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HomeMy WebLinkAbout11-9265Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY HSBC Bank USA, N.A. vs. Christy Lerch (et al.) FILED-OFD iC{ OF THE PROTHONOTA. ??~wtiti'' of tirout,Gr?,r?b 2911 DEC 29 AM 8: 31 CUt? NNSY ?AN A TY ? Case Number 2011-9265 SHERIFF'S RETURN OF SERVICE 12/19/2011 06:52 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 19, 2011 at 1852 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Neil J. Lerch, Sr., by making known unto Christy Lerch, Wife of Defendant at 204 N. Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEPUT?- 12/19/2011 06:52 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 19, 2011 at 1852 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christy Lerch, by making known unto herself personally, at 204 N. Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEPU SHERIFF COST: $60.00 December 20, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c Got,m Suite Shenff, Teioosoft. Inc. IN THE COURT OF COMMON PL EAS OF CUMBERLAND COUNT S C-j -0,rn PENNSYLVANIA HSBC Bank USA, National Association, as CIVIL DIVISION Trustee for Wells Fargo Home Equity Trust 2004- _._,_ 2, No.: 11-9265 CID cr Plaintiff ISSUE NUMBER: VS. TYPE OF PLEADING: Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) Defendant(s). FILED ON BEHALF OF: I Hereby certify that the last known address of Defendant(s) is/are: HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004- 204 North 2nd Street 2 Wormleysburg, PA 17043 Plaintiff 44k4o-fl /YIN, 'J, COUNSEL OF RECORD FOR THIS PARTY: Attorney for Plaintiff 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.: XCP-158363 C,M+4/&. TO ?d a / Gk N 36199 / P-427121 Zucker, Goldberg & Ackerman, L,L.,C XCP-1 58363 Na fi-'L'D- mo"&j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee for CIVIL DIVISION Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendant(s). PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendant(s), Neil J. Lerch, Sr. a/k/a Neil Lerch and Christy M. Lerch aka Christy Lerch, in the amount of $108,862.30 which is itemized as follows for failure to file an Answer: Principal $105,148.17 Interest through 02/10/12 $4,068.73 Late Charges $ 129.12 Suspense Balance ($785.44) Escrow Advance $ 96.72 Inspection Fees $ 80.00 Corporate Advance 125.00 Total $108,862.30 plus interest on the principal sum ($105,148.17) from February 11, 2012, at the rate of $14.40 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: (UM0jA'_,' 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 Atty File No.: XCP-158363 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX Zucker, Goldberg & Ackerman, LLC XCP-158363 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. 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 Dated: By: ofim U'?? ScottA. ie 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 Atty File No.: XCP-158363 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 s 14 day of February, 2012 4ublic My Commission Expires: EDWARD J. SCHWAHI II No Commission # 2383239 tary Public, MYC State of New Jersey ommission Expires March 09, 2014 Zucker, Goldberg & Ackerman, LLC XCP-158363 ,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 Feb-10-2012 08:11:08 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency LERCH NEIL J 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). Aft A 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://www.defenselink.mil/fag/t)is/PC09SLDR.httnl. 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.dmdc.osd.mil/appj/scra/popreport.do 2/10/2012 .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:7JTLGAVDNR https://www.dmdc.osd.mil/appj/scra/popreport.do 2/10/2012 , Request for Military Status Department of Defense Manpower Data Center ID Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Feb-10-2012 08:13:10 < Last Name First/Middle Begin Date Active Duty Status I Active Duty End Date Service [ _ Agency LERCH CHRISTY Based on the information you have furnished, the DMDC does not possess M 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). 47 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/pis/PC09SLDR.htm1. 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.dmdc.osd.mil/appj/scra/popreport.do 2/10/2012 , 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 SCR,4 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:25TE78OGGM https://www.dmdc.osd.mil/appj/scra/popreport.do 2/10/2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee CIVIL DIVISION for Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 vs. Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendant(s). NOTICE OF ORDER, DECREE OR JUDGMENT TO: Neil J. Lerch, Sr. a/k/a Neil Lerch 204 North 2nd Street Wormleysburg, PA 17043 ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ?p X01 ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $108,862.30 plus interest on the principal sum ($105,148.17) from February 11, 2012, at the rate of $14.40 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, LLC XCP-158363 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee CIVIL DIVISION for Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. : Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendant(s). NOTICE OF ORDER, DECREE OR JUDGMENT TO: Christy M. Lerch aka Christy Lerch 204 North 2nd Street Wormleysburg, PA 17043 ( ) Plaintiff (X) Defendant ( ) Additional Defendant You are hereby notified that an Order, ecree or Judgment was entered in the above captioned proceeding on c? 1 ?- ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $108,862.30 plus interest on the principal sum ($105,148.17) from February 11, 2012, at the rate of $14.40 per diem, plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sal f Proth Zucker. Goldberg & Ackerman, LLC XCP-158363 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart solicitor Loa?tir of +?uabrrla?b 20I I DEC 29 AM 8= 31 CUMBERRLAND COUNTY OFFICE OF THE SHERIFF PENNSYLVANIA HSBC Bank USA, N.A. vs. Christy Lerch (et al.) Case Number 2011-9265 SHERIFF'S RETURN OF SERVICE 12/19/2011 06:52 PM - Ryan Burgett, Deputy Sheriff, who being duty swom according to law, states that on December 19, 2011 at 1852 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Neil J. Lerch, Sr., by making known unto Christy Lerch, Wife of Defendant at 204 N. Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. _; ? '::? I RYAN BURGETT, DEPU?P 12119/2011 06:52 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 19, 2011 at 1852 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Christy Lerch, by making known unto herself personally, at 204 N. Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEPU SHERIFF COST: $60.00 December 20, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED-OFFICE Ot THE PROTHONOTARY SO ANSWERS, 19 X.11 >> --- RON R ANDERSON, SHERIFF ;c) CamtySuite Shenk Teieosoft Oic. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee for CIVIL DIVISION Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. Neil J. Lerch, Sr. a/k/a Neil Lerch Christy M. Lerch aka Christy Lerch Defendant. IMPORTANT NOTICE TO: Neil J. Lerch, Sr. a/k/a Neil Lerch 204 North 2nd Street Wormleysburg, PA 17043 DATE OF NOTICE: 1/23/2012 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 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 HSBC Bank USA, National Association, as Trustee for CIVIL DIVISION Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. Neil J. Lerch, Sr. a/k/a Neil Lerch Christy M. Lerch aka Christy Lerch Defendant. TO: Neil J. Lerch, Sr. a/k/a Neil Lerch 204 North 2nd Street Wormleysburg, PA 17043 AN S0EVJ?MTANM FECHA DEL AVISO:1/23/2012 LMM ESTA FN FE?A PCRQLE HA FALIADD ICE TCMAR IA ACCICIN IN E; IE CASQ A NEMM (LE LT= WNE AMCN EENIRD IIE LICE P14DXUVDS I;tE7 (10 SFAS ICE LA FF M A I EESM ANM, SE PCFCE IIGTAR T. NFALIAIN01,4Zn? SUYAM'41=ARSEACABOLIVANL'STAYL1&=PCB PEITER SU PRCIMD60 Y OIRCR 77 El CS D&=ANIM LB= LLEVAR E= DC)CIAdENID Il4VMATA1VENM A SU ABCCIADQ SE LMM NC 'II> NM LN ABOCvaM O IVQ PCH:E PACzAR LNQ VAYA O I.IANE IA CEICINA ABATO INEXCADA PARR QLE LE Il T DCP E PUEEE CXINSEPLIR AYLIDA IE3AL r CMCE'PODE &1,dWNVM1WX 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, GOIDBERG&AC T BY S= A. Dietta ck Scutt A Diett rids, Esquire Anomeys for PI ainti PAID # 55650 200 Sheffield Street, Slate 301 P-0- Boat 1024 Maurtammc e, NJ 07092-0024 (717) 533-3560 FIRST CLASS U S MAIL., PCISTAGE PREPAID 158363 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee for CIVIL DIVISION Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. Neil J. Lerch, Sr. a/k/a Neil Lerch Christy M. Lerch aka Christy Lerch Defendant. IMPORTANT NOTICE TO: Christy M. Lerch aka Christy Lerch 204 North 2nd Street Wormleysburg, PA 17043 DATE OF NOTICE: 1/23/2012 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 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 HSBC Bank USA, National Association, as Trustee for CIVIL DIVISION Wells Fargo Home Equity Trust 2004-2 Plaintiff, N0.:11-9265 VS. Neil J. Lerch, Sr. a/k/a Neil Lerch Christy M. Lerch aka Christy Lerch Defendant. ANW01N2NMTAI'TW TO: Christy M. Lerch aka Christy Lerch 204 North 2nd Street Wormleysburg, PA 17043 FECHA DEL AVISO:1/23/2012 LM M ESTA INCA PCIRQLE HA FALLAEO ICE TCMAR LA ACEICII? RH C?RII?A FN ESIE CASO A ? QLE LlMM TM1E AMCN EENIRO EE LC S PRUMMM Dl? (10j ERAS DE LA FBa-A I:EEa IE AN.SO, SE PCEEE IICTAR LNFA JO EN C CNIRA SCJYA SN LLEVAR.SEA C.ABO LNA VISTA Y L1SIID FCC PE11:E R SU MCFEECAD Y C URCS I33REKI-IDS DvFCFUTAN1M LL 11D I1--VAR = DtJCXAEMO IlqVMIATAMENM A SU AB )SADO S[ LAS= I? 