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HomeMy WebLinkAbout11-7842I., Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Christina C. Viola, Esquire ID. Nos. 04267 / 85165/308909 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Tz? ?n- ?r1C1 CC UAVe,. Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgage Loan Trust, Series 2011- 1 Asset-Backed Pass-Through Certificates, PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ` DOCKET NO: `1_-) CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT - CIVIL ACTION NOTICE TO DEFEND NOTICE Q C?? as-l3lP It YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim of relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION ACERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE 2 OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 ,I Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Christina C. Viola, Esquire ID. Nos. 04267 / 85165/308909 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgage Loan Trust, Series 2011- 1 Asset-Backed Pass-Through Certificates, PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgage Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: Plaintiff, Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgage Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, is a national banking association under 4 and pursuant to the National Banking Act (13 Stat. 99, 12 U.S.C. 1 et seq.) with its principal place of business at 1610 E. St. Andrew Pl. #B150, Santa Ana, CA 92705. 2. Defendants, Tracy L. Shulda and Ronald L. Shulda Jr., are the real owners, mortgagors, and grantees in the last Deed of record to the real property located at 614 North Front Street Wormleysburg, PA 17043 and, if applicable, riparian rights appertaining thereto (hereinafter referred to as "Premises") . 3. On September 13, 2006, Defendants made, executed, and delivered a Mortgage to Mortgage Electronic Registration Systems, Inc. nominee for Capital One Home Loans LLC its successors and assigns (hereinafter referred to as "Originating Lender") as security for Defendants' payment and other obligations in consideration of a loan made to Defendants by the Originating Lender. Said Mortgage is recorded in the Office of the Recorder in and for Cumberland County, in was recorded on October 3, 2006 in Carlisle County in Mortgage Book 1968, Page 787 , and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. The aforesaid Mortgage has not been re-recorded. The aforesaid Mortgage has not been modified. 6. Plaintiff is the Originating Lender, a legal successor thereto, or an assignee of the Originating Lender through Assignment of Mortgage. 7. The address of the Premises is 614 North Front Street, Wormleysburg, PA 17043. The aforesaid Mortgage is in default because the required monthly payments due under the terms of the aforesaid promissory note and Mortgage have not been made from February 1, 2010 through the present date. By the terms of the aforesaid Mortgage, upon 9 10 11. 12. breach and failure to cure said breach after written notice thereof, all sums secured by said Mortgage shall be immediately due and owing. The terms of the aforesaid Mortgage further provide that, in the event of default, Defendants shall be liable for, inter alia, Plaintiff s costs and attorneys' fees. The following amounts are due as of October 1, 2011: Principal Accrued Interest through October 1, 2011 Late Fees Corporate Advances Escrow Advances Unapplied Funds 5% of Principal for Attorneys' Fees Total $ 111,333.31 $ 15,325.11 $ 1335.78 $ 1503.00 $ 3468.97 $ 262.42 $ 5566.66 $ 138,795.25 plus additional pre judgment and post judgment interest at the per diem rate of $24.02 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, and any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage and promissory note. If the Mortgage is reinstated prior to a sheriff's sale, the attorneys' fees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys' fees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneys' fees of up to five percent (5%) of the remaining principal balance in the event the Premises is sold to a third party purchaser at sheriff's sale; or, if the complexity of the action requires additional fees, such fees may exceed the amount demanded in the preceding paragraph. Plaintiff is not seeking a judgment on personal liability (or an in personam judgment) against Defendants in this action but reserves the right to bring a separate action to establish that right, if such right exists. If Defendants received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish the personal liability that was discharged in bankruptcy, but only to foreclosure the Mortgage and sell the Premises pursuant to Pennsylvania law. 13. Plaintiff has demanded the total amount due from Defendants, but Defendants have failed and/or refused to pay the same. 14. Notice of Intention to Foreclose pursuant to 41 P.S. 1 403 and Notice pursuant to the Homeowner=s Emergency Mortgage Assistance Act of 1983, 35 P.S. , 1680.402c, et seg. (hereinafter collectively referred to as "Act 91 Notice") was mailed to Defendants on March 3, 2011. WHEREFORE, Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendants, Tracy L. Shulda and Ronald L. Shulda Jr., for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 10., namely $138,795.25, plus additional pre judgment and post judgment interest at the per diem rate of $24.02 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage and promissory note, and such other relief as this Court deems just and proper. RICHARD M. SQUIRE & ASSOCIATES, LLC By: chard M. S ire, Esq. (PA I.D.# 04267) . Troy F edman, Esq. (PA I.D.# 85165) Christina C. Viola, Esq. (PA I.D.# 308909) 115 West Avenue, Suite 104 7 Date: f 4c 11 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquireAsquirelaw.com tfreedman@squirelaw.com cviola@squirelaw.com Attorneys for Plaintiff UNLESS YOU NOTIFY US WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER/NOTICE/PLEADING THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED, WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE, WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR REQUEST WITHIN THIRTY (30) DAYS, WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Christina C. Viola, Esquire ID. Nos. 04267 / 85165/308909 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgage Loan Trust, Series 2411- 1 Asset-Backed Pass-Through Certificates, PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION Tom Croft, hereby states that he/she is SVP of REO for Carrin on Mortgage Services LLC as Attorney In Fact of Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgage Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, Plaintiff in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge, information or belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. ill n Name: Tom C ft DATE: SP 3 0 2011 File #: CMS-107F Title: Sr. Vice President of REO Name: Tracy L. Shulda and Ronald L. Shulda Jr. f w EXHIBIT "A" In brad pidd, dw meeipt wlatraof is husby acbw*WW the aid, Motor dm Weby l toselber ad CORM to ft Wd VmiW% ALL thid catain l pw*W or tract of Fmzx , w#0i the knpwvmaft Wma erwead. slam a in the Borough of dead b ? Ctmb~ ' Pmm*=* more, p curl r bw4nd?ed end BZCyllNl IW at a paint *0 to aaothwastara line of North Front $MO. said point bd16 9114.00 f6d D a tatarOWN d dm ftm 60 J#k%V Of Nork Font Skye d acid: 9W& Avnuw, esid poW being WW on the dlvidias liter b o un LOIA Nou. 30 and 40 on dlw,haWoAW urea d Plan of low, tbe"cse a k ft said he !lnuth 48 *pm 30 minim VW4 175.00 feat fm a point an ttie noramo m laaa of a f tbeto't fool theme along ssid allay North 41 degree 30 mirnutm Wm 20.0 thet'1 a point an the dividiag line bWmxn Tats Na. 40 and 411 throe don$ said 1m ad dbw* tin cuter of a padliaaet wall aptatiing pneattiia 614 and 616 Nm* P'aW Mar& 49 &pm 30 this wj EsK 175-00 feat to at ptuatt on the soutlmatm lim of Nus Prom Stmct; tbUM along the line ot` NaKh Front Str" Bow& 41 depus 30 minatat' Bast 7A09 het to a polK the pob t ad placo of UCYllMNG. 'l WG 't`NMON IMECTED a two and Me-half r brick and 9&Vk dwelling b*wn aaa No., 414 W*dh Front S ka t, BZfi41G Lot No. 40 on plan of lou lipid out by Edwin U ltmAny ud known as "Rivearvi+betl"' Paid plan being rooamed in Pfau Book 1. Peg* YOB, t barlmd Cemr Record. 10 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor pti? 11' 0? C 111111) r' l4/ X0 THELFRq NONOTAR 201 I NOV 16 AM 9: 23 VUMB£RLAND COUNT4' PENNSYLVANIA Wells Fargo Bank Case Number vs. 2011-7842 Ronald L. Shulda, Jr. (et al.) SHERIFF'S RETURN OF SERVICE 11/03/2011 07:50 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 3, 2011 at 1950 hours, he served a true copy of the within Complaint in gage Foreclosure, upon the within named defendant, to wit: Ronald L. Shulda Jr., by making known to imself personally, at 614 N. Front Street, Wormleysburg, Cumberland County, Pennsylvani 704 its c ntents and at the same time handing to him personally the said true and correct copy of ttn . S DE 11/03/2011 07:50 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on November 3, 2011 at 1950 hours, he served a true copy of the within Complai i Mortgage Foreclosure, upon the within named defendant, to wit: Tracy L. Shulda, by making kn wn u to erself personally, at 614 N. Front Street, Wormleysburg, Cumberland County, Pennsylvani 704 its ontents and at the same time handing to her personally the said true and correct copy of t e. y 74 ISON, DEPUTY SHERIFF COST: $60.44 November 04, 2011 'C? cowltySuitc Snerfl. I einossea t. I"I" SO ANSWERS, RON R ANDERSON, SHERIFF t0 a0TA'T' Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff f'4 P"I 1: 11 Attorneys for PlamtifLgiG -C 0 U`1T Y EF??13YL` AN'lA Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS. TO THE PROTHONOTARY: PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2011-7842 CIVIL ACTION Kindly enter judgment in favor of Plaintiff and against Tracy L. Shulda and Ronald L. Shulda Jr., Defendants, for his/her/its/their failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises as described in Plaintiffs Complaint, and assess Plaintiff's damages as follows: As set forth in the complaint Interest from 10/2/2011 to 6/20/2012 Total $ 138,795.25 $ 6,245.20 $ 145,040.45 ??,# as3sa -7oQ3 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) Wk8 FAClients\Carrington\Shulda - 107F\Default JudgmentmpdHAO i A r l? 1P that notice has been given in accordance with Rule 237.1, copy attached. RICHARD M. SQUIRE & ASSOCIATES, LLC By: Richard. Squire, Esq. (PA I.D.