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Home My WebLink About11-7187.,% FILED-OFFICE K?- 4 K PROTHONOTAW L1211 SEP 16 All 9: '--,1 "UMOERLANG COUNT`r' PENNSYLVANIA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. 1 Home Campus Des Moines, Iowa 50328 =iLL-OFFICE T i"`ROTN !NO R 70' 1 SEP A 10: 215 CUMBERLAP UNIT`` PENNS V 'N1 Cumberland County Court of Common P for Plaintiff Number 11-110 N V. Sandra Staub aka Sandra A. Staub 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 CIVIL ACTIONIMORTGAGE FORECLOSURE (AWL ?? IySSgS? 6q 814 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 A Le han demandado a usted defenderse de estas demand siguientes, usted tiene veinti de la fecha de la demanda y asentar una comparencia es abogado y entregar a la c defensas o sus objeciones a su persona. Sea avisado qui corte tomara medidas y pue, contra suya sin previo aviso corte puede decidir a favor que usted cumpla con tod demanda. Usted puede perd u otros derechos imt)ortante USTED LE DEBE SU ABOGADO INMEDIA] TIENE A UN ABOGADO, ' OFICINA EXPUSO ABA, PUEDE PROPORCIONAI ACERCA DE EMPLEAR E SI USTED NO Pl PARA EMPLEAR UN AB( PUEDE SER CAPAZ DE PI INFORMACION ACERC4 QUE PUEDEN OFREC LEGALES A PERSONA; HONORARIO REDU1 HONORARIO. Cumberland County Bar As 32 South Bedford Street Carlisle, Pennsylvania 1701 (800) 990-9108 n la corte. Si usted quiere s ex-puestas en las paginas (20) dias de plazo al partir a notificacion. Hace falta rita o en persona o con un )rte en forma escrita sus as demandas en contra de si usted no se defiende, la e continuar la demanda en notificacion. Ademas, la lel demandante y requiere s las provisiones de esta r dinero o sus propiedades para usted. 'OMAR ESTE PAPEL A kMENTE. SI USTED NO A A O TELEFONEA LA D. ESTA OFICINA LO CON INFORMATION UN ABOGADO. EDE PROPORCIONAR ,iADO, ESTA OFICINA OPORCIONARLO CON DE LAS AGENCIAS ;R LOS SERVICIOS ELEGIBLES EN UN IDO NI NINGUN ation CIVIL ACTIONIMORTGAGE FORECLOSURE 1. Plaintiff is Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A., d ly organized and doing business at the above-captioned address. 2. The Defendant is Sandra Staub aka Sandra A. Staub, who is them rtgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 5 1 West Simpson Street, Mechanicsburg, Pennsylvania 17055. 3. On October 19, 2006, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Wachovia Bank, N.A. which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1972, Page 4235, such Mortgage being incorporated herein by reference by virtue of Rule 1019(g) Pa. R. C. P. 4. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 531 West Simpson Street, Mechanicsburg, Pennsylvania 17055. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due April 1, 2011 and each month thereafter are due and unpaid, and by the 'terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $ 117,383.46 Interest through September 10, 2011 $ 3,667.38 (Plus $21.32 per diem thereafter) Attorney's Fee $ 1,300.00 Late Charges $ 79.36 Appraisals $ 127.50 GRAND TOTAL $ 122,557.70 7. Notice of Intention to Foreclose as required by Act 6 of 1974 (4J P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 A Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant irk the sum of $122,557.70, together with interest at the rate of $21.32 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISB F It7YWAY,P.C. BY: VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for tl?ie Plaintiff in the within action, and that he/she is authorized to make this verification and that the f6regoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of ) 8 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE, W Q,9dNWAY,P.C. B uire Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. v. Sandra Staub aka Sandra A. Staub I • G2944554 SCHEDULE A ALL THAT CERTAIN PROPERTY SITUATED IN THE BOROUGH OF MECHANICSBURG - WARD 5, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA BEING MORE PARTICULARLY DESCRIBED IN A DEED RECORDED IN BOOK 259 AT PAGE 4005 AMONG THE LAND F?IECORDS OF THE COUNTY SET FORTH ABOVE. PARCEL ID: 24-0785-0094-0000000-20 KNOWN AS: 531 W SIMPSON ST I Certify this to be recorded Cn Cumberland County 0-c" ? A (Cc0r-!cr of Dc ds 8K 1972PG4242 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?gttittitp gt t?r?t?6e?fy?fG C 1 ¢FFi,E -'?FTHE =-EQIFF I j: Jody S Smith Chief Deputy Richard W Stewart Solicitor 2Q 1 i SEP 26 PM 2: GUMBERLAhU PENNSYi_VANIP Wells Fargo Bank, N.A. i vs. Sandra A. Staub Case Number 2011-7187 SHERIFF'S RETURN OF SERVICE 09/19/2011 09:03 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 19, 2011 at 2103 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sandra A. Staub, by making known unto herself personally, at 531 W. Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.00 September 22, 2011 DENT S FRY, DEPUPIK SO ANSWERS, RON R ANDERSON, SHERIFF '- t-ourdySU'te Shellff Teleost. Iir;:. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-7187 civil ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: 4:J Co CD ' M 1:7 F ,,7, v -+ 7D rri C7a N CD 00 I CD . X;> , 9 - C Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $ 122,557.70 Interest from 09/11/11 to 10/25/11 $ 959.40 Total $ 123,517.10 rgaret airo, Esquire Attorney or Plaintiff AND NOW, this J'Coz* day of , 2011, Judgment is entered in favor of Plaintiff, Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A., and against Defendant, Sandra Staub aka Sandra A. Staub, and damages are assessed in the amount of $123,517.10, plus interest and costs. BY THE PROTHONOTARY: 414.oo POATT4 ?r ?5as? ?,#ac??5ya 1?laFlee I?la?e! McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-7187 civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendant, Sandra Staub aka Sandra A. Staub, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Sandra Staub aka Sandra A. Staub, is over eighteen (18) years of age, and reside as follows: Sandra Staub aka Sandra A. Staub 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 SWORN AND SUBS BEFOP)A MHil OF i 4:11 _.' IOTARY PUBLIC// 0 M M ? N'EA 7 -' C F 4ANi? Barbara J. hlcl ,er- Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EKPIRES JAN. 12, 2014 argar Gairo, Esquire Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-7187 civil AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Sandra Staub aka Sandra A. Staub 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 SWORN AND SUBS BEFO ME THM AY OF ?W, = 201,h 1 "U FARg<__ 7_ 8arbard J. Moyer_ Votary Public C4 Of Philadelphia, Philadelphia Courrty My COMMISSION EXPIRES JAN.12, 20141 Margare afro, Esquire Attorne for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 11-7187 civil CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A". SWORN AND BEFOJrI? OF AL NC3 T,44 t I ,w E3 Barbara I Mover- Notary Public City of Philac!iFhin, Philadelphia County MY COMMISSION! EXPIRES JAN. 12, 2014 M rgaret afro, Esquire Attorney or Plaintiff VERIFICATION The undersigned attorney hereby certifies that she is the Attorney for the Plaintiff in the within action, and that she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. A M rgarYo, Esquire Attorneaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS 2 Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary October 11, 2011 To: Sandra Staub aka Sandra A. Staub 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 Wells Fargo Bank, N.A. s/i/i/t Wachovia Cumberland County Bank, N.A. Court of Common Pleas vs. Sandra Staub aka Sandra A. Staub Number 11-7187 Civil NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FIE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT wTTHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOUMAYLOSEYOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROV IDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O POR ABOOADO Y PORNO HABER RADICADO POR ESCRTTO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMUI.ADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECEK USTED EN CORTE U OI R PREUBA ALOUNA, DTCTAR SENTENCIAEN SUCONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO TNMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OncwA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON WORMAC16N ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON TNFORMACON ACERCA DE LAS AGENCIES QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON IIONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 BY: Attorneys for Plaintiff N.", TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE ANDREW L. MARKOWI TZ, ESQUIRE CHRISTINE L. GRAHAM, ESQUIRE emm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Sandra Staub aka Sandra A. Staub 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 11-7187 civil NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default .- Money Judgment - Judgment in Replevin - Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway P.C. at (215) 790-1010. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-7187 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. S/I/I/T WACHOVIA BANK, N.A. Plaintiff (s) From SANDRA STAUB AKA SANDRA A. STRAUB (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: $123,517.10 Interest FROM 10/26/11 $2,720.20 AT $20.30 Atty's Comm: % Atty Paid: $170.50 Plaintiff Paid: Date: 11/23/11 L.L.: $.50 Due Prothy: $2.00 Other Costs: (Sea]) REQUESTING PARTY: Name: ANDREW L. MARKOWITZ, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 28009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION FILE NO.: 11-7187 civil Civil Term Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. V. AMOUNT DUE: $123,517.10 Sandra. Staub aka Sandra A. Staub INTEREST: from 10/26/11 µ- $2,720.20 at $20.30 `-Yr ATTY'S COMM.: COSTS:r TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or..accQiW 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 or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 531 west Simpson Street Mechanicsburg Pennsylvania 17055 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: November 16, 2011 Signature: re Print Name: Andrew L. Markowitz, EsINWAY Firm: MCCABE, WEISBERG AND C OkA' M 35.00 C6F () a • 06 41 1 1 14. to u It a&) 99I 1?0• al? Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 28009 %4k a .ooh- . . SO L[. C Ic it ? SLr 3(0-) IlJr? k ? saej LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Borough of Mechanicsburg, County of Cumberland, and State of Pennsylvania, as follows: BEING Lot No. 1 on the Plan of Lots known as Point Comfort, laid out for George B. and Minnie C. Vogelsong by Clark A. Bryan, C.E., August, 1924, and recorded in the Recorder's Office in and for said County of Cumberland in Plan Book 2, Page 36. HAVING THEREON erected a dwelling commonly known as 531 W. SIMPSON STREET, Mechanicsburg, Pennsylvania. The above described lot of ground is granted and conveyed subject to the restriction that no buildings shall be erected thereon within twenty (20) feet of the front line of said lot. PREMISES: 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055. BEING the same premises which THOMAS C. KIKER AND BARBARA J. KIKER, HUSBAND AND WIFE by deed dated October 7, 2003 and recorded October 9, 2003 in the office of the Recorder in and for Cumberland County in Deed Book 259, Page 4005, granted and conveyed to Sandra A. Staub, single, in fee. TAX MAP PARCEL NUMBER: 20-24-0785-094 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant 1 R p . o >, fig.. V!, CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 11-7187 civil AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owner or Reputed Owner Name Sandra Staub aka Sandra A. Staub Address 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 2. Name and address of Defendant in the judgment: Name Sandra Staub aka Sandra A. Staub Address 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4 5 Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Address Wachovia Bank, National Association 301 South College Street, VA 0343 Charlotte, North Carolina 28288 Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 531 west Simpson Street Mechanicsburg, Pennsylvania 17055 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name None Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. November 16, 2011 Andrew L. Markowitz,-equire DATE Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate in the Borough of Mechanicsburg, County of Cumberland, and State of Pennsylvania, as follows: BEING Lot No. 1 on the Plan of Lots known as Point Comfort, laid out for George B. and Minnie C. Vogelsong by Clark A. Bryan, C.E., August, 1924, and recorded in the Recorder's Office in and for said County of Cumberland in Plan Book 2, Page 36. HAVING THEREON erected a dwelling commonly known as 531 W. SIMPSON STREET, Mechanicsburg, Pennsylvania. The above described lot of ground is granted and conveyed subject to the restriction that no buildings shall be erected thereon within twenty (20) feet of the front line of said lot. PREMISES: 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055. BEING the same premises which THOMAS C. KIKER AND BARBARA J. KIKER, HUSBAND AND WIFE by deed dated October 7, 2003 and recorded October 9, 2003 in the office of the Recorder in and for Cumberland County in Deed Book 259, Page 4005, granted and conveyed to Sandra A. Staub, single, in fee. TAX MAP PARCEL NUMBER: 20-24-0785-094 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-7187 civil AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. C1 a The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Sandra Staub aka Sandra A. Staub 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 SWORN AND SUBS BEFON4 T S AW OF / ?