HomeMy WebLinkAbout11-8449IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
WELLS FARGO BANK, N.A., CIVIL DIVISION
Plaintiff, NO.:
VS.
TYPE OF PLEADING
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
CIVIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
Defendants.
TO: DEFENDANTS
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY.
BE ENTERED AGAINST YOU.
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS
PARTY:
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3476 STATEVIEW BLVD
MAC # X7801-013. FT. MILL. SC 29715
AND THE DEFENDANT:
18 West Locust Street
Mechanicsburg, PA 17055-6333
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
I8 West Locust Street. Mechanicsburg PA 17055-6333
Munici : Me ianicsbur
? ? kf, N ATTO LANTIFF 011, ATTY FILE NO.: XFP 158420
ZUCKER, GOLDBERG & (
ACKERMAN, LLC
Scott A. Dietterick, Esquire -:?
Pa. I.D. #55650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
Joel A. Ackerman, Esquire ;
Pa I.D. #202729
Ashleigh Levy Marin, Esquire '
Pa I.D. #306799
Ralph M. Salvia, Esquire
Pa I.D. #202946
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldberg.com
File No.: XFP- 158420/ncp
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0"'A 't 9?,60,Pd 7
Cho 90WE
(Z* 0l0-7093
Zucker, Goldberg & Ackerman, LLC
XFP-158420
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET
SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY
PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30)
DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN
AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF
REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL
FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE
ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30)
DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO
COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER
TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,
YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF
THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE
ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON
YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS
SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN
ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL
ESTATE.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., : CIVIL DIVISION
Plaintiff, . NO.:
vs.
Christopher L. Van Brederode ; Patrecia E.
Van Brederode a\k\a Patrecia Van Brederode;
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
LAWYER REFERRAL
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
Zucker, Goldberg & Ackerman, LLC
XFP-158420
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., : CIVIL DIVISION
Plaintiff, : NO.:
vs.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendants
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda
establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias
despu6s de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de
un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas y
objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar
acci6n como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un
fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o
remedio solicitado por el demandante, puede ser dictado en contra suya por la Corte. Usted
puede perder dinero o propiedades u otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE UN ABOGADO O NO PUEDE PAGAR UNO, LLAME O VAYA A LA
SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA
LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
LAWYER REFERRAL
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
Zucker, Goldberg & Ackerman, LLC
XFP-158420
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., : CIVIL DIVISION
Plaintiff, : NO.:
vs.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendants.
CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC,
and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") having its principal
place of business at 3476 STATEVIEW BLVD., MAC # X7801-013, FT. MILL, SC 29715.
2. The Defendants, Christopher L. Van Brederode and Patrecia E. Van Brederode a\k\a
Patrecia Van Brederode, are individuals whose last known address is 18 West Locust Street,
Mechanicsburg, PA 17055-6333.
3. On or about June 15, 2006, Christopher L. Van Brederode and Patrecia E. Van
Brederode executed a Note in favor of M&T Mortgage Corporation in the original principal amount of
$146,697.00.
4. On or about June 15, 2006, as security for payment of the aforesaid Note,
Christopher L. Van Brederode and Patrecia E. Van Brederode made, executed and delivered to
Mortgage Electronic Registration Systems, Inc. as nominee for M&T Mortgage Corporation a
Mortgage in the original principal amount of $146,697.00 on the premises hereinafter described,
with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on
July 10, 2006, in Mortgage Book Volume 1957, Page 4231. A true and correct copy of said Mortgage
containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached
hereto and made a part hereof.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
5. The note and mortgage was assigned by Assignment of Mortgage dated 08/30/2011
from Mortgage Electronic Registration Systems, Inc. as nominee for M&T Mortgage Corporation to
Wells Fargo Bank, N.A.. Said assignment was recorded 09/02/2011, Instrument #201124566
6. The aforesaid Mortgage was amended and increased in principal amount of
$145,097.16 pursuant to a certain Modification Agreement by and between Wells Fargo Bank, N.A.
and Defendants, Christopher L. Van Brederode and Patrecia E. Van Brederode, which is unrecorded at
this time. The terms of said modification set forth the interest rate at 5.125% with a new monthly
payment and interest amount of $ 790.04 commencing July 1, 2010 and continuing thereon with the
due date of obligation June 1, 2040. A true and correct copy of said Modification Agreement is
marked Exhibit B, attached hereto and made a part hereof.
7. Christopher L. Van Brederode and Patrecia E. Van Brederode, h\w are record and real
owners of the aforesaid mortgaged premises.
8. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due.
9. Plaintiff was not required to send Defendant(s) written Notice pursuant to 35 P.S.
§1680.403 (c) (Homeowners' Emergency Mortgage Assistance Act of 1983, - Act 91 of 1983), prior to
commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal
Housing Administration under Title II of the National Housing Act (12 U.S.C. §§1707 -1715(z) - 18) [35
P.S. §1680.401(x)(3).].
10. Plaintiff was not required to send Defendant(s) written notice of Plaintiff's intention
to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of
this action for the reason that the original principal balance of the aforesaid Mortgage is more than
the original principal balance threshold of the Act, and therefore:
(a) said Mortgage is not a "residential mortgage" as defined in 41 P.S. §101;
(b) the Defendant(s) is/are not "residential mortgage debtor(s)" as defined in 41 P.S.
§101, and;
(c) the mortgage premises is not "residential real property" as defined in 41 P.S. §101.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
11. The amount due and owing Plaintiff by Defendants is as follows:
Principal $143,360.51
Interest through 10/24/2011 $4,136.59
Late Charges $ 324.03
Escrow/Advance $1,276.78
Inspection Fee $ 80.00
Corporate Advance $20.00
Total $149,197.91
plus interest on the principal sum ($143,360.51) at the daily per diem amount of $20.13, and all other
additional amounts authorized under the Mortgage, actually and reasonably incurred by Plaintiff,
including but not limited to, late charges, costs (including escrow advances) and Plaintiffs attorneys'
fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add
such additional sums to the above amount due and owning when incurred.
12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not
seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a
separate legal action if such right exists. If Defendant(s) have received a discharge of personal
liability under the aforesaid Note in a bankruptcy proceeding, this action is in no way an attempt to
re-establish such liability.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of
$149,197.91, with interest thereon at the daily per diem amount of $20.13 plus additional late
charges, and costs (including additional escrow advances), additional attorneys' fees and costs and
for foreclosure and sale of the mortgaged premises.
ZUCKER, L BERG & ACKERMAN, LLC
r
BY: h/p
Dated: November ,2011 Scott A. D e rick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh Levy Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Attorneys for Plaintiff
XFP-158420/ncp
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
VT
CX4 b
S^Y
2886 JUL 1Q AM 10 28
ReturnTo:M3T Mortgage Corporation
P.O. Box 4613
Buffalo, NY 14240
Paroel Number: 16.23.0565.040
Its Avow 7Ws un. 7w Paces ft am] -
MA Cm No.
commawealth of Pknylvania MORTGAGE 441.7812723.703
MIN 1000501300004901063
THIS MORTGAGE ("Security Instrument') is given onJune 15, 2006
The Mortgagor is Christopher L Van Brederode, Patrfci a Van Brederode
("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc.
("MERS"), (solely as nominee for Leader, as hereinafter defied, and Larder's mccesaora and assigns), as
mortgagee. MEtS is organised and existing under the laws of Delaware, and bw an address and telephone
number of P.O. Box 2026, Flint, Ml 48301-2026, Gel, (08) 679-MERS. M&T Mortgage
Corporation
(*Lender") is organized and existing under the laws of New York , and
hasanaddmuofl N&T Plaza. Buffalo, NY 14203
. Borrower owes Leader the principal sum of
One Hundred Forty Six Thousand Six Hundred Ninety Seven And Zero/100
Dollars (U.S. $ 146, 697.00 ).
nu F+e4r1 I"w14 h6w4 a wa mu - 41%
4 ft4 tPAI to wi
Page i at 10 InIWb;
VMP MORTGAGE FORMS • 1400)821- 81
11589173 11589173
OKI957PG4231
This debt is evidenced by Borrower's note dated the same date as this Security Instrument
("Note"), which provides for monthly payments, with the full debt, if act paid earlier, due and payable
on July 01, 2036 . This Security Instrument secures to I ader: (a) the
repayment of the debt evidenced by the Note, with interest, and all rarewrals, a dendons and modiflications
of the Note; (b) the payment of all other sums, with interest, advanced unda paragraph 7 to protect
the security of this Sxurity lastcument; and (c) the performaaos of Borrower's owmanrs and
agreements under this Security Instrument and the Note. For this purpose, Borrower does
hereby mortgage, grant and convey to MFRS (solely as nominee for Lender and Lmder's sucoessors and
assigns) and to the successors and assigns of M MS, the following described property located in
Cumberland county, Pennsylvania:
Please see attached schedule A.
which has the address of 18 West Locust Street (Street)
Mechanicsburg (city), Peansylvania17055 cupcO&l
("Property Addreaa");
TOGETHER WITH all the improvements now or hereafter erected on the property, and all
easements, appurtenances and fixtures now or hereafter a part of the property. All mplace ments and
additions shall also be covered by this Security Inatrmaens. All of the foregoing is referred to in ibis
Security Insertuoent as the "Property." Borrower under mils; and agrees that NM holds only legal title
to the interests granted by Borrower in this Security Instrument; but, if necessary to ootaply with law or
custom, MERE, (as nominee for Fender and I.enderIa successors sad assigns), bas the right: to exercise
any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and
to talm any action required of Lender including, but not limited to, releasing or canceling this Security
Instrument.
BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has
the right to mortgage, grant and convey the Property and that the Property is unencumbered, ecreapt for
entrances of record. Borrower warrants and will defend generally the title to the Property against ail
claims and demands, subject to nay ancumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use ad tron-wuform
covenants with limited variations by jurisdiction to constitute a uniform security inatrntment covering real
pmPelty,
-4N(PAt lemon
11589173
Pp" Z of 10
MR144:
11589173
BK i 957PG423Z
Borrower and Leader covenant and agree as follows:
UNIFORM COVENANTS.
1. Payment of Principal, later at anal We Charge, Bonower shall pry when due the principal of,
and interest on, the debt evidenced by the Note and Isle charges dire undw the Note.