# 04267) _,,-?. oy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire ,squirelaw.com tfreedmangsquirelaw.com coppenheimer(2squirelaw.com Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: C 4: 3U6Ao • PROT OTARY FAClients\Carrington\Shulda - 107F\Default JudgmentmpdHAO Y Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Attorneys for Plaintiff Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS. DOCKET NO: 2011-7842 CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he is one of the attorneys for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemember's Civil Relief Act of 2003, as amended. (b) that Defendant(s) is/are over 18 years of age and reside(s) or maintain(s) an address at 614 North Front Street, Wormleysburg, PA 17043. FAClients\Caaington\Shulda - 107F\Default Judgment.wpdHAO ul This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RICHARD M. SQUIRE & ASSOCIATES, LLC By: Richar. . Squire, Esq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire&squirelaw.com treedman(2sauirelaw.com coppenheimera_sauirelaw.com Attorneys for Plaintiff FAClients\Carrington\Shulda - 107F\Default Judgment.wpdHAO 4 Department of Defense Manpower Data Center Results as of: Jun-1&201206:51:56 ` SCRA 2.2.1 Status ROPDrt PlursmW to Servicememben Civil Relief Act Last Name: SHULDA First Name: RONALD Active Duty Status As Of: Jun-19-2012 Active Duty Start DWe Ar#e D* End Do" Sb4a sertdaR Csatpsrw d On ACO" Duty On A*m Duty 91ekw Dele NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Lot Active Duty VONA 387 0" of Ac** Dutir Sbhrs Dear Active Duty S1uat Date Active Duty End Dads $fwtus Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or hW Vim Ung Wes Noll of a FA" Ce"* to Ao0ve Duty on Ad Duly titer D6W Order NoWcWon Star) Date Order No on End Date state service Component NA NA No NA This response reflects whether the individual or hl&ftw unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. rte,,. A ,?..?,-?.. Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Results as of: Jun-19-2012 06:57:24 SCRA 2.2.1 Status Report Pursuant to Services Civil Relief Act Last Name: SHULDA First Name: TRACY Active Duty Status As Of: Jun-19-2012 Active Duty Shut Deis #4" Duly F.nd Dow BMUR $WNa1 cornponw On Acth+ Duly On Adke Duty 6fahtt Daft NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date tale Aalka D* V9pttit1 m7 pays d ApMs puy *a as Data Active Duty Stan Data AtdM Duty End Daft StaYa sar?ice coarparrsnt NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Mernber or H1a ler Ur* Was Mollllad of a FL*m C0* la Aollva Duly on Aaw ouy %sew Data Order Notilicallon start Dale Order NoO at tlon End Data Stsbn 3rarrfcr component NA NA No NA This response reflects whether the Individual or Nsltw unit has received early nodlicetlon to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 401 We, Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. NOTICE TO: Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 Pursuant to require ents of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on o1 , a judgment(decree)(order) was entered against you in this office in the proceeding as indicated above. Deputy Prothonotary Date Mailed: va FAClients\Carrington\Shulda - 107F\Default JudgmentmpdHAO 5 i Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. NOTICE TO: Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Pursuant to req firemen of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on a judgment(decree)(order) was entered against you in this office in the proceedin indi ed abo • Prothonotary Deputy Prothonotary Date Mailed: l FAClients\Carrington\Shulda - 107F\Default JudgmentmpdHAO 6 r Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. TO: Tracy L. Shulda 614 North Front Street Wormleysburg PA 17043 DATE OF NOTICE: May 29, 2012 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST FAClients\Carrington\Shulda - 107F\10 Day LTR.wpd\HAO 0 ' YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F:\Clients\Carrington\Shulda - 107F\10 Day LTR.wpd\HAO r 1 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, PLAINTIFF, V. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. TO: Ronald L. Shulda Jr. 614 North Front Street Wormleysburg PA 17043 DATE OF NOTICE: May 29, 2012 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST FAClients\Carrington\Shulda - 107F\10 Day LTR.wpd\HAO i? 4 YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F:\Clients\Carrington\Shulda - 107F\10 Day LTR.wpd\HAO WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-7842 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. AS TRUSTEE FOR STANWICH MORTGAGE LOAN TRUST, SERIES 2011-1 ASSET-BACKED PASS-THROUGH CERTIFICATES Plaintiff (s) From RONALD L. SHULDA JR., TRACY L. SHULDA (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $145,040.45 L.L.: $.50 Interest FROM 6/Zl/2012 TO 12/5/2012 @ $24.02 PER DIEM - $4,035.36 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $199.94 Other Costs: Plaintiff Paid: Date: 9/4!2012 -~ -~ David D. Buell, Prothonotary~yy~ Deputy REQUESTING PARTY: Name: CRAIG O`PPENHEIMER, ESQUIRE Address: RIChIARD M. SQUIRE & ASSOCIATES, LLC ONE JENKINTOWN STATION, SUITE 104 115 WEST AVENUE JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 313264 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Attorneys for Plaintiff AND Telephone:215-886-8790 Fax:215-886-8791 212 SEP -4 PFD i s 3~ ~, ~~ Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. IN THE COURT OF CO1VIMbN'1~.EAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) To the Prothonotary: Kindly issue a Writ of Execution in the above matter. Amount Due $ 145,040.45 Interest From 6/21/2012 to 12/5/2012 @ $24.02 per diem ~ 4,035.36 Total: $ 149,075.81 * plus fees and costs Date: August 28, 2012 Q I~o.~ ~~ ~ t~ i. ~~' ~ !t t~ ~l~ •SD ~i a c~• sO qy Q~ By: ,...e.~oe Richard M. quire, Esq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) ~/ Craig Oppenheimer, Esq. (PA LD.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) r.~uire@,~quirelaw.com tfreedmanna squirelaw com connenheimerna.squirelaw com A orneys for Plaintiff ~a.as ~. ~. 5~ ~~ CMS-I07F/DM1 C~ ~(~3~a ,~ ~ gai t~ t~ u', ~ ~~ ~ ~- ~s~ d N v ono O N z 0 Q w O Q a a O O w O a 0 W H H ~ ~ ~ U ~ 'a~ U ~ ~~ ~°a. .~ ~a ~, as d¢ z~ Gq ~ a~ °~' ~~ 3 M ~ ~ ~ M ~ ~t ~o ~~~ '~ b~ bA ~ bA a ~' o Z E~z,a?A _ ~ rr ~ ~t ~~ ~~ z 0 H .-• W ~, G a~i ~ O ~' ~o ~ o ~ ~ U a w U ~ .~•~.a.~~ ono ~ ~ '~"~"~ ~ W W R b ~o 00 ~ .~ y ~ ~ ~ ~ a ~~~~¢a'~ w ~~~ ~ w~ N.onv~ ~~ ~o~ ~ ~~~~~~~~ I~ ,~~ ti~a ~~ U a v a 0 w e w 0 v~ U LEGAL DESCRIPTION THE FOLLOWING DESCRIBED REAL PROPERTY SITUATE IN THE BOROUGH WORMLEYSBURG, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA, TO WIT: ALL THAT CERTAIN PIECE, PARCEL OR TACT OF GROUND, TOGETHER WIT THE IMPROVEMENTS THEREON ERECTED, SITUATE IN 7HE BOROUGH OF WOR LEYSBURG, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED ND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT A POINT ON THE SOUTHWESTERN LINE OF NORTH FRONT REST, SAID P01NT BEING 300.00 FEET 1N A NORTHWESTERN DIRECTION FROM THE INT RSECTION OF NORTH FRONT STREET AND STELLA AVENUE; SAID POINT BEING ALSO N THE DIVIDING LINE BETWEEN LOTS NOS. 39 AND 40 ON THE NEREINAt1'ER MEN TONED PLAN OF LOTS; THENCE ALONG SAID LINE SOUTH 48 DEGREES 30 MINUTE WEST, 175.00 FEET TO A POINT ON THE NORTHEASTERN LINE OF A FIFTEEN FOO WIDE ALLEY; THENCE ALONG SAID ALLEY NORTH 41 DEGREES 30 MINUTES WES , 20.00 FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS N0.40 AND 41; THENCE ALONG SAI[ LINE ANO THROUGH THE CENTER OF A PARTITION WALL SEPARATING PRE tSES 614 AND 616 NORTH FRONT STREET NORTH 48 DEGREES 30 MINUTES EAST, 17 .00 FEET TC A POINT ON THE SOUTHWESTERN LINE OF NORTH FRONT ST~tEET; THENC ALONG THE LINE OF NORTH FRONT STREET SOUTH 41 DEGREES 30 MINUTES EAS , 20.00 FEET TO A POINT, THE POINT AND PLACE OF BEGINNING, HAVING THEREON ERE TED A TWC AND ONE-HALF STORY BRICK AND SHINGLE DWELLING KNOWN AS N0.614 NORTH FRONT STREET. BEING LOT N0.40 ON PLAN OF LOTS LAID OUT BY EDWIN M. HERSHEY "RIVERVIEW' SAID PLAN BEING RECORDED IN PLAN BOCK 1, PAGE 103, COUNTY RECORDS. TAX ID #: 47-19-1588-018 AND~KNOWN AS CU BERLANQ Being the same premises which Tracy L. Shulda granted and conveyed unto Tracy L. Shulda a Shulda, Jr. by Deed dated August 31, 2001 and recorded September 20, 2001 in the Office of of Deeds for Cumberland County, Pennsylvania in Deed Book 248, Page 2252. Ronald L. Recorder F:\Clients\Carrin8ton\Shulda - 107F\writ package 8-25-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. a; ~~I2 Sip , ~ ~'~'~ `' ~~~~$ Y~~~N ~~~~` IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA N0.2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 31291 Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Back Pass-Through Certificates, Plaintiff in the above action, being authorized to do so, sets forth as the date the Praecipe for the Writ of Execution was filed, the following information concerning t real property located at 614 North Front Street, Wormleysburg, PA 17043 Parc No:.47-19-1588-018. 1. Name and last known address of Owner(s) or Reputed Owner(s): Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 2. Name and last known address of Defendant(s) in the judgment: Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates 1000 Technology Drive O'Fallon, MO 63368-2240 CitiMortgage, Inc 1000 Technology Drive O'Fallon, MO 63368-2240 James C. Costopoulis 1925 Chatham Drive, Camp Hill, PA 17011 4. Name and address of last recorded holder of every mortgage of record: Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates 1000 Technology Drive O'Fallon, MO 63368-2240 CitiMortgage, Inc 1000 Technology Drive O'Fallon, MO 63368-2240 MERS PO Box 2026 Flint, MI 48501-2026 MERS 1818 Library Street, Ste 300 Reston, VA 20190 Capital One Home Loans LLC 12800 Foster Avenue Overland Park, KS 66213 5. Name and address of every other person who has any record lien on the None other. 