAGE : PASS-THROUGH CERTIFICATES, SERIES : 2004-OP 1 PLAINTIFF NO: 2011-4357 VS. ROSA LUCIDON OR OCCUPANTS DEFENDANTS fi =M X;0 C G10 t'" -Vrq t" a= <C) -4 n a• v- ?, C = M PRAECIPE TO MARK CASE DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark this action discontinued and ended without prejudice. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: August 24, 2011 27669- CPG -EM (vacate) Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610 328-2887 Attorney I.D. # 52634 WELLS FARGO BANK, N.A. AS TRUSTEE : FOR SABR TRUST 2004-OP1, MORTGAGE : PASS-THROUGH CERTIFICATES, SERIES : 2004-OP 1 PLAINTIFF VS. ROSA LUCIDON OR OCCUPANTS DEFENDANTS Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY : NO: 2011-4357 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment in the above-referenced action. Respectfully Submitted, Dated: August 24, 2011 Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff r? r+i z? z? a ? D" z Co ?c z -a a. G) N 47% x. rn -arn 7?0 0© a a --c 4 9. oo P a ATrl el#7790 0a(P38B MARTHA E. VON ROSENSTIEL, P.C. BY,