Z. Moaly Pr;yma d of Tares, hworaroe coal Odor Cdhrges. Borrower shall include in each
monthly payment, together with the principal and interact as set forth in the Note and my lame charges, a
sum for (a) taxes and special assessmeora levied or to be levied against the Property, (b) leasehold
payments or ground rents on the Property, and (e) premiums for in mum required under paragraph 4. In
any year in which tin [.ender =9 pay a mortgage insurance premium to the Secretary of Housing and
Urban Development ("Secretary% or in any you in which such premium would have been required if
Lander still bold the Security Instrument, each monthly payment shall also include either: (i) a sum for the
anmral mortgage insurance premium to be paid by Deader to the Secretary, or (li) a monthly charge instead
of a mmmgage insurance premium if this Searrity Instrument is held by the Secretary, in a reasonable
amount to be determined by the Secretary. Except for the monthly charge by the Secretary, than items are
called "Escrow Items" and the sums paid to Lander are called "Escrow Funds. "
I.ender may, at arty time, collect and hold amounts for Escrow hems in an aggregate amount not to
exceed the mutimmm stuowtt that may be required for Borrower's escrow account trader the Red Estate
Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 ot seq. ad implementing regulations, 24 CFR
Part 3300, as they may be ascended from time to time ("RESPA"), except that the cushion or reserve
permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are
available in the account may not be based on amounts due for the mortgage inarrance premium.
If the amounts held by Lander for Escrow Items exceed the amottmts permitted to be held by RESPA,
Lander shall account to Borrower for the excess fiords as required by RESPA. If the amounts of finds
held by Lennder at any time are not sufficient to pay the Escrow Items when due, Lender may notify the
Borrower and require Borrower to maim up the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional security for all secured by this Security Instrument.
If Borrower tenders to Lender the rail payment of all such sums, Borrower's account shall be credited with
the balance remaining for all installment items (a), (b), and (c) aid any mortgage insurance premium
installment that Leader has not become obligated to pay to the Secretary, and Lander shall promptly refted
say exacts Mmda to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by
Leader, Borrower's account shall be credited with any balance remaining for all instalimamts for items (a),
(b), and (c).
3. Application of Payments. All payments under paragraphs 1 and 2 shall be applied by Lender as
follows-
First, to the mortgage inanrance premium to be paid by Lander to the Secretary or to the monthly
charge by the Secretary instead of the monthly mortgage insurance premium;
Seepad, to any tastes, special asseum ants, leasehold payments or ground rents, and fire, flood and
other hazard insurance premiums, as requited;
7%W, to interest due under the Note;
Fourth, to amortization of the principal of the Note; aM
Fitt , to late charges due under the Note.
T-776, Flood and Other Haotard Insunna. Borrower shall insure all i epmvemants on the
Property, whether now in existence or subsequently erected, against any hazards, cacudtin, and
contingencies, including fire, for which Lender requires insurance. This insurance shall be nuidnWaed in
tf tialiPA) (ow) P@U" 3 0 to
11589173
11589173
BK f 957PG4233
the :mounts and for the periods that Lender requires. Borrower shall also insure all improvements on the
property, whether now in exisa mce or subsequently erected, against loss by floods to the extort required
by the Secretary. All insurance shall be carried with companies approved by Leader. The insuravice
policies and any renewals shall be held by Lennler and shall include loss payable clauses in favor of, and in
a form acceptable to, Lander.
In the event of loss, Borrower shall give Lender immediate notice by mail. Leader may make proof of
loss if not made promptly by Borrower. Each insurance company eonoerned is hereby authorized and
directed to mains payment for such loaf directly to Lender, instead of to Borrower and to Gender jointly.
All or any part of the inauram proceeds may be applied by Lander, at its option, either (a) to the
reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts
applied in the order in paragraph 3, and than to prepayment of principal, or (b) to due restoration or repair
of the damaged Property. Any application of the proceeds to the principal :hail not extend or postpone the
due date of the monthly payments which are refereed to in paragraph 2, or change the amount of such
payments. Any excess insurance proceeds over in amount required to pay all outstanding indebee ess
under the Note and this Security Itatcument shall be paid to the entity lepllyx MOW thereto.
in due event of foreclosure of this Security Instrument or other trtnrsfer of title to the Property that
extinguishes the indebtedness, all right, title and interest of Borrower in and to infnrsoce policies in force
shall pass to the purchaser.
S. Occap o y, Ptateavadon, Malatanaaee sad Froteedon of due Ptvputy; Borrower's Loma
AppNatim; Leaseholds. Borrower shall occupy, establish, and use the Properly as Borrower's principal
residence within sixty days after the execution of this Security h tnument (or within sixty days of a later
sale or tramfer of the Property) and shall continue to occupy the Property as Borrower's principal
residence for at least one year after the date of occupancy, unless Lends determines that requirement will
cause undue hardship for Borrower, or unless extenuating circiiantances. old which are beyond
Borrower's control. Borrower mhall notify Lander of any extentuetimg circumttanow. Borrower shall not
commit waste or destroy. damage or substantially slumps the Property or allow the Property to deteriorate,
reasonable wear send tar excepted. I.sodar may inspect the property if the Property is vacant or abandoned
or the loan is in default. Leader may tales ruraaonahrle action. to protect and preserve such vacant or
abandoned Property. Borrower shall also be in default if Borrower, during the loan application process,
gave materially false or inaccurate information or statements to Lender (or failed to provide Leader with
any material fth oration) in cormection with the loan evidanced by the Note, including, but not limited to,
repRessatatlons concerning Borrower's ocwpmq of the Property as a principal residence. If this Security
Instrument is on a leasehold, Borrower shall oonnply with the provisions of the lease. If Borrower acquires
fee title to the property, the leasehold and fee title shall not be merged unless Lander sprees to the merger
in writing.
ti. Coodsmaadon. The proceeds of any award or claim for damages, direct or consequential, in
connection with any condemnation or other taking of any part of the Property, or for conveyance in place
of condemnation, are hereby assigned and shall be paid to I.emdar to the extent of the full amount of the
itdebtedtaeas that remains unrpald under the Note and this Security bastm-t. I.tncler shall apply mticb
proceeds to the reduction of the indebtedness under the Note and this Security Insavmant, first to any
delinquent amounts applied in the order provided im paragraph 3, and then to prepayment of principal. Any
application of the proceeds to the principal :ball not extend or postpone the due date of the monthly
payments, which are referred to in paragraph 2. or change the amount of much payments. Any excess
proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security
instillment shall be paid to the entity legally entitled tlwetu.
qk-WPAf loon Page a of $0
11589173 11588173
$K1957PG4234
7. Charges to Borrower snd Pratecdoa of Leader's Rhgpb In the Property. Borrower shall pay all
governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower
shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would
adversely affix [.creches interest in the Property, upon Leader's request Borrower shall promptly finrnish
to I receipts evidmiug then payments.
If Borrower fails to make these payments or the payments required by padataph 2, or fans to
perform nay other covenants and agreements contained In this Security Instrument, or there is a legal
proceeding drat may significantly affect I.anderIs rights in the Property (such as a proceeding in
bankruptcy, for condeargation or to enforce laws or regulations), then Gender may do and pay whatever is
necessary to protect the value of the Property and Lender's rights in the property, including payment of
taxas, hand insuraaoe and other items mentioned in paragraph 2.
Any amounts disbursed by Lender uoda this puagcaph shall become an additional debt of Borrower
and be secured by this Security Instrument. These amounts shall bear interest from the date of
disbursement, at the Note rate, and at de option of Lender, shall be immediately due and payable.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a mama acceptable
to Lender; (b) contests in good faith the lien by, or deaurda against enforcesum of the lien in, legal
proceedings which in the Leader's opinion operate to prevent the enforcement of the lien; or (c) secures
from the holder of the lien an agreement satisfactory to Lender subordinating the Tian to this Security
Instrument. If Lender determines that any part of the Property Is subject to a lien which may attain priority
over this Security Instrument, Lender may Siva Borrower a notice identifying the lien. Borrower shall
satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice.
8. Fees. Lender may collect fees and charges authorized by the Secretary.
9. Groomes for Aeoderstion of Debt.
(a) Debult. Lender may, except as limited by regulations issued by the Secretary, in the case of
payment defaults, require immediate payment in full of all sums secuued by this Security
Instrument if:
(i) Borrower defaults by failing to pay In full any monthly payment required by this Security
Instrument prior to or on the due date of the next monthly payment. or
(ii) Borrower defaults by failing, for a period of thirty days, to perform any odner obligations
contained in this Security Instrument.
(b) Me Whbout Credit Approval. Lender shall, if permitted by applicable law (including
Section 341(d) of the Garn-St. Germain Depository Institutions Act of 1982, 12 U.S.C.
1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all
sums secured by this Security Instrument if:
(i) All or part of the Property, or a beneficial interest in a trust owning all or part of the
Property, is sold or otherwise transferred (odor than by devise or descent), and
(ii) The Property is not occupied by the purchaser or grantee a his or her priacipat residenen,
or the purchaser or grantee does so occupy the property but his or her credit has not bean
approved in accordance with the requirements of the Secretary.
(c) No Waiver. If circumstances occur that would permit I.amder to require immediate payment in
full. but Lender does not require such payments, Leader does not waive its rights with respect to
subsequent events.
-?NPA) 102071 Paw a of +o
11589173 11589173
OK ! 957PG4235
(d) Regulations of HUD Secrefary. In many cinuestaaoes regulations issued by the Secretary -
will limit Lender's rights, in the can of payment defailts, to require immediate payment in full
and foreclose if not paid. This Security Instrument does not sudwrize acceleration or foreclosure if
not permitted by regulations of the Secretary.
(a) Mesipp Not Ioaoaed. Borrower agrees that if this Security Instrument and the Note are not
determined to be eligible for insurance under the National Housing Act within 60 days from the
date hereof, Leader may, at its option, require immediate payment in full of all sums secured by
this Security Instrument, A written statamoent of any authorized agent of the Secretary dated
subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the
Note, shall be domed conclusive proof of sash ineligibility. Notwithstanding the foregoing, this
option may not be exercised by Lender wban the uoavsilability of hwx nee is solely due to
leader's failure to remit a mortgage hrz=ce premium to the Secretary.