6. Name and address of every other person who has any record interest in the prope~ and whose interest may be affected by the sale: Domestic Relations 13 North Hanover Street PO Box 320 Carlisle, PA 17013 F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd Tax Claim Bureau One Courthouse Square -Room 106 Carlisle, Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn :Legal Department Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 7. Name and address of every other person of whom the plaintiff has knowledge w~o has any interest in the property which may be affected by the sale: Tenant/Occupant 614 North Front Street Wormleysburg, PA 17043 VERIFICATION I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC By: - 'char .Squire, Esquire M. Troy Freedman, Esquire / Craig Oppenheimer, Esquire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215)886-8790 Attorneys for Plaintiff Date: August 28, 2012 F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 3132b4 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Attorneys for Plaintiff #; ~..,_ 1.~.~.1 ~r ~lGt ~~ ~' ~NSYl~.~~H~~V ~A Telephone:215-886-8790. Fax:215-886-8791 Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. CERTIFICATION IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNSYLVANIA N0.2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE Craig Oppenheimer, Esquire, hereby verifies that he is an attorney for the Plaintiff in the captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA Mortgage ( ) Non-owner occupied ( ) Vacant (X) Act 91 Procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to uns~ falsification to authorities. Date: August 28, 2012 By; ~_ Richard 1GC Sq~e, Esq. (PA LD.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) ~/ Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquirena squirelaw com tfreedmanna.sauirelaw.com copnenheimer(a~,~uirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone:215-886-8790 Fax:215-886-8791 Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. -, 101p~EP -4 ~~~~'` IN THE C PLE CUMBERLAN ,' NIA N0.2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE AFFIDAVIT OF LAST KNOWN DRESSES I, Craig Oppenheimer, Esquire, being duly sworn according to law, hereby depose and say that I am one of the attorneys for Plaintiff in the above matter and that the last known address for the Defendants herein ar~ as follows: Defendants: Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 Date: August 28, 2012 By: Richard . Squir , sq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) !/Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire,, s~uirelaw.com tfreedmanna,~quirelaw.com coppenheimerla.squirelaw com F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone:215-886-8790 Fax:215-886-8791 Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, . v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. ~~ ~~ ~~~~ ~ ~M~1~f0~'Ar',=,. ~, 2Q~1 SEP -4 PM 1: ~ ~ ~~~~ERLQ~p C~~ITY i~E~?~,~Y~v,~~;~ 1N THE COURT OF COMMON PLE CUMBERLAND, PENNSYLVANIA N0.2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION OF NON-MILITARY SERVICE Craig Oppenheimer, Esquire, hereby verifies that he is one of the attorneys for the P above-captioned matter, and that on information and belief, he has knowledge of the following facts, to (a) that the Defendants aze not in the Military or Naval Service of the United States or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 2003, as amend< (b) that Defendants aze over 18 years of age and reside at 614 North Front Street, W 17043. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating falsification to authorities. Dated: August 28, 2012 By: ~-- Richaz M. Squire, Esq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) ~ Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquirela.sauirelaw.com lfreedmannasAuirelaw. com copt~enheimer(a~squirelaw.com iff in the Allies, or PA unsworn F:\ClientslCarrington\Shulda - 107F\writ package 8-25-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 ! 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff ~, ~ -a'... ~ ~ ~ f~3~ ~~ai~ ~ _7 tp.. ~,t1p~a~ ~ P~ ~ ` ~ 7 PENS ~~ A ~U,Y~y, Nlq Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 Your house (real estate) at 614 North Front Street, Wormleysburg, PA 17043 is schedule to be sold at Cumberland County Sheriff Sale, on Wednesday,12/5/2012 at 10:00 a.m., at the Courthouse, l ourthouse Square, Carlisle, PA 17013 to enforce the court judgment of $145,040.45 plus interest to th sale date obtained by Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Seri s 2011-1 Asset-Backed Pass-Through Certificates against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale you must take immediate action: 1. The sale will be canceled if you pay back to Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, the mount of the judgment plus costs or the back payments, late charges, costs and reasonable ttorneys' F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire, M. Troy Freedman, Esquire or Craig Oppenheimer, Esquire at (215) 886-8790.' 2. You may be able to stop the sale by filing a petition asking the Court to strike ' r open the judgment, if the judgment was improperly entered. You may also ask the Court o postpone the sale for good cause. i 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more ~hance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1 2 3 4. 5. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder You may find out the price bid by calling the Cumberland Sheriff s Office at 717-240-610 . You may be able to petition the Court to set aside the sale if the bid price inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriff the full amount due To find out if this has happened you may call the Cumberland County Co 717-240-6100. If the amount due from the buyer is not paid to the Sheriff, you will, remain the property as if the sale never happened. You have a right to remain in the property until the full amount due is paid to the the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal prc evict you. 6. You may be entitled to a share of the money which was paid for your house. A distribution of the money bid for your house will be filed by the Sheriff no later t] after the Sheriff s Sale. This schedule will state who will be receiving the money. will be paid out in accordance with this schedule unless exceptions (reasons why tl distribution is wrong) are filed with the Sheriff within ten (10) days after the date said schedule. 7. You may also have other rights and defenses or ways of getting your house immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 grossly the sale. house at of the and s to hedule of n 30 days he money proposed f filing of if you act F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Attorneys for Plaintiff ~: t ~ -~ ~ ~ t_4_,,N I' r ,1 ~ ~ ~ i ~ ~ I f"~'... r~. ~•.jJ~r ~_,ti1. ~.~ Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS. 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE PLAINTIFF'S MOTION FOR ALTERNATIVE SERVICE OF THE NOTICES OF SHERIFF'S SALE AND NOW, comes Plaintiff, Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, by its undersigned attorney and moves this Honorable Court for an Order permitting alternative service of the Notices of Sheriffs Sale upon Defendants by (1) sending a true and correct copy thereof to Defendants via simultaneous certified mail return receipt requested and regular mail postage prepaid to 614 North Front Street, Wormleysburg, PA 17043 and to the Defendants' last known address at 133 South 48`h Street, Apartment 6S, Harrisburg, PA 17111; (2) posting a true and correct copy thereof on the mortgaged premises at 614 North Front Street, Wormleysburg, PA 17043 by any competent adult. In support thereof, Plaintiff avers the following: 1. In this mortgage foreclosure proceeding, Plaintiff properly caused a default judgment to be entered against Defendants. as a result of their failure and/or refusal to make, tender, and deliver the monthly mortgage payments. 2. Plaintiff thereafter properly caused a Writ of Execution to be issued in order to list Defendants' property situated at 614 North Front Street, Wormleysburg, PA 17043 (hereinafter referred to as "mortgaged premises") for the 12/05/2012 Cumberland County sheriff s sale. That sale may need to be postponed to a later date due to difficulties encountered in serving Defendants with the Notices of Sheriffs Sale, pursuant to Pa. R.C.P. 3129.2(a), as explained herein. 3. The Defendants could not be served with the Notices of Sheriff's Sale at the mortgaged premises. A true and correct copy of the Cumberland County Sheriff's Return of Service for both Defendants is attached hereto as Exhibit "A" and made a part hereof. Notably, the Cumberland County Sheriff's Return of Service states the following: " `Not Found' at 614 N. Front Street, Wormleysburg, PA 17043, property is vacant, post office is still delivering mail there." as to both defendants. See Ex. "A." 4. Pursuant to Pa. R.C.P. 430, Plaintiff has made good faith efforts to locate Defendants. Affidavits of Good Faith Investigation, which sets forth the specific inquiries made and the results thereof, are collectively attached hereto as Exhibit "B" and made a part hereof. ` 5. The Defendants could not be served with the Notices of Sheriff's Sale at a suspected alternate address of 133 South 48"' Street, Apartment 6S, Harrisburg, PA 17111. True and correct copies of the private process server's Affidavits of 'Social security numbers and dates of birth have been omitted in observance of federal privacy laws. Service for both Defendants are collectively attached hereto as Exhibit "C" and made a part hereof. Notably, the private process server's Notes indicate the following: "The provided address is vacant." See Ex. "C." 6. Requests for Change of Address or Boxholder [hereinafter referred to as "Requests"], pursuant to 36 C.F.R. 265.6(d)(6)(iii), completed and certified by the Wormleysburg, Pennsylvania Postmaster indicate that Defendants received mail at the mortgaged premises as of the date thereof. True and correct copies thereof are collectively attached hereto as Exhibit "D" and made a part hereof. 