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11-7208
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, Plaintiff, vs. JOHN E. RIFE, JR. Defendant. TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULTJUDGMENT 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: 1420 3rd Street Enola. PA 17025 I HE BY ERT T E LOCATION OF THE .AL EST T E Y THIS LIEN IS 420 3 5 ree I P 7 25 Muni a1 v: Ea P sb r ATTQRN FOR PLAINTIFF ATTY IL NO.: XFP 153326 CIVIL DIVISION NO.: TYPE OF PLEADING CIVIL ACTION - COMPLAINT IN MORTGAGE FO ECLOSU FILED ON BEHALF OE: COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG I& ACKERMAN, LLC Scott A. Dietterick, El' quire Pa. I.D. #55650 Kimberly A. Bonner, ' Esquire Pa. I.D. #89705 Joel A. Ackerman, Es quire Pa I.D. #202729 Ashleigh Levy Marin? Esquire Pa I.D. #306799 c "C} .mow C)J 200 Sheffield Street 101 0 M 2 Mountainside, NJ 092 (908) 233-8500 (908) 233-1390 FAX C-:' office@zuckergoldb rg.com File No.: XFP- 15332 /swo N r rn C j r:) -rf cx? `--5 c-) 1 9? oo f/d IV-7 Zuckeru Goldberg & Ackerman, LLC XFP-153326 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 TFIEREOF, 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 T EREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIFiTY (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) IDAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. VEN 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. FURTHERMO E, 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 EBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD AT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFOR S (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INF RMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS A D 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-153326 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, CIVIL DIVISION Plaintiff, NO.: VS. • II JOHN E. RIFE, JR. Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice re 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," ithout 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 TAE 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 GE LEGAL HELP. 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 Coun y Bar Association 32 S. Bedf rd Street Carlisle, A 17013 Phone (80 990-9108 (717 249-3166 ZuckerN Goldberg & Ackerman, LLC XFP-153326 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, Plaintiff, vs. JOHN E. RIFE, JR. Defendant. CIVIL DIVISION NO.. AVISO LISTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse a las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro d los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personal ente o por medio de un abogado una comparecencia escrita y redicando en la Corte por escrito sus de ensas de, y objeciones a, los demandas presentadas aqui en contra suya. Se le advierte de que si us ed falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fall por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio soli itado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Uste puede perder dinero 0 propiedad u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A LINO, LLAME A VAYA A LA SIGUEINTE O ICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland Coun 32 S. Bedford Street 32 S. Bedf Carlisle, PA 17013 Carlisle, I Phone (800) 990-9108 Phone (80C (717) 249-3166 (717 :y Bar Association )rd Street A 17013 990-9108 249-3166 Goldberg & Ackerman, LLC XFP-153326 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, Plaintiff, CIVIL DIVISION NO.. vs. JOHN E. RIFE, JR. Defendant. And now comes Wells Fargo Bank, NA, by its attorneys, Zucker, Goldborg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, NA, (hereinafter "plaintiff") h?ving its principal place of business at 3476 STATEVIEW BLVD., MAC # X7801-013, FT. MILL, SC 29715.11. 2. The Defendant, John E. Rife, Jr., is an individual whose last known address is 1420 3rd Street, Enola, PA 17025. 3. On or about January 25, 2008, John E. Rife Jr. executed a Not4 in favor of Wells Fargo Bank, N.A. in the original principal amount of $101,500.00. 4. On or about January 25, 2008, as security for payment of the Rife Jr., a married man made, executed and delivered to Wells Fargo Bank, original principal amount of $101,500.00 on the premises hereinafter descrit being recorded in the Office of the Recorder of Deeds of Cumberland Coun. Instrument #200803737. A true and correct copy of said Mortgage contain premises subject to said Mortgage is marked Exhibit "A", attached hereto and 5. John E. Rife, Jr., married man is the record and real mortgaged premises. 6. Defendant is in default under the terms of the aforesaid inter alia, failure to pay the monthly installments of principal and interest wF 7. On or about March 6, 2011, Defendant was mailed a Notice Mortgage, in compliance with Act 6 of 1974, 41 P.S. §101, et seq. Zucker, foresaid Note, John E. A. a Mortgage in the i, with said Mortgage on February 6, 2008, a description of the ade a part hereof. ier of the aforesaid rtgage and Note for, due. Intention to Foreclose rg & Ackerman, LLC XFP-153326 8. Plaintiff was not required to send Defendant(s) written Notice pursuant to 35 P.S. §1680.403 (c) (Homeowners' Emergency Mortgage Assistance Act' of 1983, - Act 91 of 1983), prior to commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the Natiional Housing Act (12 U.S.C. §§1707 - 1715(z) - 18) [35 P.S. §1680.401(a)(3).]. 9. The amount due and owing Plaintiff by Defendant is as follow l: Principal $97,000.71 Interest to 06/14/2011 $3,247.20 Late Charges $ 128.84 Corporate Advance $20.00 Escrow $ 360.70 Inspection Fee $ 60.00 Total $100,817.45 plus interest on the principal sum ($97,000.71) from June 14, 2011 at the d?ily interest of $16.61, plus additional late charges, and costs (including additional escrow advance), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. WHEREFORE Plaintiff demands judgment in mortgage foreclosure for the amount due of $100,817.45, with interest thereon at the daily interest of $16.61 from June 1? 1 2011 plus additional late charges, and costs (including additional escrow advances), additional at?orneys' fees and costs and for foreclosure and sale of the mortgaged premises. Zucker, I oldberg & Ackerman, LLC XFP-153326 ZUCKER, GO BY: JAU Dated: I1/2011 Scott A. D erick, Esquire; P 55650 Kimberly/A. onner, Esquire; PAL #89705 Joel A. Ac erman, Esquire; PA I.D. # 02729 Ashleigh Levy Marin, Esquire; PA I.DJ. #306799 Attorneys for Plaintiff XFP-153326/swo 200 Sheffield Street Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAXI Email: Office@zuckergoldberg.com'p THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-153326 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-153326 • - • ?cht*bi**AAF -1 Prepared By: MRTTECK A. ZENXCK WELLS FARGO SANK, N. A. 2301 RZXMXDS DR STE 260 RALEIGH, NC 27607 Return To: HELLS FARGO BANK, N. A. 1000 SLUE GENTIAN R0AD ZAG1AH, M 55121-1663 Parcel Number: 45171044018 Premises: 420 3RD ST ENOLA ISpce Above This Lin For Recording Data] ' PHA Can No. Commonwealth of Pennsylvania MORTGAGE 441-81555 7-703 THIS MORTGAGE ("Security Instrument") is given on JA?11RY 2S, 2006 The Mortgagor is JOHN $ . RIY'i JR A lH1RRI? MAN ("Borrower"). This Security Instrument is given tD WELLS aARGO BANK, N.A. which is organized and existing under the laws of THE UNITED STATES , and whose address is P. O. R= 5137 DES (DINES, IA 50306-5137 ("Leader"). Borrower owes L.ende jthe principal sum of ONE HUNDRED ONE THOUSAND FIVE HUNDRSD AM 50/100 Dollars (U.S. $ ***10> 300.00 ). MMFL 00642 (PAFM) Rev 4/44/4008 FHA Pennsyivsnin Mortgage - 41% ?riR(PA) t06oq VaP moraw SOW", Inc. _ w ?(? Pqp 1 do InltldN.. This debt is evidenced by Borrowces note dated the same date as this Pecurity Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on nBIRXMRY 1, 2038 . This Security hu&ument secures to Lend :r (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and nodifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 protest the saxuity of this Security Instrument; and (c) the performance of Borrower's covenants and order this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, Igmnt and convey to the Leader the following described properly located in CMMZRLUM C4unty, Pennsylvania: LSGRL DESCRIPTION IS ATTACIRRD BaRgTo AS SCMWLS "A" AND WWpZ A PART E:R>ZOF. which has the address of 420 3RD ST, ZKOLn [SUM] BD MJL [city], Pennsylvania 1705 ly;P c-j ("Property. Address"); TOGETHER WITH all the improvements now or hereafter erected on property, and all easements, appurtenances and fixtures now or hereafter a part of the property. I replacements and additions shall also be covered by this Security Instrument. All of the foregoing i rented to in this Security Instrument as the "Property." BORROWER COVENANTS that Borrower is lawfirlly seized of the estate here conveyed and has the right to mortgage, grant and convey the Property and that the Property is bared, 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 non-uniform covenants with limited variations by jurisdiction to constitute a uniform security in covering real property. Bonowcr and Lender covenant and agree as follows: UNIFORM COVENANTS. 