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HomeMy WebLinkAbout11-5846IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., VS. Plaintiff, SARA JANE GANDY, ADMINISTRATRIX OF THE ESTATE OF HARRY C. GANDY Defendant. TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAYBE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: 3476 STATEVIEW BLVD. MAC # X7801-013. FT. MILL, SC 29715 AND THE DEFENDANT: CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 55 Cavalrv Road. Carlisle PA 17013 Municipality: North Middleton C . . . I ATTORNEY FOR PLAINTIFF ATTY FILE NO.: XFP 15310 CIVIL DIVISION NO.: I l , S6q ? Oi vi' TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh L. Levy, Esquire Pa I.D. #306799 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP- 153104/bga :-'a > . , C ''TT It- (sir ,O3 ^ CD f" . H C? :X C:) -?, :z D ?? c' i i aSaga.w a W 9a(.c7 g atoa-aq a Zucker, Goldberg & Ackerman, LLC XFP-153104 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Zucker, Goldberg & Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, CIVIL DIVISION NO.: VS. Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, CIVIL DIVISION NO.: VS. Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy Defendant. AVISO LISTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y redicando en la Corte por escrito sus defensas de, y objeciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero O propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., : CIVIL DIVISION Plaintiff, . NO.: vs. SARA JANE GANDY, ADMINISTRATRIX OF THE ESTATE OF HARRY C. GANDY Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") having its principal place of business at 3476 STATEVIEW BLVD., MAC # X7801-013, FT. MILL, SC 29715. 2. The Defendant, Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, is an individual whose last known address is 55 Cavalry Road, Carlisle, PA 17013. 3. On or about March 15, 2004, Harry C. Gandy executed a Note in favor of New Freedom Mortgage Corporation in the original principal amount of $79,287.00. 4. On or about March 15, 2004, as security for payment of the aforesaid Note, Harry C. Gandy, a married man made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for New Freedom Mortgage Corporation a Mortgage in the original principal amount of $79,287.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on April 26, 2004, in Mortgage Book Volume 1862, Page 2982. 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. Said Note and Mortgage was assigned by an assignment of mortgage dated 05/20/2011 from Mortgage Electronic Registration Systems, Inc., as nominee for New Freedom Mortgage Corporation to Wells Fargo Bank, N.A., plaintiff herein. This assignment as recorded on 05/24/2011, Instrument #201114909 Zucker, Goldberg & Ackerman, LLC XFP-153104 6. The aforesaid Mortgage was amended and increased in principal amount of $67,746.93 pursuant to a certain Modification Agreement by and between Wells Fargo Bank, N.A. and Defendant, Harry C. Gandy, which is unrecorded at this time. The terms of said modification set forth the interest rate at 5.500% with a new monthly payment and interest amount of $ 689.00 commencing June 1, 2008 and continuing thereon with the due date of obligation April 1, 2019. A true and correct copy of said Modification Agreement is marked Exhibit B, attached hereto and made a part hereof. 7. Defendant, Harry C. Gandy, a married man, is the record owner of the aforesaid mortgaged premises. Harry C. Gandy, a married man died on 05/11/2008, with defendant Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, succeeding to his interest as believed heir and administratrix of his Estate. 8. Defendant, Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, is hereby released from any and all personal liability under the Note pursuant to Pa. R.C.P. 1144(b). 9. 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).]. 10. Plaintiff was not required to send Defendant(s) written notice of Plaintiff's intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this action for the reason that the original principal balance of the aforesaid Mortgage is more than the original principal balance threshold of the Act, and therefore: (a) said Mortgage is not a "residential mortgage" as defined in 41 P.S. §101; (b) the Defendant(s) is/are not "residential mortgage debtor(s)" as defined in 41 P.S. §101, and; (c) the mortgage premises is not "residential real property" as defined in 41 P.S. §101. Zucker, Goldberg & Ackerman, LLC XFP-153104 11. The amount due and owing Plaintiff by Defendant is as follows: Principal $53,247.47 Interest to 06/17/2011 $1592.68 Late Charges $ 245.00 Escrow ($67.65) Corporate Advance $20.00 Inspection Fee $60.00 Total $55,097.50 plus interest on the principal sum ($53,247.47) at the daily interest of $8.02, and all other additional amounts authorized under the Mortgage, actually and reasonably incurred by Plaintiff, including but not limited to, late charges, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums to the above amount due and owning when incurred. 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability under the aforesaid Note in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $55,097.50with interest thereon at the daily interest of $8.02 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, Goldberg & Ackerman, LLC XFP-153104 ZUCKER, GOLDBERG & ACKERMAN, LLC BY: Dated: ] j 1 2011 Scott A. Diet eric , sq re; PA I.D. #55650 Kimberly A. Bonner, Es uire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Levy, Esquire; PA I.D. #306799 Attorneys for Plaintiff XFP-153104/bga 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-153104 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-153104 GANDY,H203098 D j c1 Wells Fargo f' Transmittal Wells Loan Number: Borrowers Name: HARRY C. GANDY NFM Loan Number: 203098 Address: 55 CAVALRY ROAD CARLISLE,PA 17013 I i FHA/VA Case #: 441-7461282-703 SSN: 419-52-8791 To complete the above captioned loan, we hereby submit and enclose all of the following documents in accordance with the policies outlined in Section 565 of this Seller Guide. ? Original Mortgage Insurance Certificate (FHA) V ginal Loan Guaranty Certificate (VA) ginal Recorded Mortgage / Deed of trust ? Original Assignment of Mortgage / Deed Of Trust ? Original Intervening Assignments ? Original Title Policy / Attorney's Certificate of Title Completed by: NEW FREEDOM MORTGAGE CORPORATION FINAL DOC'S DEPARTMENT 2363 SOUTH FOOTHILL DRIVE SALT LAKE CITY, UT 84109 Date: 05/10/04 iB-Fnat Does Transng 1 j5Q4 09 C%M X3098 !"?l5"'? (.:.!?`RLAN, Or DEEDS D COU?.jTY_? ' ^R 2fi nn 2 10 poor Quality Rec-rdl, nfo; m`T,4? o Q ?. n 'fteftmr-+o: EW FREEDOM MORTGAGE CORPORATION 2363 SOUTH FOOTHILL DRIVE SALT LAKE CITY, UT 84109 Parcel Number: 29-19-1639-122 AP# GANDY,H203098 LN# 203098 [Space Above This Line For Recording Data] Ft1A Case No. Commonwealth of Pennsylvania MORTG G Oq NLQg? 441-7461282-703 MIN 1000360-0000203098-5 THIS MORTGAGE ("Security Instrument") is given on March 15, 2004 The Mortgagor is HARRY C. GANDY, A MARRIED MAN RETURN TO (NLS): NATIONS TITLE AGENCY INC. 5370 W. 95TH ST. .SHAWNEE, KS 66207 ("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. ("MFRS"), (solely as nominee for Lender, as hereinafter defined, and Lender's successors and assigns), as mortgagee. MERS is organized and existing under the laws of Delaware, and has an address and telephone number of P.O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS. NEW FREEDOM MORTGAGE CORPORATION. A CORPORATION ("Lender") is organized and existing under the laws of THE STATE OF UTAH , and has an address of 2363 SOUTH FOOTHILL DRIVE, SALT LAKE CITY, UT 84109 . Borrower owes Lender the principal sum of Seventy Nine Thousand Two Hundred Eighty Seven and no/100 Dollars (U.S. $ 79.287.00 ). FHA Pennsylvania Mortgage with MERS - 4/% sa®-4NiPA1 *2071 Amended 610h Page 1 of 10 MW 07/02 Irklei[/ai VMP MORTGAGE FORMS - (8001521-7291 sell 1111111111111111 1111 BK 1862PG2982 This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on April 1, 2019 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose. Borrower does hereby mortgage, grant and convey to MFRS (solely as nominee for Lender and tender's successors and assigns) and to the successors and assigns of MFRS, the following described property located in CUMBERLAND County, Pennsylvania: *** SEE ATTACHED LEGAL DESCRIPTION *** which has the address of 55 CAVALRY ROAD [Street] CARLISLE [City). Pennsylvania 17013 [zip Code) ("Property Address"); TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument; but, if necessary to comply with law or custom, MFRS. (as nominee for Lender and Lender's successors and assigns), has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. IA ?. AN(PA1 10207) o,ps z of io Inida OXI862PG2933 Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. 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) tares and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a 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. Section 2601 et seq. and implementing regulations, 24 CFR Pan 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lendcr 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 sufficient 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 pledged as additional security for all sutras secured by this Security Instrument. If Borrower tenders to Lender the full 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 obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paragraphs I and 2 shall be applied by Lender as follows: First, to the mortgage insurance premium to be paid by-Lender to-the Secretary or to the-monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; Fourth, to amortization of the principal of the Note; and Fifth, to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in ANIPA1 (0207) Pape 3 01 10 I "L•a?s . 8?t 1862pu2984 the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection or 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 circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this ;Security Instrument is on a leasehold. Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess 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. ANWA? ro=a» rage a oe 10 g? 1862PG2985 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 arc not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or 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 by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, 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 the payment of the obligation secured by the lien in a manner acceptable to Lender: (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien: or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (r) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of payment defaults, require immediate 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 to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if- 0) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to subsequent events. /l N inuiab 1 PY ANiPA) fozo» Pepe 5 Of 10 BK 1862Pv298? (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance 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 authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that 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 commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's 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 any demand trade by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Instrument 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-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. hwilMs-&- 6-9. -4N(PA) ro2071 Faye 6 of 10 $K1862PG2987 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower 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 that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower ]cams, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the 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 Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each -"(PA) colon Papa 7 of 10 Initials: • L BK 1862PG2988 tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has'not and will not perform any act that would prevent Lender from exercising its rights 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 of 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. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3751 et seq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy 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 Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument, if one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)]. El Condominium Rider F-1 Growing Equity Rider E-1 Other [specify] Planned Unit Development Rider El Graduated Payment Rider al sfLj- -"(PA) 10=07i Fapo a of io snit 9 BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses: (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower -4N(PA) 10207, f _ (Seal) HARRY C. NDY -Borrower Pogo 9 of 10 BKI8b2P-b2990 ._ (Seal) -Borrower _ (Seal) Borrower -_ (Seal) -Borrower _ (Seal) -Borrower Certificate of Residence c I•E?f?(?l? do hereby certify that the correct address of the within-named Mortgagee is P.O. Box 2026, Flint, MI 48501-2026. Witness my hand this 14?7Y1 day of mftc i+ , 7,M q. Agent of..Nongagee COMMONWEALTH OF PENNSYLVANIA, CUJm 12 ZA Id County ss: On this, 1S 1 day of -MCt,t,J 22004 , before me, the undersigned officer, personally appeared HARRY C. GANDY I G MW'upt(' morS known to me (or satisfactorily proven) to be the person(s) whose name(s) is/arc subscribed to the within instrument and acknowledged that he/she/they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: t Rora M. Vogt, Notary Pttbtlo- ' Ceflisle 9oro, Cumberland Couftty My Commission Expires May 21, 20115 Member, PennryNanioAsswmow ionotNOiapes Title of Officer '- •! 45 Initial$ vhf ®4NIPA) 10207) Page ID or io 811 1862?62991 ALL THAT CERTAIN LOT OF GROUND SITUATE IN NORTH MIDDLETON TOWNSHIP. CUMBERLAND COUNTY. PENNSYLVANIA. BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE INTERSECTION OF THE EASTERN LINE OF CAVALRY ROAD AND THE SOUTHERN LINE OF HARRIET STREET; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF HARRIET STREET 72 FEET MORE OR LESS; THENCE ALONG OTHER PROPERTY NOW OR FORMERLY OF VINCENT M. ZELADONIS AND PEGGY A. ZELADONIS. SOUTHWARDLY 100.40 FEET MORE OR LESS: THENCE WESTWARDLY ALONG THE LINE OF LOT NO. 11 OF THE HEREINAFTER MENTIONED PLAN OF LOTS 92 FEET MORE OR LESS: THENCE NORTHWARDLY ALONG THE EASTERN LINE OF CAVALRY ROAD 102.6 FEET MORE OR LESS TO THE PLACE OF BEGINNING. BEING THE WESTERN PORTION OF LOTS NOS 12 AND 13 OF THE PLAN OF LOTS KNOWN AS HARRIET ACRES. AS RECORDED IN THE OFFICE OF THE RECORDER OF DEED IN AND FOR CUMBERLAND COUNTY. IN PLAN BOOK 2 PAGE 100. BEING IMPROVED WITH A ONE STORY DWELLING HOUSE KNOWN AS NO. 55 CAVALRY ROAD. CARLISLE. PENNSYLVANIA. PROPERTY ADDRESS: 55 CAVALRY ROAD TAX ID#: 29-19-1639-122 I Certify tl,iS tI be rec ?., C'trmbcr1,111c1 ? County PA r } 4*` Recorder Of aK 18624?2?92 EXHIBIT B B Zucker, Goldberg & Ackerman, LLC XFP-153104 Wells Fargo Home Mortgage MAC X7801-03K ?J"_T 3476 Stateview Boulevard Fort MITI, SC 29715 LOAN MODIFICATION TRANSMITTAL FORM Part A: Servicer Information Preparer Name: Seller/Service Number: 99999 Date Prepared: Phone Number: Fax Number: Servicer Name : Servicer Address: Part B: Loan Data 03-28-08 (800) 416-1472 (866) 359-7363 Wells Fargo Bank, N A 3476 Stateview Blvd., MAC X7801-03K Fort Mill SC 29715 Investor Loan Number: 0192904589 Loan Number: 7080192904589 Borrower Name: Harry C Gandy Co-Borrower Name: Loan Origination Date: 03-15-04 Loan Type: FHA 05-14-08 A09:35 IN Property Address: 55 Cavalry Road ??. Carlisle PA 17013 Mortgage Insurer: Hud Risk-based r" Certificate Number: 441-7461282 Has MI Approved? Y / N Owner Occupied? OWNER / VACANT / TENANT / UNKNOWN Number of Units 1 / 2-4 / OTHER Part C: Modification Data Pre-Modification Modified Unpaid Principal Balance $ 65,455.32 $ 67,746.93 Note Rate 5.500001 5.500 Monthly P&I Payment 647.84 689.00 DDLPI(I) Eff. Interest Change Date (II) 00-00 05/01/2008 Maturity Date 04-19 04/01/2019 First Modified Payment Due Date 06/01/2008 New Term (months) 131 Breakdown of Amounts Due: Interest (Plus Del Prin if Structured Finance mod) $ 1,500.00 Escrow 791.61 Corp Recov/Title/Mod Fees/Atty/FC/BPO/Appraisal 812.58 FHLMC 2t Fee .00 Borrower's Payment Toward Arrearages $ 812.58 Mortgage Insurer Contribution .00 Total Capitalized Amount $ 2,291.61 LC176/K3I Wells Fargo Home Mortgage Is a division of Wells Fargo Bank, N.A. Walls Fargo Homo Mortgage MAC X7801-03K 3476 Statevlew Boulevard Fort Mill, SC 29715 LOAN MODIFICATION AGREEMENT LOAN NUMBER: 7080192904589 THIS LOAN MODIFICATION AGREEMENT made on March 28, 2008, by and between HARRY C GANDY and (the "Borrower(s)") and Wells Fargo Bank, N A (the "Lender") W I T N E S S E T H WHEREAS, Borrower has requested, and Lender has agreed, subject to the following terms and conditions, to a modification in the payment as follows: NOW THEREFORE, in consideration of the covenants hereinafter set forth and.of other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged by the parties,, it is agreed as follows (notwithstanding anything to the contrary contained in the Note and Mortgage dated 3/15/2004): 1. BALANCE. As of March 28, 2008, the amount payable under the Note and Mortgage (the "Unpaid Principal Balance") is U.S. $ 65,455.32. 2. EXTENSION. This agreement hereby modifies the following terms of the Security Instrument described herein above as follows: A. The current contractual due date has been extended from 01-01-08. The first modified contractual due date is due on 06/01/2008. B. The maturity date has been extended from 04-19 (month/year) to 04/01/2019. C. The amount of interest to be capitalized will be U.S. $ 1,500.00. The modified unpaid principal balance is U.S. $ 67,746.93. D. The borrower promises to pay the unpaid principal balance plus interest, to the order of the Lender. Interest will be charged on the unpaid principal balance of U.S. $ 67,746.93. The borrower promises to make monthly payments of principal and interest of U.S. $ 689.00, at a yearly rate of 5.500W, not including any escrow deposit, if applicable. If on the maturity date the borrower still owes amount under the Note and Security Instrument, as amended by this Agreement, borrower will pay these amounts in full on the maturity date. * (If applicable, all scheduled step rate changes according to your Note and Mortgage will remain unchanged.) LC175/K3I/Page 1 Wells Fargo Home Mortgage Is a division of Wells Fargo Bank NA Wags Fargo Honor Mortgage MAC X7801.03K 3476 Stateview Boulevard Fort Mill, SC 29715 Loan Modification Agreement Page 2 of 2 Loan 7080192904589 3. NOTE AND MORTGAGE. Nothing in this Agreement shall be understood or construed to be a satisfaction or release, in whole or in part of the Borrower's obligations under the Note or Mortgage. Further, except as otherwise specifically provided in this Agreement, the Note and Mortgage will remain unchanged, and Borrower and Lender will be bound by, and shall comply with, all of the terms and provisions thereof, as amended by this Agreement. CORRECTION AGREEMENT. The undersigned borrower(s), for and in consideration of the approval, closing and funding of this Modification, hereby grants Wells Fargo Bank, N A, as lender, limited power of attorney to correct and/or initial all typographical or clerical errors discovered in the Modification Agreement required to be signed. In the event this limited power of attorney is exercised, the undersigned will be notified and receive a copy of the document executed or initialed on their behalf. This provision may not be used to modify the interest rate, modify the term, modify the outstanding principal balance or modify the undersigned's monthly principal and interest payments as modified by this agreement. Any of these specified changes must be executed directly by the undersigned. This limited power of attorney shall automatically terminate in 120 days from the closing date of the undersigned's Modification. (Borrower Initial) IN WITNESS WHEREOF, the parties hereto have executed this Agreement as the date first above written. By signing this loan Modification I hereby consent to being contacted concerning this loan at any cellular or mobile telephone number I may have. This includes text messages, at no cost to me, and telephone calls including the use of automated dialing systems to contact my cellular or mobile telephone. Harry ndy 61- Date Wells Fargo Bank, N A,' ficer Date LC175/K3I/2 8 Wells Fargo Home Mortgage Is a division of Wells Fargo Bank, N.A. VERIFICATION Elia Cuadra, hereby states that/ht//she is Vice President Loan Documentation of, WELLS FARGO BANK, N.A., servicing agent for Plaintiff in this matter, that /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best 0f)i9her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 4JQ 91 2 D 1 Nam : E a Cuadr Title: Vice President Loan Documentation Servicer: WELLS FARGO BANK, N.A. File #: 153104 Name: GANDY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r ? j Sheriff j - 17 T s, Jody S Smith Chief Deputy Richard W Stewart CSI E Solicitor L- W, i Wells Fargo Bank, N.A. vs. Case Number Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy 2011-5846 SHERIFF'S RETURN OF SERVICE 08/03/2011 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: Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, 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 Sara Jane Gandy. Request for service at 55 Cavalry Road, Carlisle, Pennsylvania 17013 the Defendant was not found. The Carlisle Postmaster has confirmed, Sara Jane Gandy's new address is 5616 Ridgerock Road, Fort Worth, Texas 76132. SHERIFF COST: $39.00 August 03, 2011 SO ANSWERS, &Z ??Z2? RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 11-5846 VS. mc o Administratrix of the Estate of Sara Jane Gandy r o rn -Vrn , Harry C. Gandy; ??. ?'- M ? ?FZ Defendants . CC) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please mark the Complaint in Mortgage Foreclosure filed at the above-captioned term and number reinstated. ZUCKER, G L RG & ACKERMAN, LLC BY Maw" Dated: November '2011 Scott A. Diet nck, Esquire; PAL D. 55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-153104/jab 200 Sheffield Street, Suite 101 Mountainside, N1 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoIdberg.com S I ID - 00 P,0 A4T7t/ aw 2(081? &.707-7t/8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, VS. CIVIL DIVISION NO.: 11-5846 Sara Jane Gandy, Administratrix of the Estate of Harr C. Gandy; Defendant(s). MOTION FOR SPECIAL SERVICE ON DEFENDANT PURSUANT TO Pa. R.C.P. 430 FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire r a ?.z Cn Pa. I.Q. #55650 i Kimberly A. Bonner, Esquire M ="I Pa. I.D. #89705 - y -3i'l Joel A. Ackerman, Esquire > o a® Pa. I.D. #202729 ? C Ashleigh Levy Marin, Esquire 'c? Pa. I.D. #306799 o Ralph M. Salvia, Esquire W Pa I.D. #202946 ` r") Jaime R. Ackerman, Esquire Pa I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckereoldbere.com File No.: XFP-153104/ns Zucker, Goldberg & Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 11-5846 vs. Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy; Defendant. MOTION FOR SPECIAL SERVICE PURSUANT TO Pa.R.C.P. 430 AND NOW, comes the Plaintiff, Wells Fargo Bank, N.A., by and through its attorneys, Zucker, Goldberg & Ackerman, LLC, and files the within Motion for Special Service pursuant to Pa.R.C.P. 430 as follows: 1. On or about July 25, 2011, Plaintiff filed its original Complaint in Mortgage Foreclosure ("Complaint") against the Defendant, Harry C. Gandy ("Defendant(s)"), at the above-captioned number and term. 2. Plaintiff directed the Sheriff of Cumberland County to serve Defendant(s) at defendant's last known address being 55 Cavalry Road, Carlisle, PA 17013, but service was returned not found. A true and correct copy of said Return of Service from the Cumberland County Sheriff's Office is marked Exhibit A, attached hereto and made a part hereof. 3. On May 4, 2011 a request for confirmation of an alternate address for defendant(s) was forwarded by Plaintiff's counsel to the US Postmaster for 55 Cavalry Road, Carlisle, PA 17013, but no such information was provided by said postal authorities. 4. Plaintiff directed the Sheriff of Cumberland County to serve Defendant(s) at defendant's last known address being 1000 CLAREMONT RD, CARLISLE PA 17013-7310, but service was returned competent. A true and correct copy of said Return of Service from the Cumberland County Sheriff's Office is marked Exhibit B, attached hereto and made a part hereof. 5. On May 4, 2019. a request for confirmation of an alternate address for defendant(s) was forwarded by Plaintiff's counsel to the US Postmaster for 1000 CLAREMONT RD, CARLISLE PA 17013- 7310, but no such information was provided by said postal authorities. 6. Also, Plaintiff attempted service of the defendant(s) via certified mail, return receipt to defendant(s) at an alternate address being 5616 Ridgerock Road Fort Worth, TX 76132, but certified mail was returned unclaimed. A copy of said return is marked Exhibit C, attached hereto and made a part hereof 7. On May 4, 2011 a request for confirmation of an alternate address for defendant(s) was forwarded by Plaintiff's counsel to the US Postmaster for 5616 Ridgerock Road Fort Worth, TX 76132, but no such information was provided by said postal authorities. 8. An internet person locator search provided no alternative address for Defendant(s). 9. Plaintiff conducted an investigation to determine the whereabouts of Defendant(s), Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, but all sources indicated no alternative address other than that of the Mortgaged Premises. An affidavit of Plaintiffs counsel regarding the investigation taken to determine the whereabouts of Defendant(s) is marked Exhibit D, attached hereto and made a part hereof. 10. Plaintiff attempted to obtain concurrence of Defendant(s) Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy with the Motion, but Defendant(s) cannot be located, therefore no concurrence was obtained. 11. There has been no other motion filed in this case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court to permit Plaintiff to serve Defendant(s), Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, with the Complaint and Notice of Sale, if necessary, by instructing the Cumberland County Sheriff's Office to POST a copy of same on the Mortgaged Premises, being 55 Cavalry Road, Carlisle PA 17013 and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 1000 CLAREMONT RD, CARLISLE PA 17013-7310 and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 5616 Ridgerock Road Fort Worth, TX 76132, with said service being valid and complete upon such posting and mailing in accordance with Pa R C P 430. ZUCKER GOLDBERG & ACKERMAN, LLC Dated: December , 2012 By: Scott A. Dietterick, Esquire; PA I.D. 455650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-153104 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ?orrn of C4unb,,Z4 6 OFFICE of THE b1WMF I 5310q Wells Fargo Bank, N.A. VS. Case Number Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy 2011-5846 08103/2011 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: Sara Jane.Gandy, Admin'stratrix of the Estate of Harry C. Gandy, butwas unable to,locate her in his bailiwick. He-therefyre returns the wlthin Complaint in Mortgage Foreclosure as riot found as to the defendant Sam Jane Gandy. Request for service at 55 Cavalry Road, Carlisle, Pennsylvania 17013 the Defendant was not found. The Carlisle Postmaster has confirmed, Sara Jane Gandy's new address is 5616 Ridgerock Road, Fort Worth, Texas 76132. SHERIFF COST: $39.00 SO ANSWERS, August 03, 2Q11 RON R ANDERSON, SHFRIFF j Ad*MSA. r0 Bm 1214 "- Wn". W 0r092.12f0 1 7196 9006 9295 4280 0577 I ilh"I'1"nl1lP'ipll4''4111'i"i41'"''I'il''IIIIIII'II'" Sara Jane Gandy, Adm 5616 RIDG£ROCK RD inisiratrix of the Estate of Harry C? FORT WORTH, TX 76132-2545 I--? t !I II I. f if 1 f 111 I. ? 1 {I ? hhi4 I 1 f Nthll'lf°Il I'll tiff I'f III Il EXHIBIT D Zucker, Goldberg & Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. . CIVIL DIVISION vs. Plaintiff, NO.: 11-5846 Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy; Defendant. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Ralph M. Salvia, Esquire, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and says that Plaintiff, or counsel for Plaintiff, conducted an investigation to determine the whereabouts of Defendant(s), which included, but was not limited to searches of the following records: N Records of the U.S. Postmaster with results of same attached to the foregoing Motion. (X) Internet Person Locator Records (X) Credit Report Agency. (X) Telephone Directory (X) Records of the County Recorder of Deeds and Prothonotary Finally, Affidavit deposes and says that if Defendant(s) is/are not located at the addr uncovered by this investigation, the whereabouts of Defendant(s) is/are unknown to Plaintiff. ess ZUCKER GOLDBERG ACKERMAN, LLC Dated: December 2012 Y: Scott A. ietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Atty File No.: XFP-153104 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX Sworn to and cribed before me this ay of 2012. -G Notary Public My Commission Expires: J ?s CoMMONWEALTII OF PFNNSYI VANIA r NOTARIAL SLAI. DENISE L FOS ITIR- NO'I ARY PUBLIC CITY OP IIARRISMAW, DAUPI IIN COUNTY MY COf?IMISSION EXPIRIS MARCI10S, 2013 Comprehensive Report Page 1 of 15 Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this system supplies, it should be independently verified, For Secretary of State documents, the following data is for information purposes only and is not an official record. Certified copies may be obtained from that individual state's Department or State. The criminal record data in this product or service may include records that have been expunged, sealed, or otherwise have become inaccessible to the public since the date on which the data was last updated or, collected. Accurint does not constitute a "consumer report" as that term is defined in the federal Fair Credit Reporting Act, 15 USC 1681 et seq. (FCRA). Accordingly, Accurint may riot be used in whole or in part as a factor in determining eligibility for credit, insurance, employment or another permissible purpose under the FCRA. Your DPPA Permissible Use: Civil, Criminal, Administrative, or Arbitral proceedings Your GLBA Permissible Use: Use by Persons Acting In a Fiduciary Capacity on Behalf of the Consumer Comprehensive Report: Date: 11/22/11 Report processed by: ZUCKER, GOLDBERG 8 ACKERMAN 200 SHEFFIELD STREET MOUNTAINSIDE, NJ 07092 908-233-8500 Main Phone Subject Information (Best Information for Subject) Name: SARA 3 GANDY Date of Birth: 2/25/1943 Age: 68 SSN: 161-34-4168 issued in Pennsylvania between 1/1/1958 and 12/31/1961 View All SSN Sources AKAs (Names Associated with Subject) SARA D KANDY Age: 68 SSN: 161-34-xxxx SARA GANDY SSN: 161-34-xxxx S 3 GANDY Age: 68 SSN: 161-34-xxxx SARA 3 ANDY Age: 68 SSN: 161-34-xxxx SARA D KANDY Age: 70 SSN: 161-34-xxxx Report Legend: ` Shared Address - Deceased - Probable Current Address Indicators Bankruptcy: No Property: Yes Corporate Affiliations: No Others Associated With Subjects SSN: (DOES NOT usually indicate any type of fraud or deception) ROMAR MECHANICAL SERVICE: Age: 161-34-xxxx issued in Pennsylvania between 1/1/1958 and 12/31/1961 Address Summary: View All Address Variation Sources V55 CAVALRY RD, CARLISLE PA 17013-1602, CUMBERLAND COUNTY (Jun 1995 - Nov 2011) 5616 RIDGEROCK RD, FORT WORTH TX 76132-2545, TARRANT COUNTY (Aug 2011 - Sep 2011) 1000 CLAREMONT RD, CARLISLE PA 17013-7310, CUMBERLAND COUNTY (Jul 2011) 55 CLARA RD, CARLISLE PA 17013-9599, CUMBERLAND COUNTY (Jul 1995 - Jan 2002) 313 N PITT ST, CARLISLE PA 17013-1981, CUMBERLAND COUNTY (Apr 1985 - Mar 1999) 55 CLOVER LN, CARLISLE PA 170131 CUMBERLAND COUNTY (Jul 1995) 142 W PENN ST, CARLISLE PA 17013-2326, CUMBERLAND COUNTY (Feb 1989 - Jan 1995) 142 E PENN ST, CARLISLE PA 17013-2434, CUMBERLAND COUNTY (Mar 1989 - Sep 1994) CARLISLE PA, SPARKILL NY 10976, ROCKLAND COUNTY (Dec 1985 - Dec 1991) 17013 NY, CARLISLE PA 17013, CUMBERLAND COUNTY (Jun 1969 - Jul 1991) 146 W PENN ST, CARLISLE PA 17013-2326, CUMBERLAND COUNTY (Jun 1969 - https: //Secure-accui-int. COM/app/bpsi'reporl 11/22/2011 Comprehensive Report Apr 1989) 161 LINCOLN ST, CARLISLE Apr 1986) 307 N PITT ST # A, CARLISLE Bankruptcies: PA 17013-1940, CUMBERLAND COUNTY (Jun 1969 - PA 17013-1944, CUMBERLAND COUNTY (Apr 1984) [None Found) Liens and Judgments: Filing Number: 063263 Filing Type: CIVIL JUDGMENT Location: CUMBERLAND CNTY PROTHONOTARY State: PA Original Filing Date: 8/1/2006 Amount: $3,544 Debtor Name: SARA J GANDY Debtor SSN: 161-34-xxxx Debtor Address: 55 CAVALRY RD, CARLISLE PA 17013-1602 Creditor: CAPITAL ONE BANK Phones Plus(s): Name: SARA GANDY Address: 55 CAVALRY RD, CARLISLE PA 17013-1602 Phone Number: 717-422-2731 - EST Phone Type: Mobile Carrier: NEW CINGULAR WRL DC - (CARLISLE, PA) People at Work: Maximum 50 People at Work records returned [None Found] Active Address(es): View All Address Variation Sources *?'S5 CAVALRY RD, CARLISLE PA 17013-1602, CUMBERLAND COUNTY (Jun 1995 - Nov 2011) Name Associated with Address: S J GANDY Current Residents at Address: SARA J GANDY 717-258-1410 GANDY S J Property Ownership Information for this Address Property: Parcel Number 19-1639-0122-0000000-29 Book - 122 Page- 700 Name Owner : GANDY HARRY C Property Address: - 55 CAVALRY RD, CARLISLE PA 17013- 1602, CUMBERLAND COUNTY Owner Address: 55 CAVALRY RD, CARLISLE PA 17013- 1602, CUMBERLAND COUNTY Sale Date - 05/26/1995 Sale Price - $83,000 Land Usage - RESIDENTIAL (NEC) Total Market Value - $115,700 Assessed Value - $115,700 Land Value - $24,500 Improvement value - $91,200 Land Size - 7,840 Square Feet Year Built - 1951 Data Source - A Neighborhood Profile (2000 Census) Average Age: 39 https://secure.accurint, coin/app/bps,/report Page 2 of 15 11/22/2011 Comprehensive Report Median Household Income: $46,025 Median Owner Occupied Home Value: $99,700 Average Years of Education: 13 Previous And Non-Verified Address(es): View All Address Variation Sources 5616 RIDGEROCK RD, FORT WORTH TX 76132-2545, TARRANT COUNTY (Aug 2011 - Sep 2011) Name Associated with Address: SARA J GANDY Current Residents at Address: ROBERT HORACE BLOCKER DENISE RANDASS