10. RalmotahasmL Borrower has a right to be reinserted if Lender has required immediate payment
in full because of Borrower's failure to pay an amount due under the Note or this Security lnatnumemt. This
right applies even after foreclosure proceedings me instituted. To reinstate the Security hwiru meat,
Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including,
to the extant they are obligations of Borrower under this Security iastrnaemt, foreclosure costs and
reasonable and customary attorneys' fees and expetwo properly associated with the foreclosure proceeding.
Upon reinstatement by Borrower, this Security Instrument and the obligations that it segues shall remain
in effect as if Lender had not required immediate payment in hull. However, mender is not required to
permit rei t if: (i) Imder has accepted reimtaumpn after the commencement of foreclosure
proceedings within two years immediately preceding the commencement of a currant foreclosure
proceeding, (it) miaotatemeut will preclude foreclosure on diftrent grounds in the future, or (iii)
reinstatement will adversely affect de priority of the lien created by this Security Iastnmont.
11. Borrower Not R[isaaed; Forbearance By I,saier Not a Wah'er. Extension of the time of
payment or medlflcation of amortization of the was secured by this Security Instrument granted by Leader
to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or
Borrower's successor in interest. Lendcx shall not be required to commence proceedings against any
successor in interest or refuse to extend time for payment or otherwise modify amortization of the awns
secured by this Security Lnstnunemt by reason of airy demand made by the original Borrower or Bormwer's
successors in interest. Any fb,tesunoe by Lender in arercising any right or remedy shall not be a waiver
of or preclude the exercise of any right or remedy.
12. ?Smccee n sad Assips Bound; Joint sod Several IdabOy, C0,9igsass. The covenants and
agreement: of this Security bmtrument sball bind and beaallt the sueoasors and assigns of leader and
Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and sSnonoms shall be joint
and several. Any Borrower who co-signs this security Insttumeat but does not execute the Note: (a) is
co-signing this Security Instrument only to mortgage, grant and convoy that Borrower's interest in the
Property under the terms of this Security lastrmment; (b) is not personally obligated to pry the sums
secured by this security Instrmmew; and (c) agrees that I.errder and any other Borrower may agree to
extend, modify, forbear or main any accommodations with regard to the terms of this Security Instnmmment
or the Note without that Borrower's wnseat.
IPA) mom Page a of 10
11589173 11588173
OK 1957PG4236
13. Nodoes. Any notice to Borrower provided for in this Security Instrument shall be given by
delivering it or by mailing it by first class mail unless applicable law requires use of another method. The
notice shall be directed to the Property Address or any other address Borrower designstes by notice to
Lender. Any notice to Lender shall be given by first class mail to Leader's address stead heroin or any
address Lender dedSuates by notice to Borrower. Any notice provided for in this Security Instrument shall
be deemed to have been given to Borrower or Lender when given as provided in this paragraph.
14. Goosing Law; Severabi ft. This Security Instrument shall be governed by Federal law and
the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this
Security Instrument or the Note conflicts with applicable law. such conflict sbakl not affect other provisions
of this Security Instrument or the Note which can be given effect without the conflicting provision. To this
end the provisions of this Security Instrument ad the Not* are declared to be severable.
1S. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security
Instrument.
16. Hssatrdoua Subshnees. Borrower shall not cause or permit the presence, use, disposal, storage,
or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone
else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding
two sentences shall not apply to the presence, use, or storage on the Property of small quantities of
Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to
maintenance of the property.
Borrower shall promptly give Larder written notice of any investigation, claim, demand, lawsuit or
otter action by any governmental or regulatory agency or private parry involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns,
or is notified by any governmental or regulatory authority, that any removal or other remedia ion of any
Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary
mmedial actions in accordance with Environmental Law.
As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or
hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other
flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials
containing sabeens or formaldehyde, and radioactive materials. As used in this paragraph 16,
'Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that
relate to health, safety or environmental protection.
NON-UNIFORM COVENANTS. Borrower and I.ender further covenant and agree as follows:
17. AmdamseM of Rents. Borrower unconditionally assigns and ttmtshn to Lender all the rents and
revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents anal revenues
and hereby directs each tenant of the Property to pay the rents to Lea>dar or Lender's agents. However,
prior to Leader's notice to Borrower of Borrower's breach of any covenant or agreement in die Security
Instrument, Borrower shall collect and receive sU rants and revenues of the Property as trustee for the
benefit of Lender sod Borrower. This assignment of rents constitutes an absolute assignment am not an
assignment for additional security only.
If I?ender gives notice of breech to Borrower: (a) all rents received by Borrower shall be held by
Borrower as trustee for benefit of Lender only. to be applied to the sums secured by the Security
Instrument; (b) Leader shall be entitled to collect and receive all of the tarots of the Property; and (c) each
-4NtPA) 102071 Pp" T 01 10
11588173 11589173
6K 1957PG4237
tenant of the Property shall pay all rents due and unpaid to Lander or bender's agent on Lender's written
demand to the tesuat.
Borrower has not executed any prior assignment of the rents and has not and will not perform any act
that would prevent Lender from exereising its rights under this p unrapb 17.
Linder shall not be required to inter upon, take control of or mslnwin the Property before or after
giving notice of breach to Borrower. However, Lander or a Judicially gpoirnad receiver may do so at any
time there is a breach. Any application of no dual not cure or waive gay default or inval dace any other
right or remedy of Loader. This assignment of rents of the property dual terminate whoa the debt secuted
by the Security Instrument is paid in W.
18. Foredssure Pr'ovedm+e. N Lentder requires imescdiate poyase d in lull order parapapb 9,
Leader may foreclose tole goodly Itatrauaat by JWkld psvcssM . Leader d M be 111de I to
collect ail expenses hwursW to pursuing the reandles provided in this poregroph 18, Including, but
mot MWW to, atter'sys' her add nosh of tuts a Monte.
9 the Loooder's Interest in this goodly Inshvroeait b held by the Secretary and the Secretary
requires imwdhte paymurot in !Mill under 1!lar pq6 9, the Ssae<ary rosy lavohs the aegjndicial
power of gate prodded in the Sites FWdly 116 ISags !'eredosure Aid of JIM ("Act') (u U.S.C.
3751 d seq.) by regmw ft a forsdssttn eowalssisner doWded under the Act to commence
foreclosure mod to sell the Property as provkhd In the Act. Nothing to the prueding sse/esnce shoo
deprlye the Secretary of any rights otbervlse available to a Lender mvi r this Puvip aph 18 or
applicable law.
19. Release. Upon payment of all sums secured by this Security iastrun=, this Security Instrument
and the astem conveyed shall terminate and become void. After such occurrence. Lender shall disdwge
and satisfy this Security Instrrnem without charge to Borrower. Borrower shall pay any recordation
costs.
?A. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or
defects in proceedings to enforce this Security Instrument, and hereby waives the boadit of any present or
futum laws providing for stay of execution, extension of time. examption from attachment, levy and sale,
and homestead exemption.
31. Rishwh Cement Period. Borrower's time to rdustate provided in paragraph 10 stroll extend to
one hour prior to the commencement of bidding at a sbotifrs sate or other sale pursuant to this Security
Instrument.
ZZ. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is leaf to
Borrower to acquire title to the Property, this Security Instrument :bail be a purchase money mortgage.
23. L detest Rate Alter Judgment. Borrower agrees that the interest rase payable after a judgment
is entered on the Note or in an action of mortgage fomclosum shall be the rate payable from time to time
under the Note.
Z4. Rides to this Seeudly hotr usreot. If one or more riders are executed by Borrower and
recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into
and dull amend and supplement the covenants and agreements of this Security Inatnunent as if the rider(s)
were a part of this Security Inshunent. [Check applicable box(es)].
? Condominium Rider Growing Equity Rider ? Other [specify]
? Planned Unit Development Rider Graduated Payment Rider
inner: /G "
qk-4WPA) tom» Pp. $ *f to
11589173
11589173
OKI957PG4238
BY SIGNING BELOW, Borrower accepts and agrees to the tetma contained in tWs Sectuity -
Instrumant and in any rider(s) exectued by Borrower and recorded with it.
Witnesses:
(.Sea)
hri stopher L Van 8rederode •Dormwer
atr*ci a Van Brederode -Borrower
-(Seld)
-Borrower
- (Scat)
-Borrower
(Seal)
-Borrower
- (Seal)
-Borrower
- (Seal) (Seal)
•Borrowor -Borrower
4 ftAWA) 10207) Pace • of 10
11589173 11589173
SK! 957PG4239
CsavllciNe /
I, , do hereby certify that
the correct of the G
within-named Mortgage is P.O. Box 2026, Flint, MI 48501-2026.
Witness my hand this 15th day of June 2006
AVW of Moraaaee
COMMONWEALTH OF PENNSYLVAM A, ouv&e/6-17? Cooney as:
Oa this,15th day of June , 2006 , before me, the undersigned officer,
personally appearodChri stopher t Van Brederode and Patricia Van Brederode
]mown to me (or sadsfacwUy proven) to be the
person(s) whose name(s) is/are subscribed to the within instrunwat and aclmowtedged that he dWdwy
executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hemunto set my hand and official seal.
My Commission Expires:
EAtH ! Yt vd?INIA
adsasi
Poaedt C?,n. Nnoddtr tic
t? T* 000* tbds*
hers Wvft l v t?psas J* i3, g0W
d WWW. PrIN010 M. ANOOlsbon
]tide of omm
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11588173
?w• logo 10
11588173
BKI957PG4240
FIDELITY NATIONAL TITLE INSURANCE COMPANY
SCHEDULE C
DESCRIPTION
File No. 0286
Property Parcel Number
Commitment No. 0286
See Attached Exhibit A
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ft"b"d and WK Or&vM hwein.
`,e.rtity LIILS to be recorded
In Cumberland County PA
a
Recorder of Deeds
8K 1957PG42`4 1
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP-158420
6M(BIT
Wells Fargo Home Mortgage
MAC X9999-01 N
1000 Blue Gentian Rd
Ste 300
Eagan, MN 55121
LOAN MODIFICATION AGREEMENT
LOAN NUMBER: 708
THIS LOAN MODIFICATION AGREEMENT ("Agreement"), made on
May 06, 2010, by and between Christopher L van Brederode and
Patrecia Van Brederode and (the "Borrower(s)") and
Wells Fargo Bank, N A (the "Lender", together with the
Borrower(s), the "Parties").