7. As of the present date, Defendants have not contacted Plaintiff or the undersigned to bring their delinquent mortgage loan current through a reinstatement, enter into a forbearance plan, propose a Deed in Lieu of Foreclosure, or discuss the sale of the mortgaged premises. Defendants' inaction and utter failure to take any initiative whatsoever strongly suggests that they are avoiding and/or evading their mortgage company and outstanding indebtedness. 8. Despite Plaintiffs good faith efforts to locate Defendants, it appears more likely than not that they are avoiding and/or evading service of the Notice of Sheriff's Sale. Plaintiff requests an Order in the form attached so that Defendants can be properly served via alternate means with notice of the sheriff s sale thirty (30) days or more before such sale in accordance with Pa. R.C.P. 3129.2(c). 9. Pursuant to Cumberland County Local Rule 208.3(a)(9), Plaintiff sent a request for concurrence with copies of the herein Motion for Alternative Service of the Notice of Sheriff s Sale to Defendants on October 30, 2012 via simultaneous regular mail and certified mail, return receipt requested. True and correct copies of the cover letter and proofs of the aforesaid mailing are collectively attached hereto as Exhibit "E" and made a part hereof. Defendants have not responded to Plaintiff s request for concurrence. 10. This matter has not previously been assigned to a Judge for disposition. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting service of the Notices of Sheriffs Sale upon Defendants by (1) sending a true and correct copy thereof to Defendants via simultaneous certified mail return receipt requested and regular mail postage prepaid to 614 North Front Street, Wormleysburg, PA 17043 and to the Defendants' last known address at 133 South 48`h Street, Apartment 6S, Harrisburg, PA 17111 ;and (2) posting a true and correct copy thereof on the mortgaged premises at 614 North Front Street, Wormleysburg, PA 17043 by any competent adult. Respectfully submitted, ~j RICHARD M. SQUIRE & ASSOCIATES, LLC Dated: November ! , 2012 By: Richard .Squire, Esq. (PA LD.# 04267) ~M. T ~ reedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsauirensauirelaw.com tfreedmannsquirelaw.com coppenheimer(a,sauirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS. 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2011-7842 CIVIL ACTION MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, M. Troy Freedman, Esquire, hereby certify that, on this date, I served or caused to be served a true and correct copy of the foregoing Plaintiff's Motion for Alternative Service of the Notice of Sheriff's Sale, Brief/Memorandum of Law, Verification, Praecipe for Argument, and proposed form of Order upon the following person via regular mail, postage prepaid: Ronald L. Shulda Jr. 614 North Front Street And 133 South 48`h Street, Apt 6S, Wormleysburg, PA17043 Harrisburg, PA 17111 Tracy L. Shulda 614 North Front Street And 133 South 48`h Street, Apt 6S, Wormleysburg, PA17043 Harrisburg, PA 17111 RICHARD M. SQUIRE SOCIAT ~- Dated: November ~ , 2012 By: Richard .Squire, Esq. (PA I.D.# 04267) M. Tr y Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsauirena.sa uirelaw. com tfreedmannae,squirelaw.com c~enheimer(asauirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC' Attorneys for Plaintiff By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215- 886-8790 Fax: 215-886-8791 Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, PLAINTIFF, v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2011-7842 CNIL ACTION MORTGAGE FORECLOSURE BRIEF/MEMORANDUM OF LAW With respect to service of a Notice of Sheriff's Sale, Pa. R.C.P. 3129.2(c) provides, in pertinent part: (c) The [Notice of Sheriff s Sale] shall be prepared by the plaintiff, shall contain the same information as the handbills or may consist of the handbill and shall be served at least thirty days before the sale on all persons whose names and addresses are set forth in the affidavit required by Rule 3129.1. (1) Service of the [Notice of Sheriff s Sale] shall be made (i) upon a defendant in the judgment who has not entered an appearance and upon the owner of the property. (A) by the sheriff or by a competent adult who is not a party to the action in the manner prescribed by Rule 402(a} for the service of original process upon a defendant, or (B) by the plaintiff mailing a copy in the manner prescribed by Rule 403 to the addresses set forth in the affidavit; or (C) if service cannot be made as provided in subparagraph (A) or (B), the notice shall be served pursuant to special order of court as prescribed by Rule 430, except that if original process was served pursuant to a special order of court under Rule 430 upon the defendant in the judgment, the under Rule 430 upon the defendant in the judgment, the notice may be served upon that defendant in the manner provided by the order for service of original process without further application to the court; and [...] Pa. R.C.P. 430(a) provides, in pertinent part: (a) If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of defendant and the reasons why service cannot be made. Official Note A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales v. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As reflected on the attached Sheriff's Return of Service and private process server's Affidavits of Service, Plaintiff's multiple attempts to have Defendants served with the Notices of Sheriffs Sale, in accordance with Pa. R.C.P. 3129.2(c)(1)(i)(A), have been unsuccessful. See Exs. "A" and "C." Requests for Change of Address or Boxholder, pursuant to 36 C.F.R. 265.6(d)(6)(iii), completed and certified by the Wormleysburg, Pennsylvania Postmaster indicate that Defendants received mail at the mortgaged premises as of the date thereof. See Ex. "D." Good faith efforts to discover the whereabouts of Defendants have been made, as evidenced by the numerous inquiries set forth in the attached Affidavit of Good Faith Investigation. See Ex. "B." In particular, inquiries have been made to the following persons and entities: Directory Assistance, White Pages, and On-Line Telephone Records; 2. County Tax Assessment; Federal Aviation Administration; Pennsylvania Department of State-Uniform Commercial Code filings; and 6. Pennsylvania Department of Corrections. See id. Also searched were United States Bankruptcy Court records, sexual offenders database, nationwide professional licenses, federal firearms and explosives licenses, and civil proceedings filed in the Commonwealth of Pennsylvania. See id. As of the present date, Defendants have not contacted Plaintiff or the undersigned to bring their delinquent mortgage loan current through a reinstatement, enter into a forbearance plan, propose a Deed in Lieu of Foreclosure, or discuss the sale of the mortgaged premises. Defendants' inaction and utter failure to take any initiative whatsoever strongly suggests that Defendants are avoiding and/or evading their mortgage lender and outstanding indebtedness. Based on the foregoing, it is more likely than not that Defendants are avoiding and/or evading service of process. For all of the foregoing reasons, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) and 430 permitting service of the Notices of Sheriffs Sale upon Defendants by (1) sending a true and correct copy thereof to Defendants via simultaneous certified mail return receipt requested and regular mail postage prepaid to 614 North Front Street, Wormleysburg, PA 17043 and to the Defendants' last known address at 133 South 48`h Street, Apartment 6S, Harrisburg, PA 17111; and (2) posting a true and correct copy thereof on the mortgaged premises at 614 North Front Street, Wormleysburg, PA 17043 by any competent adult. Respectfully submitted, RICHARD M. SQUIRE & ASSOCIATES, LLC Dated: November ~, 2012 Richar .Squire, Esq. (PA I.D.# 04267) ~M. y Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquirena,squirelaw.com tfreedman(a,squirelaw.com coppenheimernsquirelaw.com Attorneys for Plaintiff Exhibit "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith __ -- __ Chief Deputy _ _. _ F-. Richard WStewart Solicitor ~.F~;~~ =~~.~= ~~-~ ~us~~~~=~ Wells Fargo Bank Case Number vs. Ronald L. Shulda, Jr. (et al.) 2011-7842 SHEF'IF~F'S RET~~RN OF SERVICE 09/28/2012 03:29 PM -Deputy Ryan Burgett, 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 614 N. Front Street, Wormleysburg Borough, Wormleysburg, PA 17043, Cumberland County. 10/10/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Tracy L. Shulda, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 614 N. Front Street, Wormleysburg, PA 17043, property is vacant, post office is still delivering mail there. 10/10/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Ronald L. Shulda, Jr., but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 614 N. Front Street, Wormleysburg, PA 17043, property is vacant, post office is still delivering mail there. SHERIFF COST: $908.75 SO ANSWERS, ~. October 10, 2012 RONN R ANDERSON. SHERIFF Exhibit "B": Affidavit of Good Faith Investigation _ _ AFfiDAVIT OF GOOD-FAITH INVESTiGAfiION Commonwealth of Pennsylvania County of Montgomery SS: I, Rosemary McCrory Sweet, an Owner of Rosemary McCrory Sweet Investigation, BEING OF FULL AGE AND UPON MY OATH STATE AND DEPOSETHE FOLLOWING: 1) I HAVE PERFORMED A GOOD FAITH INVESTIGATION ON THE FOLLOWING SUBJECT AND PROPERTY LOCATED IN THE COMMONWEALTH OF PENNSYLVANIA. 