BLOCKER SARA J GANDY 682-224-5206 BLOCKER ROBERT Property Ownership Information for this Address Property: Parcel Number - 31290-18-15A Page - 135 Name Owner : BLOCKER, DENISE Property Address: - 5616 RIDGEROCK RD, FORT WORTH TX 76132- 2545, TARRANT COUNTY 2545, TARRANT COUNwner Address: 5616 RIDGEROCK RD, FORT WORTH TX 76132- Assessed value - $293,900 Land Size - 6490 SF Year Built - 2009 Data Source - B Neighborhood Profile (2000 Census) Average Age: 41 Median Household Income: $36,719 Median Owner Occupied Home Value: $88,400 Average Years of Education: 14 1000 CLAREMONT RD, CARLISLE PA 17013-7310, CUMBERLAND COUNTY (Jul 2011) Name Associated with Address: SARA J GANDY Current Residents at Address: ARTHUR C BELL AMY C BURCHFIELD FAE A ERB ANASTASIA A KESLAR KENNETH R WALTERS JEAN ARLENE MCCOY Current phones listed at this address: 717-243-0816 GINTER LAURA 717-243-2031 CLAREMONT NURSING & REHABILITATION CENTER 717-245-0413 LIFE TIME ADULT DAY CARE Property Ownership Information for this Address Property: Parcel Number - 08-0575-0001-OOOOOEX-21 Book - 1MM Page- 305 Name Owner : CUMBERLAND COUNTY OF Property Address: - 1000 CLAREMONT RD, CARLISLE PA 17013- 7310, CUMBERLAND COUNTY Owner Address: 1 COURT HOUSE SQ, CARLISLE PA 17013- 3323, CUMBERLAND COUNTY Land Usage - TAX; EXEMPT Total Market Value - $40,000,000 Assessed Value - $40,000,000 Land Value - $6,720,990 Improvement Value - $33,279,010 Land Size - 3,702,600 Square Feet nn+- c - A https://secure-accurint.com/app/bps/report Page 3 of 15 11 /22/2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILEO-O FICE Sheriff T t�aiah HE PROTHONOT, rly Body S Smith4 # Chief Deputy � AM � Richard W Stewart CUMBERLAND Solicitor �tCs OF�`"`E s"ORIFF COUNTY ENNS YLYANtA Wells Fargo Bank, N.A. vs. Gass Number Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy 2011-5846 SHERIFF'S RETURN OF SERVICE 03/0812013 03:28 PM-Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy, pursuant to Order of Court by'Posting"the premises located at 55 Cavalry Road, North Middleton Township, Carlisle, PA 17013 with a true and correct copy according to law, JlAtON KINSLER, DEPUTY SHERIFF COST: $40.00 SO ANSWERS, March 13, 2013 RON R ANDERSON, SHERIFF (c)COUMYSuite Shenft,Teleosoft.lnc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., ISSUE NO.: 11-5846 Plaintiff, TYPE OF PLEADING VS. AFFIDAVIT OF SERVICE OF Sara Jane Gandy,Administratrix of the Estate of COMPLAINT PURSUANT TO Harry C. Gandy; Pa.R.C.P.,430 SPECIAL ORDER OF COURT Defendant. CODE: FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire- PA I.D.#202729 Ashleigh Levy Marin, Esquire-PA I.D.#306799 Ralph M. Salvia, Esquire- PA I.D.#202946 Jaime R.Ackerman, Esquire- PA I.D.#311032 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office @zuckergoIdberg.com File No.:XFP- 153104/ns ZK rTi 0D p -z- ,t C �.r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 11-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy; Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT I, Scott A. Dietterick, Esquire, Kimberly A. Bonner, Esquire, Joel Ackerman, Esquire,Ashleigh Levy Marin, Esquire, Ralph M.Salvia, Esquire,Jaime R.Ackerman, Esquire, attorney for Plaintiff,Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Complaint in Mortgage Foreclosure on Defendant, Sara Jane Gandy, Administratrix of the Estate of Harry C.Gandy, as follows: 1. On or about January 2, 2013, an Order of Court was entered granting Plaintiff's Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit "A",attached hereto and made a part hereof. 2. Pursuant to said Order,on or about March 14, 2013, Zucker, Goldberg&Ackerman, LLC, the counsel for Plaintiff served Defendant,Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure,via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the defendant's last known address being 1000 CLAREMONT RD,CARLISLE PA 17013-7310 and 5616 Ridgerock Road Fort Worth,TX 76132. A true and correct copy of said returned receipt and certificate of mailing are marked Exhibit"B", attached hereto and made a part hereof. 3. Pursuant to said Order, on or about March 8, 2013,the Sheriff of Cumberland County posted the property subject to the Mortgage, being 55 Cavalry Road,Carlisle, PA 17013 with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure. A true and correct copy of the Service Form from the Cumberland County Sheriff's Office is marked Exhibit"C", attached hereto and made a part hereof. Zucker A& k n, LLC Dated: July �� , 2013 BY: Scott A. et eric , qui A I.D.#55650 Kimberly onner, Esquire; PA I.D.#89705 Joel A.Ac man, Esquire; PA LD.#202729 Ashleigh Levy Marin, Esquire; Pa I.D.#306799 Ralph M.Salvia; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 200 Sheffield Street,Suite 301 Mountainside, NJ 07092 File No.: XFP-153104 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com Sworn to and subscribed before me this day of July, 2013 Qoiry Public MY COMMISSION EXPIRES: 1 Debeneadto Notary P20lw Chery Ex ires Oct.16, 16 My Commb#27.80276 State 01 New Jersey EXHIBIT A Q . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, NO.: 11-5846 VS. Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy; Defendant. ORDER OF COURT AND NOW,this day of ,20g,upon consideration of Plaintiff's Motion for Special Service;it is hereby O DERED,ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, If necessary,on Defendant(s) Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 55 Cavalry Road,Carlisle PA 17013,and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 1000 CLAREMONT RD, CARLISLE PA 17013-7310 and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 5616 Ridgerock Road Fort Worth,TX 76132,with said service being valid and complete upon such posting and mailing In accordance with Pa.R.C.P.430. BY THE�COURT: cti J. '. '• . _4ca 54 Zucker,Goldberg&Ackerman,LLC XFP-153104 EXHIBIT B i er c f f! 02 Im BO�ec 7!TL:• :i►1 00042 '' [ ZOo A1L + Ro& ... RR 14 201 { This Certificate of Mailing Provides evidence that mail has been presented to USPS'tor mailing.This form may be��.._. _. MzrpC 3 I and international ill. Od-070,92 From: Scott A. Dietterick,Esquire .....-_. ... c/o Zucker,Goldberg&Ackerman, LLC ` 200 Sheffield Street,Suite 101 f Mountainside, NJ 07092 XFP-153104/cperTEAM B To Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy Postmark.Here �o - Sds/) 55 Cavalry Road oEi? Carlisle, PA 17013 County of P.Q.:CUMBERLAND !, y PS Form 3817,April 2007 PSN 7530-02-000-9065 i I i i i i LOS PA% O � airnev atowEs 02 IM ill ;l; zT _., 0004282038 MAR i 4 2013 y POMS, END MAILED FROA4 ZIPCODE 0 7092 This Certificate of Mailing provides evidence that mall has been presented to USPSe for mailing.This fom:maybe used ford°mestic and international mail. kom: Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/cper TEAM B T Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy Postmark ��- SdS� 0 1000 Claremont Rd o � Carlisle, PA 17013-7310 �� County of P.Q.:CUMBERLAND �. y N 0-1sk PS Form 3817,April 2007 PSN 7530-02-000-9065 i i t i i os E g.Sp F ; t ITF l 7` 02 1M, 01.20° ".:......_.'..' ,;..�:. _..... `- 0004282036 MAR 14 2013 S v MAIIED FROISA ZIP CODE 0 70 92 This Certificate of Maging provides evidence that mall has been presented to USPS•for mailing.This form, ......... ...... ......... and Inamatlanal maP. tram: Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 Sds XFP-153104/cper TEAM B �,� r To: Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy Postmark He I 5616 Ridgerock Rdd�� �.-ZE Fort Worth,TX 76131 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 I I 7 i i i I EXHIBIT C SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ] G c Sheriff oxxxxti+'c4'elfluber'rjl ` J Jody S Smith t' Chief Deputy 'T Richard W Stewart Solicitor OrPiCE OF THE PHERIFF Wells Fargo Bank, N.A. Case Number vs. 2011-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy SHERIFF'S RETURN OF SERVICE 03/0.8/2013 03:28 PM- Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy,pursuant to Order of Court by"Posting"the premises located at 55 Cavalry Road, North Middleton Township, Carlisle, PA 17013 with a true and correct copy according to law. J SON KINSLER, DEPUTY SHERIFF COST: $40,00 SO ANSWERS, March 13, 2013 RidNW R ANDERSON,SHERIFF to countysu is Shativ,Toleo$00.Mc. i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C"11 S Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff No.: 11-5846 VS. ISSUE NUMBER: Sara Jane Gandy,Administratrix of the Estate of Harry TYPE OF PLEADING: C. Gandy; PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT Defendant(s). (MORTGAGE FORECLOSURE) Mortgaged Premises: FILED ON BEHALF OF: 55 Cavalry Road, Carlisle, PA 17013 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-153104 a l � C�IL�sio� Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC XFP-153104 A/e/� /�/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 11-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy; Defendant. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $55,097.50 plus interest on the judgment amount($55,097.50)from June 18, 2011, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 1000 Claremont Road 5616 Ridgerock Road address is: Carlisle, PA 17013-7310 Fort Worth,TX 76132 ZUCKER, GOLBE , Dated: BY: �U Joel A.A erman, 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-153104 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 `7 a toll Prothonotary "' °" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N�� CIVIL DIVISION Plaintiff, ' '— � NO.: 11-5846 Sara Jane Gandy,AdrninistratMxof the Estate � uf Harry C.Gandy; � Defendant ' AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TOTAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION |, 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 beat of my knowledge, information and belief as evidenced by the attached copies; 3\ The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.i and that the time limits provided for that notice have expired. Dated: ' BY: Joel A.AckeEsquire; Ashleigh L. Marin, Esquire; PA I.D.#306799 '2__Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-1B104 3OU Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (9O8)233-1]9OFAX Email: Office@zuckergo|dbaq§zom Sworn to and subscribed before me This,,,2 'S day of j ,20 »~�' Notary Public 0 My Commission Expires: Cheryl Dabonea�nNobq/PVbUU /ny�onnm . E^ 7b 2016 /D���22V -- ' G��ofNew--~ JmmeY Zucker,Goldberg&Ackerman, LLC XFP'1531U4 ` Department of Defense Manpower Data Center Results as of:JuF96-2013 01:44:48 SCRA 3.0 Pursuant to SeMcemembers Civil Relief Act Last Name: GANDY First Name: SARA Middle Name: JANE Active Duty Status As Of: Jul-18-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the Ind viduaW active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status SerAw Component NA 'NA _`�:,r3 �;;}-t t i °No' t NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HislHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA .,No y NA This response reflects whether the Individual or hWher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Otr Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The`Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.htmf. 