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Home My WebLink About11-9340SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OfFiCE Sheriff 4i T9F tn Jody S Smith V ttyt of .u?nGr, fj ?? ?: a Chief Deputy 7011 DEC 29 Richard W Stewart x_. CUMBERLAND COU141 Solicitor OFF -'E T.r PENNSYLYpAm Wells Fargo Bank, NA vs. Daniel J. Behrens (et al.) Case Number 2011-9340 SHERIFF'S RETURN OF SERVICE 12122/2011 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: Daniel J. Behrens, 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 Daniel J. Behrens. Request for service at 44 W. Main Street, Plainfield, Pennsylvania 17081 is vacant. 12/22/2011 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: Kimberlee K. Behrens, 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 Kimberlee K. Behrens. Request for service at 44 W. Main Street, Plainfield, Pennsylvania 17081 is vacant. 12/22/2011 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: Kimberlee K. Behrens, 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 Kimberlee K. Behrens. Request for service at 98 Cherry Lane, Carlisle, Pennsylvania 17015 the Defendant was not found. 12122/2011 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: Daniel J. Behrens, 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 Daniel J. Behrens. Request for service at 98 Cherry Lane, Carlisle, Pennsylvania 17015 the Defendant was not found. SHERIFF COST: $96.00 December 22, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF !c) irnmtySu!te Shenff. Td e'art "t Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL OIVISlON Plaintiff, NO.: 11-9340-CIVIL vs. MOTION FOR SPECIAL SERVICE ON DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; DEFENDANT PURSUANT TO Defendant(s). Pa.R.C.P. 430 FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PART(: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa. LD. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 Joel A. Ackerman, Esquire Pa. LD. #202729 Ashleigh Levy Marin, Esquire -= Pa. LD. #306799 ,~-, Ralph M. Salvia, Esquire ~~-- - Pa 1.D. #202946 ~ ~"'~---. c~ ~,._.. ~ '` ~ ~ Jaime R. Ackerman, Esquire Pa LD. #311032 - ~~'" _~~ 200 Sheffield Street, Suite 101 ~' A .. c~=~ ._ ,.--., Mountainside, N1 07092 - '~ (908} 233-8500 (908} 233-1390 FAX office@zuckeraoidbera.com File No.: XFP-160651/ns Zucker, Goldberg & Ackerman, LLC XFP-160651 iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, N0.:11-9340-CIVIL vs. DANIEL 1. BEHRENS; KIMBERLEE K. BEHRENS; Defendant(s). MOTION FOR SPECIAL SERVICE PURSUANT TO Pa.R.C.P. 430 AND NOW, comes the Plaintiff, Wells Fargo Bank, N.A., by and through its attorneys, Zucker, Goldberg & Ackerman, LLC, and files the within Motion for Special Service pursuant to Pa.R.C.P. 430 as follows: 1. On or about December 20, 2011, Plaintiff filed its original Complaint in Mortgage Foreclosure ("Complaint") against the Defendants, DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife ("Defendant{s)"), at the above-captioned number and term. 2. Plaintiff directed the Sheriff of Cumberland County to serve Defendant{s} at defendant's last known address being 44 West Main Street, Plainfield, PA17081, but service was returned not found. A true and correct copy of said Return of Service from the Cumberland County Sheriff s Office is marked Exhibit A, attached hereto and made a part hereof. 3. On November 17, 2011 a request for confirmation of an alternate address for .defendant{s) was forwarded by Plaintiffs counsel to the US Postmaster for 44 West Main Street, Plainfield, PA17081, but no such information was provided by said postal authorities. 4. Also, Plaintiff attempted service of the defendants} via certified mail, return receipt to defendant(s) at an alternate address being 54 MAGNOLIA AVE., MAYWOOD, NJ 07607, but certified mail was returned attempted not known. A copy of said return is marked Exhibit B, attached hereto and made a part hereof. 5. On November 17, 2011 a request for confirmation of an alternate address for defendant{s) was forwarded by Plaintiffs counsel to the US Postmaster for 54 MAGNOLIA AVE., MAYWOOD, NJ 07607, but no such information was provided by said postal authorities. 6. Also, Plaintiff attempted service of the defendant(s) via certified mail, return receipt to defendant(s) at an alternate address being 1416 SPRING ST., LITTLE ROCK, AR 72202 ,but certified mail was delivered but resident of address called into office and stated he is not the defendant of the property. A copy of said return is marked Exhibit C, attached hereto and made a part hereof 7. On November 17, 2011 a request for confirmation of an alternate address far defendants} was forwarded by Plaintiffs counsel to the US Postmaster for 1416 SPRING ST., LITTLE ROCK, AR 72202 , but no such information was provided by said postal authorities. 