1. Payment of Prlnclpal, Interest and Late Charge. Borrower shall pay when the principal of; and interest on, the debt evidenced by the Note and late charges due under the Nate. . 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower include in each monthly payment, together with the principal and interest as set forth in the Note any late charges, a sum for (a) taxes and special assessments levied or to be levied against the , (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required paragraph 4. In any year in which the Lender must pay a mortpgc insurance premiurn to the of Housing and Urban Development ("Secretary"), or in any year in which such premium would ve been required if Lender still held the Security Instrument, each monthly payment shall also include e' er; (i)(i) alsum for the i"a : a %WPA) mm) Pop 2 "r s annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a m ly charge instead of a mortgage insurance premium if this Security instrument is held by the Sec , in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the ary, 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 amount not to exceed the maximum amount that may be required for Borrower's escrow account the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 el seq. and implementing gulations, 24 CFR Part 3500, as they may be amended from time to time ("RESPA"), except that flu cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Bo ces payments arc available in the account may not be based on amounts due for the mortgage insurance um. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the at, wunts of tlrnds held by Leader at any time are not sufficient to pay the Escrow Item: when due, Lei der 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 this 5ecurity Instrument. If Borrower tenders to Lender the bull payment of all such aims, Borrower's account all be credited with the balance remaining for all installment items (a? (b), and (c) and any atom Insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender l promptly raftmd any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrowees account shall be credited with any balance remaining for all instal ants for items (a? (b), and (c). 3. Application of Payments. All payments under paragraphs 1 and 2 shall be plied by Lender as follows: First to the mortgage insurance premium to be paid by Lender to the Sccrctar remium monthl m a e insurance inst ad of th t rt h ey th S ? or to the monthly y g g p ; o arge e ecre ary e c e Sewn to any taxes, special assessments, leasehold payments or ground rents,l ! and fire, flood and other heard 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 i provements on the Property, whether now in existence or subsequently erected, against any casudties, and contingencies, including fire, for which Lender requires insurance. This insurance I be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all ' vem e? on the Property, whether now in existence or subsequently erected, against loss by floods the extent required by the Secretary. All insurance shall be carried with companies approved by The insurance policies and any renewals shall be held by Lender and shall include loss payable Claus in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. may make proof of loss if not made promptly by Borrower. Each insurance company concerned is by authorized and directed to make payment for such loss directly to Lender, instead of to Borrower d to Lender jointly. All or any part of the insu nmcc proceeds may be applied by Lender, at its o either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to an 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 note nd 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 outst anding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled hereto. % 4R(PA) lm) P"p" s d e In the event of foreclosure of this Security Instrument or other transfer of title t o the Property that cxtinguishm the indebtedness, all right, title and interest of Borrower in and to insuran ce policies in force shall pass to the purchaser. rty; 5. Occrpamey, Preservation, Malatemanee and Protection of the P Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Propas s principal residence within sixty days after the execution of this Security Instrument (ohin days of a later sale or transfer of the Property) and shall continue to occupy the Propeas s principal residence for at least one year after the date of occupancy, unless Lender detees requirement will cause undue hardship for Borrower, or unless extenuating circumstancist ch are beyond Borrowees control. Borrower shall notify Lender of any extenuating cucum wer shall not commit waste or destroy, damage or substantially change the Property of allo l to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Prois or abandoned or the loan is in default. Lender may take reasonable action to protect a such vaunt or abandoned Property. Borrower shall also be in default if Borrower, during oan lira 'on process, to gave materially false or inaccurate information or statem ents to Lender (or fto Lender with L any material information) in cormection with the loan evidenced by the Note, but not limited to, representations conecruirg Borrower's occupancy of the Property as a princisi us If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of thse. [ Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless der grata to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct r consequential, in connection with any condemnation or other taking of any part of the Property, or for onveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of full amount of the indebtedness that remains unpaid under the Note and this Security Instrument shall apply such proceeds to the reduction of the indebtedness under the Note and this Security first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepsym of principal. Any application of the proceeds to the principal shall not extend or postpone the due of the monthly payments, which are referred to in paragraph 2, or change the amount of such pa Any excess proceeds over an amount required to pay all outstanding indebtedness under the N e 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. shall pay all governmental or municipal charges, fines and impositions that are not included in graph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If to pay would adversely affect Leader's interest in the Property, upon Lender's request Borrower promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by ParA h 2, or fails to porform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly of vt Lender's rights in the Property (such a proceeding in bankruptcy, for condemnation or to enforce laws or regulatiiomsl then Leader may do ' pay whatever is necessary to protect the value of the Property and Undoes rights in the Property, lading payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an addin debt of Borrower and be secured by this security Instrument. These amounts shall bear inters from the date of disbursement, at the Note rate, and at the option of Leader, shall be immaturely due . pie. l Borrower shall promptly discharge any flea which has priority over this ess im un Borrower: (s) agrees in writing to the payment of the obligation secured by the lien in manner acceptable to Leader; (b) contests in good faith the lien by, or defends against enforcement f the lien in, legal tht proceedings which in the Lende-es opinion operate to prevent the enforcement of err (c) secwcs lie n; ? / 4%4RIPA) loess) PW 4 d 9 from the holder of the lien an agreement satisfactory to Lender subordinating the en to this Security Instrument. If Lender determines that any part of the Property is subject to a lien whi may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the l' Borrower "I satisfy the lien or take one or more of the actions set forth above within 10 days of the 'ving of notice. L 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 , in the case of payment defaults, require immediate payment in full of all sums secu? y this Security Instrument if (i) Borrower defaults by failing to pay in fall any monthly payment requi d 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 other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by appli to law (including Section 341(4) of the Garn-St. Germain Depository Institutions Act o 1992, 12 U.S.C. 1701j-3(d)) and witb the prior approval of the Secretary, require immediate p yment in full of all sums secured by this Security Instrument if: (i) All or part of the Property, or a beneficial interest in a trust all or part of the Property, is sold or otherwise transferred (other than by devise or descent and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or Santee does so occupy the Property but his or her 't has not been approved in accordance with the requirements of the Secretary. ' (e) No Waiver. If circumstances occur that world permit Lender to require mediate payment in full, but Lender does not require such payments, Lender does not waive its with respect to subsequent events. (d) Regulations of BUD Secretary. In many circumstances regulations ' by the Secretary will limit Lender's rights, in the case of payment defaults, to require imm ate payment in full and foreclose if not paid. This Security Instrument does not authorize acccl on or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument the Note are not determined to. be eligible for insurance under the National Housing Act with n 60 days from the date hereof, Lender may, at its option, require immediate payment in full of Il mms secured by this Security Instrument. A written statement of any authorized agent of fie Secretary dated subsequent to 60 days from the date hereof, declining to insure this Securi? Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstandiq the foregoing, this option may not be exercised by Lender when the unavailability of ins 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 ty Instrument. This right applies even after foreclosure proceedings arc instituted. To reinstate the Instrument, Borrower shall tender in a lump sum all amounts required to bring Bonower's t current including, to the extent they are obligations of Borrower under this Security Instrumart, losum costs and reasonable and customary attorneys' fees and expenses properly associated with the lows proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it shall remain in effect as if Larder had not required immediate payment in fbll. However, L is not required to permit reinstatement if (i) Lender has accepted reinstatement alter the ent of foreclosure proceedings within two years immediately preceding the commencement of a Trent forreclosorc %WPA) (oam PNG a or 0 proceeding, (ii) reinstatement will preclude foreclosure on diffoctut grounuda in a future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security I nst went. o 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Exto 'on of the time of payment or modification of amortization of the sums secured by this Security Instrume gmnted by Lender to any successor in interest of Borrower shall not operate to release the liability of the 'ginal Borrower or Borrower's successor in interest. Lender shall not be required to commence against any successor in interest or refuse to extend time for payment or otherwise modify and 0 zction of the sums secured by this Security Instrument by reason of any demand made by the original B or Borrower's successors in interest. Any forbearauce by Lender in exercising any right or remedy i all not be a waiver of or preclude the exercise of any right or remedy. 12. Sueemwrs and Assigns Bound; Joint and Several Llabillty; Co-Sipe The covenants and agreements of this security Instrument shall bind and benefit the successors and goer of Lender and Borrower, subject to the provisions of paragraph 9(b). Bommar's covenants and agm ents shall be joint and several. Any Borrower who co-signs this Security Instrument but does not em ute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Bom s interest in the Property under the terms of this Security Instrument; (b) is not personally obli to pay the sums secured by this Security Instrument; and (c) agrees that Lenda and any other may agree to extend, modify, forbear or make any accommodations with regard to the terms of thi Security Instrument or the Note without that Borrower's consent. 13. Notices. Any notice to Borrower provided for in this Security rostrum shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of tx method. The notice shall be directed to the Property Address or any other address Borrower grates by notice to Lender. Any notice to Lender shall be given by fast clang mail to Leader's address herein or any address Lender designates by notice to Borrower. Any notice provided for in this Sec 'ty Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this h. 14. Governing Law- Severability. This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that any or clause of this Security instrument or the Note conflicts with applicable law, such conflict shall not other provisions of this Security Instrument or the Note which can be given effect without the conflicts provision. To this end the provisions of this Security Instrument and the Note are declared to be severab . 15. Borrower's Copy. Borrower shall be given one confomxd copy of the N and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, u disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not , nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property O small quantities of Hazardous Substances that are generally recognized to be appropriate to normal idential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, c demand, lawsuit or other action by any governmental or regulatory agency or private party involving Property and any Hazardous Substance or Environmental Law of which Borrower has actual Imowl If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or remediation of any Hazardous Substances affecting the Property is neceau", Borrower shall promptl take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasol ne, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatil solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in thisparaggWb 16, In v ?R(PA) PM) ara• a a s i i I? I! "Environmental Law" means federal laws and laws of the jurisdiction when the Prop ?rty is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower cad Lender further covenant and agree as f ows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to L all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect nts and revenues t and hereby directs each tenant of the Property to pay the rents to Lender or Lender' gents. However, prior to Lendees notice to Borrower of Borrower's breach of any covenant or agre t in the Security Instrument, Borrower shall collect and receive all rents and revenues of the trustee for the a benefit of Lender and Borrower. This assignment of rents constitutes an absolute ass gament and not an assigruncnt for additional security only. If Lender gives notice of breach to Borrower; (a) all rents received by Borrow x shall be held by Borrower as trustee for benefit of Lender only, to be WUod to the sums acur id by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the , and (c) each tenant of the Property shall pay all rents due and unpaid to Leader or Lender's agent Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will perform any act that would prevent Lender flora exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Prop irty before or after giving notice of breach to Borrower. However, Lender or a judicially appointed may do so at any time there is a breach. Any application of rents shall not cure or waive any default or validate any other right or remedy of Lender. This assignment of rents of the Property shall terminate en the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender regvires Immediate payment In full r paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding, Lender be entitled to collect all expenses incurred in pursuing toe remedies provided in this paragrap 18, including, but not limited to, attorneys' fees end costs of title evidence. If the Lender's interest in this Security Instrument is held by the Seeretan and the Secretary requires immediate payment in frill under Paragrapb 9, the Secretary may Ism ke the nonjudielal power of sale provided In the Single Family Mortgage Foreclosure Act of 1"Al "Act") (12 U.S.C. 3751 et seq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided In the Act. Nothing in the pr g sentence shall deprive the Secretary of any rights otherwise available to a Lender under tbi Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, thii Security Instrument and the estate conveyed shall terminate and become void. Agar such oocurrence, shall discharge and satisfy this Security Instrument without chtue to Borrower. Borrower shall pay recordation cents. y ZS Wnivers. Borrower, to the extent permitted by applicable law, waives and leases arty error or defects in proceedings to enforce this Security Instrument, and hereby waives the of any present or ftam laws providing for stay of execution, extension of time, exemption from attar levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 1 ahdI extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale purm to this security Instrument. 