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. I More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 73V6R3DDKOF1500 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 11-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy; Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy 1000 Claremont Road Carlisle, PA 17013-7310 AND 5616 Ridgerock Road Fort Worth,TX 76132 [ J Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order Decr a or Judgment was entered in the above captioned proceeding on (p [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $55,097.50 lus ell Pr&W&notary Zucker,Goldberg&Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A. = CIVIL DIVISION Plaintiff, VS. NO.: 11-5846 Defendant. IMPORTANT NOTICE TO: Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy 1000 Claremont Road Carlisle, PA 17013-7310 DATE OF NOTICE: 6/10/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice,ajudgment may be entered against you without a hearing and you may lose your property or other important rights.You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S.Bedford Street 32 S.Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 11-5846 Defendant. AVISO IMPORTANTE TO: Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy 1000 Claremont Road Carlisle, PA 17013-7310 FECHA DEL AVISO:6/10/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A NfENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO nRYIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &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 ZUCKER,GOLDBERG &ACKERMAN BY: Scctt A. Q ietterick Scott A. Dietteri ck,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 11-5846 Defendant. IMPORTANT NOTICE TO: Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy 5616 Ridgerock Road Fort Worth,TX 76132 DATE OF NOTICE: 6/10/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 11-5846 Defendant. AVISO IMPORTANTE TO: Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy 4616 Ridgerock Road Fort Worth,TX 76132 FECHA DEL AVISO:6/10/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS MIPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICIrTA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. 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 ZUCKER,GOLDBERG &ACKERMAN BY: Saatt A. D ietteridc Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07042-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A., ISSUE NO.: 11-5846 Plaintiff, TYPE OF PLEADING VS. AFFIDAVIT OF SERVICE OF Sara Jane Gandy,Administratrix of the Estate of COMPLAINT PURSUANT TO Harry C.Gandy; Pa.R.C.P.,430 SPECIAL ORDER OF COURT Defendant. CODE: FILED ON BEHALF OF: Wells Fargo Bank N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG&ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire-PA I.D.#202729 Ashleigh Levy Marin, Esquire-PA I.D.#306799 Ralph M.Salvia, Esquire-PA I.D.#202946 Jaime R.Ackerman, Esquire- PA I.D.#311032 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908)233-1390 FAX office @zuckergoldberg.com File No.:XFP-153104/ns IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.:11-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy; Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT 1,Scott A.Dietterick, Esquire, Kimberly A. Bonner,Esquire, Joel Ackerman, Esquire,Ashleigh Levy Marin, Esquire,Ralph M.Salvia,Esquire,Jaime R.Ackerman,Esquire,attorney for Plaintiff,Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Complaint in Mortgage Foreclosure on Defendant,Sara lane Gandy, Administratrix of the Estate of Harry C.Gandy, as follows: 1. On or about January 2,2013,an Order of Court was entered granting Plaintiff's Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit"A",attached hereto and made a part hereof. 2. Pursuant to said Order,on or about March 14,2013,Zucker,Goldberg&Ackerman,LLC, the counsel for Plaintiff served Defendant,Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure,via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the defendant's last known address being 1000 CLAREMONT RD,CARLISLE PA 17013-7310 and 5616 Ridgerock Road Fort Worth,TX 76132. A true and correct copy of said returned receipt and certificate of mailing are marked Exhibit"B",attached hereto and made a part hereof. :3; Pursuant to said Order,on or about:March 8;2013,the Sheriff of Cumberland County posted the.property subjectto the Mortgage,being 55.Cavalry Road;Carlisle, PA 17013 with a true and correct copy of Plaintiffs Complaint in.Mortgage Foreclosure. A true and correct copy of the Service Form from the Cumberland County Sheriff's.Office is marked Exhibit"C,attached hereto and made:a part hereof; Zucker Go b0& , n,LLC Dated: July ,2013 By: Scott A. et eric , qWeJA I.D.#55650 Kimberly onner, Esquire; PA LD.#89705 Joel A.Ack@ man, Esquire; PA I.D.#202729 Ashleigh Levy Marin,Esquire; Pa I.D.#306799 Ralph M.Salvia; PA.I.D.4202946 Jaime K.Ackerman, Esquire; PA I.D.#311032 200 Sheffield Street,Suite.301 Mountainside, N1 07092 File No.:XFP-153104 (908)233-8500;;(908) 233-1390 FAX &mail:. Office@zuckergoldberg.com Sworn to and.subscribed before me this ( day of July, 2013 Qoiry 4blic My COMMISSION EXPIRES: Cheryl DebPneadto'.Notary Public My.COMM.E�09()Cl'1 s'2016; io State 0i New Jersey. EXHIBIT A f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, VS. NO.:11-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy, Defendant. ORDER OF COURT AND NOW,this day of ,20g,upon consideration of Plainti€Ys Motion for Special Service;it is hereby O DERED,ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, If necessary;on Defendant(s)Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, by Instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises,being 55 Cavalry Road,Carlisle PA 17013,and by mailing a copy, via Certified Mail, no signature required and First-Class U.S. Mail, Postage Prepaid to 1000 CLAREMONT .RD, CARLISLE PA 17013-7310 and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail,Postage Prepaid to 5616 Ridgerock Road Fort Worth,TX 76132,with said service king valid and complete upon such posting and mailing in accordance with Pa R C P 430. BYTHE�COURT: J. COT- 't �� • -ter. z-n , cl 3* : : fr1 Zucker,Goldberg&Ackerman,LLC xFP-253104 EXHIBIT B Cei 1 R� MSTALSMWI� 02 IA# a eon M�°4za20ss ... 1.200 ' ...... v Tbk C*nP�rata of Wing proNda avidonaothat mall has boon pnsamad to 115PSOtormalU�.Thtt farm may 6i v...._ ��FR��2j�R 2013 q � � j . and tntarnaiWnatmatl. .. _ CODE 0 7092 `'0m' Scott A.Dietterick,Esquire Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 XFP-153104/cperTEAM B Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy poOmaOKWO �o - Sds� 55 Cavalry Road' \w Carlisle,PA 17013 County of P.R..CUMBERLAND 4� 4) r y PS Form 3817,April 2007 PSN 7530.02-000-9065 {s 1 I i I r e if t�- 02 IM r I7N nowra 00042820;3a $ 01,200 MAItED FROl4 Z pC4o 14 2013 CODE 07092 Ws ternmteolMan. providsavldonc•thatm►Ahdcb°mpradntddtoUSPS•for malin e�Thkf°m,may bdu�ddfordomdttk • dntl International m.n. ...... ..... ....... .. Scott A. Dietterick,Esquire c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/cperTEAM 8 To: Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy Postmark Here �� SdS� 1000 Claremont Rd Carlisle,PA 17013-7310 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i i i 1 �6OS R [ gi � .� 'tea"twcv eovrrrss t, lUlT 02 1M $ 01.200 0004282036 MAFl14 2013 .: 00042?FR36 7092 • � CODE 0 Wds Certificate of Ma6lnp provld■i avldonto Uat mall has boon presented to LISPS•for mallne•Yhlsfo ,,,-,,,,-_,,,-„- ,,,,, _,,,, ,,,-, ..._.. •....• •,• ...•. l and Intornatbnal ma p, rr°m' Scott A. Dietterick,Esquire c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 ~Mountainside, NJ 07092 XFP-153104/Cper TEAM B o�0 r SdSg T Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy Postmark He ar`° 5616 Ridgerock Rd Fort Worth,TX 76131 I County of P.Q.:CUMBERLAND PS Form 3617,April 2007 PSN 7530-02-000-9065 I I 1 • ji i i I EXHIBIT C SHERIFF`S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson / O^ Sheriff Jody S Smitho���µi+ot�lrni��r�rjfa' Chief Deputy. Richard W Stewart =� �.r�: Solicitor OFFfCG Or nfe SHERWr Wells Fargo Bank,N.A. vs. Case Number Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy 2011-5846 SHERIFF'S RETURN OF SERVICE 03!08/2013 03:28 PM-Deputy Jasort Kinsler, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy,pursuant to Order of Court by"Posting"the premises located at 55 Cavalry Road,North Middleton Township,Carlisle,PA 17013 with a true and correct copy according to law. .r.r� J SON KINSLER, DEPUTY SHERIFF COST:$40.00 SO ANSWERS,/ March 13, 2013 RONNY R ANDERSON,SHERIFF !r}CoumySullo Sheriff,Tofoo$oft.4u. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION • File No. 11-5846 Wells Fargo Bank, N.A., Amount Due $55,097.50 Plaintiff, Interest from 06/18/2011 to date of sale $8,155.05 vs. Costs Sara Jane Gandy,Administratrix of the Estate of • Harry C. Gandy; Defendant. • TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract 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 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 t e attached exhibit. DATE: jJ C�� Signature. I Print Name: Scott . Dietterick, Esquire Kimberly A. Bonner, Esquire 4(98.a) pp rn-r-I Joel A.Ackerman, Esquire 3Q. oo C BF Ashleigh L. Marin, Esquire 3 •1414 u Ralph M. Salvia, Esquire oo I. Jaime R.Ackerman, Esquire -1:313 w Qa 00 " Address: Zucker, Goldberg&Ackern4 C I6o - ej 75 �� 200 Sheffield Street,Suite 1:11 Mountainside, NJ 07092 r"z Ct1r ( 5O Attorney for: Plaintiff A s • _ a7a 19 _ PD A Telephone: 908-233 8500 h Supreme Court ID No.: 55650 . ;' ' 89705 . -? 202729 306799 '0 202946 .5 O LL 311032 alt 51314 Zucker,Goldberg&Ackerman,LLC dg7743 XFP-153104 P.E Gter► IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., : CIVIL DIVISION Plaintiff, : NO.: 11-5846 +' VS. t cs' Execution No.: In o Sara Jane Gandy,Administratrix of the Estate of Harr : zvo -+c tc C. Gandy; cs , �z <t-I i�r Defendant(s). ° xcp. s.c cam, n 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 55 Cavalry Road, Carlisle, PA 17013. 1. Name and Address of Owner(s)or Reputed Owner(s): HARRY C. GANDY 55 Cavalry Road Carlisle, PA 17013 2. Name and Address of Defendant(s) in the Judgment: SARA JANE GANDY,ADMINISTRATRIX OF THE ESTATE OF HARRY C. GANDY 55 Cavalry Road Carlisle, PA 17013 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff Zucker,Goldberg&Ackerman,LLC XFP-153104 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR NEW FREEDOM MORTGAGE CORPORATION,A CORPORATION P.O. Box 2026 Flint, MI 48501-2026 AND 1901 E.Voorhees Street, Suite C Danville, IL 61834 AND 2363 South Foothill Drive Salt Lake City, UT 84109 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 55 Cavalry Road Carlisle, PA 17013 UNKNOWN SPOUSE 55 Cavalry Road Carlisle, PA 17013 Zucker,Goldberg&Ackerman,LLC XFP-153104 UNKNOWN SPOUSE 1000 Claremont Road Carlisle, PA 17013-7310 UNKNOWN SPOUSE 5616 Ridgerock Road Fort Worth,TX 76132 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: 1 ( I3 BY: 1 1 . Scott A.S 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 Attorneys for Plaintiff XFP-153104/11 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • NO.: 11-5846 vs. 4- Sara Jane Gandy,Administratrix of the Estate • 71 of Harry C. Gandy; ttt Z • • Defendant. - • rn NOTICE OF SHERIFF'S SALE °' OF REAL PROPERTY PURSUANT TO (7, PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy 55 Cavalry Road Carlisle, PA 17013 AND 1000 Claremont Road Carlisle, PA 17013-7310 AND 5616 Ridgerock Road Fort Worth,TX 76132 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 .9311350044 at 10:00am prevailing local time. 3//c9/41)/11 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: 55 Cavalry Road,Carlisle, PA, 17013 ( !dhcr & \LI'roan.J \I j) % ).4 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-5846 THE NAME(S)OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Harry C. Gandy 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-153104 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 • Dat ed: 1 akl l BY: a 1 t_ L1 Al 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 Attorneys for Plaintiff XFP-153104/11 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND POSTING, BY ORDER OF COURT Zucker,Goldberg&Ackerman,LLC XFP-153104 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, vs. NO.: 11-5846 Sara Jane Gandy,Administratrix of the Estate of . Harry C.Gandy; .