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HomeMy WebLinkAbout11-8931SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Lollttitr ofutbrrfpy? OFFICE ';v '-E S.! E 2IFP fY, I ]+ tl? °10 t1? 1 v.. Y.. V Y ? i 4} gGn rn Y S4f L` ifiN1A Wells Fargo Bank, N.A. vs. Chris A. Smith (et al.) SHERIFF'S RETURN OF SERVICE Case Number 2011-8931 12/05/2011 03:59 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on December 5, 2011 at 1559 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Susan C. Smith, by making known unto Chris Smith, Husband of Defendant at 1262 W. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and orrect copy of the same. SWA" S , DEPUTY 12/05/2011 03:59 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on December 5, 2011 at 1559 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Chris A. Smith, by making known unto himself personally, at 1262 W. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of th me. 1 -1 A UT ALL, DEPUTY 12/07/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Susan C. Smith, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Susan C. Smith. Request for service at 361 Sherwood Drive, Carlisle, Pennsylvania 17013 the Defendant was not found. Susan C. Smith currently resides at 1262 W. Trindle Road, Mechanicsburg, Pennsylvania 17055. 12/07/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Chris A. Smith, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Chris A. Smith. Request for service at 361 Sherwood Drive, Carlisle, Pennsylvania 17013 the Defendant was not found. Chris A. Smith currently resides at 1262 W. Trindle Road, Mechanicsburg, Pennsylvania 17055. SHERIFF COST: $100.00 December 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) GountySuite Sheriff, Teleosoft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION -. N ?)3: Plaintiff No.: 11-8931 CIVIL TERM r -t co ri -n ? r-n ,pr- vs. r-- v? ? T1 a C ISSUE NUMBER: Chris A. Smith; Susan C. Smith; TYPE OF PLEADING: CD Defendant(s). t`? Y PRAECIPE FOR DEFAULT JUDGMENT I Hereby certify that the last known address (Mortgage Foreclosure) of Defendant(s) is/are: 1262 West Trindle Road Mechanicsburg,, PA 17055-4517 44"44 2.. Mme, Attorney for Plaintiff 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-159407 Q, `X?ko. SO ?d at Ck?k ?Sos21 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. CIVIL DIVISION NO.: 11-8931 CIVIL TERM Chris A. Smith; Susan C. Smith; Defendant(s). PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant(s), Chris A. Smith and Susan C. Smith, in the amount of $168,474.93 which is itemized as follows for failure to file an Answer: Principal $159,589.08 Interest through 02/01/12 $7,639.26 Late Charges $ 360.50 Escrow $ 806.09 Inspection Fees $ 80.00 Total $168,474.93 plus interest on the principal sum ($159,589.08) from February 2, 2012, at the rate of $27.87 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 Dated: By: \. Scott . Di tterick, 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 Atty File No.: XFP-159407 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX Zucker. Goldberg & Ackerman, LLC X FP-159407 AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY COUNTY OF UNION SS: 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 Ackerman, Esquire, Ashleigh L. Levy 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: By: Scott A. Die er ck, 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 Atty File No.: XFP-159407 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX to and subscribed before me Z day of February, 2012 ry Polic My Commi3sion Expires: EDWARD J. SCHWAHL 11 Commission # 2383239 Notary Public, State of New Jersey My Commission Expires March 09, 2014 Zucker. Goldberg & Ackerman, L,L,C X FP-159407 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page I of 2 Feb-01-2012 04:56:01 Last N First/Middle Begin Date Active Duty Status Active Duty End Date Service ame Agency SMITH SUSAN C Based on the information you have furnished, the DMDC does not 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). 460V 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 httn:t/w?vw.defenselink.mil/fau/pis/PC09SI_Dl(.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. 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 https://www.dmdc osdl.mil/appj/scra/popreport.do 2/1/2012 Request for Military Status Page 2 of 2 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:45VSAILTOF https://www.dmdc os(i.mil/appj/scra/popreport.do 2/1/2012 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-01-2012 04:54:32 '< Last First/Middle N Begin Date Active Duty Status Active Duty End Date Service ame Agency SMITH CHRIS A Based on the information you have furnished, the DMDC does not 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, NOAH, Public Health, and Coast Guard). Ail 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 huo:iw???a.dcfenselink.milltuq;pis'PC09S[.1')1't hUnl. Ifyou 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. 