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Home My WebLink About11-6053IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, VS. KATHERINE THOMAS ;RICHARD THOMAS CIVIL DIVISION -,- NO : . TYPE OF PLEADING c- c? =? =- _. ci r-, '' r n CIVIL ACTION - COMPLAIN IN MORTGAGE FORECLOSU14 ca 1 Defendants. TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 STATEVIEW BLVD. MAC ># X7801-013. FT. MILL. SC 29715 AND THE DEFENDANT: 1182 GreenspringRoad Newville. PA 17241 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 13 North Corporation Street. Newville PA 17241 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 ATTORNEY FOR PLA 1 200 Sheffield Street, Suite 101 ATTY FILE NO. XFP 15241 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP- 152413/ncp c--_:-,-) QZL ., aU Zucker, Goldberg & Ackerman, LLC XFP-152413 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-152413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., : CIVIL DIVISION Plaintiff, : NO.: VS. Katherine Thomas ; Richard Thomas Defendants NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action 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 Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-152413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., : CIVIL DIVISION Plaintiff, : NO.: vs. Katherine Thomas ; Richard Thomas Defendants. AVISO USTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los proximos veinte (20) dias despues de la notification 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 reclamation 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 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-152413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION Plaintiff, : NO.: vs. KATHERINE THOMAS ;RICHARD THOMAS Defendants 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 Defendants, Katherine Thomas and Richard Thomas, are individuals whose last known address is 1182 Greenspring Road, Newville, PA 17241. 3. On or about November 8, 2010, Katherine Thomas executed a Note in favor of Allied Mortgage Group, Inc., a Pennsylvania Banking Corporation in the original principal amount of $80,433.00. 4. On or about November 8, 2010, as security for payment of the aforesaid Note, Katherine Thomas and Richard Thomas, wife and husband made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Allied Mortgage Group, Inc., a Pennsylvania Banking Corporation a Mortgage in the original principal amount of $80,433.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on November 15, 2010, Instrument #201033190. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. The note and mortgage was assigned to plaintiff by Assignment of Mortgage dated 05/13/2011 from Mortgage Electronic Registration Systems, Inc. as nominee for Allied Mortgage Zucker, Goldberg & Ackerman, LLC XFP-152413 Group, Inc., a Pennsylvania Banking Corporation to Wells Fargo Bank, N.A. Said assignment is unrecorded at this time. 6. Richard Thomas and Katherine Thomas, husband and wife are record and real owners of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest being contractually due for the January 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written notice of said default to Defendant(s), the entire principal balance and accrued interest due thereunder has been accelerated. 8. On or about April 20, 2011, Defendant(s) were mailed a combined Notice of Homeowners' Emergency Mortgage Assistance Act of 1983 and Notice of Intention to Foreclose Mortgage, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983 and Act 6 of 1974, 41 P.S. §101, et seq. 9. The amount due and owing Plaintiff by Defendants is as follows: Principal $80,433.00 Interest to 06/14/2011 $1,830.95 Escrow ($21.25) Late Charges $ 22.41 Corporate Advance $ 205.00 Total $82,470.11 plus interest on the principal sum ($80,433.00) at the daily interest of $ 9.37, 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 additional 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. 10. 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. Zucker, Goldberg & Ackerman, LLC XFP-152413 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $82,470.11, with interest thereon at the daily interest of $ 9.37 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 BY: a ? I aLi __ Dated: 7 , 2011 Scott A. Dietterick, squire; PA I.D. #55650 Kimberly A. Bo r, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire, PA I.D. #2027:29 Ashleigh L. Levy, Esquire; PA I.D. #306799 Attorneys for Plaintiff XFP-152413/ncp 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-152413 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-152413 la ? ?3??go ti This Instrument Prepared By: ALLIED MORTGAGE GROUP, 7 BALA AVE., STE BALA PA 19004 (610)668-2745 After Recording Return To: ALLIED MORTGAGE GROUP, INC 7 BALA AVE., STE 108 BALA CYNWYD, PENNSYLVANIA 19004 Loan Number: 131010033 Uniform Parcel Identifier Number: 27201754225 Property Address: 13 NORTH CORPORATION STREET NEWVILLE, PENNSYLVANIA 17241 [Space Above This Una For Recording Datal S MORTGAGE FHA CASE NO. 4460035151703 MIN: 100090710110176032 THIS MORTGAGE ("Security Instrument") is given on NOVEMBER 8, 2010 The mortgagor is KATHERINE THOMAS AND RICHARD THOMAS, WIFE AND HUSBAND ("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. ("MERS") as Mortgagee. MERS Is the nominee for Lender, as hereinafter defined, and Lender's successors and assigns. MERS Is organized and existing under the laws of Delaware, and has a mailing address of P.O. Box 2026, Flint, MI 48501-2026 and a street address of 3300 S.W. 34th Avenue, Suite 101, Ocala, FL 34474, tel. (888) 679•MERS. ALLIED MORTGAGE GROUP, INC, A PENNSYLVANIA BANKING CORPORATION ("Lender") is organized and existing under the laws of PENNSYLVANIA and has an addressof 7 BALA AVE., STE 108, BALA CYNWYD, PENNSYLVANIA 19004 Borrower owes Lender the principal sum of EIGHTY THOUSAND FOUR HUNDRED THIRTY-THREE AND 00/100 Dollars (U.S, s 80,433.00 ). FHA PENNSYLVANIA MORTGAGE - MERS DOCM291C tfl= W0449.1362 PAMTGZ.FHA 08/26/10 Page 1 of 11 www.dwmVk.com P.wgx &A.xd This debt is evidenced by Borrower's note dated the same dale as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on DECEMBER 1, 2040 . 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 Ibis Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS the following described property located In CUMBERLAND County, Pennsylvania: LEGAL DESCRIPTION ATTACHED HERETO EXHIBIT A A.P.N.: 27201754225 which has the address of 13 NORTH CORPORATION STREET [Stroh NEWVILLE Pennsylvania 17241 ""ProperryAddress"): ICityl [Zip Code) 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, MERS (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 seised 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 an6 &:rn-uniform covenants with limited variations by jurisdiction to constitute a uniform security instiument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest and Late Charge. Borrower shalt pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. FHA PENNSYLVANIA MORTGAGE - MERS OoeMagie dMrW= aoaacras: PAMTG2.FHA 06126/10 Page 2 of 11 www.doemagk-cam Pamks.m.xw 2. Monthly Payment of Taxes, Insurance, and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property. (b) leasehold payments to 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: (1) a sum for the annual mortgage Insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. §2601 et seq. and implementing regulations, 24 CFR Parl 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 b;; RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds Seld by Lender at any time are not sufficlent 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 sums secured by (his 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 W. 3. Application of Payments. All payments under paragraphs l 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 (he 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 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 FHA PENNSYLVANIA MORTGAGE - MFRS OocMagM CJWW B W01040- 136Z PAMTGL.FHA 08/26!10 Page 3 of 11 www.dacnw9a.c6m P-WPA 1 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 tide to the Properly that extinguishes the indebtedness, all right, tide and interest of Borrower in and to insurance policies in form shall pass to the purchaser. 3. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least a;ac 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 lake 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 indebie3 i-s that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the ra,ac:tion of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied In the order provided in paragraph 3, and (ben 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 Nate and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest 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 Z, 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 hL Ftvperty and Lender's rights in the Property, including PaYrrient of taxes, hazard insurance and other items mentioned in paragraph 2. FHA PENNSYLVANIA MORTGAGE • MERS Docafagrc CftM= SMU&+J62 PAMTGZ.FHA 08126/10 Page,lof 11 www.dbcrmgk.com P-tF.m..W 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 Ben 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 holds: of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any put of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the Ben. 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, (a) 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. 1701.j-3;e"/) and with the prior approval of the Secretary, require immediate payment in full of all sums segued bi this Security Instrument If: (1) 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 (it) 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. (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 i° ',.:!I 1w 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 FHA PENNSYLVANIA MORTGAGE - MERS 006mavic e7amm wo-"91362 PAMTGZ.FHA 08/26110 Page 5 of 11 www.d0eJM6 .com h,1V.6u.m1 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 fender had not required immediate payment in full. However, Lender is not required to permit reinstatement if: (f) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (it) reinstatement will preclude foreclosure on different grounds In the future, or (iii) reinstatement will adversely affect the priority of the lien created by (his 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 successors 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 made 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. T::o•, or;: cants and agreements of Oils Security Instrument shall bind and benefit the successors and assigns of Lender grid 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 ft 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. 13. Notices. Any notice to Borrower provided for in Oils Security Instrument shall be given by delivering it or by mailing it by fast 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; SeverabBity. 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 elaue_'a:.lt?i 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 Nate 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 Properly 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 Properly and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediallon of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordanti.,;?:ili- :Znvironmental Law. FHA PENNSYLVANIA MORTGAGE - MERS D=Mogic 470m a aoa64a1362 PAMTGZ.FHA 08126/10 Page 6 of 11 www.docmagic.eom :,...'I; As used in this paragraph 16, "Hazardous Substances" are those substances dented 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: I7. 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 called (be rents and rtavtw,.es 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 Inutee 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 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 Properly shall terminate when the debt secured by the Security I:.st; ,ament is paid in full. I8. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding and/or invoke any other remedies permitted by applicable law. Lender shall he entitled to collect all expenses Incurred in pursuing the remedies provided or referred to in this paragraph 18, including, but not limited to, attorneys' fees and costs of tide evidence to the extent permitted by applicable law. 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 norjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3751 el in.) by requesting a foreclosure commissioner designated under the AM 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. Borrower shall pay any recordation costs. Lender may charge Botrolver a. fee for releasing this Security Instrument, but only if the fee is paid to a third parry for services rendered charging of the fee is permitted under applicable law. 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 sheriffs sale or other sale pursuant to this Security Instrument. FHA PENNSYLVANIA MORTGAGE - MERS DOCAAWc a' WNW eaa049- rre2 PAMTGZ.FHA 06126/10 Page 7 of l l www.docmmgk.com 22. Purchase Money Mortgage. If any or 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 alley .tjudgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time io 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 (his Security Instrument as if the rlder(s) were a part of this Security Instrument. [Check applicable box(es)[. ? Condominium Rider ? Graduated Payment Rider ? Growing Equity Rider ? Planned Unit Development Rider ? Adjustable Rate Rider ? Rehabilitation Loan Rider ? Non-Owner Occupancy Rider ? Other (Specify] [REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK] FHA PENNSYLVANIA MORTGAGE . MERS DoeMagic t7== aaasra•yav PAMTGZ.FHA 08126/10 Page S of 11 www.dacrosgic.com PamlgMb,.-a BY SIGNING BELOW. Borrower accepts and agrees to the terms contained in pages 1 through 11 of this Security Instrument and in any rider(s) executed by Borrower and recorded with it. (Seal) KATHERINE THOMA-Borrower (Seal) -Borrower (Seal) Borrower WitnesS MILLER -'?„ -FJ LL?R (Seal) RICHARD HOMAS -Borrower (Seal) -Borrower (Seal) -Borrower Witness: ZE. MILLER / FHA PENNSYLVANIA MORTGAGE - MERS PAMTGZ.FHA 0812W10 Page 9 of 11 M C47www = dvej= r c P-S.A.-I [Space Below TMs Line For Acknowledgment] State of PEN SYLVANIA County of On this the J!?ay of before me 271'ihh C en the undersigned officer, personally appeared KATHERINE THOMAS AND RICHARD THOMAS , WIFE AND HUSBAND known to me (or satisfactorily proven) to he the person(s) whose name(s) Is/are subscribed to the within instrument and acknowledged that he/she/they executed the same for the purposes therein contained. In witness whereof, I hereunto set my hand and official seals. 7 XC Signature Printed N e/ ?, Z /"c (Seal) tie of Officer My commission expires: -.,.'-, ? 13 t]OMMONWEALTH OF PENNSYLVANIA ' Notarial Seal q== E MNW, Notary Public East: HonorerTnp., DWjph% COWRY tbmmasbn Expires Sept. 22, 2013 Member, Porw0anla AssodOw of Notaries FHA PENNSYLVANIA MORTGAGE - MERS DocuagictZ110'.76 80"49,IJ62 PAMTGL.FHA 08/26110 Page 1001`11 www.docnwgk.com Certificate of Residence of Morttraaee The undersigned hereby certifies that: (i) he/she is the Mortgagee or the duly authorized attorney or agent of the Mortgagee named in the within instrument; and (ii) Mortgagee's precise residence is: 3300 S. W. 34th Avenue, Suite 101, Ocala, FL 24474, P. O. Box 2026, Flint, Michigan 48501-2026 Witness my hand this 8T8 day of NOVEMBER, 2010 Sf lure of artgagee or Mortgagee's Duly Authorized Attorney or Agent JOE HUGHES Type or Print Name of Mortgagee or Mortgagee's Duly Authorized Attorney orAgent FHA PENNSYLVANIA MORTGAGE - MERS Doc"1c evegam 80O64a•17a7 PAMTGZ.FHA 08/26/10 Page 11 of 11 www.docmjsk.com Pmip.Ri.kml Escrow File No.: 671 All Real Estate Solutions, LLC 781 Beta Drive Suite I Mayfield Village, OH 44143 LEGAL DESCRIPTION - EXHIBIT "A" All that certain tract or parcel of land and premises situate, lying and being in the Borough of Newville in the County of Cumberland and Commonwealth of Pennsylvania, and known as 13 Corporation Street, more particularly described as follows: Bounded on the North by land now or formerly of Ralph C. Lehman, Jr. and Charlotte I. Lehman and now or formerly of Jeffrey Kough; on the East by Corporation Street; on the South by property now or formerly of Gerreth M. Mains and Mary E. Mains; and on the West by an Alley. Containing thirty (30) feet front on said Corporation Street, and a depth of one hundred eighty (180) feet, more or less, to said Alley. Being the same property conveyed to Richard Thomas and Katherine Thomas, by deed filed of record December 28, 2006, of record in Book 278, Page 782, in the Office of the Cumberland County Register. Permanent Parcel Number: 27-20-1754-225 VERIFICATION Melissa Maldonado, hereby states that hele is Vice President Loan Documentation of, WELLS FARGO BANK, N.A., servicing agent for Plaintiff in this matter, that he/ h? 