'IIEIVIE LN ABOGIDO O NU PCELE PACAR LNQ VAYA O LIANE LA CIRCESA ABATO Il'4CgCAEA PARR QL E LE r4KXU4N DC1NCE PCECE CCNSEQUR AYC1:7A I13C y- 1?: - • a : a- t4 30 ;) -i V.11 III Z0 CO -? 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 ZUCXII;, GOIDBERG&ACKEFOAAN BY S=A. Maoick Soott A Dietterick Esquire Attameys for Plairmff PAID # 55650 200 ShefeldStreet, Suite 301 P-0. Baas 1024 Maartainside, NJ 070924)024 (717) 533-3560 FIRST C3A5S U. St MAII.., POSTAGE PLAID 158363 .l IN THE COURT OF COMMON PLEAS OF C IJi.A" COUNTY PENNSYLVANIA CIVIL DIVISION HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004-2, Plaintiff, VS. Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendants. File No. 11-9265 Amount Due $108,862.30 „ Interest from 2/11/2012 to date of sale `2, 80 • Costs 2r- _ t zo - a Imo. TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (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: _ Wo .ocU R';, 00 u a 14.sau P . SUL K ?0q1 b a ft, So u' ((y 35/"z ? y17 Supreme Court ID No.: as -Wt & Signature: Print Name: Kimberly ott A Bonner, E wire` squire Joel Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 55650: 89705 : 202567: 306799: 202946: 311032 Zucker. Goldhera & Ackerman. LLC X01- I MW ?uf ;? Q? TKC__?8 J Exhibit "A" LEGAL DESCRIPTION PROPERTY SITUATED IN WORMLEYSBURG BOROUGH OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING REFERRED TO AS "THE PROPERTY" AND MORE FULLY DESCRIBED AS FOLLOW: LEGAL DESCRIPTION: DISTRICT: 047, CITY: WORMLEYSBURG BOROUGH, ASSESSORS'S MAP REFERENCE: MAP 1588 HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 204 NORTH 2ND STREET, WORMLEYSBURG, PA, 17043. BEING THE SAME PREMISES WHICH DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA N.A., AS TRUSTEE FOR VENDEE MORTGAGE TRUST 2002-3, BY DEED DATED FEBRUARY 17, 2004 AND RECORDED APRIL 7, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 268, PAGE 1535, GRANTED AND CONVEYED UNTO NEIL J. LERCH, SR. AND CHRISTY M. LERCH. TAX MAP NO.: 47-19-1588-151. Zucker, Goldberg & Ackerman, LLC XCP-158363 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004 2, Plaintiff, VS. Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M Lerch aka Christy Lerch; Defendant(s). ?r??«? r"'°.7 FELL CIVIL DIVISION "'y.. ?.a.• ?C7 NO.: 11-9265 co z° Execution No.: ?P- c-) as C:)? ; . HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004-2, 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 204 North 2nd Street, Wormleysburg, PA 17043. 1. Name and Address of Owner(s) or Reputed Owner(s): NEIL J. LERCH, SR. AND CHRISTY M. LERCH 204 North 2nd Street Wormleysburg, PA 17043 2. Name and Address of Defendant(s) in the Judgment: NEIL J. LERCH, SR. A/K/A NEIL LERCH 204 North 2nd Street Wormleysburg, PA 17043 CHRISTY M. LERCH AKA CHRISTY LERCH 204 North 2nd Street Wormleysburg, PA 17043 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 Plaintiff Zucker, OoidhLrg & Ackerman. L.LC XCP-1 58363 t HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 3476 Stateview Boulevard Fort Mill, SC 29715 AND C/O ANDREW C. BRAMBLETT, ESQ. 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 APPLIED CARD BANK 800 Delaware Avenue Wilmington, DE 19801 AND C/O EDWIN A. ABRAHAMSEN & ASSOCIATES 1729 Pittston Avenue Scranton, PA 18505 4. Name and Address of the last record holder of every mortgage of record: HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 Plaintiff WELLS FARGO HOME MORTGAGE, INC. P.O. Box 5137 Des Moines, IA 50306-5137 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 BOROUGH OF WORMLEYSBURG 20 Market Street Wormleysburg, PA 17043 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 /ucker, Goldb re. & Ackerman. 