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 Nary 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 https://www.dmdc.os(i.mil/appj/scra/popreport.do 2/1/2012 Request for Military Status Page 2 of 2 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:M8MMUFQMGH https://www.dmdc.os(i.mil/appj/scra/popreport.do 2/1/2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 11-8931 CIVIL TERM Chris A. Smith; Susan C. Smith; Defendant(s). NOTICE OF ORDER, DECREE OR JUDGMENT TO: Chris A. Smith 1262 West Trindle Road, Mechanicsburg, PA 17055-4517 ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified at 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: $168,474.93 plus interest on the principal sum ($159,589.08) from February 2, 2012, at the rate of $27.87 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. PROTHONOTARY Zucker. Goldberg & Ackerman, LAX X FP-159407 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, VS. Chris A. Smith; Susan C. Smith; Defendant(s). CIVIL DIVISION NO.: 11-8931 CIVIL TERM NOTICE OF ORDER, DECREE OR JUDGMENT TO: Susan C. Smith 1262 West Trindle Road, Mechanicsburg, PA 17055-4517 ( ) 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: $168,474.93 plus interest on the principal sum ($159,589.08) from February 2, 2012, at the rate of $27.87 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. wow PROTHONOTARY Zucker, Goldberg & Ackerman, L IX X FP-159407 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor icitibrb CQy?aq of OFFCEOFTHE %M WC isq ?r? Wells Fargo Bank, N.A. Case Number VS. Chris A. Smith (et al.) 2011-8931 SHERIFF'S RETURN OF SERVICE 12/05!2011 03:59 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on December 5, 2011 at 1559 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Susan C. Smith, by making known unto Chris Smith, Husband of Defendant at 1262 W. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and orrect copy of the same. Akj-117'0?p- SUAQVN S , DEPUTY 12105/2011 03:59 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on December 5, 2011 at 1559 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Chris A. Smith, by making known unto himself personally, at 1262 W. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and, at the same time handing to him personally the said true and correct copy ofth me., A-IQ UT LL, DEPUTY 12/07/2011 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Susan C. Smith, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Susan C. Smith. Request for service at 361 Sherwood Drive, Carlisle, Pennsylvania 17013 the Defendant was not found. Susan C. Smith currently resides at 1262 W. Trindle Road, Mechanicsburg, Pennsylvania 17055. 12/0712011 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search . and inquiry for the within named defendant to wit: Chris A. Smith, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Chris A. Smith. Request for service at 361 Sherwood Drive, Carlisle, Pennsylvania 17013 the Defendant was not found. Chris A. Smith currently resides at 1262 W. Trindle Road, Mechanicsburg, Pennsylvania 17055. SHERIFF COST: $100.00 SO ANSWERS, December 07, 2011 RON W RSON;'SHERIFF (C) CaMtySL*e Sheriff, Teleosoft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. VS. Susan C. Smith Chris A. Smith Plaintiff, Defendant. CIVIL DIVISION NO.: 11-8931 CIVIL TERM IMPORTANT NOTICE TO Chris A. Smith 1262 West Trindle Road Mechanicsburg, PA 17055.4517 DATE OF NOTICE: 12/27/2011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A =TEN 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 JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER Rv2ORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU D 0 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE Y CAN GET LEGAL HELP. ]NOTICE TO DEFEND & LAN Y ERREFERR4L SERVICE 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. Susan C. Smith Chris A. Smith Defendant. NO.: 11-8931 CIVIL TERM AVTSO R"FORTANTE TO: Chris A. Smith 1262 West Trindle Road Mechanicsburg, PA 17055-4517 FECHA DEL AVISO:12/27/2011 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MBNOS 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 2ThIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORNMN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE 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 a. `t)ietteticfi Scott A. Dietterick, Esquire Attorneys for Plaintiff PA I.D. 4 55550 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 159407 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs Susan C. Smith Chris A. Smith TO: Susan C. Smith 1262 West Trindle Road Mechanicsburg, PA 17055-4517 DATE OF NOTICE: 12/27/2011 NO.: 11-8931 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR B Y 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 JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & L NVYERREFERRAL SER?TCE 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 Defendant. IN THE? COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Susan C. Smith Chris A. Smith Defendant. TO: Susan C. Smith 1262 West Trindle Road Mechanicsburg, PA 17055-4517 NO.: 11-8931 CIVIL TERM AVISO ]AMORT ANTE FECHA DEL AVISO:12/27/2011 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOM-AR 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 SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LANVYERREFERRA?L SURVICE 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: scett Q. _`t)ietteiich Scott A. Dietterick, Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 RO. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 159407 File No. 11-8931 CIVIL TERM Wells Fargo Bank, N.A., Amount Due $168,474.93 Plaintiff, Interest from 2/2/2012 to date of sale $6,019.92 VS. Chris A. Smith; Susan C. Smith; Costs - rrnlqu ? Z? -e ?, _rm Gn Defendants. -< > ao CD C5 11 TO THE PROTHONOTARY OF THE SAID COURT: =C:) o f The undersigned hereby certifies that the below does not arise out of a retail installment sale, c ntr 00! account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached 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: t? 7A Signature: O?M rl # 21M Print Name: Scott . ck, E ui O Kimberly A. Bonner, Esquire a-?ogj'. °la•> O? 1 U. SD It `1 so U &I d aA-A Joel Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esfguire Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650: 89705; 202567:306799: 202946: A 311032 . L- ?. 35 ? SI Zucker, 6oidberg & Ackerman, 1.1V X FP-159407 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE NO. 64 1) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES 15 MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THEINCE BY OTHER LANDS OF JAMES R. WEINREICH AND CATHY M. WEINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRINDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND 135 FEET FROM THE REAR LINE OF SAID LOT. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WEST TRINDLE ROAD, MECHANICSBURG, PA, 170554517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND'KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED] MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. Zucker, Goldher, &: Ackerman, Llk' XFP-I 59407 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION N C: _ Plaintiff, NO.: 11-8931 CIVIL TERM r"GZ7 ? - f - vs. n,r- c > -< cry C:) Execution No.: Q v Chris A. Smith; Susan C. Smith; n -- r Defendant(s). c? . 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 1262 West Trindle Road, Mechanicsburg, PA 17055-4517. 1. Name and Address of Owner(s) or Reputed Owner(s): CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE 1262 West Trindle Road Mechanicsburg, PA 170554517 2. Name and Address of Defendant(s) in the Judgment: CHRIS A. SMITH 1262 West Trindle Road Mechanicsburg, PA 17055-4517 SUSAN C. SMITH 1262 West Trindle Road Mechanicsburg, PA 170554517 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 Lucker. Goldberg & Ackernimi. 11C X1 1'-b 59407 CAPITAL ONE BANK 140 East Shore Drive Glen Allen, VA 23059 AND C/O JAMES C. WARMBRODT 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO Box 15530 Harrisburg, PA 17105 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 fucker. (oidbers_? & Ackerman. U.(:' X111-1 59407 t UNKNOWN TENANT OR TENANTS 1262 West Trindle Road Mechanicsburg, PA 17055-4517 UNKNOWN SPOUSE 1262 West Trindle Road Mechanicsburg, PA 17055-4517 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: c 1 BY: (W A40 ? Scott A. Di 'ck, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #02729 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-159407 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com' Zucker. Goldberg & Ackerman. L.!_C X F11- 159407 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE NO. 641) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES 15 MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THENCE BY OTHER LANDS OF JAMES R. WEINREICH AND CATHY M. WEINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRINDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND 135 FEET FROM THE REAR LINE OF SAID LOT. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WEST TRINDLE ROAD, MECHANICSBURG, PA, 17055-4517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. tucker, Gnidherg &: Ackerman, LW XFP-154407 01 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. VS. Chris A. Smith; Susan C. Smith; CIVIL DIVISION Plaintiff, NO.: 11-8931 CIVIL TOW a, u,r ca Defendant(s). PC-) v? -11 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Chris A. Smith 1262 West Trindle Road Mechanicsburg, PA 17055-4517 AND 361 Sherwin Drive Carlisle, PA 17013 TAKE NOTICE: co r. -_-- That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 9/5/2012 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: 1262 West Triadic Road, Mechanicsburg, PA, 170554517 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-8931 CIVIL TERM Zucker, Goldberg & Ackerman, LLC XFP-159407 i i 4 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Chris A. Smith; Susan C. Smith 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. IBIS 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 QKE. 