1. THE SUBJECTS NAME(S) IS/ARE: RONALDLEOPOLDSHULDAIR D08:7/17/1962 2. THE PROPERTYADDRESS IS 614 N FRONT 5T, WORMLEYSBURG PA 17043-1022, CUMBERLAND COUNTY (Oct 2002 -Jun 2008 2) THE FOLLOWING SEARCHES WERE PERFORMED IN AN EFFORT TO LOCATE THE SUBJECT(S): 1. SOCIAL SECURITY MASTER DEATH INDEX: NO RECORD FOUND 2. THE SUBJECTS CURRENT ADDRESS AS DETERMINED BY THIS REPORT IS BELIEVED T0: 614 N FRONTST, WORMLEYSBURG PA 17043-1022, CUMBERLAND COUNTY (Oct 2002 -Jun 2008) Name Associated with Address: RONALD L SHULDA 1R Current Residents at Address: RONALD LEOPOLD SHULDA JR 717-763-4358 3. DIRECTORY ASSISTANCE, WHITE PAGES, AND OTHER ON-LINE TELEPHONE RECORDS 614 N FRONT ST, WORMLEY58URG PA 17043-1022, CUMBERLAND COUNTY (Oct 2002 -Jun 2008) Name Associated with Address: RONALD L SHULDA JR Current Residents at Address: RONALD LEOPOLD SHULDA JR 717-763-4358 Phones Plus[s): Phones Plus 1 Name: SHULDA, RONALD Address: 614 N FRONTST, LEMOYNE PA 17043-1022 Phone Number: 717-720-3028 -EDT Carrier: VERIZON PENNSYLVANIA - (HARRISBURG , PA ) Phones Plus 2 __ _ _ Name: SHULDA, RONALD Address: SWATARA PA 17111 Phone Number: 717-877-2607 -EDT Phone Type: Mobile Carrier: NEW CINGULAR WRL DC- (HARRISBURG, PA ) 4. ADDRESS HISTORY SEARCH Address Summary: 614 N FRONT ST APT B, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY (Sep 1956 -Sep 2012) 614 N FRONTST, WORMLEYSBURG PA 17043-1022, CUMBERLAND COUNTY (Oct 2002- Jun 2008) 133 5 48TH ST APT 6, HARRISBURG PA 17111-3466, DAUPHIN COUNTY (May 2012) 19 CITADEL DR, CAMP HILL PA 17011-7632, CUMBERLAND COUNTY (Oct 1997 -Mar 2005) 6 WESTWOOD CT, ENOLA PA 17025-1508, CUMBERLAND COUNTY (tan 2001) 119 CHARLOTTE WAY, ENOLA PA 17025-1548, CUMBERLAND COUNTY (Oct 1996 -Jan 1999) 409 GEARY AVE APT A, NE~V CUMBERLAND PA 17070-1839, CUMBERLAND COUNTY (Sep 1956 -Jul 1997) 104R SUMMER LN R, ENOLA PA 17025-2186, CUMBERLAND COUNTY (Nov 1995 -tan 1947) 104 SUMMER LN APT R, ENOLA PA 17025-2188, CUMBERLAND COUNTY (Dec 1995) SS BALD CYPRESS CIR, ETTERS PA 17319-9743, YORK COUNTY (Jan 1991- Dec 1992} 661 S 82ND ST APT 1, HARRISBURG PA 17111-5536, DAUPHIN COUNTY (Jun 1988 -Dec 1990} 5. STATEWIDE COUNTY TAX ASSESSMENT AND PROPERTY OWNERSHIP Possible Properties Owned by Subject: Property: Parcel Number-47-19-1588-018 Book - 20091 Page - 976 Owner Name: RONALD L SHULDA JR Owner Name 2:TRACY LSHULDA Property Address: - 614 N FRONT ST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Owner Address: 614 N FRONTST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Land Usage -DUPLEX (2 UN1T5, ANY COMBINATION) Assessed Value - $131,600 Land Size - 3485 SF Year Built- 1939 Legal Description -RIVERVIEW L0T40 PB 1 PG 103 Data Source - B Property: Parcel Number -19-1588-0018-0000000-47 Book-248 Page - 2252 Owner Name: RONALD L SHULDA JR Owner Name 2: TRACY L SHULDA Property Address: - 614 N FRONT ST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Owner Address: 614 N FRONTST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Land Usage -RESIDENTIAL (NEC) Subdivision Name -RIVERVIEW Total Market Value - $131,600 Assessed Value - $131,600 __ - Land Value - $37,500 Improvement Value - $94,100 Land Size - 3,484 Square Feet Year Built - 1939 Legal Description -LOT 40 PB 1 PG 103 Data Source - A I i 6. UNIFORM COMMERCIAL CODE FILINGS UCC Filings: Original Filing Number: 2009 0408309 Original Date: Feb 6, 2009 Filing Agency: SECRETARY OFSTATE/UCC DIVISION Filing Agency Address: FEDERAL & DUKE OF YORK STS, DOVER DE 19901 Filing State: DE Debtor(s): Debtor Name: RONALD L SHULDA Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Debtor Name: TRACY L SHULDA Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Secured(s): Secured Name: BANK OF THE WEST Secured Address: PO BOX 8160, WALNUT CREEK CA 94596-5160 Filing(s): FilingType: INITIAL FILING Filing Number: 2009 0408309 Filing Status: Date Filed: Feb 6, 2009 Original Filing Number: 2007032403793 Original Date: Mar 21, 2007 Filing Agency: SECRETARY OFSTATE/UCC DIVISION Filing Agency Address: 308 NORTH OFFICE BUILDING, HARRISBURG PA 17120 Filing State: PA Debtor(s): Debtor Name: RONALD LSHULDAIR Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Debtor Name: TRACY L SHULDA Debtor Address: 614 N FRONT 5T, WORMLEYSBURG PA 17043-1022 Secured(s): Secured Name: BANK OFTHE WEST Secured Address: PO BOX 8160, WALNUT CREEK CA 94596-8160 Filing(s): Filing Type: INITIAL FILING - -- - - - FilingNumber: 2007032403793 Filing Status: Date Filed: Mar 21, 2007 Filing Expiration Date: 3/21/2012 Collateral(s): Description: 03/21/2007 2007032403793 -UNSPECIFIED 7. FEDERAL BANKRUPTCY COURT Date Filed:ll/04/2011 Chapter: 13 Disposition Date: Disposition: Filing Status: JOINT, Voluntary Case Number: 1107512 Court Location: PENNSYLVANIA MIDDLE -HARRISBURG Debtor: RONALD LEOPOLD SHULDA JR Debtor Address: 614 N FRONTST, WORMLEYSBURG PA 17043-1022 Additional Debtor: TRACY LYNN SHULDA Additional Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Assets available for unsecured creditors: Yes Debtor is self-represented: No Liabilities: Assets: Attorney: LAW OFFICE OF DOROTHY L MOTT FEIN: Attorney Address: 125 STATE ST, HARRISBURG PA 17101-1025 Attorney Phone Number: 717-232-6650 -EDT Attorney: MARC A CRUM Attorney Address: 125 STATE ST, HARRISBURG PA 17101-1025 Attorney Phone Number: 717-232-6650 -EDT Trustee: CHARLES J DEHART Ill Trustee Address: 8125 ADAMS DR, HUMMELSTOWN PA 17036-8625 Trustee Phone Number: 717-566-6097 -EDT Judge Assigned: ROBERT N OPEL II Creditors Meeting Date: 12/15/2011 Creditors Meeting Time: 10:00 Creditors Meeting Location: FEDERAL BLDG TRUSTEE HEARING RM RM 1160 11TH FL 22 Complaints Deadline: Claims Deadline: 03/14/2012 Date Filed: 12/17/1997 Chapter: 7 Disposition Date: 03/31/1998 Disposition: Discharged Filing Status: INDIVIDUAL Case Number: 9705390 Court Location: PENNSYLVANIA MIDDLE -HARRISBURG Debtor: RONALD L SHULDA JR Debtor Address: 614 N FRONTST, WORMLEYSBURG PA 17043-1022 Assets available for unsecured creditors: No Debtor is self-represented: No Liabilities: Assets: Attorney: CHARLES E PETRIE Attorney Address: 3528 BRISBAN ST, HARRISBURG PA 17111-1803 Attorney Phone Number: 717-561-1939 -EDT Trustee: LEON P HALLER Trustee Address: 1719 N FRONT ST, HARRISBURG PA 17102-2305 Trustee Phone Number: 717-234-4178 -EDT 13. Judge Assigned: RJW Creditors Meeting Date: 01/29/1998 Creditors Meeting Time: 09:00 Creditors Meeting Location; 22 Complaints Deadline: Claims Deadline: 8. STATEWIDE CIVIL COURT RECORDS, LIENS, AND JUDGEMENTS NO RECORD FOUND 9. PENNSYLVANIA DEPARTMENT OF CORRECTIONS CURRENT INMATES NO RECORD FOUND 10. PEOPLE IN THE NEWS- PHILADELPHIA INQUIRER, DAILY NEWS, BUSINESS JOURNAL NO RECORD FOUND 11. SEXUAL OFFENDERS DATABASE NO RECORD FOUND 12. FEDERAL AVIATION ADMINISTRATION REGISTERED AIRCRAFT NO RECORD FOUND PROFESSIONAL LICENSES (NATIONWIDE) NO RECORD FOUND 14. FEDERAL FIREARMS AND EXPLOSIVES LICENSES (NATIONWIDE) NO RECORD FOUND 15. DEA CONTROLLED SUBSTANCE LICENSES (NATIONWIDE) NO RECORD FOUND 16. CORPORATIONS ANf) RIISINFCC' onin ancctai G GnnDi nvroc - -- ----- NO RECORD FOUND 17. OTHER INFORMATION NO RECORD FOUND 3) I DECLARE THATTHE FOREGOING IS TRUE AND CORRECT. October 16, 2012 SIGNATURE: 'i~~^Y~1~x~~-~ti.k-., ~w4~ SWORN TO AND SUBSCRIBED BEFORE ME THIS 16`h Dav of October, 2012 ..- NOTARY PUBLIC MMONVYEAL'TH OF ~ET1N}SYWAMA NOTARIAL SEAL PATRiCIA TARDITI, Notary Public Clty of Phllade hia, Phila. Counttyy My Commission ~xpires June 13, 2b18 AFFIDAVIT OF GOOD FAITH INVESTIGATION Commonwealth of Pennsylvania SS: County of Montgomery I, Rosemary McCrory Sweet, an Owner of Rosemary McCrory Sweet Investigation, BEING OF FULL AGE AND UPON MY OATH STATE AND DEPOSE THE FOLLOWING: 1) I HAVE PERFORMED A GOOD FAITH INVESTIGATION ON THE FOLLOWING SUBJECT AND PROPERTY LOCATED IN THE COMMONWEALTH OF PENNSYLVANIA. 1. THE SUBJECTS NAME(S) IS/ARE: TRACEY L SHULDA AKA TRACEY LYNN HITT DOB:1/19/1970 2. THE PROPERTYADDRESS IS 614 N FRONT ST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY (Apr 1998 -Sep 2012 2) THE FOLLOWING SEARCHES WERE PERFORMED IN AN EFFORT TO LOCATE THE SUBJECT(S): 1. SOCIAL SECURITY MASTER DEATH INDEX: NO RECORD FOUND 2. THE SUBJECTS CURRENT ADDRESS AS DETERMINED BY THIS REPORT IS BELIEVED T0: 133 5 48TH ST APT 6S, HARRISBURG PA 17111-3466, DAUPHIN COUNTY (May 2012 -Sep 2012) Name Associated with Address: TRACY SHULDA Current Residents at Address: TRACEY LYNN HITT 3. DIRECTORY ASSISTANCE, WHITE PAGES, AND OTHER ON-LINE TELEPHONE RECORDS Phones Plus(s): Phones Plus 1 Name: SHULDA, TRACY Address: 614 N FRONTST, LEMOYNE PA 17043-1022 Phone Number: 717-315-7279 -EDT Phone Type: Mobiie Carrier: NEW CINGULAR WRL DC - {HARRISBURG CITY ZONE-1, PA ) Phones Plus 2 Name: SHULDA, TRACY Address: 614 N FRONT ST, LEMOYNE PA 17043-1022 Phone Number: 717-720-3028 -EDT Carrier: VERI20N PENNSYLVANIA- (HARRISBURG, PA ) Phones Plus 3 Name: SHULDA, TRACY Address: 133 S 48TH ST, HARRISBURG PA 17111-3466 Phone Number: 717-877-2607 -EDT Phone Type: Mobile Carrier: NEWCINGULARWRLDC-(HARRISBURG,PA) Phones Plus 4 Name: SHULDA, TRACY Address: 614 N FRONT ST, LEMOYNE PA 17043-1022 Phone Number: 717-877-2607- EDT Phone Type: Mobile Carrier: NEW CINGULAR WRL DC - (HARRISBURG , PA ) 4. ADDRESS HISTORY SEARCH Address Summary: 133 S 48TH ST APT 6S, HARRISBURG PA 17111-3466, DAUPHIN COUNTY (May 2012 -Sep 2012) 614 N FRONTST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY (Apr 1998 -Sep 2012) 3000 PINEFORD DR, MIDDLETOWN PA 17057-2630, DAUPHIN COUNTY (May 2012) RR 1 80X 38-1, BLAIN PA 17006-9801, PERRY COUNTY (Aug 1989 -Mar 2001) PO BOX 23, LANOISBURG PA 17040-0023, PERRY COUNTY (Mar 1998 -Dec 2000) 619 N FRONT ST, WORMLEYSBURG PA 17043, CUMBERLAND COUNTY (Aug 1999 -Sep 1999) 619 N FRONT ST, LEMOYNE PA 17043, CUMBERLAND COUNTY (Aug 1999) 601 N FRONT ST, WORMLEYSBG PA 17043, CUMBERLAND COUNTY (Mar 1998) PO BOX 12, NEW GERMANTOWN PA 17071-0012, PERRY COUNTY (Jan 1993 -Sep 1996) MAIN ST, NEW GERMANTOWN PA 17071, PERRY COUNTY (Jan 1990 -Dec 1991) 601 N FRONT ST, LEMOYNE PA 17043, CUMBERLAND COUNTY 5. STATEWIDE COUNTY TAX ASSESSMENT AND PROPERTY OWNERSHIP Possible Properties Owned by Subject: Property: Parcel Number- 47-19-1588-018 Book-20091 Page - 976 Owner Name: TRACY L SHULDA Owner Name 2: RONALD L SHULDA JR Property Address: - 614 N FRONT St, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Owner Address: 614 N FRONT ST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Land Usage -DUPLEX (2 UNITS, ANY COMBINATION) Assessed Value - $131,600 Land Size - 3485 SF Year Built - 1939 Legal Description - RIVERVIEW LOT 40 PB 1 PG 103 Data Source - B Property: Parcel Number- 19-1588-0018-0000000-47 Book-248 Page - 2252 Owner Name: TRACY L SHULDA Owner Name 2: RONALD L SHULDA JR Property Address: - 614 N FRONT ST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Owner Address: 614 N FRONTST, LEMOYNE PA 17043-1022, CUMBERLAND COUNTY Land Usage -RESIDENTIAL (NEC) Subdivision Name - RIVERVIEW Total Market Value - $131,600 Assessed Value - $131,600 Land Value - $37,500 Improvement Value - $94,100 Land Size - 3,484 Square Feet Year Built - 1939 Legal Description -LOT 40 PB 1 PG 103 Data Source - A 6. UNIFORM COMMERCIAI [nnF Fu wrc UCC Filings: Original