8. An Internet person locator search provided no alternative address for Defendant(s). 9. Plaintiff conducted an investigation to determine the whereabouts of Defendant(s), DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, but all sources indicated no alternative address other than that of the Mortgaged Premises. An affidavit of Plaintiffs counsel regarding the investigation taken to determine the whereabouts of Defendant(s) is marked Exhibit D, attached hereto and made a part hereof. 10. Plaintiff attempted to obtain concurrence of Defendant(s) DANIE! 1. BEHRENS and KIMBERLEE K. BEHRENS with the Motion, but Defendant(s) cannot be located, therefore no concurrence was obtained. 11. There has been no other motion filed in this case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court to permit Plaintiff to serve Defendants}, DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, with the Complaint and Notice of Sale, if necessary, by instructing the Cumberland County Sheriff's Office to POST a copy of same on the Mortgaged Premises, being 44 West Main Street, Plainfield PA 17081 and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service being valid and comolete upon such aostine and mailing in accordance with Pa.R.C.P. 430. ZUCKER GOLDBERG & ACKERMAN, LLC ~` ~ Dated: October I ~ , 2012 BY: - ~ ~ Scott A. Di terick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Flle No.: XFP-160651 (908} 233-8500; (908) 233-1390 FAX E-mail: office@zuckergoldberg.com EXHfBiT A Zucker, Goldberg & Ackerman, LLC XFP-160651 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~ 6~bS ~ Ronny R Anderson sherry ~,vai ~ "~~a ~Jody.S Smfth Chfsf Deputy Richard W Stewart . Soikifor °F~OF~ . .Wells Fargo Bank, NA Cass Number ~• 2011-9340 Daniel J: Behrens (et al.) . SHERIFF'S RETURN OF SERVICE 17122!2019 ••~Ronny R. Arideroon, Sheriff, who being duly swum accordng to law, bt~es that"fie rnade'e diligent search and inquiry for the within named deferxlantto wrt: Daniel J. Behrens; but was unable fo loksita him in hfs balGwick. He therefore returns the within Corr~lafnt in Mortgage For+edosure as not found se to the defendant Daniel J. Behrens: Request for service at M W. Main Street, P1a(nfieid, Pennsylvania 17081 Is vat~urt. 12122/2011 Ronny R. Anderson, Sheriff, who beirq duly sworn acoork~tg to Iaw, states that he made a dipgent search and inquiry for the wthin named defendant to wife Ktrr K Behrens, but was unable fio lok~te her in his bailiwick. He thensfore returns the within Complaint in Mortgage Forecbeure as not found as to the defen~ntlQmberlee fC. Behrens. Request for service at 44 W. Main Stn3et, Plau>field, Pennsylvania 17081 is vacant. 12!2212011 Ronrry R Anderson, Shert'g, who being duly sworn according to~taw, states that he made a diNgent seatCh and inquiry for the within named defendant to wit: Kmberlae K Behrens, but was unable to bkxrte her in his ba~uMk~c. He therefore returns the within Cornplalnt in Mortgage Foreclosure as not found as to the defendant Iamberiee K Behrens. Request for service at 96 Cherry Lane, Cartfsk, Pennsyhrania 17015 the Defendant was not found: 12122/2011 Ronrry R. Anderson, Sheriff, who being duly swum according to law, states that tte made a diigent search and inquiry for the within named defendant to wiL Dental J. Behrens, but was unabb td lokx~te hfin in his bailiwick. He ttrerefore returns the within Complaint in Mort~e Foreclosure as rat ivkmd as to the defendant Danief J. Behrens. Request for service at 88 Cherry Lane, Carlisle, Pennsylvania 17015 the Defendant was net found. SHERIFF COST: 588.00 December 22, 2011 SO ANSWERS, "_ RON R ANDERSON, SHERIFF cap cano~ew Sh«nR tdao~at ak. EXHIBIT 6 Zucker, Goldberg & Ackerman, LLC XFP-160651 ~o~ m N g~ 2 ~ m10 c.. V ~ m N N_ ~ (D y ~7C= v ~ W ~ m _ ~ T ~ = • z Q o m= ox= z ~a~ ~ _ m ~ °m~= m = o s ~ N O rLI /'ww 1 VI _ ~ = w' 3 Tm 0 a ~. _ 1 711E 100E 7275 8021 2518 ~~~ ~~ ! 4 MM1711d0~MN ~ifAr~t N' 1. MWnAMrld~ "~ t ,. ~ ~ . IO~EW.EE K B'E~B1S StWM47p01.tAlWE It10l6f IiA~VIl00D,NJW807-1ff9 ~~ arms nx ~o +z~s e~ tstil-3at R6Ram lHl,Jrrry100{ panrMSlYgrn heap MMLYDIM ''r .