22. Purchase Money Mortgage. If any of the debt secured by this Security eat is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase 23. bstareat Rate After Judgment. Borrower agrees that the interest rate payab oney uxntgagp. after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payab a frown time to time under the Note. Gk4MPA) (alas) 7 oro and Condominium Rider Growing Equity Rider ? Othe? [specify] BY SIGNING BELOW, Borrower accepts and agrees to the arms contained in this Security Instrument and in any s) executed by Borrower and recorded with it. W, Z RITZ A'r -(Seal) -Borrows (Seal) -Honowa 24. Riders to this Security Instrument If one or mart riders are exec by Borrower and recopied together with this Security instrument, the covenants of each such rider shall incorporated into shall amend and supplement the covenants and agreements of this Security Instrw at as if the rider(s) a part of this Security Instrument. (Chock applicable box(es)]. Planned Unit Development Rider U Graduated Payment Rider (Sod) -Borrower -(Seal) -Banow (Seal) Borrows (Seal) Boeoww (Seal) -Borrower Qk-4MPA) ) Pop. sara COMMONWEALTH OF PENNSYLVANIA, Cak=RLUM County as: On this, 25TH day of JANUARY, 2008 persooslly appeared JOIN Z. RIZE JR A nARR=ZD MAN known to me (or satisfae y proven) to be the person(s) whose name is/= subscnbed to the within instrument and acknowled cd that helshe/they executed the same for the purposes herein contained. IN WrrMS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: ! I- apt - 0%0 11 NOTAIUAL SEAL WWam p. Unddq, NdmY Mk -Mwnbw rItlc of Offim 3"aban N p, Ad-C-dy to c n mhdon Exom Nm 74 2011 Ibaaywum Amackftn Certificate of Redden I, W , ?. WOW -E do hereby certify that correct address of the within-named Lender is P. O. HOx 5137 DZS IIDINZS, IA 50308-513 Witness my hand this 25TH day of JANUARY, 2006_ A 0 Agent of IAuiw &L?- Qt. jRMA) P1 Papa 9 of 9 LandAmerica Commonwealth Commitment Number. 08-05512 SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT THIRD STREET AT NORTH CORNER OF LOT NOW OR FORMERL OF JOHN G. TURNER AND PREVIOUSLY OF WILLIAM WRITER; THENCE IN A SOUTHWESTERLY COUR E ALONG LINE OF SAID TURNER LOT 113 FEET TO AN ALLEY ALONG THE RUN; THENCE IN A NOR WESTERLY COURSE ALONG ALLEY 30 FEET TO ANOTHER ALLEY; THENCE IN A NORTHEASTERLY C URSE ALONG ALLEY 112 FEET TO THIRD STREET; THENCE IN A SOUTHEASTERLY COURSE ALONG HIRD STREET 30 FEET TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AS NO. 420 JHIRD STREET EAST PENNSBORO TOWNSHIP, PENNSYLVANIA. ALTA Commitment Schedule C (08-05512.PF0=45512133) VERIFICATION Damaris Stephanie Beltran, hereby states that he she is Vice PrOident Loan Documentation of WELLS FARGO BANK, N.A., in this matter, that h he is authorized to take 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) Der kno*ledge, 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. Name: Damaris Stephanie Beltran DATE: ?epf Cn7 7?/ Title: Vice President Loan ';Documentation 032-PA-V2 Zucker Goldberg & Ackerman, LLC XFP-153326 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ?I i r e Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OF; CE , F 7 w6 2P 1 ! , u J F,.. `.., FtN1'S'?'' Wells Fargo Bank, N.A. vs. Case Number John E Rife, Jr 2011-7208 SHERIFF'S RETURN OF SERVICE 09/28/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: John E. Rife Jr., 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 John E. Rife Jr. Request for service at 420 Third Street, Enola, Pennsylvania 17025 is vacant. SHERIFF COST: $63.00 SO ANSWERS, September 28, 2011 RON R ANDERSON, SHERIFF (c GOLUITYS ite Shenifi. Teiecso'.i. In::. a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA . ~ CIVIL DIVISION t""3 ra Plaintiff, ~ 4 'I N0.:11-7208 -~ ~ vs. A ~ ~ ~~ 3 r:..: John E. Rife, Jr.; x ~ cn~" ~ r*~ A Defendant(s). ~ ~~"'~ ~ '~'' -,r; x:c~ t=a --~s ~ .~ PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please mark the Complaint in Mortgage Foreclosure filed at the above-captioned term and number reinstated. ZUCKER, GOLDB & ACKERM LC r By: Dated: August /(~, 2012 Scott A. ' tterick, Esquire; PA I.D. #55650 Kimber 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 • ~ Y Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-153326/cper 200 Shefiteld Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Ofbce@zuckergoldberg.com O } ~~i.~s d a~ ate C~.~ 3`''~s ~µ ~~9 i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OFFICE C: T 1E SHERIFF Ui? r TH i .0 l t t C''1'r Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, N.A. VS. John E Rife, Jr 710, 12 OCT 16 A M 9 * I PENNSYLVAMIA Case Number 2011-7208 SHERIFF'S RETURN OF SERVICE 08/23/2012 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: John E. Rife, Jr., but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 08/30/2012 10:46 AM - Dauphin County Return: And now August 30, 2012 at 1046 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: John E. Rife, Jr. by making known unto Sonia Bendrick, Grandmother of John E. Rife, Jr. and adult in charge at 304 Schuylkill Street, Dauphin, Pennsylvania 17018 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/05/2012 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: John E. Rife, Jr., 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 John E. Rife, Jr. Doris Benson is the current resident at 323 Cascade Road, Mechanicsburg, Pennsylvania 17055, she advised Deputies John E. Rife, Jr, re§ides at 304 Schuylkill Street, Dauphin, Pennsylvania 17018. SHERIFF COST: $68.00 October 10, 2012 SO ANSWERS, /j RON R ANDERSON, SHERIFF (c) CountySufle Sheriff, Teleosoft, Im (etfirt of Shelle Ruhl Real Esta a Deputy William T. Tully Solicitor Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin WELLS FARGO BANK, NA VS JOHN E. RIFE, JR Sheriff s Return No. 2012-T-2394 OTHER COUNTY NO. 2011-7208 And now: AUGUST 30, 2012 at 10:46:00 AM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon JOHN E. RIFE, JR by personally handing to SONIA BENDRICK 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 304 SCHUYLKILL STREET DAUPHIN PA 17018 GRANDMOTHER OF DEFENDANT AND ADULT PERSON IN CHARGE AT TIME OF SERVICE. Sworn and subscribed to before me this 31 ST day of August, 2012 -)P*0Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17 2014 So Annsswers,r Sheriff of uphin Coun , By Deputy Sheriff Deputy: WILLIAM T SNYDER Sheriffs Costs: $49.25 8/28/2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN;1~- :_~,, ~.: ,~ ~ n -~ . , Wells Fargo Bank, NA, CIVIL DIVISION .~ "~r--~ ~ r~ ~°~ ~'~~~' ;;_ ~ ~- ~~ ~, ' Plaintiff No.: 11-7208 ~ ;~ ~,. ~ H"~? vs. ISSUE NUMBER: y,~ ~' ~' -~ John E. Rife, Jr.; TYPE OF PLEADING: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 420 3rd Street, Enola, PA 17025 FILED ON BEHALF OF: Wells Fargo Bank, NA Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh L. Marin, Esquire-Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-153326 ~~~~~~ ~~ Q~ U (8S c ~3~ a83 ~ a~ Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XFP-153326 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, N0.:11-7208 vs. John E. Rife, Jr.; Defendant. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to PlaintifYs Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $100,817.45 plus interest on the judgment amount ($100,817.45) from November 15, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 304 Schuykill Street address is: Dauphin, PA 1701476 w,.e: ~~ lid I~ 3 ZUCKER, BY: ~ Joel A. Ac an, Esqui PA I. 02729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-153326 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX ~ Email: Office@zuckergoldberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED Date 1, Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. John E. Rife, Jr.; AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIF{GATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY COUNTY OF UNION CIVIL DIVISION Plaintiff, N0.:11-7208 Defendant. SS: I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: i) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ~ o., a. II I~~ ~~ ZUCKER, BY: ~/ (/ Joel A. A rman, squire; PA I.D. #202729 Ashleigh . Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-153326 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com LLC Sworn to and subscribed before me This ~(~ day of NOVCM~jG~, 20 12~ C^ ~ ' Notary Pu lic My Commission Expires: PAUL C. NADRATOWSKI Notary Public of New Jersey ID# 2407850 My Commission Expires 4/27!2016 Zucker, Goldberg & Ackerman, LLC XFP-153326 Department of Defense Manpower Data Center a7i~~~ ~~ ~O SC~V1CCn1C7l1~MC?ffi ~lYl~ ~~1+~f 1~C't Last Name: RIFE, JR First Name: JOHN Middle Name: E Active Duty Status As Of: Nov-14-2012 Results as of :Nov-14-201206:19:27 SCRA 2.3 at Ao1Ne Duty or, Adlve tkrry sleep oaMe A011ve Dut1' 9gat Dane AdM EM+q' End Dste Suva 90rtbs fkxnperrnt NA NA No NA This response reflects 6N hdMlduals' eoeve duly I~pteesbgad on drs Aothe OutY Statue Data c.n,~. a,ry www, 36T Dgye aAnlw Duy 8geu Dete Rctlw Dtdy Start Dwe AgNe Duty lznd Dee BESew Service Coenponsnt NA NA No NA This eeeponae re6ecta w41sre its Individual IeR actir• duty sOMkw b19Yn 367 Jaya pracedtnp the Adlve Dory Statue Date TM elenrber or NhlFlw 1JMt wM NoiMed at a Fuese CeEUp is Adv~ Bup m Aotlw Duty 8tetus Dsb Order NotllloWan Btfrt Dada Order Nelplcsf>ep Bed Dde s'fMUS Service Carepensnl NA NA No NA Thls response reflects vrhethsr 9w Mdhiduel or hWtmr unA pas receNedpar•y no61be6on b report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. .," ~M ~' • Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rete. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http:/lwww.