Filing Number: 2009 0408309 Original Date: Feb 6, 2009 Filing Agency: SECRETARY OFSTATE/UCC DIVISION Filing Agency Address: FEDERAL & DUKE OF YORK STS, DOVER DE 19901 Filing State: DE Debtor(s-: Debtor Name: TRACY L SHULDA Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Debtor Name: RONALD L SHULDA Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Secured(s): Secured Name: BANK OF THE WEST Secured Address: PO BOX 8160, WALNUT CREEK CA 94596-8160 filing(s): Filing Type: INITIAL FILING Filing Number: 2009 0408309 Filing Status: Date Filed: Feb 6, 2009 Original filing Number: 2007032403793 Original Date: Mar 21, 2007 Filing Agency: SECRETARY OFSTATE/UCC DIVISION Filing Agency Address: 308 NORTH OFFICE BUILDING, HARRISBURG PA 17120 Filing State: PA Debtor(s): Debtor Name: TRACY L SHULDA Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Debtor Name: RONALD L SHULDAJR Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Secured(s): Secured Name: BANK OF THE WEST Secured Address: PO BOX 8160, WALNUT CREEK CA 94596-8160 Filing(s): Filing Type: INITIAL FILING Filing Number: 2007032403793 Filing Status: Date Filed: Mar 21, 2007 Filing Expiration Date: 3/21/2012 Collateral(s): Description: 03/21/2007 2007032403793 -UNSPECIFIED 7. FEDERAL BANKRUPTCY COURT Date Filed: 11/04/2011 Chapter: 13 Disposition Date: Disposition: Filing Status: JOINT, Voluntary Case Number: 1107512 Court Location: PENNSYLVANIA MIDDLE -HARRISBURG Debtor: RONALD LEOPOLD SHULDA JR Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Additional Debtor: TRACY LYNN SHULDA Additional Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Assets available for unsecured creditors: Yes Debtor is self-represented: No Liabilities: Assets: Attorney: LAW OFFICE OF DOROTHY L MOTT FEIN: Attorney Address: 125 STATE ST, HARRISBURG PA 17101-1025 Attorney Phone Number: 717-232-6650 -EDT Attorney: MARC A CRUM Attorney Address: 125 STATE ST, HARRISBURG PA 17101-1025 Attorney Phone Number: 717-232-6650 -EDT Trustee: CHARLES J DEHART III Trustee Address: 8125 ADAMS DR, HUMMELSTOWN PA 17036-8625 Trustee Phone Number: 717-566-6097 -EDT Judge Assigned: ROBERT N OPEL 11 Creditors Meeting Date: 12/15/2011 Creditors Meeting Time: 10:00 Creditors Meeting Location: FEDERAL BLDG TRUSTEE HEARING RM RM 1160 11TH FL 22 Complaints Deadline: Claims Deadline: 03/14/2012 Date Filed: 09/09/2008 Chapter: 13 Disposition Date: 07/21/2011 Disposition: Dismissed Filing Status: INDIVIDUAL, Voluntary Case Number: 0803243 Court Location: PENNSYLVANIA MIDDLE -HARRISBURG Debtor: TRACY L SHULDA AKAs:TRACY L MARTIN Debtor Address: 614 N FRONT ST, WORMLEYSBURG PA 17043-1022 Assets available for unsecured creditors: Yes Debtor is self-represented: No Liabilities: Assets: Attorney: LAW OFFICE OF DOROTHY L MOTT FEIN: Attorney Address: 125 STATE ST, HARRISBURG PA 17101-1025 Attorney Phone Number: 717-232-6650 -EDT Attorney: MARC A CRUM Attorney Address: 125 STATE ST, HARRISBURG PA 17101-1025 Attorney Phone Number: 717-232-6650 -EDT Trustee: CHARLES J DENARY III Trustee Address: 8125 ADAMS DR, HUMMELSTOWN PA 17036-8625 Trustee Phone Number: 717-566-6097 -EDT Judge Assigned: MARY D FRANCE Creditors Meeting Date: 10/16/2008 Creditors Meeting Time: 11:00 Creditors Meeting Location: FEDERAL BLDG TRUSTEE HEARING RM RM 1160 11TH FL 22 8. STATEWIDE CIVIL COURT RECORDS, LIENS, AND JUDGEMENTS NO RECORD FOUND 9. PENNSYLVANIA DEPARTMENT OF CORRECTIONS CURRENT INMATES NO RECORD FOUND 10. PEOPLE IN THE NEWS -PHILADELPHIA INQUIRER, DAILY NEWS, BUSINESS JOURNAL NO RECORD FOUND 13 11. SEXUAL OFFENDERS DATABASE NO RECORD FOUND 12. FEDERAL AVIATION ADMINISTRATION REGISTERED AIRCRAFT NO RECORD FOUND PROFESSIONAL LICENSES (NATIONWIDE) NO RECORD FOUND 14. FEDERAL FIREARMS AND EXPLOSIVES LICENSES (NATIONWIDE) NO RECORD FOUND 15. DEA CONTROLLED SUBSTANCE LICENSES (NATIONWIDE) NO RECORD FOUND 16. CORPORATIONS AND BUSINESS `AND POSSIBLE EMPLOYERS NO RECORD FOUND NO RECORD FOUND 17. OTHER INFORMATION 3) I DECLARE THAT THE FOREGOING lS TRUE AND CORRECT. October 16. 2012 SIGNATURE: ~~`~k"r`~Q~-'~~~1~~'~~ti~~~i4 ~.k SWORN TO AND SUBSCRIBED BEFORE ME THIS 16"' Day of October, 2012 ~ ~~~ NOTARY PUBLIC ~ MO 7H OFPLNNS1f V11MA NOTARIAL SEAL PATRICIA TARDIFI, Notary Public Ciiy of Pha hia, Phila, Coun~y M Commission Tres tune 13, 2D18 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AFFIDAVIT OF SERVICE Wells Fargo Bank, N.A., et al vs Ronald L. Shulda, Jr. and Tracy L. Shulda Commonwealth of Pennsylvania County of Dauphin ss. CASE NO.: 2011-7842 I, Todd Kepner, a competent adult, being duly sworn according to law, depose and say that at 3:44 PM on 10/22/2012, Inon-served Ronald L. Shulda, Jr. at 133 South 48th Street, Apartment 6S ,Harrisburg, PA 17111 in the manner described below: a true and correct copy of Notice of Sheriff s Sale of Real Property issued in the above captioned matter. Comments/Prev. Attempts: The provided address is vacant. x ~/ Sw r to and subs r' ed before me on his Todd Kepner day of 4(, ~~ 20~`~. Shinkowsky Investigations Post Office Box 126538 ~' Harrisburg, PA 17112 (800) 276-0202 NOT? RY PUB C COMMONWEALTH OF YENNSYLVAMA Atty File#: -Our File# 22583 NOTARIAI, SEAL Kathryn S. Fogle, Notary Public Lower Paxton Twp, Dauphin County My commission ex fires Au st 13, 2016 Law Firm: Richard M. Squire and Associates, LLC Address: One Jenkintown Station, 115 West Avenue, Suite 104, Jenkintown, PA, 19046 Telephone: (215) 886-8790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA AFFIDAVIT OF SERVICE Wells Fargo Bank, N.A., et al vs Ronald L. Shulda, Jr. and Tracy L. Shulda CASE NO.: 2011-7842 Commonwealth of Pennsylvania County of Dauphin ss. I, Todd Kepner, a competent adult, being duly sworn according to law, depose and say that at 3:44 PM on 10/22/2012, Inon-served Tracy L. Shulda at 1.33 South 48th Street, Apartment 6S ,Harrisburg, PA 17111 in the manner described below: a true and correct copy of Notice of Sheriffs Sale of Real Property issued in the above captioned matter. Comments/Prev. Attempts: The provided address is vacant. x~'~~-CG~^~ SwRr to ar.d subs d before me on this Todd Kepner _~ day of ~"~{~~~/ 2p j~, Shinkowsky Investigations Post Office Box 126538 Harrisburg, PA 17112 (800) 276-0202 NOTARY PUBL COMMUNWEALTHfJFPEMVSYLVAMA Atty File#: - Our File# 22584 NOTARIAL SEAL Kathryn S. Fog3e, Notary Public Lower Paxton Twp, Dauphin County M commission ex fires Au ust 13, 2016 Law Firm: Richard M. Squire and Associates, LLC Address: One Jenkintown Station, 115 West Avenue, Suite 104, Jenkintown, PA, 19046 Telephone: (215) 886-8790 RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LAW Richard M. Squire' Montgomery County Office Chester Countv Office M. Troy Freedman 33 South Brick Lane Craig Oppenheimer One Jenkintown Station Elverson, PA 19520 * Also admitted in MD 115 West Avenue, Suite 104 Tel.: (610) 913-8442 Jenkintown, PA 19046 Fax: (610) 913-6381 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.squirelaw.com Please reply to: Montgomery County Office Postmaster Wormleysburg, PA 17043 October 15, 2012 Request for Change of Address or Boxholder Information Needed for Service of Leaal Process Dear Madam or Sir: Please furnish the new~addre~s~ o~~the name and street address (if a boxholder) for the following: Name: Ronald L. Shulda Jr. Address: 614 North Front Street Wormleysburg PA 17043 Note: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 36 CFR 265.6(d)6(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney at Law 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: Wells Fargo Bank. N.A. as Trustee for Stanwich Mortgge Loan Trust Series 2011-1 Asset-Backed Pass-Through Certificates v Tracy L. Shulda and Ronald L. Shulda Jr. 4. The court in which the case has been or will be heard: County Court of Common Pleas Pennsylvania 5. The docket or other identifying number if one has been issued: Not yet issued 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Richard M. S wire & sociates, LLC By: Richard M. Squire, Esquire FOR POST OFFICE USE ONLY No change of address order on file. NEW ADDRESS or BOXHOLDER'S POSTMARK Not known at address given. NAME and STREET ADDRESS Moved, left no forwarding address. No such address. -~-_~:~ ~; Spc RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYSAT LAW Richard b1. Squire* Montgomery County Office Chester County Office ><1. Troy Freedman 33 South Brick Lane Craig Oppenheimer One Jenkintown Station Elverson, PA 19520 * Also admitted in MD 11.5 West Avenue, Suite 104 Tel.: (610) 913-8442 Fax: (610) 913-6381 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.sduirelaw.com Please reply to: Montgomery County Office Postmaster Wormleysburg, PA 17043 October 15, 2012 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Dear Madam or Sir: Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Tracy L. Shulda Address: 614 North Front Street. Wormleysburg PA 17043 Note: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 36 CFR 265.6(d)6(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. Capacity of requester (e.g., process server, attorney, party representing himself): Attorney at Law 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: Wells Farpo Bank. N.A. as Trustee for Stanwich Mortgge Loan Trust Series 2011-1 Asset-Backed Pass-Through Certificates v. Tracy L. Shulda and Ronald L. Shulda Jr 4. The court in which the case has been or will be heard: County Court of Common Pleas. Pennsylvania 5. The docket or other identifying number if one has been issued:_Not yet issued 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Richard M. Squire & Associates, LLC By: ' Richard M. Squire, Esquire FOR POST OFFICE USE ONLY ~Pdo change of address order on file. Not known at address given. Moved, left no forwarding address. No such address. NEW ADDRESS or BOXHOLDER'S POSTMARK NAME and STREET ADDRESS / l~' ~~~• Qq u ~ ~, ? 7 + r r. C, ~ 1 cn ~ ~ ~ 7l3 to -°! ''° ~ ~~~ ~' m m o m ~ ~ ~ n ~ ~ o ~ TI m Z v ~~ - ,•, j ~ .. - r ~ .~ ~ ~ m-iz ~ w~; ° cn A w n~ ~ ~ ~ ~~ ~ t7 °< ~ ~~ ~ .~ ~ ~ -i o m ~ m 7J m t7 m "D 'rte o ~. z (~ G ~ ~ .• - C" C, -' C7 (n ~ C7 C7 (n ~ C~ ~ O Q. ~ ~ pp {p ~~ c ~ m'~ 1't1 ~ ou Ooo~ O°p~ D :n r n n D o ~~= Z D Z D n~ p- ' ~ -^ -- - - - _ _ o . © r ~. ~. ~ y ~ ,N !