~ o Z ~~s N '~ F C ~~ Q- s g ~ - N ~ rn Q T lV r Q '4 = =V~Wo Y1 ~ZQ~ _~ W flJ ` Q' J '7 Z W Z ..o °c = a O p ~-i~0 ~ ~ ~~ ~ W ~ =z3 ~ _ = o~~ w~ortmM ~u+~.n ~ba moa~.r•~ie~ee m~-wsz umr rrz< +oar au xw~sia ~~ I BCtI-lOBL01'N'00t]MAYW ~~ I 3AYYI'1DN~JV1'YM-S t w of srl~aroe r i3urvo Mt h IMF rNMMQ iN~Wtl 'r g 7VNdiNIWD N(t uM~S Y ~ '~V~W~`rMMM'CiAp r ~ It dllwOq MAYlPrI~A~AMC~'0 x""01"' X w+v LhS2 6200 5626 9006 96tG ~~~~~ ~o~wo • r1+ao+Ow«rwuaw~ Y +.am.ow z ~ ?y ~ ' ` ~ }' j I EXHIBIT C Zucker, Goldberg & Ackerman, LLC XFP-160651 fA . ~~G ~ m D m ~ Z W N ~~~ ~ ~~~ w~ N ~~~ _ ..o °' mom= ~, ~ - z .~ O~m~ °o~~ ~~~_ ~a _ ~j y~~~ f1J ~ N m ` m0 ~~ N= ~ ~ ~ = ~ ~ p~j - Qo N LA N ~ L n 5i4'-~. EXHIBIT D Zucker, Goldberg & Ackerman, LLC XFP-160651 IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, N0.:11-9340-CIVIL vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; . Defendant(s). ' AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Ralph M. Salvia, Esquire, attorney far and authorized representative of Plaintiff, who being duly sworn according to law, deposes and says that Plaintiff, or counsel for Plaintiff, conducted an investigation to determine the whereabouts of Defendant{s), which included, but was not limited to searches of the following records: (X) Records of the U.S. Postmaster with results of same attached to the foregoing Motion. (X) Internet Person Locator Records (X) Credit Report Agency. (X) Telephone Directory (X) Records of the County Recorder of Deeds and Prothonotary Finally, Affidavit deposes and says that if Defendant(s) is/are not located at the address uncovered by this investigation, the whereabouts of Defendant(s) is/are unknown to Plaintiff. ZUCKE ~LDBERG ACKERMAN, LLC Dated: October ~ -'~ 2012 By: Sc tt A. ietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A, Ackerman, Esquire; PA I.D. #202729 Ashleigh i.evy Marin, Esquire; PA I.D. #305799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D, #311032 Atty File No.: XFP-160651 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@xuckergoldberg.com (908) 233-8500; (908) Z33-1390 FAX Sworn to and subscribed before me this y of 2012. No Public My Commission Expires: ~ ~'~~"~ COMMONWFAI.TI I OF PF:NNSYI VANIA NOTARIAL S{iAL DENSE L. FOSTEiR. NOTARY ['UBLEC CITY OF HARRISF3URG, DAUI'il1NCOUNTY MY COMMISSION EX['IRES MAKCH (~5, 21113 Page 1 of 5 Lexis Nexis Report for DAVID T PEGG Subject Name: DAVID T PEGG SSN: 153520253 issued in New Jersey between 1972 and 1973 DOB: 8/10/1956 Address: 54 MAGNOLIA AVE MAYWOOD, NJ 07607 Possible AKAs for Subject Name SSN Date of Birth DAVID T PEGG 153520253 8/10/1956 DAVID T PEGG 153520253 /11957 DAVID PEGG 153520253 8/10/1956 T P DAVID 153520253 8/10/1956 DAVIDD T PEGG 153520253 //1957 D PEGG 153520253 //1957 Other SSNs Associated With Subject Name SSN Date of Birth DAVID T PEGG 153520253 8/10/1956 DAVID T PEGG 153520253 //1957 DAVID PEGG 153520253 8/10/1956 T P DAVID 153520253 8/10/1956 DAVVD T PEGG 153520253 //1957 D PEGG 153520253 //1957 Possible Driver Licenses Possible Relatives Relative Name Addresses TERESA M PEGG TERESA M WILSON THERESA PEGG THERESA WILSON .THEODORE E PEGG TED PEGG LOUISE M PEGG LOUISE PEGG JUDITH L PEGG J L PEGG JUDITH L PEGG JUDITH LYNN PEGG JANET LOUISE PEGG J L PEGG file://W:\lb\160651\FC\160651 SKIP Kimberlee 11242011.htm1 10/17/2012 Page 2 of 5 JANET T PEGG Possible Addresses Associated with Subject Date Range Address/Phone ~ 11/1977 - 11!2011 54 MAGNOLIA AVE !, MAYWOOD, NJ 07607 10/1991 - /2002 57$ MAYWOOD AVE MAYWOOD, NJ 07607 4/1977 - 8/1992 215 STONE ST MAYWOOD, NJ 07607 201909$923 8/1990 - 8/1990 815 STOHL MAYWOOD, NJ 07607 11/1987 - 11/1987 91 BLARE CASTLE DR PALM COAST, FL 32137 3864455614 ~ Phone Listings for Subject's Addresses Name Address Phone 54 MAGNOLIA AVE, MAYWOOD, NJ 07607 578 MAYWOOD AVE, MAYWOOD, NJ 07607 j PEREZ ANNA 215 STONE ST, MAYWOOD, NJ 07607 2019098923 815 STOHL , MAYWOOD, NJ 07607 PEGG THEODORE 91 BLARE CASTLE DR, PALM COAST, FL 32137 3864455614 Neighbors Name Address Phone JULIE C BECAN 53 MAGNOLIA AVE, MAYWOOD, NJ 07607 2018438953 DARKEN J BECAN 53 MAGNOLIA AVE, MAYWOOD, NJ 07607 2018438953 JULIE C BECAN 52 MAGNOLIA AVE, MAYWOOD, NJ 07607 CHRISTINA ECOCHARD 56 MAGNOLIA AVE, MAYWOOD, NJ 07607 JOSEPH R BERNAL 56 MAGNOLIA AVE, MAYWOOD, NJ 07607 KAREN L BARNES 56 MAGNOLIA AVE, MAYWOOD, NJ 07607 GLORIA BERNAL 56 MAGNOLIA AVE, MAYWOOD, NJ 07607 2015561690 SARKIS ASHEKIAN SO MAGNOLIA AVE, MAYWOOD, NJ 07607 2018455196 ROSE Z ASHEKIAN 50 MAGNOLIA AVE, MAYWOOD, NJ 07607 201$455196 Possible Reai Property Ownership and Deed Transfers Owner Name: County: Assess State: PA ~~ MONROE UNUSABLE LAND (REMNANT, STEEP, ETC.) file://W:\161160651\FC1160651_SKIP Kimberlee 11242011.htm1 10/17!2012 Page 3 of 5 Parcel Number: 09/18A/2/51 Recorded Date: Short Legal Description: Book: Document Number: page; Situs Address: 54 