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) 249-3165 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-159407 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: May Q/?BY: Scott A. 151fteiick, Alw"_ squire; 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-159407 (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-159407 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE NO.641) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES 15 MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THENCE BY OTHER LANDS OF JAMES R. WEINREICH AND CATHY M. WEINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRUNDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND 135 FEET FROM THE REAR LINE OF SAID LOT. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WEST TRINDLE ROAD, MECHANICSBURG, PA, 17055-4517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. Zucker, G(Mber-& Ackerman, L:LC' a FF'-159407 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-8931 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 CHRIS A. SMITH; SUSAN C. SMITH (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: $168,474.93 L.L.: $.50 Interest FROM 2/2/2012 TO DATE OF SALE - $6,019.92 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $139.50 Other Costs: Plaintiff Paid: .-? Date: 5/18/12 David D. Buell, Prothono (Seal) oe ;Nz??? 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 C?? ` n ? 01 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV? E ?y N Wells Fargo Bank, N.A., CIVIL DIVISION C-) , z n =? Plaintiff, NO.: 11-8931 CIVIL TERM C: C5 VS. TYPE OF PLEADING Chris A. Smith; Susan C. Smith; Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE Defendants. OF DEFENDANT/OWNER AND 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 officeAzuckereoldberR.com File No.: XFP- 159407/dsc c? ----4 C7 3-n a c' Yi Zucker, Goldberg & Ackerman, XFP-159 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, VS. Chris A. Smith; Susan C. Smith; Defendants. CIVIL DIVISION NO.: 11-8931 CIVIL TERM 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, atto for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the followin Affidavit regarding the service of Plaintiff's Notice of Sheriffs Sale of Real Property in this matter o Defendant/Owner and Other Parties of Interest as follows: 1. Defendants, Chris A. Smith and Susan C. Smith, his wife, are the record owners of real property. 2. On or about June 21, 2012, Defendants Chris A. Smith and Susan C. Smith were with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, via Certified M return receipt requested at the address of the mortgaged premises, being 1262 West Trindle Ro Mechanicsburg, PA 17055. True and correct copies of said Notices and Proofs of Service are marl Exhibit "A", attached hereto and made a part hereof. 3. On or about June 27, 2012, Plaintiffs counsel served all other parties in interest Plaintiffs Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Cl U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, XFP-159 Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P 3129.2. ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Dated: July 10, 2012 DANIEL SCHLESINGER Paralegal/Legal Assistant Sworn to and subscribed before me this day of July, 2012 Notary Public MY COMMISSION EXPIRES: PAUL C. NADRATOWSKt c of Notary 10Publ #i240 850 Jersey my commission Expires 4/2712016 Zucker, Goldberg & Ackerman, XFP-159 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-159407 K-0 - m N D2T'= C)?3_ C13ps= Cr ;u m = G7 ? ?v V O cri U1 1 V -d t-+ Q' 0 0 Q' ru .a 0" 0 w OR rU 0" Qs 133 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 11-8931 CIVIL TERM vs. Chris A. Smith; Susan C. Smith; Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Chris A. Smith 1262 West Trindle Road Mechanicsburg, PA 17055-4517 AND 361 Sherwin Drive Carlisle, PA 17013 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 9/5/2012 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: 1262 West Trindle Road, Mechanicsburg, PA, 170554517 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-8931 CIVIL TERM Zucker, Goldberg & Ackerman, LLC XFP-159407 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS. PROPERTY ARE: Chris A. Smith; Susan C. Smith 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. WM Zucker, Goldberg & Ackerman, LLC XFP-159407 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: May BY: Old----'? Scott A. licktsquire; 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-159407 (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-159407 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE NO.641) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES IS MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THENCE BY OTHER LANDS OF JAMES R. WEINREICH AND CATHY M. WEINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRINDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND 135 FEET FROM THE REAR LINE OF SAID LOT. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WEST TRINDLE ROAD, MECHANICSBURG, PA, 17055-4517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. !,ticker, Goldhcrp & Ackerman, L AI: X FP-1 59407 ch co go co eD = ' O n =" '4 Os r r n C Z m v Cn m CA D r Cl) m m -p c -pM Z m m p Qe m? o w = .d m a N yA n N N Z*? - 0 Cl) - c r, ;u m - D o - VI = V1 - Ul = v - -J k-+ 0' 0 0 Er .0 N .A Q' 0 w Do _0 N Do IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 11-8931 CIVIL TERM VS. Chris A. Smith; Susan C. Smith; Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Susan C. Smith 1262 West Trindle Road Mechanicsburg, PA 17055-4517 AND 361 Sherwin Drive Carlisle, PA 17013 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 9/5/2012 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: 1262 West Trindle Road, Mechanicsburg, PA, 170554517 UW2 Zucker, Goldberg & Ackerman, LLC 92 XFP-159407 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-8931 CIVIL TERM THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Chris A. Smith; Susan C. Smith 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. M Zucker, Goldberg & Ackerman, LLC XFP-159407 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the 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: Qr a-/ BY: jam Scott A. Diettenc , squire; 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-159407 (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-159407 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE NO. 641) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES 15 MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THENCE BY OTHER LANDS OF JAMES R. WEINREICH AND CATHY M. WEINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRUNDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND 135 FEET FROM THE REAR LINE OF SAID LOT, HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WEST TRINDLE ROAD, MECHANICSBURG, PA, 17055-4517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. 7TM ile6_11 Zwkcr, Uildhcrg & Askwrnan, L:I,C \FI'-159407 i N C w Y c am= O - 0 (D CL - co co ( go -- t° a - C.) o V CD 1 r r n r c z m 'v D m O m 0 m TCM21 m NO?? ?m Z O gel m ? m o lull = m a EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-159407 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 11-8931 CIVIL TERM vs. Chris A. Smith; Susan C. Smith; Defendant(s). NOTICE TO UENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: CUMBERLAND COUNTY TAX CLAIM BUREAU UNKNOWN SPOUSE Cumberland County Courthouse 1262 West Trindle Road One Courthouse Square Mechanicsburg, PA 17055-4517 Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 UNKNOWN TENANT OR TENANTS 1262 West Trindle Road Mechanicsburg, PA 17055-4517 CAPITAL ONE BANK 140 East Shore Drive Glen Allen, VA 23059 PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO Box 15530 Harrisburg, PA 17105 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 CAPITAL ONE BANK C/O JAMES C. WARMBRODT 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 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 9/5/2012 at 10:00am, the following described real estate which Chris A. Smith and Susan C. Smith, his wife 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-159407 159407D I 004CO6192012P I 1262 West Trindle Road, Mechanicsburg, PA 17055-4517 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank, N.A. Chris A. Smith, et al Plaintiff Defendant(s) at EX. NO. 11-8931 CIVIL TERM in the amount of $168474.93 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 Sheriff's Sale or this Notice, you should contact your attorney as soon as possible. ZUCKER GOLDBERG ACKERMAN, LLC Dated: /;3'2 //a2 BY: Scott A. letterick, 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-159407 .(908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VS. Zucker, Goldberg & Ackerman, LLC XFP-159407 159407D 1 004C06192012P2 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE NO. 641) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES 15 MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THENCE BY OTHER LANDS OF JAMES R. WEINREICH AND CATHY M. WEIINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRINDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND 135 FEET FROM THE REAR LINE OF SAID LOT. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WESTTRINDLE ROAD, MECHANICSBURG, PA, 17055-4517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. Zucker, Goldberg & Ackerman, LLC ((Field2»-((Field I» ((Field I)Q 1004C02/ 12/2008P3 NTL CERT UNITED STATES Certificate of Mailing P2 POSTAL SERVICEs hen fa.,allbstamps ormater postage This CertSiab of ma*g provides wldanm Over mall has been preswftd to USPSa for me ft. This form may be used for domestic and Intemationel mall. From" Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/11 TEAM C TO: CAPITAL ONE BANK 140 East Shore Drive Glen Allen, VA 23059 County of P.Q.: CUMBERLAND Neale PS Form 3817, April 2007 PSN 7530-02-000.9065 Postmark Here 4°, ?ea?a? AttsEy t3ge? ?OVIF 02 1M $ 01.150 0004282038 JUN27 2012 ZIPCODE 0 7092 JUN 2 7 2012 UNITED STATES Certificate of Mailing 0 2F PWAL SERVICE. he PaY fa., aft stamps or meter postaSe This CertMente of Madlas proMei evidence that mall has been presarmsd to USPSa for maNn6. This form may be used for domestic and International me#. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/11 TEAM C CAPITAL ONE BANK C/O JAMES C. WARMBRODT 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530.02-000-9065 Postmark Here o 02 1M $ 01.15° 0004282036 JUN 27 2012 QM ZIPGODE 0 7092 rJUN 27 2012 Page 1 of 5 I NTL CERT UNITED STATES Certificate Of To pay %a, affix stamps or meter postage POSTAL SERVIC& Mailing hare. This CertNfrate of Moling provides evidence that mall has been presented to t15PSe for mardM This form may be used for domestic and IMematlonal mail. "o"" Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/11 TEAM C To: CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS form 3817, April 2007 PSN 7530-02-000-9065 09PO fai- I z""-wwwo-9 &&Owr - 02 1M $ 01.150 JUN 27 2012 ZIP CODE 07092 UNITED STATES Certificate Of Mailing P2 POSTAL SERVICES hen fee, aMGr stamps or meter pastels This Grtma" of Malen% prwWes evitfenm that maN has been presented to USPSe for maNkV. This form may be used for domestic and Imematbnal mal. From; Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/11 TEAM C To: COMMONWEALTH OF PENNSYLVANIA Postmark Here 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 0Poe%. $ 01.15° 036 JUN 27 2012 MOM ZrCODE 07092 A-?Iw 0 2 7 2012 -pa-win Page 2 of 5 NTL CERT A-D UNITEDSTdTES PC1S7dt SERVlCEe Certificate Of Mailing To pay fee, affix stamps or rrww postage hare. This Cartlikate of Mailing provides wMana that mail ha been presented to USPSe for mal ft This form may be used for domestk and international mall. `fem` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/II TEAM C To: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Posdimark Here Domestic Relations Section 13 N. Hanover Street ?cA PO Box 320 Carlisle, PA 17013 0 a 1r•••• mwaaa, PflteEYv aovjm County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 021M $ 01.15' 0004282036 JUN 27 201 "LED FROM ZIP CODE 0 70 5 'JUN 2 7 2012 ? la- UNITEDSTdTES POSTAL SERI/KEs Mailing To Pay fee, aft stamps or mater postage hare. Thla drtMate of Malling Provides wkwRe that mail has ban Presented to USPSa for mallr%This form may be used for domestic and international mail. 'mm; Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/11 TEAM C 7` PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here PN 0 2 1N1 $ 01.150 0004282038 JUN 27 2012 MAILED FROM Zr COtE 0 70 92 27 2012 t? Page 3 of 5 NTL CERT UNITED STATES Certificate Of To pay fee, aft stamps or metal postage OPOSTALSERVIC& Mailing here. This CenMaaw of MYling provides avidance ftt mall has boon promMed to USPSe for met". Ink form may be used for domestic and international mail. From Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/11 TEAM C To: i IAIVAarmA/kl TC111AM1r r%D TCAIAMTC postmark Here 1262 West Trindle Road Mechanicsburg, PA 17055-4517 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES ?POSFdL SERVKEe ThisGnNiwta d MaINq pros evidence that mal has been presented to USPSe for mtifRy. This form may be wed and Intemational moll. "or", Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-159407/II TEAM C T°` UNKNOWN SPOUSE 1262 West Trindle Road Mechanicsburg, PA 17055-4517 County of P.Q.: CUMBERLAND PS Form 3827, April 2007 PSN 7530-02-000-9065 -mmomw MMEV BOWES 02 1M $ 01.131 0004282036 JUN27 201 MAILED FROM ZIPCODE 0 70 9 27 2012 To pay foo, of M7 hen. // Postmark Here ls1'f 0 02 1M $ 01.150 2036 JUN 27 2012 FROM ZIP CODE 0 70 92 UL; ri :a 70 2012 `A Page 4 of 5 a NTL CERT UNITED STATES Certificate of Mailing POSTAL SERVICES ?payfa..iHz stemps°rma•rpostage This Catlliwte of Whaling pravldes aidnrw that WWII has been presented to USPSa for maibrs. This form may be used for domestic and International mail ff0w Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, N1 07092 XFP-159407/11 TEAM C To` PENNSYLVANIA HOUSING FINANCE AGENCY Postmark Here 211 North Front Street PO Box 15530 Harrisburg, PA 17105 ?qp County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ko,--wlvvassa 02 1M $01.150 4282036 JUN 2 7 2012 ODSE 0 70 92 JUN 7 2012 Page 5 of 5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY RonnyRAnderson ~ ~ F,LE~-OF~'1%E sheriff ~- TAE ~'R01'NONQTARI' ~~~~tit~ of ~Ir,n~,p~~~~ Jody S Smith ° ZQ+~ OCT 29 QM 10~ 5$ Chief Deputy ~ ~~ -~-t'~~ .. -~°: Richard W Stewart ~ CUMBERLAND COUNTY solicitor c~~f ~.E ~, r -~~~I~~ PENNSYLVANIA Wells Fargo Bank, N.A. Case Number vs. Chris A. Smith (et al.) 2011-8931 SHERIFF'S RETURN OF SERVICE 06/21/2012 08:20 PM -Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 1262 West Trindle Road, Mechanicsburg, PA 17055, Cumberland County. 06/21!2012 08:20 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be SUSAN SMITH-WIFE, who accepted as "Adult Person in Charge" for Chris A. Smith at 1262 W. Trindle Road, Silver Spring Township, Mechanicsburg, PA 17055, Cumberland County. 06/21/2012 08:20 PM -Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Susan C. Smith at 1262 W. Trindle Road, Middlesex Township, Mechanicsburg, PA 17055, Cumberland County. 09/06/2012 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, PA on September 5, 2012 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Scott Dietterick, on behalf of Wells Fargo Bank, NA, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $905.59 SO ANSWERS, October 29, 2012 RON R ANDERSON, SHERIFF ~~- ~~~ (c. ~nunty5uite Sl;enif, Telecsoft, Irc. Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs. Chris A. Smith; Susan C. Smith; Defendant(s). CIVIL DIVISION NO.: 11-8931 CIVIL TERM 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 1262 West Trindle Road, Mechanicsburg, PA 17055-4517. 1. Name and Address of Owner(s) or Reputed Owner(s): CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE 1262 West Trindle Road Mechanicsburg, PA 17055-4517 2. Name and Address of Defendant(s) in the Judgment: CHRIS A. SMITH 1262 West Trindle Road Mechanicsburg, PA 17055-4517 SUSAN C. SMITH 1262 West Trindle Road Mechanicsburg, PA 17055-4517 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. C~oidbere & ,~ckcn»an. I.L.C X FP-159dQ7 CAPITAL ONE BANK 140 East Shore Drive Glen Allen, VA 23059 AND C/O JAMES C. WARMBRODT 436 Seventh Avenue, Suite 2718 Pittsbwgh, PA 15219 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO Box 15530 Harrisburg, PA 17105 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 Harrisbwg, 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 Luchcr. Gotdbcre ~~ ,1ckcnnan. I.LC XFP-l.>9d~)7 UNKNOWN TENANT OR TENANTS 1262 West Trindle Road Mechanicsburg, PA 17055-4517 UNKNOWN SPOUSE 1262 West Trindle Road Mechanicsburg, PA 17055-4517 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: ~~ ~ ~ ~ ~ l BY: Scott A. Die 'ck, 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-159407 (908) 233-8500; (908) 233-1390 FAX E-mail : Office@zuckergoldberg. com lueker. C;oldberg ctc ;1ckennan. I.LC XFP-i:i9dg7 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE N0.641) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES 15 MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THENCE BY OTHER LANIIS OF JAMES R. WEINREICH AND CATHY M. WEINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRINDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND 135 FEET FROM THE REAR LINE OF SAID LOT. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WEST TRINDLE ROAD, MECHANICSBURG, PA, 17055-4517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. 'Locker, Gnidber~ & :lckcrman, LLC Fk'-154407 y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I Wells Fazgo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 11-8931 CIVIL TERM vs. Chris A. Smith; Susan C. Smith; Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Susan C. Smith 1262 West Trindle Road Mechanicsburg, PA 17055-4517 AND 361 Sherwi ve Cazli A 17013 l TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Squaze, Cazlisle, PA 17013 on 9/5/2012 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: 1262 West Trindle Road, Mechanicsburg, PA, 17055-4517 Zucker, Goldberg & Ackerman, LLC XFP-153407 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-8931 CIVIL TERM THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Chris A. Smith; Susan C. Smith 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 Squaze, Cazlisle, 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 awaze of a legal defect in the obligation or the procedure used against you. Zucker, Goldberg & Ackerman, LLC XFP-159407 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 Sheriff s Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding pazagraphs 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: ~ ~/ J~ a , ~ Q~ ~ BY: l y Scott A. Diettenck, squire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Mann, 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-159407 (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-159407 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE TRUNDLE ROAD (PA. ROUTE N0.641) AT LANDS NOW OR LATE OF JOHN L. ROTTER, SR.; THENCE ALONG SAID LANDS, NORTH 0 DEGREES 15 MINUTES EAST, 208.04 FEET, MORE OR LESS, TO A PIN;THENCE BY OTHER LANDS OF JAMES R. WEINREICH AND CATHY M. WEINREICH, HIS WIFE, SOUTH 87 DEGREES 45 MINUTES EAST, 100 FEET TO A PIN;THENCE BY LANDS NOW OR LATE OF OSCAR N. BRICKER AND MABEL E. BRICKER, HIS WIFE, SOUTH 0 DEGREES 15 MINUTES WEST, 210.72 FEET, MORE OR LESS, TO A POINT IN THE CENTER LINE OF THE TRUNDLE ROAD (PA. ROUTE 641), AFORESAID; THENCE ALONG THE CENTER LINE OF SAID TRINDLE ROAD (PA. ROUTE 641), NORTH 86 DEGREES 13 MINUTES WEST, 100.13 FEET, MORE OR LESS, TO A POINT IN THE CENTER OF SAID ROAD, AT THE PLACE OF BEGINNING. SUBJECT HOWEVER, TO THE RESTRICTION THAT NO BUILDING ERECTED ON SAID PREMISES SHALL BE ERECTED FORWARD OF A LINE PARALLEL TO AND l35 FEET FROM THE REAR LINE OF SAID LOT. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 1262 WEST TRINDLE ROAD, MECHANICSBURG, PA, 17055-4517. BEING THE SAME PREMISES WHICH MICHAEL R. SWIFT AND KIMBERLY A. SWIFT, HIS WIFE, BY DEED DATED FEBRUARY 28, 2005 AND RECORDED MARCH 2, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 267, PAGE 3878, GRANTED AND CONVEYED UNTO CHRIS A. SMITH AND SUSAN C. SMITH, HIS WIFE. TAX MAP NO.: 38-24-0773-005. luckcr, GaldLtcr~ & ackcrman, L:L.C ., XFP-ISUdh7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWE/3LTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-8931 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 CHRIS A. SMITH; SUSAN C. SMITH (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: $168,474.93 L.L.: $.50 Interest FROM 2/2/2012 TO DATE OF SALE - $6,019.92 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $139.50 Other Costs: Plaintiff Paid: Date: 5/18/12 David D. Buell, Prothonot (Seal) By: 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 TRUE COPY FROM RECORD In Testimony whereof, I here untc set myhand Supreme Court ID No. 306799 and the sell of said Cou Cariisla. Pa. This ,_..