WITNESSETH
WHEREAS, Borrower has requested and Lender has agreed, subject to the
following terms and conditions, to a loan modification as follows:
NOW THEREFORE, in consideration of the covenants hereinafter set forth
and for other good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged by the Parties, it is agreed
as follows (notwithstanding anything to the contrary in the Note and
Security Instrument dated 06/15/2006.)
1. BALANCE. As of May 06, 2010, the amount payable under the Note
and Security Instrument (the "Unpaid Principal Balance") is U.S.
$ 140,781.28.
2. EXTENSION. This Agreement hereby modifies the following terms of the
Note and Security Instrument described herein above as follows:
A. The current contractual due date has been extended from 02-01-10
to 07/01/2010. The first modified contractual due date is on
07/01/2010.
B. The maturity date has been extended from 07-36 (month/year) to
06/01/2040.
C. The amount of :interest to be included (capitalized) will be U.S.
$ 4,106.10.
The amount of the Escrow Advance to be capitalized will be U.S. $1,426.48.
The amount of Recoverable Expenses* to be capitalized will be
U.S. $0.00.
The modified Unpaid Principal Balance is U.S. $ 145,097.16.
* Recoverable Expenses may include, but are not limited to: Title,
Attorney fees/costs, BPO/Appraisal, and/or Property Preservation/
Property Inspections
D. The Borrower(s) promises to pay the Unpaid Principal Balance plus
interest, to the order of the Lender. Interest will be charged on the
Unpaid Principal Balance of U.S. $ 145,097.16. The Borrower(s) promises
to make monthly payments of principal and interest of U.S. $ 790.04,
at a yearly rate of 5.1251, not including any escrow deposit, if
applicable. If on the maturity date the Borrower (s) still owes an amount
under the Note and Security Instrument, as amended by this Agreement,
Borrower(s) will pay this amount in full on the maturity date.
* (If applicable, all scheduled step rate changes according to your Note
and Security Instrument will remain unchanged.) LM521/OMT/1
Wells Fargo Home Mortgage
is a division of Wells Fargo Bank, N.A.
Wells Fargo Home Mortgage
MAC X9999-01 N
1000 Blue Gentian Rd
Ste 300
Eagan, MN 55121
3. NOTE AND SECURITY INSTRUMENT. Nothing in this Agreement shall be
understood or construed to be a satisfaction or release, in whole or in
part of the Borrower's obligations under the Note or Security Instrument.
Further, except-as otherwise specifically provided in this Agreement, the
Note and Security Instrument will remain unchanged, and Borrower and
Lender will be bound by, and shall comply with, all of the terms and
provisions thereof, as amended by this Agreement.
4. The undersigned Borrower (s) acknowledge receipt and acceptance of the
Loan Modification Settlement Statement. Borrower(s) agree with the
information disclosed in and understand that I/we am/are responsible for
payment of any outstanding balances outlined in the Loan Modification
Settlement.
5. The undersigned Borrower (s) acknowledge receipt and acceptance of the
Borrower Acknowledgements, Agreements, and Disclosures Document (BRAD).
6. If included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the Truth in Lending statement.
7. If included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the special Flood Hazard Area (SFHA).
8. That (he/she/they) (is/are) the Borrower(s) on the above-referenced
Mortgage Loan serviced by Wells Fargo Bank, N A.
That (he/she/they) have experienced a financial hardship or change in
financial circumstances since the origination of (his/her/their)
Mortgage Loan.
That (he/she/they) did not intentionally or purposefully default on the
Mortgage Loan in order to obtain a loan modification.
LM521/OMT,/ 2
Wells Fargo Home Mortgage
is a division of Wells Fargo Bank, N.A.
Wells Fargo Homo Mortgage
MAC X9999-01 N
1000 Blue Gentian Rd
Ste 300
Eagan, MN 55121
CORRECTION AGREEMENT. The undersigned borrower(s), for and in
consideration of the approval, closing and funding of this
modification, hereby grants Wells Fargo Bank, N A, as
lender, limited power of attorney to correct and/or initial all
typographical or clerical errors discovered in the modification
Agreement required to be signed. In the event this limited power of
attorney is exercised, the undersigned will be notified and receive
a copy of the document executed or initialed on their behalf. This
provision may not be used to modify the interest rate, modify the
term, modify the outstanding principal balance or modify the
undersigned's monthly principal and interest payments as modified by
this agreement. Any of these specified changes must be executed
directly by the undersigned. This limited power of attorney shall
automatically terminate in 120 days from the closing date of the
undersigned's Modification. C4-. (Borrower initial)
IN WITNESS WHEREOF, the Parties hereto have executed this Agreement as
the date first above written.
By signing this Agreement I hereby consent to being contacted concerning
this loan at any cellular or mobile telephone number I may have. This
includes text messages and telephone calls including the use of
automated dialing systems to contact my cellular or mobile telephone.
You will. not be billed by your cellular or mobile carrier for any text
messages you may receive from wells Fargo, however, any calls we place
to your cellular or mobile phone will incur normal airtime charges
assessed by your mobile carrier.
aated as of s C1 f4 day of M 2a
Chr'stopher L Van Brederode Patrecia Van Brederode
Signature Signature
Wel s Fargo Bank, N A
Name: -Kirn
VP of Loan Documentation
Its:
LM527/OMT/3
Wells Fargo Horne Mortgage
is a division of Wells Fargo Bank, N.A.
VERIFICATION
Joseph Haddad, hereby states that he/o(e is Vice President Loan Documentation
of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in
this matter, that he/ is authorized to make this Verification, and verify that the
statements made in the foregoing Civil Action in Mortgage Foreclosure are true and
correct to the best of his/ information and belief. The undersigned understands that
this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
Name: Joseph Haddad
DATE: JVLA/`W ?1. ? Lilt-fI
T Title: Vice President Loan Documentation
File #: X?FP-158420
Name: VAN BREDERODE
032-PA-V3.1
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?flt??,tr at 4uuiGrr???j+9
OFFicC i - -FRIFF
i? ILED-OFF It,L
C'F THE PR01- ON0TAR Y
20,11 NOY 18 AM 10: 55
CUMBERLAND COUNTY
PENNSYLVANIA
Wells Fargo Bank, NA
VS.
Christopher L. Van Brederode (et al.)
Case Number
2011-8449
SHERIFF'S RETURN OF SERVICE
11/14/2011 06:02 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
November 14, 2011 at 1802 hours, he served a true copy of the within Complaint in Mortgage
Foreclosure, upon the within named defendant, to wit: Christopher L. Van Brederode, by making known
unto Patrecia E. Van Brederode, Wife of Defendant at 18 W. Locust Street, Mechanicsburg, Cumberland
County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and
correct copy of the same.
GERALD WORTHINGTO , EPUTY
11/14/2011 06:02 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
November 14, 2011 at 1802 hours, he served a true copy of the within Complaint in Mortgage
Foreclosure, upon the within named defendant, to wit: Patrecia E. Van Brederode, by making known unto
herself personally, at 18 W. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its
contents and at the same time handing to her personally the said true and correct copy of the same.
'A"a I 1'1-? - -/,--
GERALD WORTHING , DEPUTY
SHERIFF COST: $54.00
November 15, 2011
SO ANSWERS,
M
RON R ANDERSON, SHERIFF
;,C) COLIMYSWE? Snenff. Teleosoft. Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Blank, N.A.,
Plaintiff
vs.
CIVIL DIVISION
No.: 11-8449 CIVIL
ISSUE NUMBER:
?r
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Christopher L. Van Brederode ; Patrecia E. Van TYPE OF PLEADING:
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
I Hereby certi:Fy that the last known address
of Defendant(s) is/are:
18 West Locust Street
Mechanicsburg, PA 17055-6333
14d"Aq.4.2 Aa4il Z
Attorney for Plaintiff
PRAECIPE FOR DEFAULT JUDGMENT
(Mortgage Foreclosure)
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
Plaintiff
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire- Pa I.D.# 55650
Kimberly A. Bonner, Esquire- Pa I.D. #89705
Joel A. Ackerman, Esquire- Pa I.D. #202729
Ashleigh L. Marin, Esquire-Pa I.D. #306799
Ralph M. Salvia, Esquire- Pa I.D. #202946
Jaime R. Ackerman, Esquire- Pa I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
Atty File No.: XFP-158420
P---a- D ) t.2 ?
N141,<5 "&1/4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
vs.
Christopher L. 'Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
NO.: 11-8449 CIVIL
PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant(s),
Christopher L. 'Van Brederode and Patrecia E. Van Brederode a\k\a Patrecia Van Brederode in the amount
of $151,001.54 which is itemized as follows for failure to file an Answer:
Principal $143,360.51
Interest through 01/18/12 $5,847.64
Late Charges $ 416.61
Escrow $1,276.78
Inspection Fee $ 80.00
Corporate Advance $ 20.00
TOTAL $151,001.54
plus interest on the principal sum ($143,360.51) from January 19, 2012, at the rate of $20.13 per diem,
plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees
and costs and for foreclosure and sale of the mortgaged premises.
ZUCKER, GOLDBERG & ACKERMAN, LLC
(All
jai Y it BY:
Dated: Scott ie e ick, Esquire; A I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-15 8420/pn
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFP-15 8420
AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF
NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT
STATE OF NEW JERSEY
SS:
COUNTY OF UNION
Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth,
personally appeared Scott A. Dietterick, Esquire, Kimberly A. Bonner, Esquire, Joel A. Ackerman, Esquire,
Ashleigh L. Marin, Esquire, Ralph M. Salvia, Esquire, Jaime R. Ackerman, Esquire, attorney for and
authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the
Defendant is not in the military service of the United States of America to the best of his/her knowledge,
information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in
accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies.