~ ~o A ~~ ' '•~ , R1 m w O o ~ L/ ~ 0 O ~O ~O ~ O t j ;\ ~ 0 ~ ° om cn cn o ~i O ~W~~ D ~ ~ - , 3~ ~ S c .y.D Q u D m ! ',~ - am m -D~nai m . 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I ~ Ill `~°-Om 3 ~ ~ "o~o~1D 3 N fnTC ~'u' " { sy D ~~, mn^~xo r 1 Qy~ t_g~ ~ womd ~ ~ ~-~O'69 F.4 c i~ ~ ~ ° om ~~' i ~ OOD~ O r~, ,~' fOD Il X l g o am ~~~~~a ~ AO(A G~ p. ~ r rnrncnmlo =. ~. ~ ~ <n3m 3d N ' ~ Ill fn m 3 x. ~ ~ - ~ ~ o ~ 3 ~ ~ ~~ .D ['>;"' cD y . T ~ n m m p ~ ~ fD v D n ~' ~ ~ ~ z~ D m D Z O D v v m O T m Z v m z v m m O 3 D n x m n 'D D m W r O n m 0 z RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORIVEYSAT LAW Richard M. Squire * Montgamery Conn Office n1. Troy Freedman Craig A. Oppenheimer One Jenkintown Station • .4lsoAdmitted inStD 115 West Avenue, Suite 104 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.squirelaw.com Ronald L. Shulda, Jr. Tracey L. Shulda 614 North Front Street, Wormleysburg, PA 17043 Chester County Office 33 South Brick Lane Elverson, PA 19520 Tel.: (610) 913-8442 Fax: (610)913-6381 Please reply to: Montgomery County Office October 30, 2012 RE: Wells Fargo Ban, N.A., v. Ronald L. Shulda, Jr. et. al. Docket No. 2011-7842 Our File No. CMS-107 Dear Sir/Madam: The enclosed Motion for Alternative Service of Notice of Sheriff's Sale, Verification, Brief/Memorandum of Law, Certificate of Service, and proposed Order are being provided to you pursuant to the local rules of procedure. Please advise the undersigned in writing on or before November 6, 2012 via mail, facsimile, or electronic mail whether you concur to the relief sought in the enclosed Motion for Alternative Service of the Notice of Sheriff's Sale. If I do not receive any correspondence from you, we will forward a substantially similar version of the enclosed Motion/Petitionpackage to the Court for filing on November 7, 2012. Thank you for your courtesies. Enclosures, as stated Very truly yours, M. Troy Freedman, Esquire Ext. 12 tfreedman(a~squirelaw.com RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LAW Richard A'1. Squire * Montgomery Coun --Office M. Troy Freedman Craig A. Oppenheimer One Jenkintown Station Also Admitted ~~ ti>a 115 West Avenue, Suite 104 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.squirelaw.com Chester County Office 33 South Brick Lane Elverson, PA 19520 Tel.: (610) 913-8442 Fax: (610)913-6381 Please reply to: Montgomery County Office October 30, 2012 Ronald L. Shulda, Jr. Tracey L. Shulda 133 South 48`h Street, Harrisburg, PA 17111 RE: Wells Fargo Ban, N.A., v. Ronald L. Shulda, Jr. et. al. Docket No. 2011-7842 Our File No. CMS-107 Dear Sir/Madam: The enclosed Motion for Alternative Service of Notice of Sheriff's Sale, Verification, Brief/Memorandum of Law, Certificate of Service, and proposed Order are being provided to you pursuant to the local rules of procedure. Please advise the undersigned in writing on or before November 6, 2012 via mail, facsimile, or electronic mail whether you concur to the relief sought in the enclosed Motion for Alternative Service of the Notice of Sheriff's Sale. If I do not receive any correspondence from you, we will forward a substantially similar version of the enclosed Motion/Petition package to the Court for filing on November 7, 2012. Thank you for your courtesies. Very truly yours, M. Troy Freedman, Esquire Ext. 12 tfreedmannsquirelaw, com Enclosures, as stated Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, PLAINTIFF, v. Ronald I,. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043, DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 2011-7842 CIVIL ACTION ti -> MORTGAGE FORECLOSURE ~~ r.:, :.n r_- ~~, ~-- ~~ ~ ~~ ~~ r_ c-: ~,, c~: 0 -o w :..+'J _~ ~~ =;;__: .~~{ ~1;~~ c} , __~ c;; c~ v~~, ORDER GRANTING ALTERNATIVE SERVICE -~-. OF THE NOTICES OF SHERIFF'S SALE AND NOW, this 2 / ` day of lua~••~.f , 2012, upon consideration of Plaintiff s Motion for Alternative Service of the Notices of Sheriff s Sale, and upon consideration of any answer or response thereto, and good cause showing; it is hereby ORDERED that Plaintiff may serve the Notices of Sheriffs Sale pursuant to Pa. R.C.P. 3129.2(a) upon Defendants by (1) sending a true and correct copy thereof to Defendants via simultaneous certified mail return receipt requested and regular mail postage prepaid to 614 North Front Street, Wormleysburg, PA 17043 and to the Defendants' last known address at 133 South 48`h Street, Apartment 6S, Harrisburg, PA 17111; and (2) posting a true and correct copy thereof on the mortgaged premises at 614 North Front Street, Wormleysburg, PA 17043 by any competent adult. Service of the aforementioned mailings is effective upon the date of mailing and is to be effectuated by Plaintiffs attorney, who will file with the Prothonotary's Office a C"ertificate of Service as to such mailings. /~Richard M. Squire, Esq. (PA I.D.# 04267) M. Troy Freedman, Esq. (PA I.D.# 85165) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rs uire(cr~squirelaw.com tfreedman(a,squirelaw.com coppenheimer(a,squirelaw.com ~ Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 / Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 Ronald L. Shulda Jr. 133 South 48th Street, Apartment 6S, Harrisburg, PA 17111 ,Tracy L. Shulda 133 South 48th Street, Apartment 6S, Harrisburg, PA 17111 Pep;es ~.~,~1~~1 ,~lar f ~a ~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~titu of ~1i~rr}~rrj~t~ ~:; z ~~r ,~ _~ ~ . ~ .- r . ~~i~~l~~ ~~ ~~ ~~~J ~U~fiBERLN~~U t;iJ~1C~ 1 .t ~~N~~Y1 ~~~~~ Wells Fargo Bank Case Number vs. Ronald L. Shulda, Jr. (et al.) 2011-7842 SHERIFF'S RETURN OF SERVICE 09/28/2012 03:29 PM -Deputy Ryan Burgett, 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 614 N. Front Street, Wormleysburg Borough, Wormleysburg, PA 17043, Cumberland County. 10/10/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Tracy L. Shulda, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 614 N. Front Street, Wormleysburg, PA 17043, property is vacant, post office is still delivering mail there. 10/10/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Ronald L. Shulda, Jr., but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 614 N. Front Street, Wormleysburg, PA 17043, property is vacant, post office is still delivering mail there. 11/27/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per {etter of instruction from Attorney. SHERIFF COST: $1,165.20 November 27, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ~~ ~S ~ L~ a - e ~,~ S , s~ ~~` ~~ gya- ~l R-~ ~3~~' On September 5, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA, known and numbered 614 North Front Street, Wormleysburg, PA 17043 fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 5, 2012 Claudia Brewbaker, Real Estate Coordinator L ~ ~8 ~/ ~- d3S llOl - v WRIT OF EXECUTION and/or ATTACHMENT COIVIMQNWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-7842 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. AS TRUSTEE FOR STANWICH MORTGAGE LOAN TRUST, SERIES 2011-I ASSET-BACKED PASS-THROUGH CERTIFICATES Plaintiff (s) From RONALD L. SHULDA JR., TRACY L. SHULDA (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the properly of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b} the garnishees} is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendants} not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due: $145,040.45 L.L.: $.50 Interest FROM 6/21/2012 TO 12/5/2012 @ $24.02 PER DIEM- $4r0353b Atty's Comm: % Due Prothy: $2.25 Atty Paid: $199.94 Other Casts: Plaintiff Paid: Date: 9/4/2012 ~ .e.41...~ - -f~ David D. Buell, Prothonotary (Seal) ~_,~j.?~~,,C,~__~~~,~Qidd~C{ Deputy REQUESTING PARTY: Name: CRAIG OPPENHEIMER, ESQUIRE Address: RICHARD M. SQUIRE & ASSOCIATES, LLC ONE JENKINTOWN STATION, SUITE 104 115 WEST AVENUE JENKINTOWN, PA 19046 Attorney for: PLAINTIFF Telephone: 215-886-8790 Supreme Court ID No. 313264 TRUE CQPY FRE~M RECC?RD En 'I'~tlmorty w[~reof, !here unto set my hand arts} the al of said Covet at Cartlste, Pa. Thy day of _,,,.~..., 20 /:Z prothonotary ~~ ~, s~~i- ~ CUMBERLAND LAW JOURNAL Writ No. 2011-7842 Civll Term WELLS FARGO BANK vs. RONALD L. SHULDA, JR. Tracy L. Shulda Atty.: Craig Oppenheimer The following described real prop- erty situate in the Borough of Worm- leysburg, County of Cumberland, and Commonwealth of Pennsylvania, to wit: ALL THAT CERTAIN piece, parcel or tact of ground, together with the improvements thereon erected, situ- ate in the Borough of Vvormleysburg Cumberland County, Pennsylvania, more pazticulazly bounded and de- scribed as follows, to wit; BEGINNING at a point on the southwestern line of North Front Street, said point being 300.00 feet in a northwestern direction from the intersection of North Front Street and Stella Avenue; said point being also on the dividing line between Lots Nos. 39 and 40 on the herein- after mentioned Plan of Lots; thence along said line South 48 degrees 30 minutes West, 175.00 feet to a point on the northeastern line of a fifteen foot wide alley; thence along said alley North 41 degrees 30 minutes West, 20.00 feet to a point on the dividing line between Lots No. 40 and 41; thence along said line and through the center of a partition wall sepazating premises 614 and 616 North Front Street North 48 de- grees 30 minutes East, 175.00 feet to a point on the southwestern line of North Front Street; thence along the 1 ine of North Front Street South 41 degrees 30 minutes East, 20.00 feet to a point, the point and place of beginning, having thereon erected a two and one-half story brick and shingle dwelling known as No. 614 North Front Street. BEING Lot No. 40 on plan of lots laid out by Edwin M. Hershey and known as °Riverview' said plan being recorded in Plan Bock 1, Page 103, Cumberlano County Records. Tax ID #: 47-19-1588-018. Being the same premises which Tracy L. Shulda granted and con- veyed unto Tracy L. Shulda and Ronald L, Shulda, Jr. by Deed dated August 31, 2001 and recorded Sep- tember 20, 2001 in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania in Deed Book 248, Page 2. 85 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication. are true. isa Marie Co ,Editor SWORN TO AND SUBSCRIBED before me this 9 da of November 2012 Notary NOTARIAL SS:AL pE80RAH A COLLINS Notary Public CARLISLE BOROUGH, CUM9ERLAND COUNTY Uly Commission Expires Apr 28.2014 .. The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE ~he~tatriot News Now you know CARLISLE PA. 