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 of his he 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. Nam : Melissa aldonado DATE: 'ZS Title: Vice President Loan Documentation Servicer: WELLS FARGO BANK, N.A. File #: XFP-152413 Name: KATHERINE THOMAS/RICHARD THOMAS SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?Qkl4liy, o{ ?sl?r!(?rr?,j tp r, tsr, r it j"! rna r- i Wells Fargo Bank, N.A. vs. Richard Thomas (et al.) Case Number 2011-6053 SHERIFF'S RETURN OF SERVICE 08/04/2011 04:07 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 4, 2011 at 1607 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Richard Thomas, by making known unto himself personally, at 1182 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. GERALD WORTHING , DEPUTY 08/04/2011 03:45 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard Thomas, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard Thomas. Request for service at 13 N. Corporation Street, Newville, Pennsylvania 17241 is vacant. 08/04/2011 04:07 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 4, 2011 at 1607 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Katherine Thomas, by making known unto Richard Thomas, Husband of Defendant at 1182 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. GERALD WORTHINGT , DEPUTY 08/04/2011 03:45 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard Thomas, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard Thomas. Request for service at 13 N. Corporation Street, Newville, Pennsylvania 17241 is vacant. SHERIFF COST: $100.00 August 05, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF !c; ?_;ounly?;uitU Shantt 7-,ia?sofi Ii7c_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,-) - PENNSYLVANIA o = Wells Fargo Bank, N.A., CIVIL DIVISION rnco Z MM r f+'t r) ?, ^} fir- -:a D < o C? Plaintiff No.: 2011-06053 a vs. zo xF ISSUE NUMBER: az ? Katherine Thomas ; Richard Thomas; " TYPE OF PLEADING: ..? '? Defendant(s). PRAECIPE FOR DEFAULT JUDGMENT I Hereby certify that the last known address (Mortgage Foreclosure) of Defendant(s) is/are: FILED ON BEHALF OF: 1182 Greenspring Road Newville, PA 17241 Wells Fargo Bank, N.A. Plaintiff Attorney for Plaintiff COUNSEL OF RECORD FOR THIS PA RTY: 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-152413 any * l y "vld 01? aµ'W?y0?) Voh-ce Wailed IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DWISION VS. Katherine Thomas ; Richard Thomas; Defendant(s). NO.: 2011-06053 PRAECIPE FOR DEFAULT JUDGMENT TO:PROTHONOTARY Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant(s), Richard Thomas and Katherine Thomas, in the amount of $84,375.50 which is itemized as follows for failure to file an Answer: Principal $80,433.00 Interest through 12/21/11 $3,601.88 Late Charges $ 156.87 Escrow $- 21.25 Corporate Adv. $ 205.00 Total $84,375.50 plus interest on the principal sum ($80,433.00) from December 22, 2011, at the rate of $9.37 per diem, 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, GOLD G &t AC AN, LLC Dated: By: .i Sco A. Dietterick, uire; 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-152413 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX "Zucker, Goldberg & Ackerman, LLC X FP-152413 AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY COUNTY OF UNION SS: Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, Kimberly A. Bonner, Esquire, Joel Ackerman, Esquire, Ashleigh L. Levy Marin, Esquire, Ralph M. Salvia, Esquire, Jaime R. Ackerman, Esquire, attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendant is not in the military service of the United States of America to the best of his/her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. ZUCKER,GOLDBER AC N,LLC Dated: a By: Scott A. D' ck, i ; 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-152413 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX Sworn to and subscribed before me This 21-3 day of December, 2011 Notary blic My Commission Expires: EDWARD J. SCHWAHL II Zucker, Goldberg & Ackerman, LLC Commission # 2383239 XFP-152413 Notary Public, State of New Jersey My Commission Expires March 09, 2014 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Dec-21-2011 13:40:15 C Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency Name KATHERINE Based on the information you have furnished, the DMDC does not possess THOMAS L any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). mial 14 1 101. 4400i.'r Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Service Members 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 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 is on active duty, 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 "defense link.mil" URL http•//www.defenselink.mil/fag/12is/PC09SLDR.htmi. If you have evidence the person is on active duty 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). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 12/21/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(0 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 TARS, Marine Corps ARs and Coast Guard 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) for a period of more than 30 consecutive days. 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. 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 SCRA extend beyond the last dates of active duty. Those who would 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 name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:JQ54TOJS5T https://www.dmdc.osd.mil/appj/scra/popreport.do 12/21/2011 Request for Military Status Department of Defense Manpower Data Center 10 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Dec-21-2011 13:43:01 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency THOMAS RICHARD Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). 0101 )4. it Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Service Members 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 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 is on active duty, 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 hqp://www.defenselink.mil/fU/--pis/PC09SLDR.html. If you have evidence the person is on active duty 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). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 12/21/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days 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 TARs, Marine Corps ARs and Coast Guard 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) for a period of more than 30 consecutive days. 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. 