1.1_C 1CP-138363 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 204 North 2nd Street Wormleysburg, PA 17043 UNKNOWN SPOUSE 204 North 2nd Street Wormleysburg, PA 17043 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: ? a BY: 0 Am Scott A. Die a k, 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.: XCP-158363 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Zucker. Goldberg & Ackerman, 1.1 .' V113-1 i33h a t Exhibit "A" LEGAL DESCRIPTION PROPERTY SITUATED IN WORMLEYSBURG BOROUGH OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING REFERRED TO AS '"THE PROPERTY" AND MORE FULLY DESCRIBED AS FOLLOW: LEGAL DESCRIPTION: DISTRICT: 047, CITY: WORMLEYSBURG BOROUGH, ASSESSORS'S MAP REFERENCE: MAP 1588 HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 204 NORTH 2ND STREET, WORMLEYSBURG, PA, 17043. BEING THE SAME PREMISES WHICH DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA N.A., AS TRUSTEE FOR VENDEE MORTGAGE TRUST 2002-3, BY DEED DATED FEBRUARY 17, 2004 AND RECORDED APRIL 7, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 268, PAGE 1535, GRAN'T'ED AND CONVEYED UNTO NEIL J. LERCH, SR. AND CHRISTY M. LERCH. TAX MAP NO.: 47-19-1588-151. Zucker, Goldberg & Ackerman, llC XCP-158363 79, II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004-2 VS. Plaintiff, Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendant(s). Cl) la- CIVIL DIVISION -0 :Z rn ? . x. Nr?" NO.: 11-9265 '7 o NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129! Neil J. Lerch, Sr. a/k/a Neil Lerch 204 North 2nd Street Wormleysburg, PA 17043 TAKE NOTICE: Ilk ---i, :r--n rnr= 'C?; a° or C:D 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 1 0:00am 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: 204 North 2nd Street, Wormleysburg, PA, 17043 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-9265 Zucker, Goldberg & Ackerman, LLC XCP-158363 s THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch 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. FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Stmt Carlisle, PA 17013 Phone (890) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: I. 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 XCP-158363 i 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: 0hA17fLQ,11L_ / Scott A. Diette c , 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.: XCP-158363 (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 XCP-158363 r Exhibit "A" LEGAL DESCRIPTION PROPERTY SITUATED IN WORMLEYSBURG BOROUGH OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING REFERRED TO AS "THE PROPERTY" AND MORE FULLY DESCRIBED AS FOLLOW: LEGAL DESCRIPTION: DISTRICT: 047, CITY: WORMLEYSBURG BOROUGH, ASSESSORS'S MAP REFERENCE: MAP 1588 HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 204 NORTH 2ND STREET, WORMLEYSBURG, PA, 17043. BEING THE SAME PREMISES WHICH DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA N.A., AS TRUSTEE FOR VENDEE MORTGAGE TRUST 2002-3, BY DEED DATED FEBRUARY 17, 2004 AND RECORDED APRIL 7, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 268, PAGE 1535, GRANTED AND CONVEYED UNTO NEIL J. LERCH, SR. AND CHRISTY M. LERCH. TAX MAP NO.: 47-19-1588-151. Zucker, Goldberg & Ackerman, LLC XCP-158363 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 11-9265 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 Plaintiff (s) From NEIL J. LERCH, SR. A/K/A NEIL LERCH; CHRISTY M. LERCH A/K/A CHRISTY LEACH (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: $108,862.30 L.L.: $.50 Interest FROM 2/11/2012 TO DATE OF SALE - $2,980.80 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $199.50 Other Costs: Plaintiff Paid: Date: 5/18/12 David D. Buell, Prot ono (Seal) ALso 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 OFF lCL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE,{, 4 6T?OTAR`f HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004-2, vs. Plaintiff, Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch A Christy Lerch; Defendant(s). 2012 JUN 28 AK 10** 18 CIVIL DIVISION ClIERLAND C"TY NO.: 11-9265 PENNSYLVANIA Execution No.: AFFIDAVIT PURSUANT TO RULE 3129.1 HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004-2, 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 204 North 2nd Street, Wormleysburg, PA 17043. 1. Name and Address of Owner(s) or Reputed Owner(s): NEIL J. LERCH, SR. AND CHRISTY M. LERCH 204 North 2nd Street Wormleysburg, PA 17043 2. Name and Address of Defendant(s) in the Judgment: NEIL J. LERCH, SR. A/K/A NEIL LERCH 204 North 2nd Street Wormleysburg, PA 17043 CHRISTY M. LERCH AKA CHRISTY LERCH 204 North 2nd Street Wormleysburg, PA 17043 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 Plaintiff HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 3476 Stateview Boulevard Fort Mill, SC 29715 AND C/O ANDREW C. BRAMBLETT, ESQ. 