• Defendant. • ORDER OF COURT AND NOW,this o7 day of -,.,uex. ,20p,upon consideration of Plaintiffs Motion for Special Service, it is hereby O�RED ADJUDGED AND DECREED that Plaintiff shall serve its P Y a Complaint in Mortgage Foreclosure and Notice of Sale, if necessary,on Defendant(s) Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises,being 55 Cavalry Road,Carlisle PA 17013,and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 1000 CLAREMONT RD, CARLISLE PA 17013-7310 and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 5616 Ridgerock Road Fort Worth,TX 76132, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P.430. BY THE COURT: isr` Kjl f-Gvt. a.. t2,�i J. in fe c 211, x : .= "Wri b . C3 x Z4? . D ) 7 I:" Zucker,Goldberg&Ackerman,LLC XFP-153104 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND SITUATE IN NORTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE INTERSECTION OF THE EASTERN LINE OF CAVALRY ROAD AND THE SOUTHERN LINE OF HARRIET STREET; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF HARRIET STREET 72 FEET MORE OR LESS; THENCE ALONG OTHER PROPERTY NOW OR FORMERLY OF VINCENT M. ZELADONIS AND PEGGY A. ZELADONIS,SOUTHWARDLY 100.40 FEET MORE OR LESS; THENCE WESTWARDLY ALONG THE LINE OF LOT NO. 11 OF THE HEREINAFTER MENTIONED PLAN OF LOTS 92 FEET MORE OR LESS; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF CAVALRY ROAD 102.6 FEET MORE OR LESS TO THE PLACE OF BEGINNING. BEING THE WESTERN PORTION OF LOTS NO. 12 AND 13 OF THE PLAN OF LOTS KNOWN AS HARRIET ACRES,AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 2, PAGE 100. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 55 CAVALRY ROAD, CARLISLE, PA, 17013. BEING THE SAME PREMISES WHICH ROBERT E.CLOUSE, INDIVIDUAL, BY DEED DATED MAY 25, 1995 AND RECORDED MAY 26, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 122, PAGE 700,GRANTED AND CONVEYED UNTO HARRY C.GANDY. TAX MAP NO.: 29-19-1639-122. Zucker,Goldberg&Ackennan,LLC XFP-153104 Y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 11-5846 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 SARA JANE GANDY,Administratrix of the Estate of HARRY C. GANDY (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: $55,097.50 L.L.: .50 Interest from 6/18/11 to Date of Sale -- $8,155.05 Any's Comm: Due Prothy: $2.25 Atty Paid: $272.19 Other Costs: Plaintiff Paid: Date: 11/5/13 -112/1,4.a David D. Buell, Prothonotary (Seal) a • Deputy REQUESTING PARTY: Name: ASHLEIGH L. MARIN, 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. 3CX,749 ' r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION ;.., • Plaintiff, NO.: 11-5846 vs. Execution No.: "(`,1-3 Sara Jane Gandy,Administratrix of the Estate of Harr : -v -,- ; C. Gandy; cp • •F • 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 55 Cavalry Road, Carlisle, PA 17013. 1. Name and Address of Owner(s) or Reputed Owner(s): HARRY C. GANDY 55 Cavalry Road Carlisle, PA 17013 2. Name and Address of Defendant(s) in the Judgment: SARA JANE GANDY,ADMINISTRATRIX OF THE ESTATE OF HARRY C.GANDY 55 Cavalry Road Carlisle, PA 17013 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR NEW FREEDOM MORTGAGE CORPORATION,A CORPORATION P.O. Box 2026 Flint, MI 48501-2026 4 AND 1901 E.Voorhees Street, Suite C Danville, IL 61834 AND 2363 South Foothill Drive Salt Lake City, UT 84109 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 MIDDLETON AUTHORITY 2051 Spring Road, 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 55 Cavalry Road Carlisle, PA 17013 UNKNOWN SPOUSE 55 Cavalry Road Carlisle, PA 17013 UNKNOWN SPOUSE 1000 Claremont Road Carlisle, PA 17013-7310 UNKNOWN SPOUSE 5616 Ridgerock Road Fort Worth,TX 76132 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Amended Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER, GOLDBERG &ACKERMAN, LLC Dated: 121-1 b 1 4 BY: Q(iii ■n; 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 Attorneys for Plaintiff XFP-153104/11 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE INTERSECTION OF THE EASTERN LINE OF CAVALRY ROAD AND THE SOUTHERN LINE OF HARRIET STREET; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF HARRIET STREET 72 FEET MORE OR LESS; THENCE ALONG OTHER PROPERTY NOW OR FORMERLY OF VINCENT M. ZELADONIS AND PEGGY A. ZELADONIS, SOUTHWARDLY 100.40 FEET MORE OR LESS; THENCE WESTWARDLY ALONG THE LINE OF LOT NO. 11 OF THE HEREINAFTER MENTIONED PLAN OF LOTS 92 FEET MORE OR LESS; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF CAVALRY ROAD 102.6 FEET MORE OR LESS TO THE PLACE OF BEGINNING. BEING THE WESTERN PORTION OF LOTS NO. 12 AND 13 OF THE PLAN OF LOTS KNOWN AS HARRIET ACRES,AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 2, PAGE 100. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 55 CAVALRY ROAD, CARLISLE, PA, 17013. BEING THE SAME PREMISES WHICH ROBERT E. CLOUSE, INDIVIDUAL, BY DEED DATED MAY 25, 1995 AND RECORDED MAY 26, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 122, PAGE 700, GRANTED AND CONVEYED UNTO HARRY C. GANDY. TAX MAP NO.: 29-19-1639-122. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 11-5846 vs. Sara Jane Gandy,Administratrix of the Estate of TYPE OF PLEADING --a Harry C. Gandy; Pa. R.C.P. RULE 3129.2(C)AFFIDAVIT O-`r> Defendants. 37 SERVICE 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 Levy Marin, Esquire- PA I.D. #306799 Ralph M. Salvia, Esquire-PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D.#311032 Jana Fridfinnsdottir, Esquire- PA I.D.#315944 Brian Nicholas, Esquire- PA I.D.#317240 Denise Carlon, Esquire- PA I.D.#317226 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908)233-1390 FAX office @zuckergoldberg.com File No.:XFP- 153104/mag Zucker, Goldberg&Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, •vs. NO.: 11-5846 Sara Jane Gandy,Administratrix of the Estate • • of Harry C. Gandy; • Defendants. • Pa.R.C.P. RULE 3129(c)AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg&Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Harry C. Gandy, is the record owner of the real property. 2. Pursuant to the Order of Court dated January 2, 2013, the Sheriff of Cumberland County posted Plaintiffs Notice of Sheriffs Sale, at the address of the mortgaged premises, being 55 Cavalry Road, Carlisle PA 17013 on or about January 6, 2014.A true and correct copy of said Order of Court and Proof of Posting are marked Exhibit"A", attached hereto and made a part hereof. 3. Pursuant to the Order of Court dated January 2, 2013, Plaintiffs counsel served Defendant, Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy with Plaintiffs Notice of Sheriffs Sale via Certified Mail no signature required and via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing at the address of 1000 Claremont Rd, Carlisle PA 17013-7310 and 5616 Ridgerock Road, Fort Worth, TX 76132, on or about November 22, 2014. True and correct copies of said Notices and Proofs of Mailing are marked Exhibit"B", attached hereto and made a part hereof. 3. On or about February 7, 2014, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiffs 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"C", attached hereto and made a part hereof. Zucker, Goldberg&Ackerman, LLC XFP-153104 Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER,GOLDBERG&ACKERMAN, LLC Attorneys for Plaintiff Dated: February 2- -2014 MARG)d T AGYEPONG Paralegal/Legal Assista t Sworn to and subscribed before me this iltlay of February, 2014 1 .. - Notary Public MY COMMISSION EXPIRES: PAUL C.NADRATOWSKI Notary Public of New Jersey ID#2407850 My Commission Expires 4/27/2016 Zucker, Goldberg&Ackerman, LLC XFP-153104 EXHIBIT A Zucker, Goldberg&Ackerman, LLC XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. • CIVIL DIVISION Plaintiff, • • NO.: 11-5846 vs. Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy; Defe nda nt. ORDER OF COURT AND NOW,this Q7 day of 209,upon consideration of Plaintiff s Motion for Special Service,it is hereby 0 DERED,ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s)Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 55 Cavalry Road,Carlisle PA 17013,and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 1000 CLAREMONT RD, CARLISLE PA 17013-7310 and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 5616 Ridgerock Road Fort Worth,TX 76132, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P.430. BY THE COURT: 151 1�- ! Q • ` a J. za!: 1'CD essr- r{—= P4 --rc -0 ="71 > Zucker,Goldberg&Ackerman,LLC XFP-153104 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff or 4 ,,;, �� Jody S Smith t.0 Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, N.A. Case Number vs. 2011-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy SHERIFF'S RETURN OF SERVICE 01/06/2014 07:52 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 55 Cavalry Road, North Middleton-Township,Carisle, PA 17013, Cumberland County. 01/06/2014 07:52 PM-Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant,to wit: Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy, pursuant to Order of Court by"Posting"the premises located at 55 Cavalry Road, North Middleton Township, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. SHERIFF COST: $953.75 SO ANSWERS, January 29,2014 BONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleoeoft,Inc EXHIBIT B Zucker, Goldberg&Ackerman, LLC XFP-153104 (§( Ea9 #-$o z /e ( Qs N ) § 33 ƒ ƒ: �2 , r �$ g /7- / \ xaE_\� '<¥ = al $ k \� o, G s.- © K�7 W $ /f - §/ y § %� � so � CD 0 $7 § •: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. • CIVIL DIVISION Plaintiff, NO.: 11-5846 vs. Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy; Defendant. • NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIYII,PROCEDURE 3129 Sara Jane Gandy,Adminlstratrix of the Estate of Harry C.Gandy 55 Cavalry Road Carlisle,PA 17013 AND 1000 Claremont Road Carlisle,PA 17013-7310 AND 5616 Ridgerock Road Fort Worth,TX 76132 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 03/12/2014 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). The LOCATION of your property to be sold is: 55 Cavalry Road,Carlisle,PA,17013 Zucker,Goldberg cY.Ackerman.Ur XFP-15 3104 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No.11-5846 THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: Harry C.Gandy 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 PAPEji 1$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 TA E 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-453104 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: 1(?. 15 BY t Al Dated: _ Scott A.D etterkk, Esquire; PA I.e,#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 10.#202946 Jaime R.Ackerman,Esquire; PALO.