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 SCRA extend beyond the last dates of active duty. Those who would 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 name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:TV2IA2TJJF https://www.dmdc.osd.mil/appj/scra/popreport.do 12/21/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Katherine Thomas ; Richard Thomas; Defendant(s). NO.: 2011-06053 NOTICE OF ORDER, DECREE OR JUDGMENT TO: Katherine Thomas 1182 Greenspring Road Newville, PA 17241 ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Or, er, Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $84,375.50 plus interest on the principal sum ($80,433.00) from December 22, 2011, at the rate of $9.37 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Prothonotary Zucker, Goldberg & Ackerman, LLC XrP-152413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2011-06053 Katherine Thomas ; Richard Thomas; Defendant(s). NOTICE OF ORDER, DECREE OR JUDGMENT TO: Richard Thomas 1182 Greenspring Road Newville, PA 17241 ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an, Orde , Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $84,375.50 plus interest on the principal sum ($80,433.00) from December 22, 2011, at the rate of $9.37 per diem, plus additional late charges, and costs (including additional escrow advances), additional age emi attorneys' fees and costs and for foreclosure and sale of joary w ProZucker, Goldberg & Ackerman, LLC XFP-152413 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, N.A. vs. Richard Thomas (et al) ?oyntr of ?uutberi??0 r?, ?r1 OF FIGS OF 'HE SHERIFF (C7 -D C? TY Case Number 2011-6053 SHERIFF'S RETURN OF SERVICE 08104/2011 04:07 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 4, 2011 at 1607 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Richard Thomas, by making known unto himself personally, at 1182 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him personally the said true and correct copy of the same. GERALD WORTHING , DEPUTY 08104/2011 03:45 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard Thomas, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard Thomas. Request for service at 13 N. Corporation Street, Newville, Pennsylvania 17241 is vacant. 08/04/2011 04:07 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on August 4, 2011 at 1607 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Katherine Thomas, by making known unto Richard Thomas, Husband of Defendant at 1182 Greenspring Road, Newville, Cumberland County, Pennsylvania 17241 its contents and at the some time handing to him personally the said true and correct copy of the same. A a / -.4'a ;&- GE LD WORTHINGT , DEPUTY 08/0412011 03:45 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard Thomas, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard Thomas. Request for service at 13 N. Corporation Street, Newville, Pennsylvania 17241 is vacant. SHERIFF COST: $100.00 August 05, 2011 SO ANSWERS, RONRYY R ANDERSON, SHERIFF IcI r„ p,mry5wte 50enrt Teleosot loc.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION VS. Katherine Thomas Richard Thomas TO: Katherine Thomas 1182 Greenspring Road Newville, PA 17241 DATE OF NOTICE: 9/27/2011 NO.: 2011-06053 IMPORTANT NOTICE 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 Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Vs. Katherine Thomas Richard Thomas TO Plaintiff, Defendant. Katherine Thomas 1182 Greenspring Road Newvilie, PA 17241 CIVIL DIVISION NO.: 2011-06053 ANV--0ZS''CRTANIE FECHA DEL AVISO:9/27/2011 LB= ESTA EN A PC RQUE HA FALIADU M TrMAR LA ACCIGN HST CIE CA,SQ A NII\rg (XE LMM TCNE AMCN TENIM ICE U)s P.iM (10) ETAS ICE LA FBM A EEESTEA-vM, SE RJUE I [CTAR LNFALL 0R4C CNIRA SUYA S N I IFWAR.SEA CA3 3 DLNA V!SMYIMM PIS PERCEt SU U3DIkD Y CURLS r1RIXICS IlV =ANIM LB= I I EVAR. Ems" IE IX CU43? 1M I14\dMATA ENM A SU ADOCADQ S[ LLMD NC; 'lIINIE UN AE OCADD 0 NCl PLE E PACAR LNQ VAYA O LI.ANE LA C HCINA AWJO PCICADik PARA CUE LE r4KXUVII D ZNM PCE EE CaEQ[ IR AY-1:'A E>F1 adi, PgC3I C TIDDEFEM &1,0VV.EIt+1144ALS Ei C 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 ZUC M , GOEDEERG&A T BY 3=A. DkOx3idc Solt A Dietteridk Esquire Auameys for Plairmff PAID. # 55650 200 Sheffield Sired, Suite 301 P.O. Bax 1024 M xzitairiside, M 07092-0024 (717) 533-3560 FIRST CIASS U S. MAII, PCS TALE PREPAID 152413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs Katherine Thomas Richard Thomas TO: Richard Thomas 1182 Greenspring Road Newville, PA 17241 DATE OF NOTICE: 9/27/2011 NO.: 2011-06053 IMPORTANT NOTICE 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 Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION VS. Katherine Thomas Richard Thomas Defendant. TO: Richard Thomas 1182 Greenspring Road Newville, PA 17241 NO.: 2011-06053 ANISOE TANM FECHA DEL AVISO:9/27/2011 LMM ESTA INREBMIA PCRQLE HA FAUTADtD M TCM4R IA ACCUMQ Mnk IN ME CA.SO A NENDS ( E LMM TOW AOCICN I04M I:E UDS PfUMVIJJS Irk (X0 IXAS LE IA FBCHA TE ESM ANM, SE RIECE LICTAR LNFALIAINCCNIRASUYA9NLIEVARSEAC"ABOU AN TAYIMMPI&EE Pmt SU EEEAD Y OIRC S Kl-" RvF UANI& LMM LEEE LLEVAR WM DC7CM1V1 NM RqVML4TAIVI NM A SU ABCCADO S[ L1= N-' 'IENILE UN AECCAM O M PLE E PACAR LIVQ VAYA O UAIVE LA ORCr A APA O R-42C.ADA PA?A QUE LE IT4K1CVFN DON CE PLECE AY MI % r4MCE'P0D1EEEM &LANNVM 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 ZUCKEP, GCEDEERG&AC1<EEQvL4N BY Soott A Dicttxrick, Esquire Attcmeys far PI aixmff PA ID_ # 55650 200 SheOidd Street, Sate 301 P_ O. Banc 1024 Mxiritairmde~ M 07092-0024 (717) 533-3560 FIRST CI ASS U S. MAIIi PGS TAGS PREPAID 152413 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-6053 Civil 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 KATHERINE THOMAS, RICHARD THOMAS (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: $84,375.50 L.L.: $.50 Interest FROM 12/22/2011 TO DATE OF SALE - $1,564.79 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $237.00 Other Costs: Plaintiff Paid: Date: 2/28/12 David D. Buell, Prothonot (Sea!) Deputy REQUESTING PARTY: Name: KIMBERLY A. BONNER, 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. 89705 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Wells Fargo Bank, N.A., VS. Plaintiff, Katherine Thomas ; Richard Thomas; Defendants. TO THE PROTHONOTARY OF THE SAID COURT: Interest from 12/22/2011 to date of sale $1,56.4,79 Costs - _ i > CO r-- -i C-) CD_ C N 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 File No. 2011-06053 Amount Due $84,375.50 PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real ate of the defendant(s) described in the attached exhibit. /// Signature: DATE: Print Name: S tt A. iette sq e /Kimberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh L. Marin, Esquire ?,\\ Ralph M. Salvia, Esquire G?'N???'a`$ 5u aon Jaime R. Ackerman, Esquire OU C Address: Zucker, Goldberg & Ackerman, LLC C) 00 t 200 Sheffield Street, Suite 101 I U " (( Mountainside, NJ 07092 Attorney for: Plaintiff a S u Telephone: a 3? . Ob Supreme Court ID No.: j) . aS LDVe . SD /-4- a-? I t,79t-) 908-233-8500 55650 89705 202567 306799 202946 311032 /uckrr G.:>Whrr?? tti ,tickcnnan I.I (od ?- 0o 0F -_?,r-A Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. AND CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRETH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPTH OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241.. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE. TAX MAP NO.: 27-20-1754-225. Ztwkcr, (Joldhcn_ A,- Ackcrinan. III' \t P-15241:3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION , Plaintiff • wi NO.: 2011-06053 71 -T1 n Sri....,.: , VS. : 1- rv CO Execution No.: c ..y C?..,• -. - -,. Katherine Thomas ; Richard Thomas; > o c? cz tv ' Defendant(s). " y' 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 13 North Corporation Street, Newville, PA 17241. 