/0 2011/ NOTARY PUBLIC , , i !d OT,(- ' J. uuic .Barbara City of Philadeil l-,", ut14 MY COMMISSI01 E°PIn?Sif?N, i2, 2014 Andrew L. N"owit; Attorney for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 -? '-j (215) 790-1010 CIVIL ACTION LAW Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Sandra Staub aka Sandra A. Staub Number 11-7187 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Sandra Staub aka Sandra A. Staub 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 Your house (real estate) at 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055 is scheduled to be sold at Sheriffs Sale on March 7, 2012 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the courtjudgment of $123,517.10 obtained by Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET CAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant Attorney for Plaintiff CUMBERLAND COUNTY L COURT OF COMMON PLEAS v. Number 11-7187 civil C'?+J w N AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 17th day of January, 2012, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRI Dr/ BEFORE THIS WDAY OF 20d NOTARY PUBLIC MCCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff By: A'a r Auze'e" TE NCE . McCABE, ESQUIRE - ID # 16496 MARC S. W ISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 11-7187 civil AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Sandra Staub aka Sandra A. Staub 2 3 Address 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 Name and address of Defendant in the judgment: Name Sandra Staub aka Sandra A. Staub Address 531 West Simpson Street Mechanicsburg, Pennsylvania 17055 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Wachovia Bank, National Association 301 South College Street, VA 0343 Charlotte, North Carolina 28288 5. Name and address of every other person who has any record lien on the property: Name Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Address 531 west Simpson Street Mechanicsburg, Pennsylvania 17055 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Arty General of the United States Name and address of Attorney of record: Name P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 31 1 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. McCABE, WEISBERG & CONWAY, P.C. January 17, 2012 Attorneys for Plaintiff DATE By: TERRENCE . McCABE, ESQUIRE MARC S. W ISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. Plaintiff V. Sandra Staub aka Sandra A. Staub Defendant DATE: January 17, 2012 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 11-7187 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Sandra Staub aka Sandra A. Staub PROPERTY: 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on March 7, 2012 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. r 60 ?? D\ U A W N ?+ ° d A C CT y WO C T S m w ? .dzF v a ? 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O n? a?Nw Av:o?Pa b ?C? y ..• y O .7 ?kiCL = ona O0 o a F n ooooon 3 O-n a m 0 o 0 o o _y 7?7o?z m 3 ? ao p $ rn ? o a ? w n o P t fD pS v aY r W ?? y O r Z A G a? A C/y ? 7 h A b n A r N +'S 4 A ? < 'x G ? ^0 Ai p m A m Nxc ?Oc?3 ^ m ?`f'? A? ?T?G ? ddnS. ?•Lv,P+ a?Q cn t Q rp??7? ? - •+? R ?OtOK? "" r?' A y ??rxy?v, ""d ? ?9 O i e t r 7 to KY n ? ? ? og : ?Y N cAO <° < Nye ro o e c .t :2 W W a au c? ? ? O c%t W A ' R n a p .f+ a C O f? rNy N ..• o a A n fit ? ?n O D. IQ - '2t ,,rpa '* R O G v n r .+s G ¢ O W n+ 00 L d X - •,A A ook D CA two W ? 'r '-? y K ^t < ^S. r O -• n O a, d fl ? w G ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~ Ronny RAnderson - ', ' ~-, Sheriff tr at ~u~6r m~. r~~ ~ r; 3 s 3~~,'a i l.A~ , ~'~ Jody S Smith Chief Deputy Richard W Stewart SOIICItOI' ~~un r~'~~'0 ~ f r. ~~ ~ ~rz ,~ . f,, 4FFi4E ;,F TAE 9N~RIFF Wells Fargo Bank, N.A. Case Number vs. Sandra A. Staub 2011-7187 SHERIFF'S RETURN OF SERVICE 01/05/2012 03:45 PM -Deputy Shawn Gutshall, being duly sworn according to law, states service was performed !: pasting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action upon the property located at 531 West Simpson Street, Mechanicsburg, Cumberland County, PA 1705: 01/06/2012 Deputy Michael Garrick, being duly sworn according to law, attempted service to the Defendant, to wit: Sandra A. Staub at 531 W. Simpson Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. The address was found to be vacant. Per the Mechanicsburg Postmaster mail is delivered to this address. 