MAGNOLIA AVE Tax Year: Mailing Address: 54 MAGNOLIA AVE Market Land Value: Assessment Year: Assessed Land Market Value: Improvements: Assessed Total Market Improvements: Value: Total Assessed Value: 1750 Prior Sale Price: Most Recent Sale: 1585 Owner Name: Count},: Assess State: PA Type: Parcel Number: 09/18A/2/52 Recorded Date: Short Legal Description: Book: Document Number: page; Situs Address: 54 MAGNOLIA AVE Tax Year: Mailing Address: 54 MAGNOLIA AVE Market Land Value: Assessment Year: Assessed Land Market Value: Improvements: Assessed Total Market Improvements: Value: Total Assessed Value: 1750 Prior Sale Price: Mast Recent Sale: 1585 HIGH MEADOW DR, E STROUDSBURG PA 18302 Owner Name: ~~~,; Assess State: PA Type: Parcel Number: 09-7315-03 01-1396 Recorded Date: Short Legal Description: Book: Document Number: Page: Situs Address: 54 HIGH MEADOW DR Tax Year: 54 HIGH Market Land file://W:\161160651\FC\160651_SKIP_Kimberlee 11242011.htm1 25 11 1977 832 117 MONROE UNUSABLE LAND {REMNANT, STEEP, ETC.) 25 11 1977 832 115 MONROE VACANT LAND (NEC) 2011 10/17/2012 Page 4 of 5 Mailing Address: MEADOW DR Value: Assessment Year: Assessed Land Market Value: Improvements: Assessed Total Market Improvements: Value: Total Assessed 1750 Prior Sale Price: Value: Most Recent Sale: HIGH MEADOW DR, E STROUDSBURG PA 18302 Owner Name: County: MONROE Assess State: PA Type: VACANT LAND (NEC) Parcel Number: 09-7315-03 01-2434 Recorded Date: Short Legal Book: Description: Document Number: Page: Situs Address: 54 HIGH MEADOW DR Tax Year: 2011 54 HIGH Market Land Mailing Address: MEADOW DR Value: Assessment Year: Assessed Land Market Value: Improvements: Assessed Total Market Improvements: Value: Total Assessed 1750 Prior Sale Price: Value: Most Recent Sale: 54 MAGNOLIA AVE, MAYWOOD NJ 07607 Owner Name: County: BERGEN Assess State: NJ Type: SFR Parcel Number: 34-00119-0000-00014 Recorded Date: 2i 10 1991 Short Legal Book: 7476 Description: Document Number: Page: 571 Situs Address: 54 MAGNOLIA AVE Tax Year: 2010 IViailing Address: 54 MAGNOLIA AVE Market Land Value: 257900 Assessment Year: Assessed Land Market 186800 Value: Improvements: Assessed Total Market Improvements: Value: Total Assessed file://W:\16\160651\FC\160651 SKIP Kimberlee 11242011.html 10/17/2012 Page 5 of 5 Value: 444700 Prior Sale Price: Most Recent Sale: 178000 New Jersey Deed Transfer Records -County Of BERGEN Parcel Number: 3400119000000014 Legal Description: Sale Price: 178000 Loan Amount: 142000 Contract Date: 15 101991 Document Type: Resale/New 1 Construction: Lender: Title Company: Situs Address: Seller(s): JOAN LAROSA Seiler Address: Buyer(s): DAVID PEGG Buyer Address: 578 MAYWOOD AVE MAYWOOD, NJ 07607 485$3322R845045160651:2 0 file:l/W:\16\160651\FC1160651_SKIP_Kimberlee 11242011.htm1 10/17!2012 Page 1 of 5 Lexis Nexis Report for DANIEL JAMES BEHitENS Subject Name: DANIEL JAMES BEHRENS SSN: 197504891 issued in Pennsylvania between 1973 and 1974 DOB; 11/27/1959 Address: p0 BOX 194 PLAINFIELD, PA 17081 Possible AKAs for Subject Name SSN Date of Birth DANIEL JAMES BEHRENS 197504891 11/27/1959 DANIEL J BEHRENS 197504891 11/27/1959 DANIEL BEHRENS 197504891 11/27/1959 DAN BEHRENS 197504891 11/27!1959 DANIEL J BEHRENS 484821104 11/27/1959 Other SSN's Associated With Subject Name SSN Date of Birth DANIEL JAMES BEHRENS 197504891 11/27/1959 DANIEL J BEHRENS 197504891 11/27/1959 DANIEL BEHRENS 197504$91 11/27/1959 DAN BEHRENS 197504891 11/27/1959 DANIEL J BEHRENS 484821104 11/27/1959 Possible Driver Licenses Name: DANIEL J BEHRENS DOB: // DL #: Issue State: Pennsylvania Issue Date: // Expire Date: I/ Height: Weight: Eye Color: Hair Color: Previous DL State: Previous DL #: SSN: 197504891 Possible Relatives Relative Name Addresses KIMBERLEE K BEHRENS KIM BEHRENS KIMBERLEE L BEHRENS filed/W:\1 611 6065 1\FC1160651_SKIP Daniel_11242011.html 10/17/2412 Page Z of 5 KIMBERLEE K BREHRENS KIMBERLEE K BEHRENS KIMBERLEE J BEHRENS KIMBERLE BEHRENS KIMBERLEE BEHRENS KIMBERLEY BEHRENS KIMBERLY BEHERNS DANIEL JAMES BEHRENS DANIEL BEHRANS DANIEL BEHREMS DAN BEHRENS DANIEL J BEHREN ANNJANETTE MARIE BEHRENS ANNJANETTE E BEHRENS ANJANETTE M BEHRENS ANN BEHRENS ANNJANETTE M BEAHRENS ANNJANETTE M BEHRUS ANN M CREWS ANNJANETTE M CREWS AMIJANETTE M BEHRUS ANNAJANETTA BEHRENS DANIEL J BEHRENS DANIEL JAY BEHRENS DANIEL J BEHRENG DANIEL BEHREWS DANIEL DEHRENS JODI RENEE PICKARD JODI RENEE BEHRENS JODI R ROBINSON JODI RENEE MALEY JODI ROBINSON J BEHRENS J PICKAR.D JODI BEHRENS Possible Addresses Associated with Subject Date Range Address/Phone 10/2004 - 11/2011 PO BOX 194 PLAINFIELD, PA 17081 10/2004 - 1112011 PO BOX 