1. Name and Address of Owner(s) or Reputed Owner(s): RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE: 1182 Greenspring Road Newville, PA 17241 2. Name and Address of Defendant(s) in the Judgment: KATHERINE THOMAS 1182 Greenspring Road Newville, PA 17241 RICHARD THOMAS 1182 Greenspring Road Newville, PA 17241 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 /uckcr. Golabcr?, ti Ackcmian_ H XI I,-I I i J 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MERS AS NOMINEE FOR ALLIED MORTGAGE GROUP, INC. PO Box 2026 Flint, MI 48501-2026 AND 7 Bala Avenue, Suite 108 Bala Cynwyd, PA 19004 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 PENNSYLVANIA DEPARTMENT OF REVENEUE, BUREAU OF COMPLIANCE Department 280946 Harrisburg, PA 17128-0946 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 13 North Corporation Street Newville, PA 17241 /uckcr_ (???IJhrre? ?? 1ti:<•r3?3.?n I I iFF'-I>":'-41 ?; UNKNOWN SPOUSE 1182 Greenspring Road Newville, PA 17241 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 GOLDBFRG & ACKF?tMAN, LLC r Dated: l3 (? BY: `f / Scott . Dietterick, quire; PA I.D. #55650 Kim erly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com /uckcr. GddbmcY Ackcrm m 1.1 kFI'-I 521113 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. AND CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRETH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPTH OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS ].3 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE. TAX MAP NO.: 27-20-1754-225. /tickcr_ t,;old bcat K acku'rri9n. I I.{' M P-152413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2011-06053 Katherine Thomas ; Richard Thomas; Defendant(s). t dd N? MUD M r co yC--) c:) N ~ry l 'r -T? :r: cam: r> NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Katherine Thomas 1182 Greenspring Road Newville, PA 17241 AND 13 North Corporation Street Newville, PA, 17241 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 6/6/2012 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: 13 North Corporation Street, Newville, PA, 17241 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2011-06053 Zucker, Goldberg & Ackerman, LLC XFP-152413 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Katherine Thomas ; Richard Thomas A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker, Goldberg & Ackerman, LLC XFP-152413 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 GOLDBFRG & ACKERMAN, LLC Dated: ?02 3111 BY: r Scottietterick, Esquire; PA I.D. #55650 Ki erly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XFP-152413 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. AND CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRETH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPTH OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE. TAX MAP NO.: 27-20-1754-225. Zucker, (nldhere X Ackerman, LLC X-1:13 _iCIAll IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, VS. Katherine Thomas ; Richard Thomas; Defendant(s). CIVIL DIVISION NO.: 2011-06053 Execution No : `0 '- . .zrn ' ;;o > C--) r't ` =CD Q C 3 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 13 North Corporation Street, Newville, PA 17241. 1. Name and Address of Owner(s) or Reputed Owner(s): RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE 1182 Greenspring Road Newville, PA 17241 2. Name and Address of Defendant(s) in the Judgment: KATHERINE THOMAS 1182 Greenspring Road Newville, PA 17241 RICHARD THOMAS 1182 Greenspring Road Newville, PA 17241 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 MERS AS NOMINEE FOR ALLIED MORTGAGE GROUP, INC. PO Box 2026 Flint, MI 48501-2026 AND 7 Bala Avenue, Suite 108 Bala Cynwyd, PA 19004 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 PENNSYLVANIA DEPARTMENT OF REVENEUE, BUREAU OF COMPLIANCE PO Box 280946 Harrisburg, PA 17128-0946 BUREAU OF COMPLIANCE PO Box 280948 Harrisburg, PA 17128-0946 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 13 North Corporation Street Newville, PA 17241 UNKNOWN SPOUSE 1182 Greenspring Road Newville, PA 17241 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. Dated: ZUCKER BY: iO ACKERMAN, LC Scott Aetterick, Esquire; PA I.D. 455650 Kimbe A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. AND CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRETH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPTH OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE. TAX MAP NO.: 27-20-1754-225. t { ?r ^ t r iL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA J Wells Fargo Bank, N.A., CIVIL DIVISION D C0U111 T Y Plaintiff, NO.: 2011-06053 VS. Katherine Thomas; Richard Thomas; TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE Defendants. OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh L. Marin, Esquire- PA I.D. #306799 Ralph M. Salvia, Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office(@zuckereoldbere.com File No.: XFP-152413/dsc Zucker, Goldberg & Ackerman, LLC XFP-152413 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 2011-06053 Katherine Thomas; Richard Thomas; Defendants. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Richard Thomas and Katherine Thomas, husband and wife, are the record owners of the real property. 2. On or about March 8, 2012, Defendants Richard Thomas and Katherine Thomas were served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, via Certified Mail, return receipt requested at the address of 1182 Greenspring Road, Newville, PA 17241. True and correct copies of said Notices and Proofs of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about April 3, 2012, Plaintiffs counsel served all other parties in interest with Plaintiff's 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 "B", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, LLC XFP-152413 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: April 17, 2012 DANIEL SCHLESIIGER.- Paralegal/Legal Assistant Sworn to and subscribed before me this ( day of April 2012 E otary Public MY COMMISSION EXPIRES: PAUL C. M0RA'TOWgKI 110M Ppbbii2 01New Jersey 407850 ?? MY Commission Expires 4/2Z?? Zucker, Goldberg & Ackerman, LLC XFP-152413 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-152413 EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-152413 R 0- ia 0 z v W m F 0 m i = ~ 6J NN= -0 0' ID M s0= J ? M cr w -Z ru N - ' a -0 co - o = Lai LLJ 21 _ - 21 N rru !al IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, VS. Katherine Thomas ;Richard Thomas; Defendant(s). CIVIL DIVISION NO.: 2011-06053 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Katherine Thomas 1182 Greenspring Road Newville, PA 17241 AND 13 North Corporation Street Newville, PA, 17241 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013 on 6/6/2012 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 ATTACKED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 13 North Corporation Street, Newville, PA, 17241 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2011-06053 . Zucker, Goldberg & Ackerman, LLC EM. XFP-152413 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Katherine Thomas ;Richard Thomas 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 batiks 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 PLAQE 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 FFI ESE TH BELOW TO OUT WHERE YOU C GET ME 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) 2493166 THE LEGAL RIGHTS YOU MAY HAVEARE• 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered, Zucker, Goldberg & Ackerman, tlC •XFP-152413 F 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. N a specific return date is desired, such date must be obtained from the Court Adminisfi toes Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKWGOLDB RG & ACKERMAN, LLC Dated: BY: _ Scott,: ietterick, Esquire, PA I.D. #55650 Kim%rly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. r Zucker, Goldberg & Ackerman, LLC ?Y - XFP-152413 Exhibit "A" LEGAL DESCREMON ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN 3R. AND CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF dEI'TREY KOUGH; ON THE EAST BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRETH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPTH OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND .COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE. TAX MAP NO.: 27-20-1754-225. i. /.u':-. CK4dhc%& Ackcrmm,1.1r ! XFP-152413 -Offidal LISPS L ao ON LY! -? S i r _ a g C3 a °' a w n ru a _ J CP. , w Q Q w ? F 8 w- CL J N 6 0 W ? J J g S yyy W i ? M N N UP If 0 N E= o I 4 ? 