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 APPLIED CARD BANK 800 Delaware Avenue Wilmington, DE 19801 AND C/O EDWIN A. ABRAHAMSEN & ASSOCIATES 1729 Pittston Avenue Scranton, PA 18505 4. Name and Address of the last record holder of every mortgage of record: HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 Plaintiff WELLS FARGO HOME MORTGAGE, INC. P.O. Box 5137 Des Moines, IA 50306-5137 WELLS FARGO BANK, N.A., S/I/I TO WELLS FARGO HOME MORTGAGE, INC. P.O. Box 5137 Des Moines, IA 50306-5137 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 BOROUGH OF WORMLEYSBURG 20 Market Street Wormleysburg, PA 17043 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 204 North 2nd Street Wormleysburg, PA 17043 UNKNOWN SPOUSE 204 North 2nd Street Wormleysburg, PA 17043 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: 6/9af?;2 BY: Scott ietterick, 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, N1 07092 File No.: XCP-158363 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION PROPERTY SITUATED IN WORMLEYSBURG BOROUGH OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING REFERRED TO AS "THE PROPERTY" AND MORE FULLY DESCRIBED AS FOLLOW: LEGAL DESCRIPTION: DISTRICT: 047, CITY: WORMLEYSBURG BOROUGH, ASSE:SSORS'S MAP REFERENCE: MAP 1588 HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 204 NORTH 2ND STREET, WORMLEYSBURG, PA, 17043. BEING THE SAME PREMISES WHICH DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA N.A., AS TRUSTEE FOR VENDEE MORTGAGE TRUST 2002-3, BY DEED DATED FEBRUARY 17, 2004 AND RECORDED APRIL 7, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 268, PAGE 1535, GRANTED AND CONVEYED UNTO NEIL J. LERCH, SR. AND CHRISTY M. LERCH. TAX MAP NO.: 47-19-1588-151. Defendants. TYPE OF PLEADING C7 rya "t7 ...? C-) -{c C t C-r j Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: HSBC Bank USA. Nation Wells Fargo Home Equity Trust 2004-2 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(@zuckereoldbers.com File No.: XCP- 158363/dsc II Zucker, Goldberg & Ackerman, L C XCP-158363 n C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV HSBC Bank USA, National Association, as Trustee CIVIL DIVISION for Wells Fargo Home Equity Trust 2004-2, NO.: 11-9265 vs Plaintiff, Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee for CIVIL DIVISION Wells Fargo Home Equity Trust 2004-2 Plaintiff, VS. Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendants. NO.: 11-9265 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, attorney)J for Plaintiff, HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004-a, being duly sworn according to law depose and make the following Affidavit regarding the service df Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of interest as follows: 1. Defendants, Neil J. Lerch, Sr. and Christy M. Lerch, are the record owners of the property. 2. On or about June 21, 2012, Defendants Neil J. Lerch, Sr. and Christy M. Lerch we served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, via Certifi Mail, return receipt requested at the address of the mortgaged premises, being 204 North 2nd Stre Wormleysburg, PA 17043. True and correct copies of said Notices and Proofs of Service are mark Exhibit "A", attached hereto and made a part hereof. 3. On or about July 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 CI U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices a Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, Ll?C XCP-15833 Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of interest were served with Plaintiff's 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: July 5, 2012 DANIEL SCHLESINGER Paralegal/Legal Assistant Sworn to and subscribed before me this day of July, 2012 n Notary Public PAUL C. NADRATOWSKI MY COMMISSION EXPIRES: Notary Public of New Jersey ID# 2407850 My Conanission Expres 412709 Zucker, Goldberg & Ackerman, L C XCP-15833 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XCP-158363 O < Z t-' Z 0' rZCDD = o f/) U) ? cr C -0 G7 = Q' C3 D Z_ w CD = o r D o°f, ru w C Ir N L-j 0 J p? j' C d ?. Aga z a o go v D N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee CIVIL DIVISION for Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. ; Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Neil J. Lerch, Sr. a/k/a Neil Lerch 204 North 2nd Street Wormleysburg, PA 17043 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: 204 North 2nd Street, Wormleysburg, PA, 17043 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-9265 Zucker, Goldberg & Ackerman, LLC XCP-158363 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch 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: I . 