ZUCKER, GOLDBERG & ACKERMAN, LLC
I
Dated: y:
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. 4311032
Atty File No.: XFP-158420
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
Email: Office@zuckergoldberg. com
(908)'233-8500; (908) 233-1390 FAX
Sworn to and subscribed before me
This day of January, 2012
Public
My Commission Expires:
EDWARD J. SCHWAHL II
Commission # 2383239
No?ary Public. State of New Jersey
my commission Expires
March 09, 2014
Zucker, Goldberg & Ackerman, LLC
XFP-] 58420
Request for Military Status
Department of Defense Manpower Data Center
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Jan-18-2012 06:25:25
Last Name First/Middle Begin Date Active Duty Active Duty End Service
Status Date Agency
VAN CHRISTOPHER Based on the information you have furnished, the DMDC does not
BREDERODE L possess any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
olu?
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL hgp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dn d(:.osd.mil/appj/scra/popreport.do 1/18/2012
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of-persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:DRDNISFEOM
https://www.dn idc..osd.mil/appj/scra/popreport.do 1/18/2012
Request for Military Status
Department of Defense Manpower Data Center
40 Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Jan-18-2012 06:27:48
Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
VAN PATRECIA Based on the information you have furnished, the DMDC does not
BREDERODE E possess any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued. hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://www.defenselink.mil/faq/l)is/PC09SLDR.html. If you have evidence the
person is on active; duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dry do.osd.mil/appj/scra/popreport.do 1/18/2012
Request for Mi., itary Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TA.Rs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:SL7SBC05OF
https://www.dn dc:.osd.mil/appj/scra/popreport.do 1/18/2012
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Plaintiff,
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
CIVIL DIVISION
NO.: 11-8449 CIVIL
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Christopher L. Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
( ) Plaintiff
(X) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on 16
( ) A copy of the Order or Decree is enclosed,
or
(X) The judgment is as follows: $151,001.54
plus interest on the principal sum ($143,360.51) from January 19, 2012, at the rate of $20.13 per
diem, plus additional late charges, and costs (including additional escrow advances), additional
attorneys' fees and costs and for foreclosure and sale o e m age mises.
ql? Prothonotary
Zucker, Goldberg & Ackerman, LLC
XFP-158420
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
vs.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
NO.: 11-8449 CIVIL
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
( ) Plaintiff
(X) Defendant
( ) Additional Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on
( ) A copy of the Order or Decree is enclosed,
or
(X) The judgment is as follows: $151,001.54
plus interest on the principal sum ($143,360.51) from January 19, 2012, at the rate of $20.13 per
diem, plus additional late charges, and costs (including ad ' 'onal crow advances), additi al
attorneys' fees and costs and for foreclosure and sale of the ortga pre < s.
onotary
Zucker. Goldberg; & Ackerman, LLC
XPP-158420
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
0,0"10 ol+cum6"y4110
C
OFFICE OF THE WERIFF
GI: rNc HPROTONOTARY
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
2011 NOY 18 AM 10: 55
CUMBERLAND COUNTY
PENNSYLVANIA
Wells Fargo Bank, NA I Case Number
vs.
Christopher L. Van Brederode (et al.) 2011-8449
SHERIFF'S RETURN OF SERVICE
11/14/2011 06:02 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
November 14, 2011 at 1802 hours, he served a true copy of the within Complaint in Mortgage
Foreclosure, upon the within named defendant, to wit: Christopher L. Van Brederode, by making known
unto Patrecia E. Van Brederode, Wile of Defendant at 18 W. Locust Street, Mechanicsburg, Cumberland
County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and
correct copy of the same.
GE LD WORTHINGTO EPUTY
11/14/2011 06:02 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
November 14, 2011 at 1802 hours, he served a true copy of the within Complaint in Mortgage
Foreclosure, upon the within named defendant, to wit: Patrecia E. Van Brederode, by making known unto
herself personally, at 18 W. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its
contents and at the same time handing to her personally the said true and correct copy of the same,
SHERIFF COST: $54.00
November 15, 2011,
iC) CountySuae Snenff. Teleosoft Inc.
GE LD WORTF ING , DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
vs
Christopher L. Van Brederode
Patrecia E. Van Brederode alkla Patrecia Van
Brederode
Defendant.
NO.: 11-8449 CIVIL
IMPORTANT NOTICE
TO: Patrecia E. Van Brederode a\Ma Patrecia Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
DATE OF NOTICE: 12/6/2011
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 (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUD GMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE 'TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIItiTD
OUT WHERE.'OU CAN GET LEGAL HELP.
NOTICE TO DEFEND Jfz LANK-TER REFERRAL SERNTCE
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
vs.
Christopher L. Van Brederode
Patrecia E. Van Brederode a1k1a Patrecia Van
Brederode
Defendant.
NO.: 11-8449 CIVIL
A'VTSO IN11PORT ANTE
TO: Patrecia E. Van Brederode alkla Patrecia Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
FECHA DEL AVISO:12/6/2011
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUMENTO INNIEDIATAMENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
.
LEGAL
NOTICE TO DEFEND & LAWYFRREFERRaL STRN,IC'F
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
ZUCKER, GOLDBERG &ACKERMAN
BY: Scott CZ. `rlietteii.ch,,
Scott A. Dietterick, Esquire
Attorneys for Plaintiff
PA I.D. # 55650
200 Sheffield Street, Suite 301
P.O. Box 1024
Mountainside, NJ 07092-0024
(717) 533-3560
FIRST CLASS U.S. MAIL, POSTAGE PREPAID 158420
IN TFIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
vs.
Christopher L. Van Brederode
Patrecia E. Van Brederode alkla Patrecia Van
Brederode
Defendant.
NO.: 11-8449 CIVIL
IMPORTANT NOTICE
TO: Christopher L. Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
DATE OF NOTICE: 12/6/2011
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE. PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE
THIS NOTICE 'TO YOUR LAWYER AT ONCE. IF YOU D O NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND 19z, L A«YERREFERRAL SER'VTCE
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
Vs.
Christopher L. Van Brederode
Patrecia E. Van Brederode alkla Patrecia Van
Brederode
Defendant.
NO.: 11-8449 CIVIL
ANTISO aIPORT ANTE
TO: Christopher L. Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
FECHA DEL AVISO:12/6/2011
USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR
UN FALLO EN CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE
LLEVAR ESTE DOCUNIENTO nRAEDIA.TANIENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA
ABAIO INNDICADA PARA QUE LE INFORNIEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL
NOTICE TO DEFEND & LAWYER REFERRAL STRVICE
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
ZUCKER, GOLDBERG &ACKERMAN
BY: Scott u. Loiettet.ia.,
Scott A. Dietterick, Esquire
Attorneys for Plaintiff
PA I.D. # 55650
200 Sheffield Street, Suite 301
P.O. Box 1024
Mountainside, NJ 07092-0024
(717) 533-3560
FIRST CLASS U.S. MAIL, POSTAGE PREPAID 158420
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8449 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 CHRISTOPHER L. VAN BREDERODE; PATRECIA E. VAN BREDERODE A/K/A
PATRECIA VAN BREDERODE
(l) 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: $151,001.54 L.L.: $.50
Interest FROM 1/18/2012 TO DATE OF SALE - $2,798.07
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $193.50 Other Costs:
Plaintiff Paid:
Date: 2/28/12 David D2Buel, Prothonotar
(Seal)
Deputy
REQUESTING PARTY:
Name: ASHLEIGH L. MARIN, ESQUIRE
Address: ZUCKER, GOLDBERG & ACKERMAN, LLC
200 SHEFFIELD STREET, SUITE 101
MOUNTAINSIDE, NJ 07092
Attorney for: PLAINTIFF
Telephone: 908-233-8500
Supreme Court ID No. 306799
` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
File No. 11-8449 CIVIL
Wells Fargo Bank, N.A., Amount Due $151,001.54
vs
Plaintiff, Interest from 01/18/2012 to date of sale $2,798.07
Christopher L. Van Brederode ; Patrecia E. Van
Costs
Y•ti1
Brederode a\k\a Patrecia Van Brederode; r--
.}
:?D cXJ -71
Defendants. "?' z ra
TO THE PROTHONOTARY OF THE SAID COURT: r'r'=
MC)
The undersigned hereby certifies that the below does not arise out of a retail installment sale,pntrWt o>p
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding fled--'
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and
costs upon the following described property of the defendant(s):
See Exhibit "A" attached
PRAECIPE FOR ATTACHMENT EXECUTION
Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six
copies of the description; supply four copies of lengthy personality list):
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
DATE: oil Signature: Print Name: ScottA. Dietterick, Esquire
Kimberly A. Bonner, Esquire
$ a $, ?d Q Joel Ackerman, Esquire
Ql Sy ir?t Ashleigh L. Marin, Esquire
9 ?, UO tai c% Ralph M. Salvia, Esquire
1 . 50 " a Jaime R. Ackerman, Esquire
S o k< « Address: Zucker, Goldberg & Ackerman, LLC
so ?? ? 200 Sheffield Street, Suite 101
Mountainside, NJ 07092
Attorney for: Plaintiff
Telephone: 908-233-8500
Supreme Court ID No.: 55650:89705:202729
) :5 6W 306799:202946:311032
SU e_L.
/ticket. C,lclhers? 1. ,??kenna.n- 1A Ca? ?t? ?? 1 JJ(11 d( ?? sl"L
-41
Exhibit "A"
LEGAL DESCRIPTION
AL'_ THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WI's:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NIIS'ETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H1W.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
Zucker, Gnidher?,, 8 Ackerman, 11C
\FP-!'58420
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.,
Plaintiff,
Vs.
CIVIL DIVISION
NO.: 11-8449 CIVIL
M
M
Tq r-r
CU
., .
p
_l > CO
-17
C
UY -
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
Execution No.:
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the
Praecipe for Writ of Execution was filed the following information concerning the real property
located at 18 West Locust Street, Mechanicsburg, PA 17055-6333.
1. Name and Address of Owner(s) or Reputed Owner(s):
CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN BREDERODE, H\W
18 West Locust Street
Mechanicsburg, PA 17055-6333
2. Name and Address of Defendant(s) in the Judgment:
CHRISTOPHER L. VAN BREDERODE
18 West Locust Street
Mechanicsburg, PA 17055-6333
PATRECIA E. VAN BREDERODE A\K\A PATRECIA VAN BREDERODE
18 West Locust Street
Mechanicsburg, PA 17055-6333
3. Name and Address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
WELLS FARGO BANK, N.A.