0 0 yea= A to I l -- C z m v a m cn 0 n ''r^^ v` m m Q X pOC N g ? m Z ?? W m r `r0^[ 4 Z - ir j. Q' _ tD - .a --1 - ' o p n 0- o Q' r"u A T? _o Ln d -7- Do co -_ N O ? W w NN -n N w O C? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 2011-06053 Katherine Thomas ; Richard Thomas; Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCED M 3129 Richard Thomas 1182 Oreenspring Road Newville, PA 17241 AND 13 North Corporation Street Newville, PA, 17241 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013 on 6/6/2012 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: 13 North Corporation Street, Newville, PA, 17241 The JUDON ENT under or pursuant to which your property is being sold is docketed to: No. 2011-06053 E Zucker, Goldberg & Ackerman, LLC XFP-152413 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Katherine Thomas ;Richard Thomas 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 TIIvIE 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 MU THIS PAPER TO YOUR LAWYER AT ONCE 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. '„ Zucker, Goldberg & Ackerman, LLC XFP-152413 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: (p'??o23? BY• Scott A. ck, Esquire; PA I.D. #55650 Kim y A. Bonner, Esquire; PAID. #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, Suits 101 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: OfCce@zuekergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. M Zucker, Goldberg & Ackerman, LLC XFP-152413 Exhibit "A" LEGAL DESCREMON ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEE MAN JR. AND CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST BY CORPORATION STREET, ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRETH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPTH OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, I7241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE. TAX MAP NO.: 27-20-1754-225. I- ruder. ('1010M. & Ackerman. 1.I.e XFP-152413 ;---Official LISP S use ONLY! -? -a u j I o N ?y In ?a o D 3 N Ns w so ?° a n ru C w mom" w o zS a 3 o m 3 ° a ? W ? J oM /4 N 16 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 2011-06053 Katherine Thomas ; Richard Thomas; Defendant(s). NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 13 North Corporation Street 1182 Greenspring Road Newville, PA 17241 Newville, PA 17241 COMMONWEALTH OF PENNSYLVANIA PA DEPT. OF REVENUE- INHERITANCE DEPARTMENT OF WELFARE TAX DIVISION P.O. Box 2675 Dept. 280601 Harrisburg, PA 17105 Harrisburg, PA 17128-0601 CUMBERLAND COUNTY TAX CLAIM CUMBERLAND COUNTY DOMESTIC BUREAU RELATIONS OFFICE Cumberland County Courthouse Domestic Relations Section One Courthouse Square 13 N. Hanover Street Carlisle, PA 17013 PO Box 320 Carlisle, PA 17013 MERS AS NOMINEE FOR ALLIED MORTGAGE GROUP, INC. PENNSYLVANIA DEPARTMENT OF PO Box 2026 REVENEUE, BUREAU OF COMPLIANCE Flint, MI 48501-2026 PO Box 280946 Harrisburg, PA 17128-0946 MERS AS NOMINEE FOR ALLIED MORTGAGE GROUP, INC. BUREAU OF COMPLIANCE 7 Bala Avenue, Suite 108 PO Box 280948 Bala Cynwyd, PA 19004 Harrisburg, PA 17128-0946 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 616/2012 at 10:00am, the following described real estate which Richard Thomas and Katherine Thomas, husband and wife 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: 13 North Corporation Street, Newville, PA 17241 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). Zucker, Goldberg & Ackerman, LLC XFP-152413 152413DIO04CO3212012PI The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank, N.A. Plaintiff VS. Katherine Thomas , et al I Defendant(s) at EX. NO. 2011-06053 in the amount of $84375.50 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 Sheriffs Sale or this Notice, you should contact your attorney as soon as possible. ZUCKER, GOLDBER ACKERMAN, LLC Dated: 3 ?3 BY: ?d? Scott Merick, Esquire; A I.D. #55650 Kim rly 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 301 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-152413 152413DI004C03212012P2 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AND BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. AND CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRETH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPTH OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE. TAX MAP NO.: 27-20-1754-225. ° page 1 of 5 NOTICE TO LIENHOLDERS UNITED STATES G POSTAL SERVICG This CartlAata of MaibK provWss widana that mai has been prauM.d to USPSe for mailni. This form may be I Flo% o 15-16M lummmmw F"wF Ravin • 12 01.15° j • 00 8 03 2012 EUW E 07092 and Inhmotbnel nw1L "°m' Scott A. Dietterick, Esquire 4 . :• c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 u Mountainside, NJ 07092 r?? f XFP-152413/sde TEAM C 2 ' T°' UNKNOWN TENANT OR TENANTS PostmerkHere A 13 North Corporation Street Nevwille, PA 17241 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 9 ?N 0 282039 UNITED STATES 0 1 FRwj 2 POST13L SERVICEe "E° I1 This Grtliate of Ma inp provides widens, that wag has bean presented to USPSe for m¦ilni. This form may b_ .....r ur wnwastlc I . end International malL From Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-152413/sde TEAM C COMMONWEALTH OF PENNSYLVANIA Postmark Here DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 .15° 3 2012 !07092 i 1 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Page 2 of 6 NOTICE TO LIENHOLDERS UNITED STATES POSTAL SOMICEs This Grtlfiwq of Mailry pre Ww evidence that mall has been presantedto USPSe for mallinp This form may and intermtbnal mail. From: CwwK A C..w..t.._ c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 0 2' 1.150 00 r'1812 2012 Ftr 07092 ?? O s CID e XFP-152413/sde TEAM C ".CUMBERLAND COUNTY TAX CLAIM BUREAU Posb rk Here Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9D65 Pawy HOWES ,,?? $ 0 UNITED STATES -15 0428 3 AP0 03 201 2 SERVICEe POSTAL 0 I IPCODE 0 7092 ThkGrtilics of YlftprwidesavkenaMatMail hubeen prawntedtoUSPS'forMailing. This form Mayon UMror°omnt. and lnternadonel mall. :':Y'• l "n"M Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-152413/sde TEAM C MERS AS NOMINEE FOR ALLIED MORTGAGE GROUP, INC. Park Here PO Box 2026 Flint, MI 48501-2026 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Page 3 of s NOTICE TO LIENHOLDERS ? r-z,?.r, r•..? 03 201 UNITED STATES ?' 02 a 2036 $PR01-160 V.?.POSMLSERVICF.e "IF YjpCODE 0 70 92 Thtr CartYkate of Mdhg prwalas widen Own: mail has be" paseMed to USPSa for malbW This form may be osad fordomestlc . . and imarneomw mad. "°n" Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC r 200 Sheffield Street, Suite 101 u; Mountainside, NJ 07092 XFP-152413/sde TEAM C T°t MERS AS NOMINEE FOR ALLIED MORTGAGE GROUP, INC. Postmarks 7 Bala Avenue, Suite 108 Bala Cynwyd, PA 19004 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 1 i E i b ? 'Ya UNITED STATES ? V POSTAL SERVICEe TM CertMfasa of MOft prwides evldanea flat mall has been pnwnted to LOW formallna. This form may he, used for domestic and Inpmatloral mad. "'rom Scott A. Dietterick, Esquire C Cl- a i nsatlr 411660 ?q2 38. APR03 2012 ,fLEOM ? CODE07092 N s J a¢ c/o Zucker, Goldberg & Ackerman, LLC s? 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-152413/sde TEAM C PENNSYLVANIA DEPARTMENT OF REVENEUE, BUREAU Postmark Here OF COMPLIANCE PO Box 280946 Harrisburg, PA 17128-0946 County of P.Q.: CUMBERLAND PS Form 3817, April 2OD7 PSN 7530.02-OOD-9065 1 ry Page 4 of 5 NOTICE TO LIENHOLDERS This CertlNcete of Ma ft pmvides evidence that matl has been presented to USPSe for maw. This form may be as and hnwratlonal natl. rfO1"` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 UNITED STATES Cer SER 0AM $01.150 POSTAL V 00 ?, APR03 2012 ZXOE 0 70 92 y f' XFP-152413/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 6 po`!n 0 I ? UNITED STATES 02 1M POSTAL SERVICEe Thb CwtVkvb of MNkrs provkes evidence that men has been presented to USPSe for maling. This form mw be used for domestk and insematbral mg . Scott A. Dietterick, Esquire w ?Qt c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-152413/sde TEAM C T°` PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Here Dept. 280601 Harrisburg, PA 17128-0601 Move" 1.150 03 2012 IE 07092 t i County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 v Page 5 of s NOTICE TO LIENHOLDERS UNITED STATES POSTAL SERVI.C& This Ce dRca a of Mallhr{ pr vWw evidence that rml has been prenntod to USPSa for malh4• This foni....