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Home My WebLink About11-7918PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. AMY L. SNYDER 4177 KITTATINNY DRIVE MECHANICSBURG, PA 17050-9138 Defendant ATTORNEY FOR PLAINTIFF 260519 COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 260519 c? > C7 .? -w C:0 ._...i CD C-) - CD -17 .i C) _ ;c: CD ?.; ?tegao????1 ct? u? aqi Q?Falob?o? NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against Wu by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BEABLE TO PROVIDE, YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 260519 Plaintiff is WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: AMY L. SNYDER 4177 KITTATINNY DRIVE MECHANICSBURG, PA 17050-9138 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/11/2007 AMY L. SNYDER made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR GRAYSTONE MORTGAGE LLC which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1998, Page 2685. By Assignment of Mortgage recorded 02/10/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201105013. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 260519 6 The following amounts are due on the mortgage as of 08/10/2011: Principal Balance $102,810.85 Interest $6,584.08 08/01/2010 through 08/10/2011 Late Charges $294.56 Property Inspections $245.00 Escrow Deficit $548.28 Subtotal $110,482.77 Suspense Credit $810.60 TOTAL $109,672.17 7 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 260519 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $109,672.17, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN H AN & SCHMIEG, LLP By: Robert )NY. Cusick, Esquire Attorney for Plaintiff File #: 260519 LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Hampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the southern right of way line of Kittatinny Drive (64 feet wide, private), of the dividing line of Lot No. 92 and Lot No. 91, said point also being located 653.18 feet West of the southwest corner of Kittatinny Drive and Tussey Court; thence by line of Lot 92 and passing through the centerline of a partition wall South 07 degrees 57 minutes 58 seconds West, 100.00 feet to a point; thence by land now or late of Mountain View Village Home Owners Association, North 82 degrees 02 minutes 03 seconds West, 20.00 feet to a point; thence by line of Lot No. 90 and passing through the center partition wall, North 07 degrees 57 minutes 58 seconds East, 100.00 feet to a point on the southern right of way line of Kittatinny Drive; thence by said right of way line South 82 degrees 02 minutes 02 seconds East, 20.00 feet to a point, the place of BEGINNING. CONTAINING 2,000 square feet. BEING Lot No. 91 on the Final Subdivision Plan of Mountain View Village, Phase IV, Recorded in Plan Book 60, Page 87-B. UNDER AND SUBJECT to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County in Misc. Book 392, Page 787, Misc. Book 393, Page 557, and Misc. Book 414, Page 1102. ALSO UNDER AND SUBJECT to certain restrictions and conditions as appear of record including those in Deed Book 104, Page 779. PROPERTY ADDRESS: 4177 KITTATINNY DRIVE, MECHANICSBURG, PA 17050- 9138 PARCEL # 10-15-1285-141 File #: 260519 VERIFICATION Florence Gomez, hereby states that he she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., in this matter. that he he .s authorized to take this Verification. and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hi enowledge. information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: S*k&PI I Name; Florence Gomez Title: Vice President Loan Documentation NAME: Snyder 032-PA-V2 f ile #J 260519 PHELAN HALLINAN & SCHMIEG, LLP Sheetal R. Shah-Jani, Esq., Id. No.81760 FIL D-0 = i' ICS. 1617 JFK Boulevard, Suite 1400 01- E PROTHONOTARY Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 1 DEC 29 V 10' 49 215-563-7000 CUMBERLANO COUNTY WELLS FARGO BANK, N.A. PENNSyY4ARMBERLAND COUNTY VS. : COURT OF COMMON PLEAS AMY L. SNYDER : CIVIL DIVISION : No. 11-7918 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against AMY L. SNYDER, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint TOTAL $109,672.17 $109,672.17 I hereby certify that (1) the Defendant's last known address is 4177 KITTATINNY DRIVE, MECHANICSBURG, PA 17050-9138, and (2) that notice has been given in accordance with Rule Pa.R.C.P 37.1. Date Sheetal R. Sha - ani, Esq ire 0LPt1s1y.00Fd Attorney for Plainti Ck-µ 111wi i99 DAMAGES ARE HEREBY ASSESSED AS INDICATED. pA %g 1 ?1 ?c? (?4A DATE: ?a? I II PHS # 260519 CC: CHARLES HARTWELL, ESQUIRE 2132 MARKET ST CAMP HILL, PA 17011 260519 PHELAN HALLINAN & SCHMIEG, LLP Sheetal R. Shah-Jani, Esq., Id. No.81760 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. AMY L. SNYDER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 11-7918 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the 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 Servicemembers Civil Relief Act of Congress of 1940, .as amended. (b) that defendant AMY L. SNYDER is over 18 years of age and resides at 4177 KITTATINNY DRIVE, MECHANICSBURG, PA 17050-9138. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date f Sheetal R. Sha -J i, squir Attorney for Plainti 260519 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A. VS. AMY L. SNYDER CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 11-7918 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on I By: If you have any questions concerning this matter please contact: Sheetal R. Shah-Jani, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" WELLS FARGO BANK, N.A. V. AMY L. SNYDER Plaintiff Defendant(s) TO: AMY L. SNYDER 4177 KITTATINNY DRIVE MECHANICSBURG, PA 1 7050-9 1 3 8 DATE OF NOTICE: December 7.2011 COURT OF COMMON PLEAS CIVIL DIVISON NO. 11-7918 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 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 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. PHS # 260519 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: wrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 / Allison F. Wells, Esq., Id. No. 309519 / William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 260519 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISON Plaintiff v. NO. 11-7918 CIVIL AMY L. SNYDER CUMBERLAND COUNTY Defendant(s) TO: AMY L. SNYDER CIO CHARLES HARTWELL, ESQ 2132 MARKET ST CAMP HILL, PA 17011 DATE OF NOTICE: December 7, 2011 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. Il"ORTANT 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 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 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. PHS # 260519 Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Ih-W wrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 i t i I" PHS # 260519 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO BANK, N.A. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION v AMY L. SNYDER Defendant(s) NO. 11-7918 CIVIL CUMBERLAND COUNTY To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 12/30/2011 to Date of Sale ($18.03 per diem) $109,672.17 $2,884.80 rn Co = rrt cn r- ?. O --6 rn co N M C t TOTAL Note: Please attach description of property. PHS # 260519 (i> 3F m e& $ ?-1 S.cxa I?? cl*r el -14,1l1man & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff 00f 015'issy ti g-?-) P- 4 a`71( ()S C ' fi _; ? F'P - 00 ? o 9 ? d Q o- i Y ? d U a?x o O a d p ? ?? o ??w d U °A ?? A? oo xT OV gyp, ? W f aid W LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Hampden, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows, to wit: BEGINNING at a point on the southern right of way line of Kittatinny Drive (64 feet wide private), at the dividing line of Lot No. 92 and Lot No. 91, said point also being located 653.18 feet West of the southwest corner of Kittatinny Drive and Tussey Court; ;thence by line of Lot 92 and passing through the centerline of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point; thence by land of Mountain View Village Home Owners Association; North 82 degrees 02 minutes 03 seconds West 20.00 feet to a point; thence by line of lot No. 90 and passing through the center partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point on the southern right of way line of Kittatinny Drive; thence by said right of way line South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point, the place of BEGINNING. CONTAINING 2,000 square feet. BEING Lot No. 91 on the Final Subdivision Plan of Mountain View Village Phase IV, recorded in Plan Book 60, Page 87-B. UNDER AND SUBJECT to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County in Misc. Book 392, Page 787, Misc. Book 393, Page 557, and Misc. Book 414, Page 1102. ALSO UNDER AND SUBJECT to certain restrictions and conditions as appear of record including those in Deed Book 104, Page 779. TITLE TO SAID PREMISES VESTED IN Amy L. Snyder, single, adult individual, by Deed from Lisa A. Hobday, formerly Lisa A. Thompson, and Hylton B. Hobday, her husband, dated 06/07/2007, recorded 07/05/2007 in Book 280, Page 4137. PREMISES BEING: 4177 KIT'TATINNY DRIVE, MECHANICSBURG, PA 17050-9138 PARCEL NO. 10-15-1285-141 PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard Suite 1400 ??F l, '"- r P,CIl(3FICTSi ?. One Penn Center Plaza Philadelphia, PA 19103 20 E 2 FEB 28 A1110:09 215-563-7000 CUMBERLAND COUNT WELLS FARGO BANK, N.A. PENNSYLVANIA! Plaintiff V. AMY L. SNYDER Defendant(s) Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-7918 CIVIL CUMBERLAND COUNTY CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. . A. § 04 relating to unsworn falsification to authorities. By: Phelan Hallinan & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff WFLLS++FARGO BANK, N.A. Plaintiff V. AMY L. SNYDER Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 11-7918 CIVIL CUMBERLAND COUNTY PHS # 260519 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 4177 KITTATINNY DRIVE, MECHANICSBURG, PA 17050-9138. 