46 file://W:\16\160651\FC\160651_SKIP Daniel_11242011.html 10/17/2012 Page 3 of 5 PLAINFIELD, PA 17081 3/2006 - 9/2011 1416 SPRING ST LITTLE ROCK, AR 72202 8/2004 - 9/2011 44 MAIN ST PLAINFIELD, PA 17081 7172268112 1/2009 - 3/2011 98 CHERRY LN CARLISLE, PA 1701 S 7174225701 10/2004 - 1/2007 194 PLAINFIELD, PA 17081 4/2006 - 4/2006 1623 HIGH ST BOILING SPRINGS, PA 17007 ,I 7/1998 - 9!2004 153 D ST CARLISLE, PA 17013 4/2004 - 8/2004 1263 HIGH ST BOILING SPRINGS, PA 17007 7172410660 8/ 1996 -12/2002 14217 ALLAMANDA DR CORPUS CHRISTI, TX 78418 3619491224 10/1991 - 3/1999 29 THOMPSON CREEK DR SHIPPENSBURG, PA 17257 7175307886 12/1998 -12/1998 14250 AVENIDA DE SAN NICO CORPUS CHRISTI, TX 78418 10/1996 - 4/1997 305 WILLOW ST CARLISLE, PA 17013 9/1994 - 9/1994 250 FULTON ST ALAMEDA, CA 94501 10/1978 - 8/1993 291 THOMPSON CREEK DR SHIPPENSBURG, PA 17257 Phone Listings for Subject's Addresses Name Address Phone PO BOX 194 , PLAINFIELD, PA 17081 PO BOX 46 , PLAINFIELD, PA 17081 file://W:\16\160651\FC\160651 SKIP Daniel 11242011.htm1 10/17/2012 Page4of5 1416 SPRING ST, LITTLE ROCK, AR 72202 44 MAiN ST, PLAINFIELD, PA 17081 BEHRENS 98 CHERRY LN, CARLISLE, PA 17015 KIMBERLE 194 , PLAINFIELD, PA 17081 1623 HIGH ST, BOILING SPRINGS, PA 17007 153 D ST, CARLISLE, PA 17013 1263 HIGH ST, BOILING SPRINGS, PA 17007 DILLARD C 14217 ALLAMANDA DR, CORPUS CHRISTI, TX 78418 BEAM ANGELA 29 THOMPSON CREEK DR, SHIPPENSBURG, PA 17257 14250 AVENIDA DE SAN NICO ,CORPUS CHRISTI, TX 78418 305 WILLOW ST, CARLISLE, PA 17013 250 FULTON ST, ALAMEDA, CA 94501 291 THOMPSON CREEK DR, SHIPPENSBURG, PA 17257 7172268112 7174225701 7172410660 3619491224 7175307886 Neighbors Name Address Phone Possible Real Property Ownership and Deed Transfers 44 MAIN ST, PLAINFIELD PA 17081 Owner Name: County: CUMBERLAND Assess State: PA Type: SINGLE FAMILY RESIDENTIAL Pazcel Number: 46-18-1394-0$8 Recorded Date: Short Legal Book: 264 Description: Document Number: Page: 3306 Sites Address: 44 MAIN ST Tax Year: Mailing Address: 44 MAIN ST Market Land Value: Assessment Year: Assessed Land Value: Market Improvements: Assessed Total Mazket Value: Improvements: Total Assessed Value: 127000 Prior Sale Price: Most Recent Sale: 44 MAIN ST, CARLISLE PA 17015 Owner Name: County: CUMBERLAND Assess State: PA Type: RESIDENTIAL {NEC} Parcel Number: 46 1394-0088-0000000- Recorded Date: Short Legal Book: 264 Description: file://W:\16\160651\FC\160651 SKII' Daniel 11242011.htmi 10!17/2012 Page 5 of S Document Number: Situs Address: 44 MAIN ST Mailing Address: 44 MAIN ST Assessment Year: Assessed Land Value: Assessed Improvements: Total Assessed Value: 127000 Most Recent Sale: 485833228845044 160651:1 0 Page: 3306 Tax Year: 20 i 1 Mazket Land Value: 34800 Market Improvements: 92200 Total Market Value: Prior Sale Price: file://W:\i61160651~FC1160651_SKIP Dazuel_11242011,htm1 10/17/2012 a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Plaintiff, DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendant(s). CIVIL DIVISION N0.:11-9340-CIVIL ORDER OF COURT S~- AND NOW, this ~ ~ day of N 0 V , 2012, upon consideration of PlaintifYs Motion for Special Service, it is hereby ORDERED, ADJUDGEp AND DECREED that Plaintiff shalt serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) DANIEL J. BEHRfNS and KIMBERLEE K. BEHRENS, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 44 West Main Street, Plainfield PA 17081, and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service beine valid and comalete upon such gostina and mailing in accordance with Pa R C P 430. BY THE COURT: J. ~w r ~ 7 _. _-, _1~4 ~ ~J ~ 7 ' .. ' _ ~ U%~ 1 V '.'~ C°? 5~ r "~ y° C J .. ~-' f r; -~ i""~~ ~; ~- ~ ,. ~ Ski 11 y ~ 11~~o~--f- ~K ~ C I .~ ~~~rCnS ~P; es ~. /t~ era/~~~i a. ~~ v Zucker, Goldberg & Ackerman, LLC XFP-160651 ~Itit°r~~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY 2 Ronny R Anderson MW �. Sheriff , Jody S Smithaak��r ofa��nf+rr, Chief Deputy - ,° 3-- Richard W Stewart Solicitor Ic „F rkl�: 6yt- fv Wells Fargo Bank, NA vs. Case Number Daniel J. Behrens(et al.) 2011-9340 SHERIFF'S RETURN OF SERVICE 01/16/2013 11:05 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Daniel J. Behrens, pursuant to Order of Court by"Posting"the premises located at 44 W. Main Street, West Pennsboro Township, Plainfield, PA 17081 with a true and correct copy according to law. I CLINE, DEPUTY Z��7 7 01/16/2013 11:05 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Kimberlee K. Behrens, pursuant to Order of Court by"Posting"the premises located at 44 W. Main Street, West Pen boro Township, Plainfield, PA 17081 with a true and