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. ~~'UBLICATION COP This ad ran on the date(s) shown below: 10/26112 11/02112 11/09112 r, 2012 A. D. ~_ ,,'1 .~~ COMMONWEALTH OF PENNSYLVANIA i Notarlal5eal Sherrie L. Owens, Notary Public Lower Paxton 7wp., Dauphin County MY Commission Expires Nov. 26, 2015 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES watt-~ RO~II~~- dR. ~ ~~ TIIEFOLTAWING DBSCfi1BED REAL PROP~GIY S1TU41TE IN THE BOROUGH OF WORMLEYSBURG, COUNTY OF CUMBERLAND, AND CQMM~dW~EAUCi3OF PENNSYLVANIA, TO WTI`. ALLTHATGBIiTAIT'gPIECE, PA1bCEL OR TACT OF.t'lii()UND; 7'(XrETHCR WITHTI;OzIIda'llfl ~EO~1~;ECT13D; STfUATE INTHEBORiHIGHOF WOIiMSBiIRG CUp~BERLAND COtTiCt , ~$Yt,V~r1, Mb~~ PAR'IICEJLl~iS'. AND DgSCRIBFD AS FOI]AWS,TO WLT; 11 ~ F.GII~iNTNG AT A POINT ON ~ SOUTHVgIESTERN LdNE OF v N~ICl~FI FRf~2A'I' SI'RF,1~ SAID 3p ' POINT BEIt'lE'i 388.96 FI3LzC IN A 8~' NORI,STF.RN N FROM '~~ THE III OF i+"~RTH ~ FRONT SI'R~'T AND STB6I.A ar AVF~~~SA[D POINT BEING ALSO 'THE DT4~IDING7: B LOTS . 39 } 40 ON THE 'iBtt TAD PLANOFIA'@S; TII AIANG SAID LINE SOI~'f,FI48 30 MTNITIES WES'~'i?3.00 FEET 1s A POINT ON THE 6tiS'TItiRN LINE OF AFIFTEENFOQTWIDE- ALLEY; THENCE ALONG SAID ALLEY NOI~I41 DEGiitEES 34 T~IIN[TTFS ~i~ES'I;2(IAOi~ET'ZTQ A POINT OATTHE DTiIIDBVG I3f«i; BETWEEN L[l`TS i3O. ~AI~FD 41; THENCE ALONG SAID L1NE AND THROUGH THE CENTBR OF A PARTTTTON WALLSF.PAItAf;NG PREMkSES614 A1VD 61~•NORTH FRONT STREET NORTH 48 DEGREES 30 MIlVtT'f'~S EAST;I~.OO FEET TO 4 pp~ ~T(~SpITlH1NE9'TERN ::INE OF NOIgigII~ONT STREET; THENCE ALONG THE L INE OF NORTH F1ttkTT SI'~TSOU'iI~I41 DEGREES 39 hBS'EAS'1; ZOA0 FEETTO,0.P!OIN'T~ 1~ POBVT AND PLACE OF BEGIt@QING, HAVING THEREON ERECTED A TWO AND OI~HALF STORY BRICKAND SHINGLE BII N0.614 NDII3"fgFIH~I" BEING IAT NO+BIE~3lAN OF LOTS LAID OUT IiY EDWIN M. HERSHEY AND IINOWlg'AS"RIYFiV'SAID PLAN BF.T6itF RI4C0BtIisliFi'IN:P1:AN BOCK 1, PI9GE ltl3, CUI~ERLAND COUNTY:RECORDS. TAX ID 4~: 47-19-1388.418 Being the pwTutsh'Itacy I.. Shulda granted aed nam!Itacy L. ShnMa sac4 Ronald L, Shulda, h. try' Deed dotal A 31, ?001 aad teeorded September TD, 2001 in the Office of the. Re -rderofDee~dafot(~mbetl~d Co v, Pem~syhania in Deed Book 1A8, PaI Richard M. Squire & Associates, LLC By : Richard 1V,t. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.I). Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for IN THE COURT OF COMMON PLEAS Stanwich Mortgge Loan Trust, Series :CUMBERLAND, PENNSYLVANIA 2011-1 Asset-Backed Pass-Through Certificates NO.2011-7842 PLAINTIFF, CIVIL ACTION v. MORTGAGE FORECLOSURE Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, Plaintiff in the above action, being authorized to do so, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 614 North Front Street, Wormleysburg, PA 17043 Parcel No:.47-19-1588-018. 1. Name and last known address of Owner(s) or Reputed Owner(s): Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 2. Name and last known address of Defendant(s) in the judgment: Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd 1 Tracy L. Shulda ' ~ 61,4 North Front Street Wormleysburg, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates 1000 Technology Drive O'Fallon, MO 63368-2240 CitiMortgage, Inc 1000 Technology Drive O'Fallon, MO 63368-2240 James C. Costopoulis 1925 Chatham Drive, Camp Hill, PA 17011 4. Name and address of last recorded holder of every mortgage of record: Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates 1000 Technology Drive O'Fallon, MO 63368-2240 CitiMortgage, Inc 1000 Technology Drive O'Fallon, MO 63368-2240 MERS PO Box 2026 Flint, MI 48501-2026 MERS 1818 Library Street, Ste 300 Reston, VA 20190 Capital One Home Loans LLC 12800 Foster Avenue Overland Park, KS 66213 5. Name and address of every other person who has any record lien on the property: None other. 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: Domestic Relations 13 North Hanover Street PO Box 320 Carlisle, PA 17013 F:\Clients\Carrington\Shulda - ]07F\writ package 8-25-2012.wpd Tax Claim Bureau ' ~ One Courthouse Square -Room 106 Carlisle,' Pa 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Public Welfare Attn :Legal Department Health & Welfare Building P. O. Box 2675 Harrisburg, PA 17105-2675 Department of Public Welfare Bureau of Child Support Enforcement Health & Welfare Bldg., Room 432 Harrisburg, PA 17105-2675 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Tenant/Occupant 614 North Front Street Wormleysburg, PA 17043 VERIFICATION I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC By: ichar .Squire, Esquire M. Troy Freedman, Esquire / Craig Oppenheimer, Esquire 115 West Avenue, Suite 104 Jenkintown, PA 19046 (215) 886-8790 Attorneys for Plaintiff Date: August 28, 2012 F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire M. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, 1N THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 2011-7842 v. Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. CIVIL ACTION MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Your house (real estate) at 614 North Front Street, Wormleysburg, PA 17043 is scheduled to be sold at Cumberland County Sheriff Sale,12/5/2012 at 10:00 a.m., Courthouse, l Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $145,040.45 plus interest to the sale date obtained by Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay back to Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' F:\Clients\Carrington\Shulda - 107P\writ package 8-25-2012.wpd fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire, M. Troy Freedman, Esquire or Craig Oppenheimer, Esquire at (215} 886-8790. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland Sheriff s Office at 717-240-6100. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6100. 4. If the amount due from the buyer is not paid to the Sheriff, you will, remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriff s Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F:\Clients\Canington\Shulda - 107F\writ package 8-25-2012.wpd r Richard M. Squire & Associates, LLC By: Ricliard,M. Squire, Esquire M.. Troy Freedman, Esquire Craig Oppenheimer, Esquire I.D. Nos. 04267 / 85165 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 (215) 886-8790 Fax (215) 886-8791 Attorneys for Plaintiff Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates PLAINTIFF, v. iN THE COURT OF COMMON PLEAS CUMBERLAND, PENNSYLVANIA NO. 2011-7842 ': CIVIL ACTION Ronald L. Shulda Jr. 614 North Front Street Wormleysburg, PA 17043 Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 DEFENDANTS. MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Tracy L. Shulda 614 North Front Street Wormleysburg, PA 17043 Your house (real estate) at 614 North Front Street, Wormleysburg, PA 17043 is scheduled to be sold at Cumberland County Sheriff Sale, on Wednesday,12/5/2012 at 10:00 a.m., at the Courthouse, l Courthouse Square, Carlisle, PA 17013 to enforce the court judgment of $145,040.45 plus interest to the sale date obtained by Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay back to Wells Fargo Bank, N.A. as Trustee for Stanwich Mortgge Loan Trust, Series 2011-1 Asset-Backed Pass-Through Certificates, the amount of the judgment plus costs or the back payments, late charges, costs and reasonable attorneys' F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd ' fees due. To find out how much you must pay, you may call: Richard M. Squire, Esquire, M. Troy Freedman, Esquire or Craig Oppenheimer, Esquire at (215) 886-8790. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling the Cumberland Sheriff s Office at 717-240-6100. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call the Cumberland County Courthouse at 717-240-6100. 4. If the amount due from the buyer is not paid to the Sheriff, you will, remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff no later than 30 days after the Sheriff s Sale. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the date of filing of said schedule. 7. You may also have other rights and defenses or ways of getting your house back, if you act immediately after the sale. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 F'\ClientslCarringon\Shulda - 107F\writ package 8-25-2012.wpd LEGAL DESCRIPTION THE FOLLOWING DESCRIBED REAL PROPERTY SITUATE IN THE BOROUGH OF WORMLEYSBURG, COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA, TO WIT: ALL THAT CERTAIN PIECE, PARCEL OR TACT OF GROUND, TOGETHER WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE BOROUGH OF WORMLEYSBURG, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT; BEGINNING AT A POINT ON THE SOUTHWESTERN LINE OF NORTH FRONT STREET, SAID POINT BEING 300.00 FEET !N A NORTHWESTERN DIRECTION FROM THE INTERSECTION OF NORTH FRONT STREET AND STELLA AVENUE; SAID POINT BEING ALSO ON THE DIVIDING LINE BETWEEN LOTS NOS. 39 AND 40 ON THE HEREINAFTER MENTIQNED PLAN OF LOTS; THENCE ALONG SAID LINE SOUTH 48 DEGREES 30 MINUTES WEST, 175.00 FEET TO A POINT ON THE NORTHEASTERN LINE OF A FIFTEEN FOOT WIDE ALLEY; THENCE ALONG SAID ALLEY NORTH 41 DEGREES 30 MINUTES WEST, 20.00 FEET TO A POINT ON THE DIVIDING LINE BETWEEN LOTS NO. 40 AND 41; THENCE ALONG SAIL LINE AND THROUGH THE CENTER OF A PARTITION WALL SEPARATING PREMISES 614 AND fi16 NORTH FRONT STREET NORTH 48 DEGREES 30 MINUTES EAST, 175.00 FEET TC A POINT ON THE SOUTHWESTERN LINE OF NORTH FRONT STREET; THENCE ALONG THE LINE OF NORTH FRONT STREET SOUTH 41 DEGREES 30 MINUTES EAST, 20.00 FEES TO A POINT, THE POINT AND PLACE OF BEGINNING, HAVING THEREON ERECTED A TWC AND ONE-HALF STORY BRICK AND SHINGLE DWELLING KNOWN AS NO. 614 NORTH FRONT STREET, BEING LOT N0.40 ON PLAN OF LOTS LAID OUT BY EDWIN M. HERSHEY AND KNOWN AS "RIVERVIEW° SAID PLAN BEING RECORDED IN PLAN BOCK 1, PAGE 103, CUMBERLAND COUNTY RECORDS. TAX ID #: 47-19-1588-018 Being the same premises which Tracy L. Shulda granted and conveyed unto Tracy L. Shulda and Ronald L. Shulda, Jr. by Deed dated August 31, 2001 and recorded September 20, 2001 in the Office of the Recorder of Deeds for Cumberland County, Pennsylvania in Deed Book 248, Page 2252. F:\Clients\Carrington\Shulda - 107F\writ package 8-25-2012.wpd