Plaintiff
/uckcr Guldhert. ti 1??kcranan I i
4. Name and Address of the last record holder of every mortgage of record:
WELLS FARGO BANK, N.A.
Plaintiff
MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION
PO Box 2026
Flint, MI 48501-2026
AND
1 M&T Plaza
Buffalo, NY 14203
5. Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE:
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
UNKNOWN TENANT OR TENANTS
18 West Locust Street
Mechanicsburg, PA 17055-6333
UNKNOWN SPOUSE
18 West Locust Street
Mechanicsburg, PA 17055-6333
luckc.r. G lithe rr). & Ackerman. 1.1 _C
X1 P- I ?N-0)
PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
ZUCKER GOLDBERG & ACKERMAN, LLC
Dated: BY:
? '6
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
/ucl,cr_ Goldb,:m & Ackcrman, I I (
X1 11-1 ;'<430
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H\W.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
Zucker, Gnidhag K Ackerman, !a_C'
XI-11-1 59420
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
VS.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\lcla Patrecia Van Brederode;
Defendant(s).
CIVIL DIVISION
NO.: I1-8449 CIVIL,
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Christopher L. Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
AND
243 Main Street
Camp Hill, PA 17011
AND
3644 Chestnut Street
Camp Hill, PA 17011
TAKE NOTICE:
c.
<>
-4Z7t
s C)
?c
' c
°s:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/6/2012 at 10:00am prevailing
local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")
The LOCATION of your property to be sold is:
18 West Locust Street, Mechanicsburg, PA, 17055-6333
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-8449 CIVIL
Zucker, Goldberg & Ackerman, LLC
XFP-158420
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Christopher L. Van Brederode ; Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person or
company that has entered judgment against you. You may also file a petition with the same
Court if you are aware of a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other
proper cause. This petition must be filed before the Sheriffs Deed is delivered.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition must be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013-3387, before presentation of the petition to the Court.
ZUCKER GOLDBERG & ACKERMAN, LLC
_
Dated: BY: 06 M UAk(
Scott A. Dietterick, Esquire; PA I.D. 455650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. 9202729
Ashleigh L. Marin, Esquire; PA I.D. 9306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail : Office@zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, HAW.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
Zucker, Goidhcr2 & Ackerman, LL.C
XFP-I 58420
'y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
vs
Plaintiff,
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
CIVII. DIVISION
C)
: NO.: 11-8449 CIVIL .
F..
T
a- n rr1 , .. -
Co -( ( Y".;
C"" tJ r
C3
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
AND
243 Main Street
Camp Hill, PA 17011
AND
3644 Chestnut Street
Camp Hill, PA 17011
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/6/2012 at I0:00am prevailing
local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
18 West Locust Street, Mechanicsburg, PA, 17055-6333
Zucker, Goldberg & Ackerman, LLC
XFP-158420
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-8449 CIVIL
THE NAME(S) OF THE OWNER(S) OR REPU'T'ED OWNER(S) OF THIS
PROPERTY ARE:
Christopher L. Van Brederode ; Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person or
company that has entered judgment against you. You may also file a petition with the same
Court if you are aware of a legal defect in the obligation or the procedure used against you.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other
proper cause. This petition must be filed before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition must be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013-3387, before presentation of the petition to the Court.
ZUCKER GOLDBERG & ACKERMAN, LLC
Dated: BY: ('x ti? C(pv_?_111
Scott A. Die eric , Esquire; PA I.D. 455650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H\W.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
Zucker, C;nidher2 & Ackerman, LLC
XFP-158420
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.,
CIVIL DIVISION
Plaintiff,
VS.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
NO.: 11-8449 CIVIL
Execution No.:
M
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5;! rtti
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of
Execution was filed the following information concerning the real property located at 18 West Locust Street,
Mechanicsburg, PA 17055-6333.
1. Name and Address of Owner(s) or Reputed Owner(s):
CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN BREDERODE, H\W
18 West Locust Street
Mechanicsburg, PA 17055-6333
2. Name and Address of Defendant(s) in the Judgment:
CHRISTOPHER L. VAN BREDERODE
18 West Locust Street
Mechanicsburg, PA 17055-6333
PATRECIA E. VAN BREDERODE A\K\A PATRECIA VAN BREDERODE
18 West Locust Street
Mechanicsburg, PA 17055-6333
3. Name and Address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
WELLS FARGO BANK, N.A.
Plaintiff
4. Name and Address of the last record holder of every mortgage of record:
WELLS FARGO BANK, N.A.
Plaintiff
MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION
PO Box 2026
Flint, MI 48501-2026
AND
I M&T Plaza
Buffalo, NY 14203
MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION, ITS SUCCESSORS AND
ASSIGNS
PO Box 2026
Flint, MI 48501-2026
AND
1 M&T Plaza
Buffalo, NY 14203
Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
BOROUGH OF MECHANICSBURG
c/o DAVID J SPOTTS, ESQUIRE
36 West Allen Street
Mechanicsburg, PA 17055
6. Name and Address of every other person who has any record interest in the property and whose
interest may be affected by the sale:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
UNKNOWN TENANT OR TENANTS
18 West Locust Street
Mechanicsburg, PA 17055-6333
UNKNOWN SPOUSE
18 West Locust Street
Mechanicsburg, PA 17055-6333
PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
I verify that the statements made in this Amended Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Dated:
ZUCKER GOLDBEIW & ACKERMAN, LLC
BY:
Scott A. letterick, squire; PA I.D. #55650
Kimbe A. Bonner, Esquire; PAID. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF WEST
LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG, CUMBERLAND
COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON SAID
LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO LOT NOW
OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD NINETY-
THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD THIRTY-FIVE (35)
FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID; THENCE BY LINE OF SAID
SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING HOUSE
NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND COUNTY,
PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND CONVEYED UNTO
CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN BRFDERODE, H\W.
CUMBERLAND COUNTY TAX PARCEL # 16-23-0565-040.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVIIL'A r 3
Wells Fargo Bank, N.A., CIVIL DIVISION -? V-q
~
Plaintiff, P {
NO.: 11-8449 CIVIL } f_`, >
vs.
TYPE OF PLEADING
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode; Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE
OF DEFENDANT/OWNER AND
Defendants. OTHER PARTIES OF INTEREST
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire PA I.D. #55650
Kimberly A. Bonner, Esquire- PA I.D. #89705
Joel A. Ackerman, Esquire- PA I.D. #202729
Ashleigh L. Marin, Esquire- PA I.D. #306799
Ralph M. Salvia, Esquire- PA I.D. #202946
Jaime R. Ackerman, Esquire- PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldberia.com
File No.: XFP-158420/dsc
Zucker, Goldberg & Ackerman, LLC
XFP-158420
¦ 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
V5.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendants.
CIVIL DIVISION
NO.: 11-8449 CIVIL
Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF
DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST
I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys
for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following
Affidavit regarding the service of Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on
Defendant/Owner and Other Parties of Interest as follows:
1. Defendants, Christopher L. Van Brederode and Patrecia E. Van Brederode, h\w, are the
record owners of the real property.
2. On or about March 10, 2012, Defendants Christopher L. Van Brederode and Patrecia E.
Van Brederode were served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa.
R.C.P. 3129, via Certified Mail, return receipt requested, at the address of 18 West Locust Street,
Mechanicsburg, PA 17055. True and correct copies of said Notices and Proofs of Service are marked
Exhibit "A", attached hereto and made a part hereof.
3. On or about April 3, 2012, Plaintiffs counsel served all other parties in interest with
Plaintiffs Notice of Sheriff's Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class
U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and
Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of
Interest were served with Plaintiffs Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P.
3129.2.
ZUCKER, GOLDBERG & ACKERMAN, LLC
Attorneys for Plaintiff--?
Dated: April 17, 2012
LESINGER
Paralegal/Legal Assistant
Sworn to and subscribed before
me th' day of April, 2012
n
No ary Public
PAUL C. WAORATOWSKI
My COMMISSION EXPIRES: Notary ip*i240 850 Jersey
My Commission Expires 4/2712016
Zucker, Goldberg & Ackerman, LLC
XFP-158420
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP-158420
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
VS.
Plaintiff,
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\lcla Patrecia Van Brederode;
Defendant(s).
CIVIL DIVISION
NO.: 11-8449 CIVIL
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Christopher L. Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
AND
243 Main Street
Camp Hill, PA 17011
AND
3644 Chestnut Street
Camp Hill, PA 17011
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/6/2012 at 10:00am prevailing
local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
18 West Locust Street, Mechanicsburg, PA, 17055-6333
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-8449 CIVIL
01-1
Zucker, Goldberg & Ackerman, LLC
XFP-158420
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Christopher L. Van Brederode ; Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person or
company that has entered judgment against you. You may also file a petition with the same
Court if you are aware of a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other
proper cause. This petition must be filed before the Sheriffs Deed is delivered.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition must be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013-3387, before presentation of the petition to the Court.
ZUCKER GOLDBERG & ACKERMAN, LLC
Dated: 11all ? BY: QAmaAk-
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PAID. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail : Office@zuckergoldberg.com
VIA CERTIFIED MAII., RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Wift Zucker, Goldberg & Ackerman, LLC
XFP-158420
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H1W.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y,
PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Pldntif
VS. NO.: 11-8449 CIVIL,
Christopher L. Van Brederode ; Patrecia E. Van
Brederode aWa Patrecia Van Brederode;
Defendant(s).
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Patrecia E. Van Brederode aWa Patrecia Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
AND
243 Main Street
Camp Hill, PA 17011
AND
3644 Chestnut Street
Camp Hill, PA 17011
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/612012 at 10:00am prevailing
local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the Mud.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is
18 West Locust Street, Mechanicsburg, PA, 17055-6333
Zucker, Goldberg & Ackerman, LLC
XFP-158420
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-8449 CIVIL
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Christopher L. Van Brederode ; Pahwis E. Van Brederode Mk1a Patrecia Van Brederode
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the 'sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE AND PLACE OF THE SALE YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE GO To OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LMAL RIGHTS YOU MAY HAVE ARE-
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person or
company that has entered judgment against you. You may also file a petition with the same
Court if you are aware of a legal defect in the obligation or the procedure used against you.