correct copy according to law. LL AM CLINE, DEPUTY SHERIFF COST: $62.00 SO ANSWERS, January 17, 2013 RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., ISSUE NO.: 11-9340-CIVIL Plaintiff, TYPE OF PLEADING vs. AFFIDAVIT OF SERVICE OF DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; COMPLAINT PURSUANT TO Pa.R.C.P.,430 SPECIAL ORDER Defendants. OF COURT CODE: 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 Levy 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@zuckergoldberg.com File No.:XFP-160651/emed cn u —c t >(-, • ter;# IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 11-9340-CIVIL DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendants. AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT I,Scott A. Dietterick, Esquire,attorney for Plaintiff,Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Complaint in Mortgage Foreclosure on Defendant,, as follows: 1. On or about November 21,2012,an Order of Court was entered granting Plaintiffs Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit"A",attached hereto and made a part hereof. 2. Pursuant to said Order,on or about January 15, 2013,Zucker,Goldberg&Ackerman, LLC,the counsel for Plaintiff served Defendants,with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure,via First Class U.S. Mail to the defendant's last known address being 44 West Main Street, Plainfield, PA 17081. A true and correct copy of certificate of mailing are marked Exhibit "B",attached hereto and made a part hereof. 3. Pursuant to said Order,on or about January 18, 2013,Zucker,Goldberg&Ackerman, LLC,the counsel for Plaintiff served Defendants,with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure,via Certified Mail, Return Receipt Requested to the defendant's last known address being 44 West Main Street, Plainfield, PA 17081. A true and correct copy of certificate of mailing are marked Exhibit"C",attached hereto and made a part hereof. 4. Pursuant to said Order,on or about January 16, 2013,the Sheriff of Cumberland County posted the property subject to the Mortgage, being 44 West Main Street, Plainfield, PA 17081 with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure. A true and correct copy of the Service Form from the Cumberland County Sheriffs Office is marked Exhibit"D",attached hereto and made a part hereof. ■ ZUCKER,GO : ' �1� •MAN, LLC i.41 Dated: + 0 t By: I Scott A. D - -rick, Esquire; PA I.D.#55650 Kimberly , :•nner, Esquire; PA I.D.#89705 Joel A.Ac - an, Esquire; PA I.D.#202729 Ashleigh Levy 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-160651 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 Email: Office @zuckergoldberg.com (908)233-8500; (908)233-1390 FAX Sworn to and subscribed before me this 3C' day of O C I y , 2013/■_ ( /Lt.., Notary Pub c MY COMMISSION EXPIRES: Cheryl Debeneadto Notary PubIIC My Comm. Ypir?s Oct. 16,2018 Ii) T# 2280276 State of New Jersey EXHIBIT A • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,NA CIVIL DIVISION • Plaintiff, NO.:11-9340-CIVIL DANIELI.BEHRENS;KIMBERLEE K.BEHRENS; Defendant(s). ORDER OF COURT AND NOW,this - / day of d. ,2012,upon consideration of Plaintiffs Motion for Special Service,it is hereby ORDERED,ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foredosure and Notice of Sale,if necessary,on Defendant(s) DANIELJ.BEHRENS and KIM BERLEE K.BEHRENS,by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 44 West Main Street, Plainfield PA 17081, and by mailing a copy,via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P.430. BY THE COURT: • J. MCP ter' COr- -< ar Fr =Q C)C7 T• C) D N iE? C.11 Zucker,Goldberg&Ackerman,LLC XFP-160651 EXHIBIT B 1,-Al> 2 � �,,� m ,cam .�� . e- `` - 7Fyazxsx s�.'. UNITED STATES -,14 01 POSTAL 1.'V10E . .4 This Ctrtdkate of Malting provides evidence that mat his been presented toUSPSa for mailing.This rams and international mall F`°° Scott A.Dietterick,Esquire c/a Zucker,Goldberg&Ackerman,LLC ,.;, t ' 200 Sheffield Street,Suite 101n Mountainside, NJ 07092 'Ld *.,,,, XFP-16 ;1/jab T B Q ID' DANIEL rk Here aANIEL J.BEHRENS F Post 44 West Main Street Plainfield, PA 17081 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000.9065 UNITED STATES POSTAL E 4 .SERVICE® 1 "23 ;;, E 9.2 Thistetemcete of Melling provides evidence that mail has been presented to LISPS'for mailing.This form ma} ` end international mail ..From: Scott A.Dietterick, Esquire tv c/a Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 , Mountainside, NJ 07092 \‘-•� XFP-160651/Ak TEAM 8 s To: KIMBERLEE K. BEHRENS Postmark Here 44 West Main Street Plainfield, PA 17081 