03/01/2012 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 5/2/2012 03/26/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed" per letter of instruction from Attorney. SHERIFF COST: $2,209.18 August 17, 2012 jc) CeuntySuite Sheriff, Telecspft, fnc. SO ANSWERS, t~-• Ctr RON R ANDF SHERIFF •.57,~ l.L~d ~'~'~~> ~ ~~ ~~ 1 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUII2E - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. McQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LaMANNA, ESQUIRE - ID # 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215 790-1010 Wells Fargo Bank, N.A. s/i/i!t Wachovia Bank, N.A. Plaintiff v. Sandra Staub aka Sandra A. Staub Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 11-7187 civil AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information conce the real property located at: 531 west Simpson Street, Mechanicsbwg, Pennsylvania 17055, as of the date the Fraecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name 2. 3. Sandra Staub aka Sandra A. Staub Address 531 West Simpson Street Mechanicsbwg, Pennsylvania 17055 Name and address of Defendant in the judgment: Name Sandra Staub aka Sandra A. Staub Address 531 West Simpson Street Mechanicsbwg, Pennsylvania 17055 Name and last known address of every judgment creditor whose judgment is a record lien on real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein Wachovia Bank, National Association 301 South College Street, VA 0343 Chazlotte, North Cazolina 28288 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any in the property which may be affected by the sale: Name Tenants/Occupants Address 531 west Simpson Street Mechanicsburg, Pennsylvania 17055 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfaze TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richazd 110 North 8`~ Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Squaze Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff s Sales United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal enlue, Ste. 311 235 North Was~gton Scranton, PA 18503 and gi Courthouse Harrisburg Federal Building 228 Walnut Street, Ste. 220 Iarrisburg, pA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8 Name and address of Attorney of record: Address Name None ersonal lrnow ed I verify that the statements made in this Affidavit are true and correct to the best of my p ies of 18 Pa. .S• or information and belief. I understand that false statements herein are made subject to the penalt Section 4904 relating to unsworn falsification to authorities. /~ November 16 2011 Andrew I.. Markowitz,' Attorney for Plaintiff DATE 1 ~ LEGA~:DLS~II~N ALL THAT CERTAIN lot of ground situate m the g~$'df Mechanicsburg, County of Cumberland, and State Pennsylvania, as follows: BEING Lot No. 1 on the Plan of Lots known as Point Comfort, laid out for George B. and Minnie C. Vogelsong 1 Clark A. Bryan, C.E., August, 1924, and recorded in the Recorder's Office in and for said County of Cumberland Plan Book 2, Page 36. HAVING THEREON erected a dwelling commonly known as 531 W. SII~SPSON STREET, Mechanicsburg, Pennsylvania. The above described lot of ground is granted and conveyed subject to the restriction that no buildings shall be ere thereon within twenty (20) feet of the front line of said lot. PREMISES: 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055. BEING the same premises which THOMAS C. KIKER AND BARBARA J• KIKER, HUSBAND AND ViTIFE by deed dated October 7, 2003 and recorded October 9, 2003 in the office of the Record ~ ~and~for Cinnberland County in Deed Book 259, Page 4005, granted and conveyed to Sandra A. Staub, singl , TAX MAP PARCEL NUMBER: 20-24-0785-094 WRIT OF EXECUTION and/or ATTACHIV><ENT COMMONWEALTH OF PENNSYLVAI\IA) NO 11-7187 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, Y.A. S/I/I/T WACHOVIA BANK, N.A. Plaintiff (s) From SANDRA STAUB AKA SANDRA A. ST~AUlB (1) You are directed to levy upon the property of the defendant (s)a:~d 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: $123,517.10 Interest FROM 10/26/11 $2,720.20 AT $20.30 L.L.: $.50 Atty's Comm: Atty Paid: $170.50 Plaintiff Paid: Date: 11/23/11 (Seal) REQUESTING PARTY: Name: ANDREW L. MARKOWITZ, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 28009 Due Prothy: $2.00 Other Costs: T David D. B 11, Prothonotary By: Deputy TRUE COPY FROM RECO to Testimony whereof, 1 here unto set r and the al of said Court at Carlisle, f This ~ day of._, 20 (~PrRtt tD v hand On November 2 8, .2011 the the levied. npan the defendant's .interest in the real .property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 531 East Simpson