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 Sheriff s Deed is delivered. yo-y Zucker, Goldberg & Ackerman, LLC XCP-158363 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. FUCKER GOLDBERG & ACKERMAN, LLC Dated: Q BY: Scott A. Diett0 ? IA4 (I P JA - e c , 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.. XCP-158363 (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. h-79 Zucker, Goldberg & Ackerman, LLC XCP-158363 Exhibit "A" LEGAL DESCRIPTION PROPERTY SITUATED IN WORMLEYSBURG BOROUGH OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING REFERRED TO AS "THE PROPERTY" AND MORE FULLY DESCRIBED AS FOLLOW: LEGAL DESCRIPTION: DISTRICT: 047, CITY: WORMLEYSBURG BOROUGH, ASSESSORS'S MAP REFERENCE: MAP 1588 HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 204 NORTH 2ND STREET, WORMLEYSBURG, PA, 17043. BEING THE SAME PREMISES WHICH DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA N.A., AS TRUSTEE FOR VENDEE MORTGAGE TRUST 2002-3, BY DEED DATED FEBRUARY 17, 2004 AND RECORDED APRIL 7, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 268, PAGE 1535, GRANTED AND CONVEYED UNTO NEIL J. LERCH, SR. AND CHRISTY M. LERCH. TAX MAP NO.: 47-19-1588-151. MICk Zucker, Goldberg & Ackerman, LLC ffm XCP-158363 0 -0 Z Q- N rzK; o ?v O cn(nCD = °' ou a =r ru a Q' O D N w Di _ rn RJ W Y m Q' ' cP 0 0 N W. 7' 13 C 2 d 7 C) O raj Q C Q a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee CIVIL DIVISION for Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendant(s). NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Christy M. Lerch aka Christy Lerch 204 North 2nd Street Wormleysburg, PA 17043 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: 204 North 2nd Street, Wormleysburg, PA, 17043 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11-9265 M-41 Zucker, Goldberg & Ackerman, LLC XCP-158363 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch 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 Conimon 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: I. 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 6-1 XCP-158363 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: Ina V D ( ?''BY: ric , squire; PA I.D. #55650 Scott A. Did 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.: XCP-158363 (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 ok XCP-158363 Exhibit "A" LEGAL DESCRIPTION PROPERTY SITUATED IN WORMLEYSBURG BOROUGH OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING REFERRED TO AS "THE PROPERTY" AND MORE FULLY DESCRIBED AS FOLLOW: LEGAL DESCRIPTION: DISTRICT: 047, CITY: WORMLEYSBURG BOROUGH, ASSESSORS'S MAP REFERENCE: MAP 1588 HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 204 NORTH 2ND STREET, WORMLEYSBURG, PA, 17043. BEING THE SAME PREMISES WHICH DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA N.A., AS TRUSTEE FOR VENDEE MORTGAGE TRUST 2002-3, BY DEED DATED FEBRUARY 17, 2004 AND RECORDED APRIL 7, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 268, PAGE 1535, GRANTED AND CONVEYED UNTO NEIL J. LERCH, SR. AND CHRISTY M. LERCH. TAX MAP NO.: 47-19-1588-151. Zucker, Goldberg & Ackerman, LLC XCP-158363 3 C) o CD 0 ? aa'°. e0 ? to = to a p o D 4 < M ..y _ r r n z m 0 a m 0 D r N m n m vcmT z mm o ae CD ?. O to - m o: EXHIBIT B Zucker, Goldberg & Ackerman, LLC XCP-158363 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HSBC Bank USA, National Association, as Trustee for CIVIL DIVISION Wells Fargo Home Equity Trust 2004-2 Plaintiff, NO.: 11-9265 VS. Neil J. Lerch, Sr. a/k/a Neil Lerch; Christy M. Lerch aka Christy Lerch; Defendants). NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: CUMBERLAND COUNTY TAX CLAIM BUREAU UNKNOWN SPOUSE Cumberland County Courthouse 204 North 2nd Street One Courthouse Square Wormleysburg, PA 17043 Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 UNKNOWN TENANT OR TENANTS 204 North 2nd Street Wormleysburg, PA 17043 HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 3476 Stateview Boulevard Fort Mill, SC 29715 APPLIED CARD BANK 800 Delaware Avenue Wilmington, DE 19801 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 HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS FARGO HOME EQUITY TRUST 2004-2 C/O ANDREW C. BRAMBLETT, ESQ. 16171FK Boulevard, Suite 1400 Philadelphia, PA 19103 APPLIED CARD BANK C/O EDWIN A. ABRAHAMSEN & ASSOCIATES 1729 Pittston Avenue Scranton, PA 18505 BOROUGH OF WORMLEYSBURG 20 Market Street Wormleysburg, PA 17043 WELLS FARGO HOME MORTGAGE, INC. P.O. Box 5137 Des Moines, IA 