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 EXHIBIT C �- a» / . \ - : § — # \ ° & S ƒ 2 s �e Vie-fa 1 * , $- ' A » % Q� 3 G % s_ s% _ _ k%a \a \ � / & as G k o 3 =3« ® ® t ƒus0 , \ k=' k 0 ir �� \ t Ve , t VII' r-- R C v j: alt in V) ri 1+! • 1 N Q. = O t91 �cn rt p�t,00 � _ r =Z h •t .eFN i �� =m mZ 6a 1- -aa- _ H _ c r =Y4d Z °- W C - _ i U J • Li- EXHIBIT D SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff rot Oltnotri Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE of THE$hERIFF Wells Fargo Bank,NA Case Number vs. 2011-9340 Daniel J. Behrens(et al.) SHERIFF'S RETURN OF SERVICE 01/16/2013 11:05 AM-Deputy William Cline,being duly sworn according to law,served the requested Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Daniel J.Behrens,pursuant to Order of Court by"Posting"the premises located at 44 W.Main Street,West Pennsboro Township,Plainfield, PA 17081 with a true and correct copy according to law. f •`CLINE,DEPUTY 01/16/2013 11:05 AM-Deputy William Cline,being duly sworn according to law,served the requested Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Kimberlee K.Behrens,pursuant to Order of Court by"Posting"the premises located at 44 W.Main Street,West Pen boro Township,Plainfield, PA 17081 with a true and correct copy according to law. J/ / r ir LFAM CLINE, DEPUTY • SHERIFF COST:$62.00 SO ANSWERS, January 17,2013 RONNY R ANDERSON,SHERIFF • ic)Counwsuke sheriff.Te4eoso8.Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAI A.. . =JC7 11 v TAR`f Wells Fargo Bank, N.A. CIVIL DIVISION _r f k ?7a _ 1 , : Plaintiff, NO.: 11-9340-CIVIL I ,xr it . ,l(e �� vs. ',::.:31 LH 3YLVAM1A DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendants. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s),for failure to file a response to Plaintiffs Complaint within the appropriate time limits from service thereof,and assess Plaintiffs damages as set forth in Complaint: Amount as set forth in Complaint $142,447.31 plus interest on the judgment amount($142,447.31)from November 17,2011,at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 44 West Main Street 44 West Main Street address is: Plainfield, PA 17081 Plainfield, PA 17081 ZUCKER, GOLBERG &ACKERMAN, LLC Dated: 8/7/i& BY: it I A 1 II 0 Joel .'•'c -r an, Esquire; 'A I.D.#202729 a Ashleigh L. Marin, Esquire; PA I.D.#306799 n Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-160651 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com DAMAGES ARE HE EBY ASSESSED AS INDICATED 417) Date 1 .,.> Prothonotary a l,u+ te46' ' t. CIL/4 S I, E-(6, f ?9?999 th Haste( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, ' NO.: 11-9340-CIVIL vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; •• Defendants. • • AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge,information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ZUCKER, GOLBERG &ACKERMAN, LLC Dated: /1/7/13 BY: a4Mak Pa Joel A.Ackerman, Esquire; I.D.#202729 j" Ashleigh L. Marin, Esquire; PA I.D.#306799 El Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-160651 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com Sworn to and subscribed before me This day of /0,t, , 20 13 / , Notary Publi a My Commission Expires: Cheryl Debeneadto Notary Public My Comm. Expires Oct. 16, 2016 State of NewOJersey Zucker,Goldberg&Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 11-9340-CIVIL • • DANIEL J.BEHRENS KIMBERLEE K.BEHRENS • Defendant. • • • IMPORTANT NOTICE TO: DANIEL J.BEHRENS 44 West Main Street Plainfield,PA 17081 DATE OF NOTICE: 5/13/2013 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 Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, vs. NO.: 11-9340-CIVIL DANIEL J.BEHRENS KIMBERLEE K.BEHRENS • Defendant. • • AVISO IMPORTANTE TO: DANIEL J.BEHRENS 44 West Main Street Plainfield,PA 17081 FECHA DEL AVISO:5/13/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXLMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO DNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS LMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INIVIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFIC NA ABAJO INDICADA PARA QUE LE INFORMEN 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: Salt A. D iette-ICjc Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 11-9340-CIVIL • DANIEL J. BEHRENS • KIMBERLEE K. BEHRENS • Defendant. • • • • • • IMPORTANT NOTICE TO: KIMBERLEE K.BEHRENS 44 West Main Street Plainfield,PA 17081 DATE OF NOTICE: 5/13/2013 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 Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 11-9340-CIVIL DANIEL J. BEHRENS