#311032 Attorneys for Plaintiff XFP-153104/11 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 (908)233-8500;(908)233-1390 FAX f Email: Office@zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND POSTING,BY ORDER OF COURT e`{ Zucker,Goldberg St Ackerman,LLC XPP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, ' vs. NO 11-5846 Sara Jane Gandy,Administratrix of the Estate of . • Harry C.Gandy; , Defendant. • • fiDE(cOF GOvft1 AND NOW,this a7 day of ,ZOO,upon consideration of Plaintiffs Motion for Special Service/It is hereby O�tDEFIEO,ADJUDGE AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary/;on Defendant(s)Sara Jane Gandy, Administratrix of the Estate of Harry C.Gandy,by instructing the Sheriff of Cumberland County to, a copy of saute on the Mortgaged Premises,being SS Cavalry Road,Carlisle PA 17013,and by mailing a copy, via Certified Mail, no signature required and First,Class U.S. Mail, Postage Prepaid to 1000 - i CLAREMONT RD, CARLISLE PA 17013-7310 and by mailing a copy via Certified Mail, no signature l required and First Class U.S.Mall,Postage Prepaid to 5616 Ridgerock Road Fort Worth,TX 75132,with said service befr ,va 4i¢,and:aomplete:uotnsuchoostine.and mailinit in:accor_pce.with Pa:114,t,430. BY THE�Cr OURT: . J. rj., ,.. . i . ..1...,,. „.4. . 1%. .: 44, •. i. g.r1 : . „. . 4 Zucker,Goldberg&Ackerman,LLC XFP4S3104 E Exhibit"N' LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND SITUATE IN NORTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA,BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE INTERSECTION OF THE EASTERN LINE OF CAVALRY ROAD AND THE SOUTHERN LINE OF HARRIET STREET; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF HARRIET STREET 72 FEET MORE OR LESS; THENCE ALONG OTHER PROPERTY NOW OR FORMERLY OF VINCENT M.ZELADONIS AND PEGGY A. ZELADONIS,SOUTHWARDLY 100.40 FEET MORE OR LESS; THENCE WESTWARDLY ALONG THE LINE OF LOT NO.11 OF THE HEREINAFTER MENTIONED PLAN OF LOTS 92 FEET MORE OR LESS; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF CAVALRY ROAD 102.6 FEET MORE OR LESS TO THE PLACE OF BEGINNING. BEING THE WESTERN PORTION OF LOTS NO.12 AND 13 OF THE PLAN OF LOTS KNOWN AS HARRIET ACRES,AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 2,PAGE 100. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 55 CAVALRY ROAD,CARLISLE,PA,17013. BEING THE SAME PREMISES WHICH ROBERT E.CLOUSE,INDIVIDUAL,BY DEED DATED MAY 25,1995 AND RECORDED MAY 26,1995 IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA,IN DEED BOOK VOLUME 122,PAGE 700,GRANTED AND CONVEYED UNTO HARRY C.GANDY. TAX MAP NO.:29-19-1639-122. Zuaka%Goldberg&Ackerman,LLC XFP•153101 ti •. tei n., 4, 1-.....‘ a i v ,,, r‘i -)..4;.7.,.Z.,, r )1= >. 0 . NIN--' 'LI CC L.7 f--1 .?: 7.1.)51-\''•,. .,1:31 ....\% ..-- ..j M UJ ci NJ ., , •<„,, rn cacs 4..., 2 - E • % w 0 J° .2...- 0 C -CI 0; .6 41.) CI ...., z s • T■ - -\ t e'D` .0 a- -' rZ '' '1- it; C■ , . -.. 1... o 6 0 0 IT' r4 Li, < ••. • -c; . 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UNINIVIN rola easerr al■ • 01) ••■•• • I " impuip vavemolproarAWMPIPMemew*******0 W. Oa • ■INOM •••••••0. cn •••... NINO* • OW. cp cr) • •..,. 410 mom* or NO (40 i..1,J .0116, PINY • *".• "*. .„..• %mei CD .„. arrow (.9 cr), CO • ‘ ....0110 11111111111111 CI) 0 (i 111•111•1111 %Sr Fj) CI) E 0 cL) •-• N an Imm • (I) ! • • r N 0 a CO 0, ff.R PI E. 0 Re g ..... C.0 ! P 0 - j3.........■ ,..0 r . = E: C3' m G) CD A' CD 0= cr NIMINIMININNOMIMIN to ...... > M,,C4'1" = r.- al 41■101111111111111•■•=10 ...1 0 3- : ru -a ... o —1 >..: -J C3 2:4 a 3 :- -...1 VI ..., W > M.•..- l;') ru Lrt 0 - o CD r+....:. CD .... 0 ..: CD 0 :..i...e.'4, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, vs. NO.: 11-5846 Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy; • • Defendant. • • NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF aim,PROC.EDVRE 3429 Sara Jane Gandy,Administratrix of the Estate of Harry C.Gandy 55 Cavalry Road Carlisle,PA 17013 • AND 1000 Claremont Road Carlisle,PA 17013-7310 AND 5616 Ridgerock Road Fort Worth,TX 76132 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 03/12/2014 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). The LOCATION of your property to be sold is: 55 Cavalry Road,Carlisle,PA,17013 ZuCkcr,Goldhcrg&Ackerman, VP-153/04 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No.11-5846 THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: • Harry C.Gandy 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 TAI( HIS 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 MAX 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. &ekes,Ooktberg&Ackerman,LIZ XFP-153104 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 1701.3-3387,before presentation of the petition to the Court. ZUCKER,GOLDBERG&ACKERMAN,LLC Dated: tattk i BY: • I.:IA i A Scott A.D etterkk, Esquire.; PA I,m,#55650 Kimberly A.Bonner,Esquire; PA I.D.#89705 Joel A.Ackerman,Esquire; PA I.D.#202729 Ashleigh L.Marin,Esquire; PA I.Q.#306799 Ralph M.Salvia,Esquire;PA I.D.#202946 Jaime R.Ackerman,Esquire;PA I.D.#311032 Attorneys for Plaintiff XFP-153104/il 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 (908)233-8500;(908)233-1390 FAX • Email: Office@zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND POSTING,BY ORDER OF COURT . .' Zucker,Goldberg&Adarm%Lt.0 XFP-153144 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA . Wells Fargo Bank,N.A CIVIL.DIVISION Plaintiff, NO,:11-5E46 vs. Sara Jane Gandy,Admintstratrix of the Estate of Harry C.Gandy; •• Defendant. . • ORDE 5,,QF.coUffT AND NOW,this c7 day of err ,,20V,upon consideration of Plaintiffs Motion for Special Service,it Is hereby ,:DERED,A�WtIDGED AND DECREED that Plaintiff shall serve Its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary;on Defendant(s)Sara Jane Gandy, F Administretrlx of the Estate of Harry C.Gandy,by instructing the Sheriff of Cumberland County to MI a copy of saute on the Mortgaged Premises,being SS Cavalry Road,Carlisle PA 17013,and by mailing a copy, via Certified Mall, no signature required and First Class U.S. Mail, Postage Prepaid to 1000 i CLAREMONT RD, CARLISLE PA 17013-7310 and by mailing a copy via Certified Mail, no signature l required and First Class U.S.Mail,Postage Prepaid to 5616 RIdgerock Road Fort Worth,TX 76132,wit said servtee betrna vaird.peril-COMbieteunan..such::vostini :ilnd=mailing;in:accordance with PCP.430. BY THE COURT: . /# i teiM;,ti,. a. J i f ..."L,. , .., tv* , A Zucker,Goldberg&Ackerman,LI,C XFP-153104 visj .. . . . . . . . . . Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND SITUATE IN NORTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA,BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE INTERSECTION OF THE EASTERN LINE OF CAVALRY ROAD AND THE SOUTHERN LINE OF HARRIET STREET; THENCE ESTWARDLY ALONG THE SOUTHERN LINE OF HARRIET STREET 72 FEET MORE OR LESS; THENCE ALONG OTHER PROPERTY NOW OR FORMERLY OF VINCENT M.ZELADONIS AND PEGGY A. • ZELADONIS,SOUTHWARDLY 100.40 FEET MORE OR LESS; THENCE WESTWARDLY ALONG THE LINE OF LOT NO.11 OF THE HEREINAFTER MENTIONED PLAN OF LOTS 92 FEET MORE OR LESS; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF CAVALRY ROAD 102.6 FEET MORE OR LESS TO THE PLACE OF BEGINNING. BEING THE WESTERN PORTION OF LOTS NO.12 AND 13 OF THE PLAN OF LOTS KNOWN AS HARRIET ACRES,AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 2,PAGE 100. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 55 CAVALRY ROAD,CARLISLE,PA,17013, BEING THE SAME PREMISES WHICH ROBERT E.CLOUSE,INDIVIDUAL,BY DEED DATED MAY 25,1995 AND RECORDED MAY 26,1995 IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA,IN DEED BOOK VOLUME 122,PAGE 700,GRANTED AND CONVEYED UNTO HARRY C,GANDY. TAX MAP NO.:29-19-1639422. Zucker,Goldba'g&Ackerman,LLC XFP-153104 $ ColN _ rU cc UJ 15 C6 "k : : in Z 0 t , st c', , . a 3 o,r. �U 4 .... "," • 0 0 ...... Uus, •—• O cn c Q' AS w.i C co 1hII 0 > c'.. > v� ii ,g_ 15 1$12 g is r- IrD fr d ti X © `-. �- E wimmemilme 111 1•••• 8 co ru . ...�... S N 0 S >. r ....w.. smeraris ] . , C >, cr) •...»». IMIIIMMIMINEM IN, . 3 (Rf�S � � ....... F •M...» . »r.w C < •A.66..11.1 4, i . "rtai ` >„...... L() . W t a �...�.� , V. 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' . • NOS CERT DRAFT - _ t �4i 0 t S 001,20 �PUNITED STATES Certificate Of Mailing t,c L N,/o POSTALSERVICE re pay fx.afnx 3lampa MOO pcytaga nom. °j This Certificate of Mailing provides evidence that mail has been preowned to USPS®for mailing.This form may be used for domestic - and international mall From: Ashleigh Levy Marin, Esquire ,? G1c• do Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 usPS_..' XFP-153104/pn TEAM C-PA To: Sara Jane Gandy,Administratrix of the Estate of Harry C. Postmark Hero Gandy 1000 CLAREMONT RD CARLISLE PA 17013-7310 County of P.Q.: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 U.S POSTAGE*PITNEY BOWES ‘,4 —44toramatemq,otamommaga, UNITED STATES POSTAL SERVICES .' =t , , 3 ?l IV F This Certificate of Mailing provides evidence that mail has been presented to USPSO for n and international mail From: Ashleigh Levy Marin, Esquire c/o Zucker, Goldberg&Ackerman, LLC r, 200 Sheffield Street, Suite 101 G 1} a Mountainside, NJ 07092 XFP-153104/pn TEAM C-PA Sara Jane Gandy, Administratrix of the Estate of Harry C. P0 '"mk Gandy 5616 Ridgerock Road Fort Worth, TX 76132 County of P,Q,: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 1 of 1 EXHIBIT C Zucker, Goldberg&Ackerman, LLC ' XFP-153104 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • NO.: 11-5846 •vs. Sara Jane Gandy,Administratrix of the Estate • of Harry C.Gandy; • Defendants. • NOTICE TO UENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P.3129(b) TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 55 Cavalry Road 55 Cavalry Road Carlisle, PA 17013 Carlisle, PA 17013 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 1000 Claremont Road Carlisle, PA 17013-7310 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR NEW UNKNOWN SPOUSE FREEDOM MORTGAGE CORPORATION,A 5616 Ridgerock Road CORPORATION Fort Worth,TX 76132 P.O. Box 2026 Flint, MI 48501-2026 NORTH MIDDLETON AUTHORITY 2051 Spring Road, MORTGAGE ELECTRONIC REGISTRATION Carlisle, PA 17013 SYSTEMS,INC.,AS NOMINEE FOR NEW FREEDOM MORTGAGE CORPORATION,A MORTGAGE ELECTRONIC REGISTRATION CORPORATION SYSTEMS, INC.,AS NOMINEE FOR NEW 1901 E.Voorhees Street, Suite C FREEDOM MORTGAGE CORPORATION, A Danville, IL 61834 CORPORATION 2363 South Foothill Drive Salt Lake City, UT 84109 Zucker,Goldberg&Ackerman,LLC XFP-153104 153104D1004C01312014P1 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 3/12/2014 at 10:00am,the following described real estate which Harry C.Gandy 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: 55 Cavalry Road, Carlisle, PA 17013 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). Zucker,Goldberg&Ackerman,LLC XFP-153104 153104D1004C01312014P2 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank, N.A. Plaintiff vs. Sara Jane Gandy,Administratrix of the Estate of Harry C. Gandy,et al Defendant(s) at EX. NO. 11-5846 in the amount of$55097.50 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. 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 BY din Dated: aJ 5/c 1 Cott A. Dietterick, Esquire; PA LD.#55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 —Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XFP-153104/sde 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-153104 153104D1004C01312014P3 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF GROUND SITUATE IN NORTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE INTERSECTION OF THE EASTERN LINE OF CAVALRY ROAD AND THE SOUTHERN LINE OF HARRIET STREET; THENCE EASTWARDLY ALONG THE SOUTHERN LINE OF HARRIET STREET 72 FEET MORE OR LESS; THENCE ALONG OTHER PROPERTY NOW OR FORMERLY OF VINCENT M.ZELADONIS AND PEGGY A. ZELADONIS,SORTHWARDLY 100.40 FEET MORE OR LESS; THENCE WESTWARDLY ALONG THE LINE OF LOT NO. 11 OF THE HEREINAFTER MENTIONED PLAN OF LOTS 92 FEET MORE OR LESS; THENCE NORTHWARDLY ALONG THE EASTERN LINE OF CAVALRY ROAD 102.6 FEET MORE OR LESS TO THE PLACE OF BEGINNING. BEING THE WESTERN PORTION OF LOTS NO. 12 AND 13 OF THE PLAN OF LOTS KNOWN AS HARRIET ACRES,AS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, IN PLAN BOOK 2, PAGE 100. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 55 CAVALRY ROAD, CARLISLE, PA, 17013. BEING THE SAME PREMISES WHICH ROBERT E.CLOUSE, INDIVIDUAL, BY DEED DATED MAY 25, 1995 AND RECORDED MAY 26, 1995 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 122, PAGE 700,GRANTED AND CONVEYED UNTO HARRY C. GANDY. TAX MAP NO.: 29-19-1639-122. Zucker,Goldberg&Ackerman, LLC XFP-153104 153104D1004C01312014P4 AS."SAFgASC.�-k' .r3>`�Y::t3r F,.'.laSFF'. ',etl;.ak.. .,"Ya.F3A,4 S -M. '.j' _. ... _.� ,. -- _ - +s.•+ +r.�*Y U t S POSTAGE')PITNEY 80WES Page 1 of 6 NOTICE TO LIENHOLDERS 01.20 UNITED STATES Certificate Of .:; POSTAL SERVICE® Mailing � To pay tee,affix stamps or meter postage hero. This Certificate of Mailing provides evidence that mall hes been presented to USPS*for mailing.This form may be used for domestic and International mall. From' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C To: UNKNOWN TENANT OR TENANTS Postmark Here 55 Cavalry Road Carlisle, PA 17013 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE® A This Certificate of Mailing provides evidence that mall has been presented to USPS*for mailing.' and International mall, Prom' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-Ce To' COMMONWEALTH OF PENNSYLVANIA Postmark 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 ay 4 „ §' A llvk'Zx ;i,'ice Page 2 of 6 NOTICE TO LIENHOLDERS "' `+ � . .. UNITED STATES '4711:r-� ; Certificate Of .�' r ; , � POSTAL J p Mailing POSTAL SERVICE® To pay fee,affix stamps or meter postage here. This Certificate of Mailing provides evidence that mail has been presented to USPSe for mailing.This form may be used for domestic and international mall. Prom' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 mm XFP-153104/sde TEAM-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 "; t` U S POSTAGE�TNEY BOWES key 124:17/ (44.,,r—17", 01. UNITED STATES 0001387430FEB 07 2014 P:;.1 ! POSTAL SERVICE® hen. This Certificate of Mailing provides evidence that mall has been presented to USPSe for mailing.This form may be used for domestic and international mall. From Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C To: UNKNOWN SPOUSE Postmark Here 1000 Claremont Road Carlisle, PA 17013-7310 County of P.Q.: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 U.S POSTAGE>>PITNEYBOwEs if—ow Page 3 of 6 NOTICE TO LIENHOLDERS a ,4*. '° * 4' fal 43:4 . $ 001 UNITED STATES Certificate Of Mailing ..r > POSTAL SERVICE affbg This Certificate of Melling provides evidence that mall has been presented to UPS*for mailing.This form may be used for domestic and international mail From' Scott A. Dietterick, Esquire d/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C` To' UNKNOWN SPOUSE Postmark Here 5616 Ridgerock Road Fort Worth,TX 76132 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 lio*' :t1 U.S POSTAGE>>PITNEY BOWES rosawoomgowea MUM AONStafflP 001.20 UNITED STATES uw 0001387430 FEB 07 2014 P:;: ' POSTAL SERVICE6 here, This Cartifkata of Melling provides evidence that mall has been presented to USPS•for mailing.This form may be used for domestic end international mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C , To' NORTH MIDDLETON AUTHORITY Postmark Here 2051 Spring Road, Carlisle, PA 17013 County of P.Q•CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 t US POSTAGE Y;PITNEY E:VJES Page 4 of 6 NOTICE TO LIENHOLDERS i » a4 Kow - a a1 00110° UNITED STATES Certificate Of 0001387430FEB 07 2C14 Mailing POSTALSERVICE® here yfea,OM(stamps ormeterpostage This Certificate of Mailing provides evidence that mall has been presented to UPS.for mailing.This form may be used for domestic and international mail. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS Postmark Here NOMINEE FOR NEW FREEDOM MORTGAGE CORPORATION,A CORPORATION 2363 South Foothill Drive Salt Lake City, UT 84109 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 +.� U S POSTAGE>>PITNEY BOWES w UNITED S 4 TATES ,-1 2 .lug 31. 4tr. POSTAL SERVICE® This Certificate of Mailing provides evidence that mill has been presented to USPS•for mailing.This form may be used for domestic and international mail. Fro" Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C To' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS ' Postmark Here NOMINEE FOR NEW FREEDOM MORTGAGE CORPORATION,A'` CORPORATION 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 5 of 6 NOTICE TO LIENHOLDERS $ 00 110° UNITED STATES Certificate Of .1PF POSTAL Mailing SERVICES To pay hot,affix namps or motor postage here This Certificate of Mailing provides evidence that mall has been presented to USP5*for mailing.Thin form may be used for domestic and inttnnattonar mad "um' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 ,, Mountainside, Ni 07092 / XFP-153104/sde TOM-C ( ' To' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS i Postmark Here NOMINEE FOR NEW FREEDOM MORTGAGE CORPORATION,A CORPORATION P.O. Box 2026 Flint, MI 48501-2026 County of P.Q.: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 US POSTAGE>>PITNEY BOWES (4,4e. '*''W' '': *,:i '1 1 0 $ ° '2° d 1114 111' ° ;,,,etowiwiemae am?0,4744441f, UNITED STATES Ewa. POSTAL SERVICES ;_ '''.. altk Z14 0001387430 FEB 07 2014 This Certificate of Mailing provides evidence that mall has been presented to U5PS*for mailing This form may be used for domestic and International moil From: Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC -- 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/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 6 of 6 NOTICE TO LIENHOLDERS f 20 at UNITED STATES Ceritifica POSTAL SERVICES Making To pay fee,affix stamps or meter postage hers. This Certificate of Mailing provides evidence that mall has been presented to USPS•for mailing.This form may be used for domestic and international mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C To' PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Hefe.. " Dept.280601 Harrisburg, PA 17128-0601 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 U.S POSTAGE>>PITNEY BOWES ' � �:w, � . 1' UNITED STATES $ 00110° POSTAL SERVICES This Certificate of Mailing provides evidence that mall has been presented to LISPS•for mailing.This form may be used for domestic and International mall. From' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-153104/sde TEAM-C To: Postmark Here UNKNOWN SPOUSE 55 Cavalry Road Carlisle, PA 17013 County of P.Q.. CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY HE P O THOHO T -AR f fi rix 2O14 MAY 15 1P1112': 146 pp curmBERLAND c0 TY oFxrcEof�asa���,F�, p'ENNSYi..VAN1A Wells Fargo Bank, N.A. vs. Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy .. Case Number 2011-5846 SHERIFF'S RETURN OF SERVICE t; r-, 01/06/2014 07:52 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.55.Cavalry Road,. North Middleton - Township, Carisle, PA 17013, Cumberland County. 01/06/2014 07:52 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy, pursuant to Order of Court by "Posting" the premises located at 55 Cavalry Road, North Middleton Township, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 03/12/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on March 12, 2014 at 10:00 a.m. He sold the same for the sum of $ 40,000.00, to Attorney Jaime Ackerman, on behalf of, Wells Fargo Bank, N.A., being the buyer in this execution, paid to the Sheriff the sum of $ 04/11/2014 Proposed Schedule Of Distribution Posted SHERIFF COST: $2,194.89 SO ANSWERS, April 30, 2014 RONNY R ANDERSON, SHERIFF (c) CountySu le Sheriff, Teleosoft, Inc. .00 - j a(a. 4/24 9!/J? A14r3 c:- gC'N, On November 7, 2013 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA, Known and numbered as, 55 Cavalry Road, Carlisle, as Exhibit "A" filed with this writ Q ,0 and by this Reference incorporated herein. C Date: November 7, 2013 By: CLULL Real Estate Coordinator ..> LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2011-5846 Civil Term Wells Fargo Bank, N.A. vs. Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy Atty.: Jaime R. Ackerman ALL THAT CERTAIN lot of ground situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point atthe intersection of the eastern line of Cavalry Road and the southern line of Harriet Street; THENCE eastwardly along the southern line of Harriet Street 72 feet more or less; THENCE along other property now or formerly of Vincent M. Zeladonis and Peggy A. Zeladonis, southwardly 100.40 feet more or less; THENCE westwardly along the line of Lot No. 11 of the hereinafter mentioned Plan of Lots 92 feet more or less; THENCE northwardly along the eastern line of Cavalry Road 102.6 feet more or less to the place of BE- GINNING. BEING the western portion of Lots No. 12 and 13 of the Plan of Lots known as Harriet Acres, as recorded in the Office of the Recorder of Deeds in and for Cumberland County, in Plan Book 2, Page 100. HAVING thereon erected a dwell- ing house being known and num- bered as SS Cavalry Road, Carlisle, PA, 17013. BEING the same premises which Robert E. Clouse, Individual, by deed dated May 25,1995 and recorded May 26,1995 in and for Cumberland County, Pennsylvania, in Deed Book Volume 122, Page 700, granted and conveyed unto Harry C. Gandy. TAX MAP NO.: 29-19-1639-122. 34 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: January 24, January 31, and February 7, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, Editcr SWORN TO AND SUBSCRIBED before me this day of February, 2014 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 'The Patriot -News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2011-5846 Civil Ter Wells Fargo Bank, N.A. Vs Sara Jane Gandy, Administratrix of the Estate of Harry C. Gandy Atty: Jaime R Ackerman ALL THAT CERTAIN LOT OF GROUND SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE INTERSECTION OF THE EASTERN LINE OF CAVALRY ROAD AND THE SOUTHERN LINE OF HARRIET STREET; THENCE EASTWARDLY ALONG ' THE SOUTHERN LINE OF HARRIET STREET 72 FEET MORE OR LESS; THENCE ALONG OTHER PROPERTY NOW OR FORMERLY OF VINCENT M. ZELADONIS AND PEGGY A. ZELADONIS,`-'5JtTl'I WARDLY 100.40 FEET MORE OR LESS; I THENCE WESTWARDLY ALONG I This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 Sworn to d supscribed before me this 18 day of February, 2014 A.D. COMMONWEALTH OF PENNSYLVANIA Holl Notarial Seal Y Lynn Warfel, Notary Public • Washington 7WP , Dauphin County My Commission Expires Dec. 12 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Bank N A is the grantee the same having been sold to said grantee on the 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 5th day of November, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 5846, at the suit of Wells Fargo Bank N A against Sara Jane Gandy, Admrx of the estate of Harry C Gandy is duly recorded as Instrument Number 201410041. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this /96L( ,A.D. 0011-/ day of Ct • �..e.2trmI DefUI / Recorder df Deeds Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018