99 Zucker, Goldberg & Ackerman, LLC
XFP-158420
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other
pamper cause. This petition must be filed before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition mast be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013=3387, before presentation of the petition to the Court
ZUCKER GOLDBERG & ACKERMAN, LLC
Dated: l ?j?'?lov BY•
Scott A. Di 'c Esquire; PA T.D. #55650
Kimberly A. Bonner, Esquire; PAID, #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092 f
File No.: XFP-158420 j
(908) 233-8500; (908) 233-1390 FAX
E-mail: Offiice@zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
i•
Zucker, Goldberg & Ackerman, LLC
XFP-158420
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF '
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING. %
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H\W.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
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EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP-158420
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
V5.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a1k1a Patrecia Van Brederode;
Defendant(s).
NO.: 11-8449 CIVIL
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(6)
TO:
UNKNOWN TENANT OR TENANTS
18 West Locust Street
Mechanicsburg, PA 17055-6333
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
CUMBERLAND COUNTY TAX CLAIM
BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
MFRS AS NOMINEE FOR M&T MORTGAGE
CORPORATION
PO Box 2026
Flint, MI 48501-2026
MERS AS NOMINEE FOR M&T MORTGAGE
CORPORATION 1 M&T Plaza
Buffalo, NY 14203
BOROUGH OF MECHANICSBURG
c/o DAVID J SPOTTS, ESQUIRE
36 West Allen Street
Mechanicsburg, PA 17055
UNKNOWN SPOUSE
18 West Locust Street
Mechanicsburg, PA 17055-6333
PA DEPT. OF REVENUE- INHERITANCE
TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
CUMBERLAND COUNTY DOMESTIC
RELATIONS OFFICE
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
MERS AS NOMINEE FOR M&T
MORTGAGE CORPORATION, ITS
SUCCESSORS AND ASSIGNS
PO Box 2026
Flint, MI 48501-2026
MERS AS NOMINEE FOR M&T
MORTGAGE CORPORATION, ITS
SUCCESSORS AND ASSIGNS
1 M&T Plaza
Buffalo, NY 14203
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in:
the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013
On 6/6/2012 at 10:00am, the following described real estate which Christopher L. Van Brederode and
Patrecia E. Van Brederode, h1w are the owners or reputed owners and on which you may hold a lien or
have an interest which could be affected by the sale of.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
15842OD1004CO3212012P1
18 West Locust Street,
Mechanicsburg, PA 17055-6333
Cumberland County
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
Zucker, Goldberg & Ackerman, LLC
XFP-158420
158420D 1004C03212012P2
The said Writ of Execution has been issued on a judgment in the action of
Wells Fargo Bank, N.A.
Plaintiff
VS.
Christopher L. Van Brederode , at al
Defendant(s)
at EX. NO. 11-8449 CIVIL in the amount of $151001.54 plus interest and costs.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
If you have any questions or comments with regard to the Sheriffs Sale or this Notice, you should
contact your attorney as soon as possible. 1
a
ZUCKER, GOLD G & ACKERMA4 LLC
3
3
3
Dated: BY:
?a Scott . Dietterick, Esquire; PA I.D. 455650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729 !
Ashleigh L. Marin, Esquire; Pa I.D. #306799 j
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R Ackerman, Esquire; PA T.D. #311032
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFP-158420
158420D1004C03212012P3
Exhibit "A'
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER
ON SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET
TO LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT
NORTHWARD NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY
WESTWARD THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER
AFORESAID; THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE
PLACE OF BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN,
BY DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H\W.
CUMBERLAND COUNTY TAX PARCEL # 16-23-0565-040.
Zucker, Goldberg & Ackerman, LLC
«Fiel&*-«Fieldl»
«Field 1 »D1004C02/12/2008P4
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Page 1 of 6 NOTICE TO LIENHOLDERS
M21 POST SM&M
Thb CwWkxU of MNbt pr°rld°s arldarca that rml has Iran prooarwd to USPS• for m o*W V6 fon
and intomatbrrl nri.
Scott A. Dietterick, Esquire j09A-
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c/o Zucker, Goldberg & Ackerman, LLC o
200 Sheffield Street, Suite 101 ,
Mountainside, N1 07092 N Q?
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18 West Locust Street
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County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITEQ.:STATES
POSTU SERV1CE6
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DEPARTMENT OF WELFARE
P.O. Box 2675 .
Harrisburg, PA 17105
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
Page 2 of B NOTICE TO LIENHOLDERS
U1NITEL? STATES Certil
POS"'TAL SERVIM
This CertMkau of Mdbra provkles evldma that mal has been praserdad to USPSa for me ft This form may be used fdr d ...."
and Wtematbnd mad. /a•
From: Scott A. Dietterick, Esquire `c/o Zucker, Goldberg & Ackerman, LLC t' A,
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
02 IM $ 101.150
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To: CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
County of P.Q.: CUMBERLAND
PS Farm 3817, April 2007 PSN 7530-02.000-9065
UNITED STATES certi
POSTAL SERVIM
ThisGrtMatedMalftProvides wA& OwtmaN has been pr• erftdtoUSPSeformdlR.Thbformmaybeusedfordomesde rr:
and Mmmatbnal med.
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TOL MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION Postmark Here
PO Box 2026
Flint, MI 48501-2026
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County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-024000-9065
Page 3 of s NOTICE TO LIENHOLDERS
PS-mviC4
This CortMwb of mo*ns pnwMu wldanm that mall has bean prawntad to L1 0 W m1k,1` Ma form mw be uwd for donrMis
and Intematlonal rma.
Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
las
Mountainside, NJ 07092
XFP-158420/sde TEAM C
To* MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION PMmark Here
1 M&T Plaza
Buffalo, NY 14203
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-024000-9065
R 1 .
POSM SERVICE
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and Werimli mal mall
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UNITEDSEATES
Mountainside, NJ 07092
XFP-158420/sde TEAM C
T°` BOROUGH OF MECHANICSBURG Postmark Here
C/o DAVID J SPOTTS, ESQUIRE
36 West Allen Street
Mechanicsburg, PA 17055
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Page 4 of 6 NOTICE TO LiENHOLDERS
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UNITED STATES Certi• f • 02 01.150 ,
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Fram: Scott A. Dietterick, Esquire `•
c/o Zucker, Goldberg & Ackerman, LLC .
200 Sheffield Street, Suite 101 J?Q
Mountainside, NJ 07092
XFP-158420/sde TEAM C
T' MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION, Postmark Here
ITS SUCCESSORS AND ASSIGNS
1 M&T Plaza
Buffalo, NY 14203
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County of P.Q.: CUMBERLAND 4
PS Form 3817, April 2007 PSN 7530-02-0009065
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UNI1 EUST E ` 000 282038
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This Certllkaq of Waltrg proaidr evicimm that mail has been praerrted to USK* far malift This form may b
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c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-158420/sde TEAM C
T MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION, Postmark Here
ITS SUCCESSORS AND ASSIGNS
PO Box 2026
Flint, MI 48501-2026
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
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200 Sheffield Street, Suite 101 z Q Q?
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XFP-158420/sde TEAM C
T°° CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here
Domestic Relations Section
13 N. Hanover Street
PO Box 320 `
Carlisle, PA 17013
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PS Form 3817, April 2007 PSN 7530-02-000-9065
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c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-158420/sde TEAM C
T PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Here
Dept. 280601
Harrisburg, PA 17128-0601
County of P.O,: CUMBERLAND
PS Form 3817, Apr112007 PSN 7530-02-000-9065
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200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-158420/sde TEAM C
T°' UNKNOWN SPOUSE
18 West Locust Street
Mechanicsburg, PA 17055-6333
Postmark Here
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530.02-000-9065
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ' j
Sheriff?it?
Jody S Smith
Chief Deputy
s
Richard W Stewart
i rC, 7? Y1{YlJ . ., ,
Solicitor _ y j j
Wells Fargo Bank, NA I Case Number
vs. 2011-8449
Christopher L. Van Brederode (et al.)
SHERIFF'S RETURN OF SERVICE
03/21/2012 02:21 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Patrecia
E. Van Brederode at 18 W. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055,
Cumberland County.
03/21/2012 02:21 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Patrecia
E. Van Brederode at 18 W. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055,
Cumberland County.
03/21/2012 02:21 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 18 W. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055,
Cumberland County.
03/21/2012 02:21 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be PATRECIA E VAN
BREDERODE - WIFE, who accepted as "Adult Person in Charge for Christopher L. Van Brederode at 18
W. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County.
03/21/2012 02:21 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be PATRECIA E VAN
BREDERODE - WIFE, who accepted as "Adult Person in Charge" for Christopher L. Van Brederode at 18
W. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County.
06/05/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $726.72 SO ANSWERS,
June 05, 2012 RON R ANDERSON, SHERIFF
.? .?5 ,,/. 60
. SZ> Lam- ??
c; GeiSu tq *t f s. as aY Inc. 7 63
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A., : CIVIL DIVISION
Plaintiff, NO.: 11-8449 CIVIL
VS.
Execution No.:
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
AFFIDAVIT PURSUANT TO RULE 3129.1
Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the
Praecipe for Writ of Execution was filed the following information concerning the real property
located at 18 West Locust Street, Mechanicsburg, PA 17055-6333.
1. Name and Address of Owner(s) or Reputed Owner(s):
CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN BREDERODE, H\W
18 West Locust Street
Mechanicsburg, PA 17055-6333
2. Name and Address of Defendant(s) in the Judgment:
CHRISTOPHER L. VAN BREDERODE
18 West Locust Street
Mechanicsburg, PA 17055-6333
PATRECIA E. VAN BREDERODE A\K\A PATRECIA VAN BREDERODE
18 West Locust Street
Mechanicsburg, PA 17055-6333
3. Name and Address of every judgment creditor whose judgment is a record lien on
the real property to be sold:
WELLS FARGO BANK, N.A.
Plaintiff
Zucker. G-)J xre & ,Ackerman. LI C
X F P-15 5420
4. Name and Address of the last record holder of every mortgage of record:
WELLS FARGO BANK, N.A.