Street, Mechanicsba~rg,: more fully described on Exhibit "~„fled. vv~ ~s Wit- ~ this re~ee inGOrpora~ec} herein. Date November 28, 201 l y: cae---, ~~~ Reel Estee Coordinator i ~t ~8 b 8 Z ,10N i l~Z M CUMBERLAND LAW JOURNAL Wsit xo. 2011-9187 Civil Term Wells Fargo Bank, N.A. s/i/i/t Wachovia Bank, N.A. vs. Sandra Staub a/k/a Sandra A. Staub Atty.: Terrence McCabe ALL THAT CERTAIN lot of ground situate in the Borough of Mechanics- burg, County of Cumberland, and State of Pennsylvania, as follows: BEING Lot No. 1 on the Plan of Lots known as Point Comfort, laid out for George B. and Minnie C. Vogelsong by Clark A. Bryan, CE., August, 1924, and recarded in the Recorder's Office in and for said County of Cumberland in Plan Book 2, Page 36. HAVING THEREON erected a dwelling commonly known as 531 W. SIMPSON STREET, Mechanicsburg, Pennsylvania. The above described lot of ground is granted and conveyed subject to the restriction that no buildings shall be erected thereon within twenty (20) feet of the front line of said lot. PREMISES: 531 west Simpson Street, Mechanicsburg, Pennsylvania 17055. BEING the same premises which THOMAS C. HIKER AND BARBARA J, HIKER, HUSBAND AND WIFE by deed dated October 7, 2003 and re- carded October 9, 2003 in the office of the Recorder in and far Cumberland County in Deed Book 259, Page 4005, granted and conveyed to Sandra A. Staub, single, in fee. TAX MAP PARCEL NUMBER: 20- 24-0785-094. 76 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County ani State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland La` Journal, a legal periodical published in the Borough of Carlisle in the County and State afores» 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 regulazl; issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz editions and issues of the said Cumberland Law Journal on the following dates, 27, February 3, and February 10, 2012 Affiant furkher deposes that he is authorized to verify this statement by the Cuml Law Journal, a legal periodical of general circulation, and that he is not interested in the matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and chazacter of publication aze true. isa Marie Coyne, E ' or SWORN TO AND SUBSCRIBED before me this 10 da of February, 2012 Notary .~_ NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My CommKaion Expires Apr 28, 2011 ~i i Tlae Patriot-News Co. 2020 Technology Pkwy ,Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the ~atriot~ NOw yo 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 Blain, being duly sworn according to law, deposes and says: Views ~ know 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 business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and tate aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 1 th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she n r said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this tatement 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 tatement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted se erally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Record ng of Deeds in and for said County of Dauphin in Miscellaneous Book "M°, Volume 14, Page 317. PUBLICATION COPY l This ad ran on the date(s) shown i i of February, 2012 A. D. ~~~ ~. ~~~.~ V SFie-r(e 1. ~M ~ ~n'~'' - ~'-' r I'10~r 01/27/12 02!03/12 02/10/12 2011-7187 Clvll Term Wells Fargo Bank, N.A. s!1/I/t Wachovla Bank, N.A. VS Sandra Staub a/k/a Sandra A. Staub Atty. Terrence McCabe ALL THAT CERTAIN lot of ground situate in the Borough of Mechanicsburg, County of Cumberland, and State of Pennsylvania, as follows: BEING Lot No. l on the Plan of Lots mown as Point Comfort, laid out for urge B. and Minnie C. Vogelsong by ~, irk A. Bryan, CE, August, 1924, and r arded in the Recorder's Office in and f Said County of Cumberland in Plan k 2, Page 36. VING THEREON erected a dwelling commonly known as 531 W. SiMPSON STREET, Mechanicsburg, Pennsylvania. The above described lot of ground is granted and conveyed subject to the restriction that no buildings shall be erected t'aereon within twenty (20) feet of the front line of said lot. PREMISES: 531 west Simpson Street, Mr '~anicsburg, Pennsylvania 17055. Bf ~ [he same premises which Tl ,4AS C. KIKER AND BARBARA J. h .KER, HUSBAND AND WIFE by deed dated October 7, 2003 and recorded October 9, 2003 in the office of the Recorder in and for Cumberland County in Deed Book 259, Page 4005, granted and conveyed to Sandra A. Staub, single, in fee. TAX MAP PARCEL NUMBER: 20-24- 0785-094