-, .,. w... ,or oormstlc and InUmatlonal mail. Pram: Scott A, Dietterick, Esquire `" c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 w Mountainside, NJ 07092 XFP-152413/sde TEA 0OPO N p/ra1Fv now" 02 1M $ 01.160 000428203& APR03 2012 MAILMFZPCODE 07092 T°` UNKNOWN SPOUSE 1182 Greenspring Road Newville, PA 17241 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here 49 4 . o UNITED-STATES Q ? 000 28 2012 V..'POSMLSERVICG oM y?92 This Grtlriaab of NYllna prwhiee avldarca that not has been pmmntad to USPSa formailrs. This form may be vaw ror oomartle and lrtarmtloml rml. ''ara: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC Q, 200 Sheffield Street, Suite 101 \ Jam' Mountainside, NJ 07092 XFP-152413/sde TEAM C TO: BUREAU OF COMPLIANCE Postmark Here PO Box 280948 Harrisburg, PA 17128-0946 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 4 ?J Ci Sheriff ,._ . l r... . Jody S Smith ,.,? r. n w J I 4;.? 7 A 1 E. J Chief Deputy ?) Richard W Stewart :=hi LA 1;0 € i<I , Solicitor 4 Wells Fargo Bank, N.A. Case Number vs. i Richard Thomas (et al.) 2011-6053 SHERIFF'S RETURN OF SERVICE 03/20/2012 06:09 PM - Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action upon the property located at 13 North Corporation Street, Newville Borough, Newville, PA 17241, Cumberland County. 03/20/2012 05:28 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same t me personally handing a true copy to a person representing themselves to be the Defendant, to wit: Richard Thomas at 1182 Greenspring Road, North Newton Township, Newville, PA 17241, Cumberland Count 03/20/2012 06:09 PM - Deputy Valerie Weary, being duly sworn according to law, attempted service to the Defendant, to wit: Richard Thomas at 13 N. Corporation Street, Newville Borough, Newville, PA 17241. The addre$s was found to be vacant. 03/20/2012 05:28 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same iME personally handing a true copy to a person representing themselves to be richard thomas - spouse, who accepted as "Adult Person in Charge" for Katherine Thomas at 1182 Greenspring Road, North Newton Township, Newville, PA 17241, Cumberland County. 03/20/2012 06:09 PM - Deputy Valerie Weary, being duly sworn according to law, attempted service to the Defend nt, to wit: Katherine Thomas at 13 N. Corporation Street, Newville Borough, Newville, PA 17241 The add esa was found to be vacant. 06/06/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice h2 been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on June 06, 2012 at 10:( AM. He sold the same for the sum of $1.00 to Attorney Scott Dietterick, on behalf of Wells Fargo Bank N.A., being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $855.24 SO ANSWERS, July 12, 2012 RO rW R ANDERSON, SHERIFF qi?.to fd CWl- SO u Id- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs. Katherine Thomas ; Richard Thomas; CIVIL DIVISION NO.: 2011-06053 Execution No.: Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 13 North Corporation Street, Newville, PA 17241. 1. Name and Address of Owner(s) or Reputed Owner(s): RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WIFE 1182 Greenspring Road Newville, PA 17241 2. Name and Address of Defendant(s) in the Judgment: KATHERINE THOMAS 1182 Greenspring Road Newville, PA 17241 RICHARD THOMAS 1182 Greenspring Road Newville, PA 17241 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 Zucker. (?oldberg & Ackerman. 1_I_(- KI P-1>2•J1 11 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MERS AS NOMINEE FOR ALLIED MORTGAGE GROUP, INC. PO Box 2026 Flint, MI 48501-2026 AND 7 Bala Avenue, Suite 108 Bala Cynwyd, PA 19004 5. Name and Address of every other person who has any record lien on the CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 PENNSYLVANIA DEPARTMENT OF REVENEUE, BUREAU OF COMPLIANCE Department 280946 Harrisburg, PA 17128-0946 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 13 North Corporation Street Newville, PA 17241 /ucker. ;oldberg & ,Ackerman. 1.1 C' X111- I 5141 > UNKNOWN SPOUSE 1182 Greenspring Road Newville, PA 17241 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 GOLDS & AC AN, LLC Dated: ' a 3 BY: r/ Scott . Dietterick, quire; PA I.D. #55650 Kim rly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. 4202729 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, N7 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Locker. (.;oldberg & Ackerman. Ll_C XFP-152411 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. D CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAS BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GER -TH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A DEPT-I OF ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS .AND KATHERINE THOMAS, HUSBAND AND WI TAX MAP NO.: 27-20-1754-225. Zucker, (;oldbcrg & Ackcrrnan,I1.1,C \PP-1 > 413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION VS. Katherine Thomas ; Richard Thomas; NO.: 2011-06053 Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Katherine Thomas 1182 Greenspring Road Newville, PA 17241 AND 13 North Corporation Street Newville, PA, 17241 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberlan County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/6/2012 at 10:00am prevailin local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consistin of a statement of the measured boundaries of the property, together with a brief mention of th? 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: 13 North Corporation Street, Newville, PA, 17241 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2011-06053 Zucker, Goldberg & Ackerman, L c XFP-152413 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 v Dated: BY: Scott X. ietterick, Esquire; PA I.D. #55650 Ki erly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, XFP-152 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING AN: BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, M PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. A D CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST Y CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRE H M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A D ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS .AND KATHERINE THOMAS, HUSBAND AND WI TAX MAP NO.: 27-20-1754-225. OF Zucker. ( wldhcr?r &: Ackerm?I, I'll, \IP-152413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2011-06053 Katherine Thomas ; Richard Thomas; Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Richard Thomas 1182 Greenspring Road Newville, PA 17241 AND 13 North Corporation Street Newville, PA, 17241 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 6/6/2012 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: 13 North Corporation Street, Newville, PA, 17241 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2011-06053 Zucker, Goldberg & Ackerman, LLC XFP-152413 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Katherine Thomas ; Richard Thomas A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental corporate entities or agencies being entitled to receive part of the proceeds of the sale receiN and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalit. that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution the proceeds of sale in accordance with this schedule will, in fact, be made unless someo objects by filing exceptions to it, within ten (10) days of the date it is filed. Information abc the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. PROPERTY. THE It has been issued because there is a Judgment against you. It may cause your property 1 be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent yol property from being taken. A lawyer can advise you more specifically of these rights. If yc wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO O TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GE FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker, Goldberg & Ackerman, LLC XFP-152413 3. A petition or petitions raising the legal issues or rights mentioned in preceding paragraphs must be presented to the Court of Common Pleas of Cumber] County. The petition must be served on the attorney for the creditor or on the cred before presentation to the Court and a proposed order or rule must be attached to petition. If a specific return date is desired, such date must be obtained from the C1 Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carli PA 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBERG & ACKERMAN, LLC Dated: BY: Scott A. ietterick, Esquire; PA D.