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Goast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer o(the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 alive duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may eMend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA eMend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing eroneous information will cause an eroneous certificate to be provided. Certificate ID: L3PG6EE4NT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, N0.:11-7208 vs. John E. Rife, Jr.; Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: John E. Rife, Jr. 304 Schuykill Street Dauphin, PA 17018-9476 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decre or Judgment was entered in the above captioned proceeding on ~ [ ] A copy of the Order or Decree is enclosed, or [~] The judgment is as follows: $100,817.45 plus cos ~_ r ~'- ~,~!" Prothonotary Zucker, Goldberg & Ackerman, LLC XFP-153326 SHERIFF'S OFFICE OF CUIIiA~ERLAND COUNTY Ronny R Anderson SheriA' Jody S !smith cnrer~:y Richard W Stewart Solicitor ~,~ ~ Cawf!~~~ OFFICE OF TIIE 311EIpfF _ = fiE Prt~THCh~`:~ Ikic`~ 28J2 QCT 16 AM 9~ d I ~u PEA Y~I.VANJa TY Weiss Fargo Bank, N.A. Csss lNtwribs~ ~• 2011-7208 John E Rife, Jr SHERIFF'S RETURN OF SERVICE 08/23/2012 Ronny R. Anderson, Sheriff who being duy sworn acoordir~g to law states that hs made a dtligsM search and inquiry for the within named defa~darrt, to wit: John E. Rih, Jr., but was unable to kx~te hfm in his baiWnick. He ttnrsfors deputized the ShsrM of Dauphin County, Pennsylvania to serve the within _. :.._ CompiaMt in Moetgage Forecbsun according to law. 08/30/2012 10:46 AM -Dauphin County Return: And now August 30, 2012 ~ 1046 hours I, Jack Lotwidc, Sheriff of Dauphin County, Pennsylvania, do hereby and return that I served a true copy of the within Complaint fn Mortgage Foredosuro, upon the within named dafsrrdant, to wit: John, E. Rih, Jr. by making known undo Sonh Bendridc, Grandmother of John E. Riffs, J-. and aduk in charge at 304 SchuyNtiN Street, Dauphin, Pennsylvania 17018 its contents and at the awns time handing to her personally the said true and corroct copy of the same. 09105/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, :fetes that he made a diN~xrt search and inquiry for the wllhin Warned dsteta rdaM to wit: Jan E. Rih, Jr., but was unable to k~ him in his back. Ms drsreta+e returns the within Complaint in Mor~ps Forsdosure as not found as ~ the dehrtdant John E. Rife, Jr. Doris t3anson is the currtint resident at 3~3 Cascade Rand, Mechanicsburg, PennsyMnia 17055, she advised Deputies John E. Rife, Jr. nNides at 304 SchuyAcill Street, Dauphin, Pennsylvania 17018. SHERIFF COST: 588.00 October 10, 2012 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF (CI CouMYS~ SMAff,1N~Oh, InC. 1 s ll~e 1 William T. Tully ~ sot«ro~~ Dauphin County 107 M~a7cot Sbroct Haaiabuc8, Ponmylwnia 17101-2079 ph: CT 17) T8(T-6590 titx: (7 t T) 255-2889 Jack Lotwick shc~rr Jack, {l Mich ~1 Wes.. hart Com®olEnv~ith of Peanaylvsuia WELLS FARGO BANK, NA VS County of Daupikin JOHN E. RIFE, JR Sheriffs Return No. 2012-T-2394 OTHER COUNTY N0.2011-7208 And now: AUGUST 30, 2012 at 10:46:00 AM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon JOHN E. RIFE, JR by personally handing to SONIA BENDRICK 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 304 SCHUYLKILL STREET DAUPHIN FA 17018 GRANDMOTHER OF DEFENDANT AND ADULT PERRON IN CHARGE AT TIME OF SERVICE. Sworn and subscribed to before me this 31 ST day of August, 2012 Cvs lywF PENNSYLVANIA NO' L Karen M. Nobay 1'ubiic ciey ot'tlnrria>wrs, D.wh+n ~ ' A 17 2014 So AnPswers, 11G7~p"-" C._._. Sheriff of uphin Coun , By Deputy Sheriff Deputy: WILLIAM T SNYDER Sheriffs Costs: X49.25 8/28/2412 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. ~ N0.:11-7208 John E. Rife, Jr. Defendant. IMPORTANT NOTICE TO: John E. Rife, Jr. 304 Schuylkill St Dauphin PA 17018-9476 DATE OF NOTICE: 10/15/2012 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 $. Bedford Stn3et 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 980-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA Plaintiff, CIVIL DIVISION vs. John E. Rife, Jr. TO: John E. Rife, Jr. 304 Schuylkill St Dauphin PA 17018-9478 NO.: 11-7208 AVISO IMPaRTANTE FECHA DEL AVISO:10/15/2012 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIGS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA ~TISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IlVIPORTANTES. USTED DEBE LLEVAR ESTE DOG'UMENTO INIVIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, ~TAYA O LLAME LA OFICINA ABAJO INDICADA PARR QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TGl DEFEND ~ LAWYERREFERR.AL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. i3edford Street Carlisle, PA 17013 Carllale, PA 17013 Phone (800) 990-8108 Phone (800) 990-8108 (717) 249-3166 (717) 249-3166 ZUCKER, GOLDBERG &ACKERMAN BY: $it3~ A. Q I~i11rIC~i Scott A. Dietterick, Esquire Attorneys for Plaintiff PA I.D. # 55550 Z00 Sheffield Street, Suite 301 P. D. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, PUSTAGE PREPAID 153326 Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA WELLS FARGO BANK,NA, CIVIL ACTION - LAW w Plaintiff, ' tq VS. No. 11-7208 Civil Term © 6 ' JOHN E. RIFE, JR., Defendant. o PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Enter our appearance on behalf of Defendant, JOHN E. RIFE, JR., in the above captioned matter and serve all papers upon us at the address listed below. Patrick A. Deibler, Esquire JACQUES H. GEISENBERGER, JR., P. C. 941 Wheatland Avenue, Suite 302 Lancaster, PA 17603-3180 717-397-3500 JACQUES H. LEIS. R, JR., P. C. September 17,2013 By: 'atrick A. Deibler, Esquire I.D. No. 311344 Attorneys for Defendant WHEATLAND PLACE 941 WHEATLAND AVE - STE 302 LANCASTER PA 17603-3180 (717) 397-3500 2013180CCP.wpd/1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA WELLS FARGO BANK,NA, CIVIL ACTION - LAW Plaintiff, z rn i,Q cn►" ,r— vs. No. 11-7208 Civil Term f--'jz CD o c JOHN E. RIFE, JR., Defendant. °n i TO THE PROTHONOTARY: SUGGESTION OF BANKRUPTCY AND NOW comes Patrick A. Deibler, Esquire, a member of the bar of this Court, and certifies to the court that Defendant, JOHN E. RIFE, JR., in the above case, filed a petition under chapter 7 of the United States Bankruptcy Code on September 16, 2013, in the United States Bankruptcy Court for the Middle District of Pennsylvania, Case No. 1:1 3-bk-04739, and said proceeding remains open and pending. A copy of the Notice of Bankruptcy Case Filing is attached. As a result of this filing, all further legal actions against the Defendant are stayed under applicable provisions of the Bankruptcy Code 11 U.S.C. §362(a). JACQUES H. GEISE R , JR., P. C. c. September 17, 2013 By: atrick A. Deibler, Esquire I.D. No. 311344 Attorneys for Defendant WHEATLAND PLACE 941 WHEATLAND AVE - STE 302 LANCASTER PA 17603-3180 (717) 397-3500 2013180CCP.wpd/3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK,NA, CIVIL ACTION - LAW , l Plaintiff, „ r -,,�� co VS. No. 11-7208 Civil Term p a • zQ JOHN E. RIFE, JR., o r: Defendant. -�- ` M 'Ty CERTIFICATE OF SERVICE 1, Patrick A. Deibler, Esquire, hereby certify that I am this day serving a true and correct copy of Defendant's Suggestion of Bankruptcy upon the person and in the manner indicated below, which service satisfies the requirement of Pa.R.C.P. 440: Name and Address Service Method Scott A. Dietterick, Esquire [X] U.S. Mail Zucker, Goldberg &Ackerman, LLC [ ] Hand Delivery 200 Sheffield Street, Suite 101 [ ] Fax Mountainside,NJ 07092 [ ] Other: [Specify] JACQUXGETSENB R, JR., P. C. Septemb er 17, 2013 By: Esquire I.D. No. 311344 Attorneys for Defendant WHEATLAND PLACE 941 WHEATLAND AVE - STE 302 LANCASTER PA 17603-3180 (717) 397-3500 2013180CCP.wpd/2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. John E. Rife, Jr.; TO THE PROTHONOTARY: CIVIL DIVISION Plaintiff, NO.: 11-7208 Defendants. PRAECIPE TO SUBSTITUTE SUCCESSOR PARTY PURSUANT TO PA.R.C.P. 2352 :OW Please substitute the Plaintiff/Party Wells Fargo Bank, NA with "CP -SRMOF II 2012 -A Trust, by U.S. Bank Trust National Association, not in it's individual capacity but solely as Trustee ", pursuant to an assignment of mortgage dated October 3rd, 2013 and recorded October 21, 2013, in the office of the Recorder of Deed of Cumberland County as instrument number 201334424, which Assignment was executed by Wells Fargo Bank, NA, and assigned the Mortgage which of the subject of the above - captioned matter to CP -SRMOF II 2012 -A Trust, by U.S. Bank Trust National Association, not in it's individual capacity but solely as Trustee. By: Dated: March 5, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC cott A. Dietterick, Esquire; ✓A77 A 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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP- 153326/jf 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com S.5-0 Pb M1 -? el loam et* 3csito Exhibit A \D Inst. # 201334424 - Page 4 of 4 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717 - 240 -6370 Instrument Number - 201334424 Recorded On 10/21/2013 At 2:26:56 PM * Instrument Type - ASSIGNMENT OF MORTGAGE Invoice Number - 149762 User ID - MBL * Mortgagor - RIFE, JOHN E JR * Mortgagee - US BANK NA * Customer - SIMPLIFILE LC E- RECORDING * FEES STATE WRIT TAX STATE JCS /ACCESS TO JUSTICE RECORDING FEES — RECORDER OF DEEDS PARCEL CERTIFICATION FEES COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $23.50 $11.50 $15.00 $2.00 $3.00 $55.50 * Total Pages - 4 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER OF DEEDS * - Information denoted by an asterisk may change during the veriflcation process and may not be reflected on this page. Inst. # 201334924 - Page 3 of 4 EXHIBIT A LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND MATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT THIRD STREET AT NORTH CORNER OF LOT NOW OR FORMERLY OF JOHN G. TURNER AND PREVIOUSLY OF WILLIAM WRITER; THENCE IN A SOUTHWESTERLY COURSE ALONG LINE OF SAID TURNER LOT 113 FEET TO AN ALLEY ALONG THE RUN; THENCE IN A NORTHWESTERLY COURSE ALONG ALLEY 30 FEET TO ANOTHER ALLEY; THENCE 04 A NORTHEASTERLY COURSE ALONG ALLEY 112 FEET TO THIRD STREET; THENCE IN A SOUTHEASTERLY COURSE ALONG THIRD STREET 30 FEET TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AS NO. 420 THIRD STREET EAST PENNSBORO TOWNSHIP, PENNSYLVANIA. Date OCT 4 .1 7113 State of Texas County of Herd Inst. # 201334424 - Page 2 of 4 ASSIGNOR: The Secretary of Housing and Urban Development by Selene Finance LP, Its attorney -in -fact* By: °1 Name: Title: Dan Shlmmin Zns1�+,n f # 0E33 ti 7a ■n G<m er%nd Gain / 6 F&Cfq: MI-O `ds. Before me, tA °�� , duly commissioned Notary Public, on this day personally appeared Dan Shiminl Seniof Vic@ PreeidQlt own to me (or proved to me on the oath of or through ) to be the person whose name is subscribed to the foregoing instrument and acknowledged to me that he/she executed the same for the purposes and consideration therein expressed. �d C Qkob X Given under my hand and seal of office this , ' day of , 20 13: Notary Public's Signature Printed Name: kM n My Commission Expires: Pal 11 Inst. # 201334424 - Page 1 of 4 CERTIFIED PROPERTY IDENTIFICATION NUMBERS 45 -17- 1044 -018 - CCGIS REGISTRY 10/21/2013 BY DC PREPARED BY: CP ;SRMOF 11 2012-A Trust, U.S. Bank Trust National Association, not in its individual capacity but solely as Trustee c/o 9990 Richmond AVE, Suite 400 South Houston, TX 77042 WHEN RECORDED RETURN TO: Avenue 365 Lender Services 401 Plymouth RD, Ste. 550 Plymouth Meeting, PA 19462 Fame) . C: 1-151710INDIS ASSIGNMENT QF MORTGAGE FOR VALUE RECEIVED. the undersigned, The Secretary of Housing and Urban Development, located at 451 7th Street S.W., Washington, DC 20410 ( "ASSIGNOR/GRANTOR "), hereby grants, conveys, assigns to: CP SRMOF 11 2012-A Trust, U.S. Bank Trust National Association, not in its Individual capacity but solely as Trustee, located at c/o.9990 Richmond AVE, Suite 400 South, Houston, TX .77042 ( "ASSIGNEE/GRANTEE ") all'beneficial interest under that certain MORTGAGE dated 1/25/2008, and executed by John E. Rife Jr a married man, borrower(s) to: Wells Fargo Bank, NA, as original lender, and certain instrument recorded 2/6/2008, in Instrument # 200803737, in the Official. ,Records of Cumberland County, the State of Pennsylvania, give, secure a certain Promissory Note in the amount of 1101,500,00 covering property located at: 42p ST, 1I€nn "e, Pennsylvania, 17025. LEGAL DESCRIPTION ATTACHED AS EXHIBIT *Y.0141 1`�a0, it iP ts+ PennSbOro . TOGETHER. with the note or notes therein described.and secured thereby, the money due and to become due thereon, with interest, and all rights accrued or to accrue under said Mortgage including the right to have • reconveyed, in whole or in part, the real property described therein. CERTIFICATE OF BUSINESS RESIDENCE: I, /7. (ittik)/ / //'"C , do certify that the Assignee's precise residence isc /o 9990 Richmond AVE, Suite 400 South, Houston, TX 77042. Witness my hand this . day of (3('443.0_ , 20 IS . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. John E. Rife, Jr.; CIVIL DIVISION Plaintiff, NO.: 11-7208 Defendants. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Praecipe to Substitute Successor Party was served on the following this 1(10> day of March, 2014, via First Class U.S. Mail, Postage Pre -Paid: John E. Rife, Jr. 323 CASCADE RD MECHANICSBURG PA 17055 -5519 304 SCHUYLKILL ST DAUPHIN PA 17018 -9476 Dated: 31 1 By: ZUC ER, GOLDBERG & ACKERMAN, LLC /IIlILii�l t A. Dietterick, Esquir:, PA I.D. #55650 berly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP- 153326/jf 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com (sk' T J(Tj 0 2M APR All 35 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTVRENNSVOMOUNT CIVIL DIVISION PENNSYLVANIA CP-SRMOF II 2012-A Trust, by u .S. Bank Trust National Association, not in it's individual capacity but solely as Trustee, VS. John E. Rife, Jr.; Plaintiff, Defendant. TO THE PROTHONOTARY OF THE SAID COURT: File No. 11-7208 Amount Due $100,817.45 Interest from 11/16/2012 to date of sale CUMBER Costs $10,896.16 The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ti tl t( claa (A-Dvs_ bacioq Zucker, Goldberg & Ackennan, LLC f_ X F P12 3 (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: // 01 / //~1 Signature: Print Name: Scott A. Dietterick Esquire Kimberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh Levy Mann, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, Esquire Address: Zucker, Goldberg & Ackerman, LIC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908'233'8500 Supreme Court ID No.: 55650 89705 202567 201493 202946 1/4 Zucker, Goldberg & Ackerman, iLC XFP-153326 I uII Iluul II 11111IIIIWIIIII Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT THIRD STREET AT NORTH CORNER OF LOT NOW OR FORMERLY OF JOHN G. TURNER AND PREVIOUSLY OF WILLIAM WRITER; THENCE IN A SOUTHWESTERLY COURSE ALONG LINE OF SAID TURNER LOT 113 FEET TO AN ALLEY ALONG THE RUN; THENCE IN A NORTHWESTERLY COURSE ALONG ALLEY 30 FEET TO ANOTHER ALLEY; THENCE IN A NORTHEASTERLY COURSE ALONG ALLEY 112 FEET TO THIRD STREET; THENCE IN A SOUTHEASTERLY COURSE ALONG THIRD STREET 30 FEET TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AS NO. 420 THIRD STREET EAST PENNSBORO TOWNSHIP, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 420 3rd Street, Enola, PA, 17025. BEING the same premises which JOHN E. RIFE, SINGLE MAN, by Deed dated April 16, 2008 and recorded May 8, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200815191, Page , granted and conveyed unto John E. Rife, Jr., married man, Sole Owner. Tax Map No.: 45- 174044 -018. Zucker, Goldberg & Ackerman, LLC XFP- 153326 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C9'SRKAOFUZO12,4 Trust, bxu.3. Bank Trust : CIVIL DIVISION National Association, not in it's individual capacity bi : solely as Trustee, : NO.: 11-7208 Plaintiff, : Execution No.: Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 VS. John E. Rife, Jr.; CP-SRK8OFUZO12-ATrustbvu.S.8ankTrustNationa|Associadmn,notinit'sindividua|capachx but solely as Trustee, 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 420 3rd Street, Enola, PA 17035. 1. Name and Address of Owner(s) or Reputed Owner(s): JOHN E. RIFE, JR., MARRIED MAN, SOLE OWNER 304 Schuykill Street Dauphin, PA 17018-9476 AND C/O JACQUES H. GEISENBERGER JR PC 941 Wheatland Avenue Suite 302 Lancaster PA 17603 2. Name and Address of Defendant(s) in the Judgment: JOHN E. RIFE, JR. 304 Schuykill Street Dauphin, PA 17018'9476 AND C/O JACQUES H. GEISENBERGER JR PC 941 Wheatland Avenue Suite 302 Lancaster PA 17603 Zucker, Goldberg a Ackerman, uc xpr /53/za 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: CP'SRK8OFU2U12-ATrust,bvu.S.8ankTrustNa%iona|Asaobahon,notinb'sindividua|caoacbvbut solely as Trustee Plaintiff 4. Name and Address of the last record holder of every mortgage of record: CP-SRMOF II 2012-A Trust, by u .S. Bank Trust National Association, not in it's individual capacity but solely as Trustee Plaintiff WELLS FARGO BANK. N.A. P.O. Box 5137, Des Moines, IA 50306-5137 5. Name and Address of every other person who has any record lien on the. property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 32O Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 420 3rd Street Eno la, PA 17025 Zucker, Goldberg & Ackerman, LLC xrp-/533zo UNKNOWN SPOUSE 304 Schuykill Street Dauphin, PA 17018-9476 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. Dated: l^ 4 ZUCKER, GOLDBERG & ACKERMAN, LLC B MN' Scott A. Dietterick Esquire; PA|.D.#SSG5O Kimberly A. Bonner, Esquire; PA|.D.#897O5 Joel A. Ackerman, Esquire; PA1.D.#202729 Ashleigh L. W1arin, Esquire; PA|.D.#3O6799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PAiD.#31S944 Brian Nicholas, Esquire; PA|.O.#31724U Denise Carlon, Esquire; PAiD.