1. Name and address of Owner(s) or reputed Owner(s): Name AMY L. SNYDER 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 4177 KITTATINNY DRIVE MECHANICSBURG, PA 17050-9138 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 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. MOUNTAIN VIEW VILLAGE MOUNTAINVIEW VILLAGE, INC MOUNTAIN VIEW VILLAGE APTS _ '"0 I HONO TAF is 20i'2 FEB 23 All 10: 00 "UMBERLAND COUNTY PENNSYLVANIA 4175 MOUNTAIN VIEW RD MECHANICSBURG, PA 17050-9118 5226 MEADOWBROOK DR MECHANICSBURG, PA 17050-6834 4173 GROUSE CT MECHANICSBURG, PA 17050-9116 MWNDHAM PLACE P.O BOX 118 ENOLA PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT AMY L. SNYDER C/O CHARLES HARTWELL, ESQUIRE Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA 4177 KITTATINNY DRIVE MECHANICSBURG, PA 17050-9138 2132 MARKET STREET CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 I verify that the statements made in this affidavit are true and correct to the knowledge or information and belief. I understand that false statem erein a of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to autho ties. Date: By: best of my personal made subject to the penalties Phelan Halli an & Schmieg, LLP Robert W. Cusick, Esq., Id. No.80193 Attorney for Plaintiff WELLS FARGO BAP,iI?,1?1L1 ?t:Fc 7W HONOTAK t' 'iIiFEB 28 AM, 10. 09 .; MBERLAN[MOUNTY PENNSYLVANIA AMY L. SNYDER : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : NO.: 11-7918 CIVIL Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: AMY L. SNYDER 4177 KITTATINNY DRIVE MECHANICSBURG, PA 17050-9138 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 4177 KITTATINNY DRIVE, MECHANICSBURG, PA 17050-9138 is scheduled to be sold at the Sheriff's Sale on 06/06/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $109,672.17 obtained by WELLS FARGO BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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 to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 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 also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 the 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Hampden, in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows, to wit: BEGINNING at a point on the southem right of way line of Kittatinny Drive (64 feet wide private), at the dividing line of Lot No. 92 and Lot No. 91, said point also being located 653.18 feet West of the southwest corner of Kittatinny Drive and Tussey Court; ;thence by line of Lot 92 and passing through the centerline of a partition wall South 07 degrees 57 minutes 58 seconds West 100.00 feet to a point; thence by land of Mountain View Village Home Owners Association; North 82 degrees 02 minutes 03 seconds West 20.00 feet to a point; thence by line of lot No. 90 and passing through the center partition wall North 07 degrees 57 minutes 58 seconds East 100.00 feet to a point on the southern right of way line of Kittatinny Drive; thence by said right of way line South 82 degrees 02 minutes 02 seconds East 20.00 feet to a point, the place of BEGINNING. CONTAINING 2,000 square feet. BEING Lot No. 91 on the Final Subdivision Plan of Mountain View Village Phase IV, recorded in Plan Book 60, Page 87-B. UNDER AND SUBJECT to certain restrictions and conditions as appear of record in the Office of the Recorder of Deeds in and for Cumberland County in Misc. Book 392, Page 787, Misc. Book 393, Page 557, and Misc. Book 414, Page 1102. ALSO UNDER AND SUBJECT to certain restrictions and conditions as appear of record including those in Deed Book 104, Page 779. TITLE TO SAID PREMISES VESTED IN Amy L. Snyder, single, adult individual, by Deed from Lisa A. Hobday, formerly Lisa A. Thompson, and Hylton B. Hobday, her husband, dated 06/07/2007, recorded 07/05/2007 in Book 280, Page 4137. PREMISES BEING: 4177 KITTATINNY DRIVE, MECHANICSBURG, PA 17050-9138 PARCEL NO. 10-15-1285-141 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 11-7918 CIVIL WELLS FARGO BANK, N.A. vs. AMY L. SNYDER owner(s) of property situate in the TOWNSHIP OF HAMPDEN, Cumberland County, Pennsylvania, being (Municipality) 4177 KITTATINNY DRIVE, MECHANICSBURG, PA 