#55650 Kimb ly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-152413 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XFP-152413 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES SITUATE, LYING 7 BEING IN THE BOROUGH OF NEWVILLE IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, AND KNOWN AS 13 CORPORATION STREET, PARTICULARLY DESCRIBED AS FOLLOWS: BOUNDED ON THE NORTH BY LAND NOW OR FORMERLY OF RALPH C. LEHMAN JR. D CHARLOTTE L. LEHMAN AND NOW OR FORMERLY OF JEFFREY KOUGH; ON THE EAST BY CORPORATION STREET; ON THE SOUTH BY PROPERTY NOW OR FORMERLY OF GERRE TH M. MAINS AND MARY E. MAINS; AND ON THE WEST BY AN ALLEY. CONTAINING THIRTY (30) FEET FRONT ON SAID CORPORATION STREET, AND A ONE HUNDRED EIGHTY (180) FEET, MORE OR LESS, TO SAID ALLEY. HAVING THEREON ERECTED A TWO STORY HOUSE BEING KNOWN AND NUMBERED AS 13 NORTH CORPORATION STREET, NEWVILLE, PA, 17241. BEING THE SAME PREMISES WHICH TIMOTHY E. TOSTEN AND CINDY E. TOSTEN, HUSBAND AND WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED DATED DECEMBER 15, 2006 AND RECORDED DECEMBER 28, 2006 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 278, PAGE 782, GRANTED AND CONVEYED UNTO RICHARD THOMAS AND KATHERINE THOMAS, HUSBAND AND WI TAX MAP NO.: 27-20-1754-225. OF Zucker, Gnldber> X Ackerman, I LC Yl:? 1 C)411 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-6053 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 KATHERINE THOMAS, RICHARD THOMAS (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: $84,375.50 L.L.: $.50 Interest FROM 12/22/2011 TO DATE OF SALE - $1,564.79 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $237.00 Other Costs: Plaintiff Paid: Date: 2/28/12 David D. Quell, Prothonotary- (Seal) tDeputy REQUESTING PARTY: Name: KIMBERLY A. BONNER, 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. 89705 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hard and the seal of said Co at Carlisle, Pa. This 07 $ day of ---- 20 I' Q Prothonotai,y r?ga &Y& On March 12, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA, known and numbered 13 North Corporation Street, Newville, PA 17241 more fully described on Exhibit"A" filed with this writ and by this reference incorporated herein. Date: March 12, 2012 l By. ` e i For Claudia Brewbaker, Real Estate Coordinator rA Writ No. 2011-6053 Civil Term Wells Fargo Bank, N.A. vs. Katherine Thomas; Richard Thomas Atty.: Kimberly Bonner ALL THAT CERTAIN tract or par- cel of land and premises situate, lying and being in the Borough of Newville in the County of Cumberland and Commonwealth of Pennsylvania, and known as 13 Corporation Street, more particularly described as fol- lows: BOUNDED on the north by land now or formerly of Ralph C. Lehman Jr. and Charlotte L. Lehman and now or formerly of Jeffrey Kough; on the east by Corporation Street; on the south by property now or formerly of Gerreth M. Mains and Mary E. Mains; and on the west by an alley. CONTAINING thirty (30) feet front on said Corporation Street, and a depth of one hundred eighty (180) feet, more or less, to said alley. HAVING THEREON ERECTED a two story house being known and numbered as 13 North Corporation Street, Newville, PA, 17241. BEING the same premises which Timothy E. Tosten and Cindy E. Tosten, husband and wife, as ten- ants by the entireties, by deed dated December 15, 2006 and recorded December 28, 2006 in and for Cum- berland County, Pennsylvania, in Deed Book Volume 278, Page 782, granted and conveyed unto Richard Thomas and Katherine Thomas, husband and wife. TAX MAP NO.: 27-20-1754-225. r" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law,lournal, of the County an( State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Lai Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesa 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 regularl; 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, 27, May 4, and May 11, 2012 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 subjec 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. Lis Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this d of May, 2012 r Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify the Sheriff's Deed in which Wells Fargo Bank, N.A. is the grantee the same having been sold to grantee on the 6 day of June A.D., 2012, under and by virtue of a writ Execution issued on the 28 day of I February, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2011 N 6053, at the suit of Wells Fargo Bank, N. A- against Katherine Thomas and Richard Thomas is duly recorded as Instrument Number 201221281. IN TESTIMONY WHEREOF, I havreunto set r an eal of said office this A.D. .4 j ber hand of Remit w of County, Carus PA My CarmM Bores the Fret Monday d Jan. 201 Dii-6053 *C1W 1181:8M. Banty?. VS 0i""e $$; Rlahard Aft. KlmberlY Bonner All That Certain %ct Or Parcel of Land And hmi,. the Borough Of a te, Lying And Being in ewville in The County ?Cumbetlandf NAnd 0fpennsylvania,AndCo. oMA. lth Co 13 As UM more panc?n?larly r Unded On The Nom Or Former BY Land Now And Chart O?R?alph C Lehman Jr. Formerly Of le ?n And Now or By CotporaeKt° The t Pro , on The th Maw Andes Or Formerly Of Gerre M. West i d E' Mme; And On The Conta Corpa aq (30) Feet Front On Said k And A Eigh To Said AUey. tY (180) Feet, More 0, 1 House Thereon Erect A'Rvo Story 13 Cho K°ONn And Nmnbered As No pa, 17241, rpora6°n Street, Newv?e Be' ET 8 The Same premy d Which Timothy And Wife An Cindy E. Torten, Husband By ts The Fn1ireties R Dated Ike ?5 2006 And Cumb? l Dumber 28'2006 In And For In Deed Boo me 2 u71, page And Conveyed Unto )?t?e 782, Granted Omas Tax Ma I rvo.: 27-201 usband And Wife?d The Patriot-dews Co. 2020 Technialogy Pkwy Suite i00 Mechanicsburg, PA 17050 Inquiries - 717-255-82'13 CIUMBERLAND CO. SHERIFFS OFFICE UMBER AND COUNTY COURT HOUSE CARLISLE PA 17013 i e atnot ? ews Now yoL 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 Holly Blair beirci duly sworn according to law, deposes and says. That she is a Staff Accountant 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 busiress at 2020 Technology Pkwy.. S.aite 300, in the Township of Hampden. County of Cumberland, State of Pennsylvania, owner and publisher of The Patric: t--News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City. i-ounty 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 reither she nor said Company is interested 'n 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 fo, the Recording of Deeds in and for said Cot my of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/27/12 05/04/12 { 05/11/12 Sworn to and subscribed before me t[} s 22 day of May, 2012 A D Notary Public _ COMMQNWEALI:N OF PkNN5YLI A ?? ?_? 5i?e*r??e?. ?>nacan?:, ?h:?rary i?wrrtlr l.OVrr?f 7<l;rrr>p 7av? 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