#317226 Attorneys for Plaintiff XFP'253326/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC xrp'1o3z* Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT THIRD STREET AT NORTH CORNER OF LOT NOW OR FORMERLY OF JOHN G. TURNER AND PREVIOUSLY OF WILLIAM WRITER; THENCE IN A SOUTHWESTERLY COURSE ALONG LINE OF SAID TURNER LOT 113 FEET TO AN ALLEY ALONG THE RUN; THENCE IN A NORTHWESTERLY COURSE ALONG ALLEY 30 FEET TO ANOTHER ALLEY; THENCE IN A NORTHEASTERLY COURSE ALONG ALLEY 112 FEET TO THIRD STREET; THENCE IN A SOUTHEASTERLY COURSE ALONG THIRD STREET 30 FEET TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AS NO. 420 THIRD STREET EAST PENNSBORO TOWNSHIP, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 420 3rd Street, Enola, PA, 17025. BEING the same premises which JOHN E. RIFE, SINGLE MAN, by Deed dated April 16, 2008 and recorded May 8, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200815191, Page , granted and conveyed unto John E. Rife, Jr., married man, Sole Owner. Tax Map No.: 45 -17 -1044 -018. Zucker, Goldberg & Ackerman, LLC XFP- 153326 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CP-SRMOF II 2012-A Trust bxu.5. Bank Trust National Association, not in it's individual capacity but solely as Trustee Plaintiff, vs. John E. Rife, Jr.; Defendants. CIVIL DIVISION NO.: 11-7208 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 John E. Rife, Jr. 304 Schuykill Street Dauphin, PA 17018-9476 AND 420 3rd Street Eno la, PA 17025 AND 323 Cascade Rd Mechanicsburg PA 17055-5519 AND 304 S Market St Fl 2 Mechanicsburg PA 17055-6326 AND PO Box 2I Dauphin PA 17018-0021 AND C/O ]ACC\UESH.GE|SEN8ERGERJRPC 941 Wheatland Avenue Suite 302 Lancaster PA 17603 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on September 3, 2014 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: Zucker, Goldberg & Ackerman, LLC XFP-153326 420 3rd Street, Eno la, PA, 17025 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-7208 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: John E. Rife, Jr., married man, Sole Owner 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 ri hts 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 Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before Zucker, Goldberg & Ackerman, LLC XFP-153326 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. BY: Dated: ZUCKER, GOLDBERG & ACKERMAN, LLC 'jiI4J.i4 Scott A.*ietehc , Esquire; PA|.Ci#S56SO Kimberly A. Bonner, Esquire; PA|.D.#B97OS Joel A. Ackerman, Esquire; R4iD.#2O2739 Ashleigh L. Mann, Esquire; PA|.D.#3O6799 Ralph M. Salvia, Esquire; PAiD.#2O3946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA|.D.#31734O Denise Cadmn, Esquire; PA|.D.#317Z36 Attorneys for Plaintiff XFP'153326/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XFP-153326 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT THIRD STREET AT NORTH CORNER OF LOT NOW OR FORMERLY OF JOHN G. TURNER AND PREVIOUSLY OF WILLIAM WRITER; THENCE IN A SOUTHWESTERLY COURSE ALONG LINE OF SAID TURNER LOT 113 FEET TO AN ALLEY ALONG THE RUN; THENCE IN A NORTHWESTERLY COURSE ALONG ALLEY 30 FEET TO ANOTHER ALLEY; THENCE IN A NORTHEASTERLY COURSE ALONG ALLEY 112 FEET TO THIRD STREET; THENCE IN A SOUTHEASTERLY COURSE ALONG THIRD STREET 30 FEET TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AS NO, 420 THIRD STREET EAST PENNSBORO TOWNSHIP, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 420 3rd Street, Enola, PA, 17025. BEING the same premises which JOHN E. RIFE, SINGLE MAN, by Deed dated April 16, 2008 and recorded May 8, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200815191, Page , granted and conveyed unto John E. Rife, Jr., married man, Sole Owner. Tax Map No.: 45 -17- 1044 -018. Zucker, Goldberg & Ackerman, 'IC XFP- 153326 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite] 00 • Carlisle, PA • 17013 (717) 240-6195 www.cepa.net CP.SRMOF II 2012-A TRUST, BY U.S. BANK TRUST NATIONAL ASSOCIATION, NOT IN IT'S INDIVIDUAL CAPACITY BUT SOLELY AS TRUSTEE Vs. NO 11-7208 Civil Term CIVIL ACTION — LAW JOHN E. RIFE, JR. WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (I) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $ IOC, 91'?. 4'S L.L.: $.50 Interest FROM 11/16/2012 TO DATE OF SALE - $10,896.16 Atty's Comm: Atty Paid: $289.25 Plaintiff Paid: Date: 4/2/14 Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: ASHLEIGH LEVY MARIN, ESQUIRE Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 201493 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CP-SRMOF II 2012-A Trust, by u .S. Bank Trust CIVIL DIVISION National Association, not in it's individual capacity In : solely as Trustee, NO.: 11-7208 Plaintiff, John E. Rife, Jr.; Defendant(s). vs. : Execution No.: AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Tj CP-SRMOF II 2012-A Trust, by u .S. Bank Trust National Association, not in it's individual capacity but solely as Trustee, 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 420 3rd Street, Enola, PA 17025. 1. Name and Address of Owner(s) or Reputed Owner(s): JOHN E. RIFE, JR., MARRIED MAN, SOLE OWNER 304 Schuykill Street Dauphin, PA 17018-9476 AND C/O JACQUES H. GEISENBERGER JR PC 941 Wheatland Avenue Suite 302 Lancaster PA 17603 2. Name and Address of Defendant(s) in the Judgment: JOHN E. RIFE, JR. 304 Schuykill Street Dauphin, PA 17018-9476 AND C/O JACQUES H. GEISENBERGER JR PC 941 Wheatland Avenue Suite 302 Lancaster PA 17603 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: CP-SRMOF 11 2012-A Trust, by u .S. Bank Trust National Association, not in it's individual capacity but solely as Trustee Plaintiff SECRETARY OF HOUSING AND URBAN DEVELOPMENT 451 7TH STREET S.W. WASHINGTON, D.C. 20410 4. Name and Address of the last record holder of every mortgage of record: CP-SRMOF II 2012-A Trust, by u .S. Bank Trust National Association, not in it's individual capacity but solely as Trustee Plaintiff WELLS FARGO BANK. N.A. P.O. Box 5137, Des Moines, IA 50306-5137 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 WEST FAIRVIEW BOROUGH 98 SOUTH ENOLA DRIVE, ROOM 101, ENOLA, PA 17025 ATTN: DEBBIE LUPOLD, TREASURER EAST PENNSBORO AREA SCHOOL DISTRICT 890 Valley Street, Enola, PA 17025 AND 98 SOUTH ENOLA DRIVE, ROOM 101, ENOLA, PA 17025 ATTN: DEBBIE LUPOLD, TREASURER PRIVATE - PA AMERICAN 800 W HERSHEYPARK DR HERSHEY, PA 17033 EAST PENNSBORO TWP 98 S ENOLA DR ROOM 101, ENOLA, PA 17025 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 420 3rd Street Enola, PA 17025 UNKNOWN SPOUSE 304 Schuykill Street Dauphin, PA 17018-9476 KATHERINE SUSANNA RIFE 717 CLASTER BLVD Dauphin PA, 17018 AND C/0 SUSAN KAY CANDELLO, ESQ 4010 Glenfinnan PI, Mechanicsburg, PA 17055 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: BY: ZUCKER, GOLDBERG & ACKER N, LLC Scott A. I etterick, 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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCP-153326/nfe 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT THIRD STREET AT NORTH CORNER OF LOT NOW OR FORMERLY OF JOHN G. TURNER AND PREVIOUSLY OF WILLIAM WRITER; THENCE IN A SOUTHWESTERLY COURSE ALONG LINE OF SAID TURNER LOT 113 FEET TO AN ALLEY ALONG THE RUN; THENCE IN A NORTHWESTERLY COURSE ALONG ALLEY 30 FEET TO ANOTHER ALLEY; THENCE IN A NORTHEASTERLY COURSE ALONG ALLEY 112 FEET TO THIRD STREET; THENCE IN A SOUTHEASTERLY COURSE ALONG THIRD STREET 30 FEET TO THE PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AS NO. 420 THIRD STREET EAST PENNSBORO TOWNSHIP, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 420 3rd Street, Enola, PA, 17025. BEING the same premises which JOHN E. RIFE, SINGLE MAN, by Deed dated April 16, 2008 and recorded May 8, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200815191, Page , granted and conveyed unto John E. Rife, Jr., married man, Sole Owner. Tax Map No.: 45-17-1044-018. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAIMA c CP-SRMOF II 2012-A Trust, by U.S. Bank Trust CIVIL DIVISION = r- r-uc �r';- 70 G7 > , National Association, not in Its individual U)I --;. capacity but solely as Trustee, NO.: 11-7208 r-- __..! Plaintiff, a`.— C & _4114 vs. TYPE OF PLEADING -2:7 John E. Rife, Jr.; Defendants. Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: CP-SRMOF II 2012-A Trust, by U.S. Bank Trust National Association, not in Its individual capacity but solely as Trustee COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh Levy Marin, Esquire -PA I.D. #306799 Ralph M. Salvia, Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon, Esquire- PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP- 153326/mag Zucker, Goldberg & Ackerman, LLC XFP-153326 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CP-SRMOF II 2012-A Trust, by U.S. Bank Trust CIVIL DIVISION National Association, not in Its individual capacity : but solely as Trustee NO.: 11-7208 vs. John E. Rife, Jr.; Plaintiff, Defendants. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, CP-SRMOF II 2012-A Trust, by U.S. Bank Trust National Association, not in Its individual capacity but solely as Trustee, 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, John E. Rife, Jr., married man, Sole Owner, is the record owner of the real property. 