17050-9138 Parcel No. 10-15-1285-141 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $109,672.17 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-7918 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. Plaintiff (s) From AMY L. SNYDER (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: $109,672.17 L.L.: $.50 Interest from 12/30/2011 to Date of Sale ($18.03 per diem) - $2,884.80 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $175.00 Other Costs: Plaintiff Paid: Date: 2/28/12 David D. B e11, Prothonota IS-,al) Deputy REQUESTING PARTY: Name: ROBERT W. CUSICK, ESQUIRE Address: PHELAN, HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 80193 AFFIDAVIT OF SERVICE (FHLMC) PLAINTIFF CUMBERLAND COUNT ' - lJ t i a WELLS FARGO BANK, N.A. FE £? ? i y 0 NO i A- 1 a PHS # 260519' DEFENDANT SERVICE TE1M8VR 10 Ali 10' 0 3 AMY L. SNYDER COURT NO.: 11-7918 CIVIL MBERLAND COUNTY CU SERVE AMY L. SNYDER AT: TYPE OF ACTIO?Iy,YL?NiA 4177 KITTATINNY DRIVE XX Notice of Shen ?'$' e MECHANICSBURG, PA 17050-9138 SALE DATE: June 6, 2012 SERVED Served and made known to AMY L. SNYDER, Defendant on the M'day of c- W , 20 1 a, at )4" 1 o'clock g. M., at 4H'r7 W I?TAM NNE M, , in the manner described below: _ Defendant personally served. A4k-.04Nics 6Uk6I PA. Adult family member, ?w?i?t?h w?h?o?m? Defendant(s) reside(s). Relationship is J?Q _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. Other: Description: Age 465 Height '0 Weight 7'S Race (/J Sex AA Other 1, Rp7I4-LD M01- L , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. r-? DATE: -31 rd I.1 NAME: PRINTED NAME: KZ)NA-C ? /00 l? TITLE: I)kf-) (f(--S5 JUyJ (EP NOT SERVED On the day of , 20_, at o'clock _. M., Defendant NOT FOUND because: Vacant - Does Not Exist _ Moved _ Does Not Reside (Not Vacant) No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF r?4 Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq.. Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 ti YiCIT. PHELAN HALLINAN & SCHMIEG, LLP Attorney for Puff?; '' t / , Lauren R. Tabas, Esq., Id. No.93337 1617 JFK Boulevard, Suite 1400???' f. Fti a tti ?;l,f`r One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff, V. AMY L. SNYDER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.: 11-7918 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, s t fort o the Affidavit and as amended if applicable. A copy of the Certificate of Mailin (For 3 7) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is h d ereto Exhibit " L6 ren R. Tabas, Es Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 260519 P, d0 Y v con Lc V) b cq ca Cd : y C o d.) CQ U a. a ° O b (U v 4) z¢0 v ? o- " T ? C 4 w .N ° O C ? O ? U C .? p •?yq o a X U ? C .? p p ?? . _.? Qo .. y .u ? ?Ei o _ o E S c-? 3 9"a .5 g a X e m ? e u O o? u >> y b w e Q p,- o C> .4 2 F rA O e ?$?2. $ 0o v q W _ ° o ° o l- / O 6 ? F V A O V° W FF?yI a ? +4 ? O Q O W Z M W ? F ? u CJ o ,cv7 0? vG F- w 9 ? { D z w ? Ow a a D F ,y? W O ? ? rn d O H F w W < d 5 d rnir, q E v z?, Q ? ? u a v O ? r ?1.4 ° o ? ? w W rA w U>C a q c w Q W aQ ?? CW7' . r U o WU' ° '? o.u at ; ti Pr a r? Q - a ti dA r- .r n n v d UF Z? GTi o N wN O i G?r ° a"3¢ a?CQ 7 ? U HAo. Qwo OWM O ? ? pZ"; 0?7w? ` >?a ?0a, r- ? a 3 ? v >P? aZ ?? rx?d A -< a° Wa ? d a w>? >>da d zA waFa U d 3>a z d 3a? i H u A ? w U?? Od? pE gF" " z a ? ' a ?xw W j E" ?C7 Ox fxFx H?HC7 ? a Z g a, ' '?? ? > ? F > v i ~ ? >W? Q ? " ? Uo °o 0 u r1i SP v ] WD`" on m g + v i A r?r Q F W Q ? (S a i CI Q S A . pq OO? aH zoaF W3 v?WN zpq'"? Oz ? O?W z U ONW O?W W" Zv o'v Z Hc? NU A -?U Uax ..,-?o. Oc?Nx ww v? ?v) v a? .n 7 Z # * i*c is 8 # U n L 9 G_ r-1 N en V In O l? 00 O 9 v r4 H O N O O N d I Ur J V3 ?C.1 24 At®' 18 Phelan Hallinan & Schmieg, LLPt? ° - ttorney For Plaintiff 1617 JFK Boulevard, Suite 1400 ?' I ERLAND CO'JS 'SYLIA"t One Penn Center Plaza qi;i Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County AMY L. SNYDER Defendant No. 11-7918 CIVIL TO THE PROTHONOTARY: PRAECIPE ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ? Please mark the above referenced case Settled, Discontinued and Ended. ® Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ? Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ? Please Vacate the Judgment entered. Date: O CT 2 3 2012 PHS # 260519 ELA ALLIN & HMIEG, LLP Y? e issa J. antwell, Esq., dAttorney for Plaintiff ?\ sb?-' 00 C'L4 da ?ff aga3l2 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County AMY L. SNYDER No. 11-7918 CIVIL Defendant CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: CHARLES HARTWELL, ESQUIRE 2132 MARKET ST CAMP HILL, PA 17011 Date: OCT 2 3 2012 P LAN LLINAN HMIEG, LLP B Melissa J. Cantwell, 308912 Attorney for Plaintiff PHS # 260519