50306-5137 WELLS FARGO BANK, N.A., S/1/1 TO WELLS FARGO HOME MORTGAGE, INC. P.O. Box 5137 Des Moines, !A 50306-5137 Zucker, Goldberg & Ackerman, LLC XCP-158363 158363DIO04CO6192012PI 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 1000am, the following described real estate which Neil J. Lerch, Sr. and Christy M. Lerch 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: 204 North 2nd Street, Wormleysburg, PA 17043 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The said Writ of Execution has been issued on a judgment in the action of HSBC Bank USA, National Association, as Trustee for Wells Fargo Home Equity Trust 2004-2 Plaintiff Vs. Neil J. Lerch, Sr. a/k/a Neil Lerch, et al Defendant(s) at EX. NO. 11-9265 in the amount of $108862.30 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. Zucker, Goldberg & Ackerman, LLC XCP-158363 158363131004C06192012P2 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. ZUCKER GOLDBERG & ACKERMAN, LLC Dated: 02P boa BY: Scott 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.: XCP-158363 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoIdberg.com Zucker, Goldberg & Ackerman, LLC XCP-158363 158363D 1 004C06192012P3 Exhibit "A" LEGAL DESCRIPTION PROPERTY SITUATED IN WORMLEYSBURG BOROUGH OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING REFERRED TO AS "THE PROPERTY" AND MORE FULLY DESCRIBED AS FOLLOW: LEGAL DESCRIPTION: DISTRICT: 047, CITY: WORMLEYSBURG BOROUGH, ASSESSORS'S MAP REFERENCE: MAP 1588 HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 204 NORTH 2ND STREET, WORMLEYSBURG, PA, 17043. BEING THE SAME PREMISES WHICH DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FORMERLY KNOWN AS BANKERS TRUST COMPANY OF CALIFORNIA N.A., AS TRUSTEE FOR VENDEE MORTGAGE TRUST 2002-3, BY DEED DATED FEBRUARY 17, 2004 AND RECORDED APRIL 7, 2005 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 268, PAGE 1535, GRANTED AND CONVEYED UNTO NEIL J. LERCH, SR. AND CHRISTY M. LERCH. TAX MAP NO.: 47-19-1588-151. Zucker, Goldberg & Ackerman, LLC ((Field2»-«Fieldl» ((Field 1 ))D1004C02/12/2008P4 NTL CERT UNITEDSTMES Certificate Of Mailing To fee, stami" V POST/JL SERVICE here" aft or meter Postage This Certga ete of Mailing provides evidence that mail has been prasemedto USPSe for mailing. This form may be used for domestic and international mall. Prom: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C To: HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS Postmark Here FARGO HOME EQUITY TRUST 2004-2 3476 Stateview Boulevard Fort Mill, SC 29715 0' I-MMENSOW County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ?rd Fowl BOWES a 01.15 ?$ 02 1M JUN27 2012 . 0004282036 .LED FROM Zjp CODE 07o92 ll? .1Um 27 2012 ;. UNITED STATES Cert sate of V.?.a POSTAL SERVICE he pay fee, aft stamps or mater postage hen. The Ceriftote of Mailing provides widence that moll has been pnesented to USPSe for meling. This form may be used for domestic and International mal. From, Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE FOR WELLS Pstmark Here FARGO HOME EQUITY TRUST 2004-2 C/O ANDREW C. BRAMBLETT, ESQ. 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 y? ses N. at, ?20 . FXYvvr:s • 02 1M $ 01.150 04 JUN 27 2012 POWE 07092 County of P.Q.: CUMBERLAND n ?p1?1 PS Form 3817, April 2007 PSN 7530-02-000-9065 ,JUN 27 LVO Page 1 of 7 NTL CERT tlNITEDSTATES ?POSTdt SER VIM Certificate Of Mailing To pay tee, affix (temps or meter postage here. This Certekate of Mding Provides evidence that mall has been Presented to USPSe for maelrg. This form may be used for domestic and international ma A. "ow* Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C T°` CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here .? s acre- P"My taowes 02 1M $01-1513 0004282038 JUN27 2012 MA I.gD FROM ZIPCODE 0 70 2 JUN 2 7 2012 This CertM ate of Mailing Provides evidence that mac has been presented to USP5e for malling. This form may be used for domestic and International mall. "mm: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 unnrEUSrArEs V.aPOSTAL sERVKEe Certificate O USps Mailing To pay fee, affix stamps or meter postage here. Postmark Here XCP-158363/11 TEAM C COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 753002-000-9065 I 61 0 2 a1, 1.150 's 00042 27 2012 MAILED PR N 0 7092 JU% 2'7 2012 aw image 2 of 7 I e NTL CERT UNITED STATES ?POSTALSERVICG Certificate Of Mailing To pry fee, affhr stamps "meter postage hare. This Certificate, of Mailing provides evidence that trail has been presented to USPSs for mailing. This