2. On or about July 3, 2014, defendant John E. Rife, Jr. was served with Plaintiff's Notice of Sheriff's Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at the address of 304 Schuykill Street, Dauphin, PA 17018-9476. A true and correct copy of said Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about July 17, 2014, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Zucker, Goldberg & Ackerman, LLC XFP-153326 Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated: August /3 , 2014 Sworn to and subscribed before me this /3 day of August, 2014 Notary Pblic MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm. Expires 27616, 2016 ID #State of New Jersey ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff MARGARET EPONG Paralegal Legal Assistant Zucker, Goldberg & Ackerman, LLC XFP-153326 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-153326 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ol Cif tr160,/,00 (4:4 r OF',CE or 114E SHERIFF Wells Fargo Bank, N.A. vs. John E Rife, Jr Case Number 2011-7208 SHERIFF'S RETURN OF SERVICE 06/19/2014 Shawn Harrison, Deputy being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 420 3rd Street, Enola, PA, Cumberland County. 07/02/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, returned by the Sheriff of Dauphin County, the within named Defendant John E. Rife, Jr., not found. So Answers: Thomas Wong, Deputy Sheriff, per defendants grandmother, who is the only resident OrSO4 Schuylkill Street, Harrisburg PA, defendant know resides at, 304 South Market Street, 2nd Floor, Mechanicsburg, PA 17055. cab. 07/03/2014 07:14 PM - Deputy Ryan Burgett, 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 time personally handing a true copy to a person representing themselves to be the Defendant, to wit: John E Rife, Jr at 304 South Market Street, 2nd Floor, Mechanicsburg, PA 17055, Cumberland County. SHERIFF COST: $1,005.75 SO ANSWERS, July 08, 2014 RONNY R ANDERSON, SHERIFF (c) CountySti, le Sherttf: 'Teloosott, Inc EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-153326 NTL Page 1 of 8 auMrensmrEs " POSTAL SERVICE. Certificate 0 Mailing U S POSTAGE >,»:PITNEYF.VNES This Certificate of Mailing provides evidence that mag has been presented to USPS• for mailing. This form may be used for domestic and International mall, Prom: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 T°` CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND XFP-153326/nfe TEAM- C p907002 .2 02 0001387430 JUL 17 2014 To pay fee, affix stamps or meter postage here. P5 Form 3817, April 2007 PSN 7530-02-000-9065 UNITEDSTQTES POSTAL SERVICE Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS* for mailing, Thls form may be used for domestic and International mall, From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C T°` COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 p I OZ L L 1nnr 0£pL8£ 1000 ooZ1.00 $ Z60L104 dIZ ZO oresom*T te; S3MD3 A3Nlld 2OVISOd S fl To pay fee, affix stamps or meter postage hero, Postmark Here NTL Page 2 of 8 UNITED STATES Mg POSTAL SERVICE® Certificate 0 Mailing U S POSTAGE ») PI NEY; YwES zlP 07092 $ 001.20° 02 tiV This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. Thls form may ba used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C To: UNKNOWN TENANT OR TENANTS 420 3rd Street Enola, PA 17025 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE® Certificate Of Mailing This Certificate of Malang provides evidence that mall hes been presented to USPS for mailing. This form may be used for domestic and International mall. "om Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C To' SECRETARY OF HOUSING AND URBAN DEVELOPMENT 451 7TH STREET S.W. WASHINGTON, D.C. 20410 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 PtO- Ll iflr 0£t'LB£1000 000 13874 30 JUL 17 2014 To pay fee, affix stamps or mater postage here. Postmark Here To pay fee, affix stamps or meter postage here. Postmark yore NTL Page 3 of 8 UNITED STATES Frailli POSTAL SERVICE® Certificate 0 Mailing U S POSTAGE }), PITNEY BOWES *to4ofearlarVe Alwarwrwr This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domesdc and lritemattonaf mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C T0: WELLS FARGO BANK. N.A. P.O. Box 5137, Des Moines, IA 50306-5137 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE® Certificate Of Mailing This Certificate of Melling provides evidence that mall hu been presented to UPS* for mailing. This form may be used for domestic and International mall. `rem Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C Tei KATHERINE SUSANNA RIFE 717 CLASTER BLVD Dauphin PA, 17018 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 6LOZ LL Ulf 0£1'L8£L000 ML ZO Z60L0 dIZ A AAPIWWWWN, ". s3MCF AANlid «30V1SOd'S n 0Ott. 00 $ ZIP 07°92 $ 001.200 02 1V,1 0001387430JUL 17 2014 To pay fee, affix stamps or meter postage here. Postmerk: lire • To pay fee, affix stamps or meter postage here. Postmark Here NTL Page 4 of 8 10.2 UNITED .STATES Aria POST/11 SERVICE® Certificate 0 Mailing U.S POSTAGE »? PITNEY BOWES This Certificate of Mailing provides evidence that mall has been presented to USPS for mailing. This form may be used for domestic end International mad. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C Tei KATHERINE SUSANNA RIFE C/0 SUSAN KAY CANDELLO, ESQ 4010 Glenfinnan PI, Mechanicsburg, PA 17055 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 �+ UNITED STATES Prat POSTAL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and international mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C Tei EAST PENNSBORO TWP 98 S ENOLA DR ROOM 101, ENOLA, PA 17025 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 1'LOZ LL lflf 0£tzL8£L000 0 0OZ.100 $ Z60L0 dIZ 40.400m, 444 ;gym ,s; S3Mid?A3Nlld `« 3OV1SOd S71 ZIP 07°92 $ 001.200 02 try 0001387430JUL 17 2014 To pay fee, affix stamps or meter postage here. Postmark 14 9 ,,.I r V1AV9. f.r-"--:t.--.. To pay fee, affil stamps or meter postage here. Postmark Here NTL Page 5 of 8 �UNITED STATES POST4L SERVICE® U S POSTAGE j» PI'NEYF_NES tr, ZIP 07092 $ 001.20°. 02 IVY 0001387430JUL 17 014 To pay fee, affix stamps or mater postage here. Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USW for mailing, Thls form may be used for domestic and internetIonel mall. Fr°m Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C T°` PRIVATE - PA AMERICAN 800 W HERSHEYPARK DR HERSHEY, PA 17033 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 aUNITED STATES POST4L SERVICE® Certificate Of Mailing Thls Certificate of Mailing provides evidence that mall has been presented to USPS* for mailing. This form may be used for domestic end International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C T°' EAST PENNSBORO AREA SCHOOL DISTRICT 98 SOUTH ENOLA DRIVE, ROOM 101, ENOLA, PA 17025 ATTN: DEBBIE LUPOLD, TREASURER County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 LG?: Lt inr 0£t,L9£L000 1 %c,c? ; cif or���y ,i'HMfy0,441mor S3A/Cifii A3ilU d «3OVISod 's n Postmark Here To pay fee, affix stamps or meter postage here. Postmark Here NTL Page 6 of 8 UNITED STATES POSTAL SERVICE Certificate Mailing U.S. POS1AGE >;? F;-NEY 8:WEs This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and international mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 T°` EAST PENNSBORO AREA SCHOOL DISTRICT 890 Valley Street, Enola, PA 17025 County of P.Q.: CUMBERLAND XFP-153326/nfe TEAM- C 00120' 0001387430 • JL 17 =;:14 To pay fee, affix stamps or meter postage here. P5 Form 3817, April 2007 PSN 7530-02-000-9065 �UNITED STATES POSTAL SERVICEm Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C T°' WEST FAIRVIEW BOROUGH 98 SOUTH ENOLA DRIVE, ROOM 101, ENOLA, PA 17025 ATTN: DEBBIE LUPOLD, TREASURER County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 t7 0 LL lflr 0£tL8£L000 zo o0Z•100 $ 60L^0 clIZ eMMOIMW S3MGa A3Nlld 3OVISOd S n To pay fee, affix stamps or meter postage here. Postmark Here NTL Page 7 of 8 UNITED STATES POSTAL SERVICE U.S POSTAGE »> PITNEY BOWES Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and international mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C Toi CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE 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 UNITED STATES 'g POSTAL SERVICEe Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C Tei PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 4LOZ L "Ifl('OEtL9£L000 00Z300 $ Z60L10 dIZ ,rteA m. S3MOBA3N11d «3VISOd S (i 0 00120° 0001387430JUL 17 2014 To pay fee, affix stamps or meter postage here. Postmark Here !'I r nom. To pay fee, affix stamps or meter postage here. Postmark Here NTL Page 8 of 8 UNITED STATES ifd POSTAL SERVICE U.S. POSTAGE» PITNEY8O ES Certificate Of !' Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. From; Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-153326/nfe TEAM- C TO7 UNKNOWN SPOUSE 304 Schuykill Street Dauphin, PA 17018-9476 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Ir� 0001387430JUL 17 2014 00120 To pay fee, affix stamps or meter postage here. Postrnprti Here IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA [P'SRW1OFUZO1Z-\Trust, byU.6.Bank Trust National Association, not in Its individual capacity : but 5oieIy as Trustee VS. Plaintiff, Defendants. CIVIL DIVISION NO.: 11-7208 Notice of the Date of Continued Sheriff Sale The Sheriff Sale scheduled for September 3, 2014 at 10:00 AM in the above captioned matter has been continued until October 1, 2014 at 10:00 AM. BY: Dated: September 2, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC 's Christina Covert, Legal Assistant File No.: XFP-153326 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com �