~~, day of , 20 ~(( ~ . T~i~D ~thor~otarY On May 22, 2012 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, Known and numbered as, 1262 West Trindle Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 22, 2012 By: eal Estate Coordinator J~ ~'.. `:' ~ ~: l~'~ d l I C7 CUMBERLAND LAW JOURNAL Writ No. ZO11-8931 Civil Term TAX MAP NO.: 38-24-0773-005. Wells Fargo Bank, N.A. vs. Chris A. Smith Susan C. Smith Atty.: Scott A. Dietterick ALL THAT CERTAIN tract of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the cen- ter of the Trundle Road (Pa. Route No. 641) at lands now or late of John L. Rotter, Sr.; thence along said lands, North 0 degrees 15 minutes East, 208.04 feet, more or less, to a pin;thence by other lands of James R. Weinreich and Cathy M. Weinreich, his wife, South 87 degrees 45 min- utes East, 100 feet to a pin;thence by lands now or late of Oscar N. Bricker and Mabel E. Bricker, his wife, South 0 degrees 15 minutes West, 210.72 feet, more or less, to a point in the center line of the Trindle Road (Pa. Route 641), aforesaid; thence along the center line of said Trundle Road (Pa. Route 641), North 86 degrees 13 minutes West, 100.13 feet, mare or less, to a point in the center of said road, at the place of BEGINNING. SUBJECT however, to the restric- tion that no building erected on said premises shall be erected forward of aline parallel to and 135 feet from the rear line of said lot. HAVING THEREON ERECTED a dwelling house being known and numbered as 1262 West Trindle Road, Mechanicsburg, PA, 17055- 4517. BEING the same premises which Michael R. Swift and Kimberly A. Swift, his wife, by deed dated Febru- ary 28, 2005 and recorded March 2, 2005 in and for Cumberland County, Pennsylvania, in Deed Book Volume 267, Page 3878, granted and con- veyed unto Chris A. Smith and Susan C. Smith, his wife. 92 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: July 27, August 3, and August 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. _~ isa Marie Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this da of Ai~ust, 2012 Notary DE80RAN A CO iListE BOROUGHrCUMBER~AND My Commission Ex Tres COUNTY P Apr 28, 2014 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffls Deed in which Wells Fargo Bank N.A. is the grantee the same having been sold to said grantee on the 5th day of September A.D., 2012, under and by virtue of a writ Execution issued on the 18th day of Mav, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2011 Number 8931, at the suit of Wells Fargo Bank N.A. against Chris A. Smith & Susan C. Smith is duly recorded as Instrument Number 201233353. or lJeeas RaoorderdDaed~dniberlarM tx~ny, (~ Pa My Comrt~ion Expvaa tlro Frst I~Cnday of Jan. ZDi4 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _~~/ ~ day of ,_, A.D. ~ D l~ 2011-8931 Clvll Term Wells Fargo Bank, N.A. Ys Chris A. Smith Susan C. SmRh Atty: Scott A Dletterlck All That Certain'IYact Of Land Situate In The Township Of Silver Spring, County Of Cumberland And State Of Pennsylvania, Bounded And Described As Follows, To Wit: Beginning At A Point In The Center Of The Trundie Road (Pa. Route No. 641) At Lands Now Or Late Of John L. Rotter, Sr.; Thence Along Said Lands, North 0 Degrees 15 Minutes Fast, 208.04 Feet, More Or Less, To A Pin;Thence By Other Lands Of James R. Weiareich And Cathy M. Weinreich, His Wife, South 87 Degrees 45 Minutes East, 100 Feet Tb A Pin;Thence $y Lands Now Or Late Of Oscaz N. Bricker And Mabel E. Bricker, His Wife, South 0 Degrees 15 Minutes West, 210.72 Feet, More Or Less, To A Point In The Center Line Of The'ilindle Road (Pa. Route 641), Aforesaid; Thence A~ng The Center Line Of Said'Itindle Road (Pa. Route 641}, North 84 Degrees 13 Mims es est,100.i3 Feet, More Or Less,lb A Point In The Center Of Said Road, At The Place Of Beginning. Subject However, Tb The Restriction That No Building Erected On Said Premises Shall Be Erected Forward Of A Line Parallel To And 135 Feet From The Reaz Line Of Said Lot. Having Thereon Erected A Dwelling House Being Known And Numbered As 1262 West'Bindle Road, Mechanicsburg, Pa, 17055-4517. Being The Same Premises Which Michael R. Swift And Kimberly A. Swift, His Wife, By Deed Dated February 28, 2005 And Recorded Mazch 2, ?A05 In And For Cumberland County, Pennsylvania, In Deed Book Volume 267, Page 3878, Granted And Conveyed Unto Chris A. Smith And Susan C. Smith, His Wife. Tax Map No.: 38-24-0773.005. Vs. The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE cue ~latriot-dews 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. ,. ~~ PUBLICATION COPY G' t This ad ran on the date(s) shown below: 07127/12 08/03/12 08/10/12 is yf day~~ugu~k, 2012 A.D. ;~ Notary NC![il`I#II $tlil Sherrie ~, t3w~na, N~titery Pub01e Low,~r P1XK~ri ~I'4rp:, Ciaupnin Cnunry a.. r,.».~....,~~,Y .:.._,_., _. _ 4