form may be used for domestt and International mall. Scott A. Dietterick, Esquire _ c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 0 f.Sri 02 IM 0004282036 .,lieu EO FROM "Um $ d1 15° JUN 2 2012 IPGO 07092 JUN 2 7 2012 This Certificate of Mailing provides evidence that mail has been presented to USPSe for me". This form may be used for domestic and International mall. prom` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 V.?w UNITED STATES POSTAL SE'RV1CEs Certificate O Usps Mailing To pry fee, affix stamps or meter postage here. Postmark Here XCP-158363/11 TEAM C TO` 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 ?sp:01PEW O r'firW ??? nmeEY BOWES Fo 01.15° MAILED 7 2012 07092 `JUN 27 2012 -Pa e 3 of 7 \U r?S NTL CERT UNITEDSTATES Certificate Of M (/a Mailing V10 POSTAL SERVI\r& heWVfee. affix stamps or meter AOSta6e here. This GNflw4 of Mading provides evidence that mail has been presented to USPSe for malling. This form may be used for domestic and international m*IL `'eT' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C To' UNKNOWN TENANT OR TENANTS 204 North 2nd Street Wormleysburg, PA 17043 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here t ?'Ne., PMEYBOVM 02 1M $ 01.151 0004282036 JUN27 201 AILED FROM ZIP CODE 0 70 £ JUN 2 7 2012 UNITED STMES Certlfl to Of filing Q e.a rtampsormeterPostaN OPOSTALSERVICEs IV This CertM cM of Me Ing provides evidence that mail has been presented to USPSe for me Abg. This form may be used for domestic and International malL Fro'"' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 0004282036 JUN27 2012 MIAIiED FROM ZIP CODE 0 70 92 law JUN 2 7 2012 L?m Page 4 of 7 Wormleysburg, PA 17043 viP County of P.Q.: CUMBERLAND 7 ' mmw! "MEV lqWES PS Form 3817, April 2007 PSN 7530-02-000-9065 n j 1M -It 01 'C11 XCP-158363/11 TEAM C T°' UNKNOWN SPOUSE Postmark Here 204 North 2nd Street NTL CERT UWITEaSFdTES ?P05T01 SEF2VICE@ Certificate Of Mailing To pay fear, atfix stamps or meter postage here. This Caakete of Mailing provides evidence that mall has been presented to VSPS' for malting. This forth may be used for domestic and international melt F'o" Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C To` APPLIED CARD BANK 800 Delaware Avenue Wilmington, DE 19801 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here PN 0 5 "IV m.. pin iev aciliun 02 1M $ 01.15 0004282036 JUN 27 2012 <D FROM ZIPCODE 0 7092 JUN 2 7 2012 !m UNITEDSTATES Certificate Of To pay fee, affix stamps or mater postage a PSTAL SERVICE Mailing here. This Willem of Maatng provides evidence that mall has been presented to USPSe for mailing. This form maybe used for domestic and International mail. 'rem: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C TO7 APPLIED CARD BANK C/O EDWIN A. ABRAHAMSEN & ASSOCIATES 1729 Pittston Avenue Scranton, PA 18505 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here • 0004282 .150 t MAILED FRO 2012 JUN 2 7 2012 &PEI 70 92 Page 5 of 7 . r r NTL CERT UNITEDSTATES Certificate Of Mailing V POSTAL SERVICES here. ? afixsmmpsor meter postage This Certfikate of Mailing provides evklence that map has been presented to USP5• for mailing. This form may be used (or domestic and International mall. Prom: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Des Moines, IA 50306-5137 005 XCP-158363/11 TEAM C To: WELLS FARGO HOME MORTGAGE, INC. Postmark Here P.O. Box 5137 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 g 02 1M 01.15° 000 JUN 27 2012 !UN 27 2012 P UNITED STATES POST,4L SFRV/CEs Certificate Of Mailing To pay fee, aft stamps or mater postage hem. This Certificate of Mailing prwMn evklencs tW mall has been Pretemed to USPS- for melting. This form may be used for domestic and international mail. ``pm: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C TO: WELLS FARGO BANK, N.A., S/I/I TO WELLS FARGO HOME MORTGAGE, INC. P.O. Box 5137 Des Moines, IA 50306-5137 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9D65 Postmark Here NTL CERT UNITED STATES Certificate Of C To pay tea, afar stamps or meter postage V,?,POSTAL SERVI E Mailing here. This Grtlarata of Malting provWes wMenee that maa has been presented to i1SPSe for molars. This form may be used for domestk and Intsmotlonal me a. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-158363/11 TEAM C Tot BOROUGH OF WORMLEYSBURG Postmark Here 20 Market Street Wormlevsbure. PA 17043 County of P.Q.: CUMBERLAND PS Form 3827, April 2007 PSN 7530-02-000-9065 XMI& FMAvI \a! PITPXV BOWES $ 01.150 0 27 20 '12 LS E07092 n SUN 2 2o1z i Page 7 of 7