Plaintiff
MERS AS NOMINEE FOR M&T MORTGAGE CORPORATION
PO Box 2026
Flint, MI 48501-2026
AND
1 M&T Plaza
Buffalo, NY 14203
5. Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the
property and whose interest may be affected by the sale:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has knowledge
who has any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
UNKNOWN TENANT OR TENANTS
18 West Locust Street
Mechanicsburg, PA 17055-6333
UNKNOWN SPOUSE
18 West Locust Street
Mechanicsburg, PA 17055-6333
Zucker. Goldbere & Ackerman. LLC
XFP-155420
IN .THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
VS.
Plaintiff,
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
CIVIL DIVISION
NO.: 11-8449 CIVIL
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Christopher L. Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
AND
243 Main Street
Camp Hill, PA 17011
AND
3644 Chestnut Street
Camp Hill, PA 17011
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/6/2012 at 10:00am prevailing
local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
18 West Locust Street, Mechanicsburg, PA, 17055-6333
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-8449 CIVIL
Zucker, Goldberg & Ackerman, LLC
XFP-158420
THE. NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Christopher L. Van Brederode ; Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person or
company that has entered judgment against you. You may also file a petition with the same
Court if you are aware of a legal defect in the obligation or the procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other
proper cause. This petition must be filed before the Sheriffs Deed is delivered.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
3., - A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition must be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013-3387, before presentation of the petition to the Court.
ZUCKER GOLDBERG & ACKERMAN, LLC
Dated: BY:
Scott A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H\W.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
"bucker, Goidhera K Ackerman, LLC
XFP-158420
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
NO.: 11-8449 CIVIL
VS.
Christopher L. Van Brederode ; Patrecia E. Van
Brederode a\k\a Patrecia Van Brederode;
Defendant(s).
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
18 West Locust Street
Mechanicsburg, PA 17055-6333
AND
243 Main Street
Camp Hill, PA 17011
AND
3644 Chestnut Street
Camp Hill, PA 17011
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/6/2012 at 10:00am prevailing
local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting
of a statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
18 West Locust Street, Mechanicsburg, PA, 17055-6333
Zucker, Goldberg & Ackerman, LLC
XFP-158420
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 11-8449 CIVIL
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Christopher L. Van Brederode ; Patrecia E. Van Brederode a\k\a Patrecia Van Brederode
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or
corporate entities or agencies being entitled to receive part of the proceeds of the sale received
and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities
that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of
the proceeds of sale in accordance with this schedule will, in fact, be made unless someone
objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about
the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of
Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR
PROPERTY.
It has been issued because there is a Judgment against you. It may cause your property to
be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your
property from being taken. A lawyer can advise you more specifically of these rights. If you
wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of Cumberland
County to open the Judgment if you have a meritorious defense against the person or
company that has entered judgment against you. You may also file a petition with the same
Court if you are aware of a legal defect in the obligation or the procedure used against you.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
2. After the Sheriffs Sale, you may file a petition with the Court of Common
Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other
proper cause. This petition must be filed before the Sheriffs Deed is delivered.
3. A petition or petitions raising the legal issues or rights mentioned in the
preceding paragraphs must be presented to the Court of Common Pleas of Cumberland
County. The petition must be served on the attorney for the creditor or on the creditor
before presentation to the Court and a proposed order or rule must be attached to the
petition. If a specific return date is desired, such date must be obtained from the Court
Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013-3387, before presentation of the petition to the Court.
ZUCKER GOLDBERG & ACKERMAN, LLC
Dated: 1 l 10)-0 BY: `
Scott A. Die eric , Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-158420
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Zucker, Goldberg & Ackerman, LLC
XFP-158420
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN HOUSE AND LOT OF GROUND SITUATED ON THE NORTH SIDE OF
WEST LOCUST STREET (FIRST WARD), IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO
WIT:
BEGINNING AT THE CORNER OF LOT NOW OR FORMERLY OF THOMAS SNYDER ON
SAID LOCUST STREET; THENCE BY SAID STREET EASTWARD THIRTY-FIVE (35) FEET TO
LOT NOW OR FORMERLY OF TIMOTHY FINK; THENCE BY LINE OF SAID LOT NORTHWARD
NINETY-THREE (93) FEET TO STOUFFER ALLEY; THENCE BY SAID ALLEY WESTWARD
THIRTY-FIVE (35) FEET TO LOT NOW OR FORMERLY OF THOMAS SNYDER AFORESAID;
THENCE BY LINE OF SAID SOUTHWARD NINETY-THREE (93) FEET TO THE PLACE OF
BEGINNING.
HAVING THEREON ERECTED A TWO AND ONE-HALF STORY FRAME DWELLING
HOUSE NUMBERED 18 WEST LOCUST STREET, MECHANICSBURG, PENNSYLVANIA 17055.
BEING THE SAME PREMISES WHICH DEBORAH G. KELLER, A MARRIED WOMAN, BY
DEED DATED JUNE 14, 2006 AND RECORDED JULY 10, 2006 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 275, PAGE 2755, GRANTED AND
CONVEYED UNTO CHRISTOPHER L. VAN BREDERODE AND PATRECIA E. VAN
BREDERODE, H\W.
CUMBERLAND COUNTY TAX PARCEL #16-23-0565-040.
Tucker, Goldberg & Ackerman, LLC:
XFP-158420
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-8449 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 CHRISTOPHER L. VAN BREDERODE; PATRECIA E. VAN BREDERODE A/K/A
PATRECIA VAN BREDERODE
(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: $151,001.54 L.L.: $.50
Interest FROM 1/18/2012 TO DATE OF SALE - $2,798.07
Atty's Comm: % Due Prothy: $2.25
Arty Paid: $193.50 Other Costs:
Plaintiff Paid:
Date: 2/28/12 .
David D. B111, Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name: ASHLEIGH L. MARIN, ESQUIRE
Address: ZUCKER, GOLDBERG & ACKERMAN, LLC
200 SHEFFIELD STREET, SUITE 101
MOUNTAINSIDE, NJ 07092
Attorney for: PLAINTIFF TRUE COPY FROM RECORD
Telephone: 908-233-8500 In Testimony wtie eof, i here unto set my hand
, 20
and the seal of said Court cadisle, Pa.
Supreme Court ID No. 306799 This of ?.,
ProthonoterY
a. ?? op?--
On March 15, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Mechanicsburg Borough, Cumberland County, PA, known
and numbered 18 west Locust Street, Mechanicsburg, PA
17055-6333 more fully described on Exhibit "A" filed with
this writ and by this reference incorporated herein.
Date: March 15, 2012
By: P', -U I 4A4 9t:U -A,_
For Claudia Brewbaker, Real Estate Coordinator
b.;
7 7
Writ No. 2011-8449 Civil Term
Wells Fargo Bank, N.A.,
vs.
Christopher L. Van Brederode;
Patrecia E. Van Brederode a/k/a
Patrecia Van Brederode
Atty.: Ashleigh L. Marin
ALL THAT CERTAIN house and lot
of ground situated on the north side
of West Locust Street (First Ward),
in the Borough of Mechanicsburg,
Cumberland County, Pennsylvania,
bounded and described as follows,
to wit:
BEGINNING at the comer of lot
now or formerly of Thomas Snyder
on said Locust Street; thence by said
street eastward thirty-five (35) feet to
lot now or formerly of Timothy Fink;
thence by line of said lot northward
ninety-three (93) feet to Stouffer Al-
ley; thence by said alley westward
thirty-five (35) feet to lot now or for-
merly of Thomas Snyder aforesaid;
thence by line of said southward
ninety-three (93) feet to the place of
BEGINNING.
HAVING THEREON ERECTED a
two and one-half story frame dwell-
ing house numbered 18 West Locust
Street, Mechanicsburg, Pennsylvania
17055.
BEING the same premises which
Deborah G. Keller, a married woman,
by deed dated June 14, 2006 and
recorded July 10, 2006 in and for
Cumberland County, Pennsylvania,
in Deed Book Volume 275, Page
2755, granted and conveyed unto
Christopher L. Van Brederode and
Patrecia E. Van Brederode, h\w.
CUMBERLAND COUNTY TAX
PARCEL #16-23-0565-040.
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:
April 27, May 4, and May 11, 2012
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the 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.
Lis ie Coyne, Editor
SWORN TO AND SUBSCRIBED before me this
11 day of May, 2012
lR
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My 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
Patr1*0t1WX(W5
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.
P BLICATION COPY
This ad ran on the date(s) shown below:
04/27/12
05104112
05111112
A. D.
COMMONW H N VANL4
Sherrie L. Owens, pe
Lower Paxton TwP ' Phl n Public
My CD MM1$WWon ks Nov. 26, MEMBER, PENNSYLVANIA ASSOCIATION Nov. OF NOTARIES
2011-8449 Civil Term
Wells Fargo Bank, N.A.,
VS
Christopher L. Van Brederode;
patrecia E. Van
Brederode a/k/a Patrecla Van
Brederode
Atti Ashlelgh L. Marln
All That Certain House And Lot Of
Ground Situated On The North Side Of
West Locust Street (First Ward), In The
Borough Of Mechanicsburg,
Cumberland County, Pennsylvania,
Bounded And Described As Follows, To
Wit:
Beginning At The Corner Of Lot Now Or
Formerly Of Thomas Snyder On
Said Locust Street; Thence By Said Street
Eastward Thirty-Five (35) Feet To
Lot Now Or Formerly Of Timothy Fink;
Thence By Line Of Said Lot Northward
F ety-Three (93) Feet To Stouffer Ali
T', ience By Said Alley Westward
Chirty-Five (35) Feet To Lot Now Or
Formerly Of Thomas Snyder Aforesai6;
Thence By Line Of Said Southward Ninety-
Three (93) Feet To The Place Of
Beginning. Having Thereon Erected A
T,,o And One-Half Story Frame Dwelling
House Numbered 18 West Locust Street,
Mechanicsburg, Pennsylvania 17055.
Being The Same Premises Which Deborah
G. Keller, A Married Woman, By
Deed Dated June 14, 2006 And Recorded
July 10, 2006 In And For Cumberland
County, Pennsylvania, In Deed Book
Volume 275, Page 2755, Granted And
Conveyed Unto Christopher L. Van
Brederode And Patrecia E. Van
Brederode, KW.
Cumberland County Tax Parcel #16-23.
0565-040.