KIMBERLEE K.BEHRENS • Defendant. • • • • AVISO IMPORTANTE TO: KIMBERLEE K.BEHRENS 44 West Main Street Plainfield,PA 17081 FECHA DEL AVISO:5/13/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXEMOS 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 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYERREFERRAL 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: ScXtt A. DIE eddc Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55550 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 160651 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA • IN RE: : CHAPTER 7 DANIEL JAMES BEHRENS AKA BEHR COUNTRY . CANDLES&KIMBERLEE KAREN BEHRENS : CASE NO.: 11-bk-08544-RNO Debtors. • • • WELLS FARGO BANK, NA • Movant. • and • DANIEL JAMES BEHRENS AKA BEHR COUNTRY . CANDLES& KIMBERLEE KAREN BEHRENS,and . LEON P.HALLER,CHAPTER 7 TRUSTEE, Respondents ORDER OF COURT AND NOW,to wit,this 17th day of February ,201 2 , upon consideration of the Motion for Relief from the Automatic Stay filed by Wells Fargo Bank, NA , it is hereby ORDERED, ADJUDGED AND DECREED, that the Motion is granted and that the Automatic Stay be and hereby is terminated as it affects the interest of Wells Fargo Bank, NA in and to the Real Property of the Debtor located at 44 West Main Street, Plainfield, PA 17081. By the Court, Dated: February 17,2012 " Robert N.Opel,II,Bankruptcy Judge Case 1:11-bk-08544-RNO Doc 16 Filed 02/17/12 Entered 02/17/12 08:33:36 Desc Main Document Page 1 of 1 • Notice Recipients District/Off:0314-1 User:BComiskey Date Created:2/17/2012 Case: 1:11—bk-08544—RNO Form ID:pdf010 Total:2 Recipients submitted to the BNC(Bankruptcy Noticing Center): db Daniel James Behrens 707 Opossum Lake Road Carlisle,PA 17015 jdb Kimberlee Karen Behrens 707 Opossum Lake Road Carlisle,PA 17015 TOTAL:2 Case 1:11-bk-08544-RNO Doc 16-1 Filed 02/17/12 Entered 02/17/12 08:33:36 Desc PDF - All Chatty: Notice Recipients Page 1 of 1 • • Results as of:Oct-01-2013 01:32:40 Department of Defense Manpower Data Center SCRA 3.0 b 3fl ,. ' 4 —r Statms Report Pursuant to Service ivil Relief Act Last Name: BEHRENS First Name: DANIEL Middle Name: J Active Duty Status As Of: Oct-01-2013 /`\ / / 3 00A09 nutypn pave 64-yStatus%iT2et*, 4 * " j*E - , NA This response refl-,ptv,„4".,,,..,,,,--- k.,..,.,f,,,'a4tnFel'fy 1;a1t P ad - .e talus Date ... NA.:-. A , ... & .`"„' ` , ff Status Date This response reflects�� indflndual left achve�� o-, 7�1ays preced"tt�g the ,u tY ”'q --;'.'"7:t:,-- : i ' ' ft t [r104w t,ji ttat'Wit aS4taied of a Future tJp A tva;r" + ' St tam tlanEndt7at :,.,$to.a, .,_ _ ;. , � This response reflects whether , 1islber unit has rec„_ z .-• to report for active duty Upon searching the data banks of the Department of Defense Manpower t r,bed on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. our, • Yk - Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)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 Servicemembers 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 only 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 was on active duty for the active duty status date,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.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 84MCQ9BCC065D20 Results as of:Oct-01-2013 01:34:31 Department of Defense Manpower Data Center SCRA 3.0 4 , _ Status Report t., Pursuant to Servieenienibers Civil Relief Acr Last Name: BEHRENS First Name: KIMBERLEE Middle Name: K Active Duty Status As Of: Oct-01-2013 X e a A ® Sfiatu Data AcEtve D dy Eru[ NA NA s This response ref �g r• -ts'aoLve 4tkty otetu$bafpd On w- � tatus Date DG{ty111{XG16e5fAYdive� • �, - t ., r t NA NA •y NA ha '' ..o. '; This response reflects£' mdtvidual left ach '� ays precedir th g ty Status Date : .\ a v Ut1Et Was N 9ed 'eta Future CalkIli oA J, Te Member o eter S -'NRdfloa Stattpate" Order No6ftC*d0fl End D$ r ' `" &fatUS Servlca 4" t c NA NA This response reflects whether ld pr unit has receiiy /to report for active duty 1, _. Upon searching the data banks of the Department of Defense Manpower Liata a :i.ased on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. yiti • —A01.4 iPdmi • a' r Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DOD)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 Servicemembers 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 only 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 was on active duty for the active duty status date,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/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(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). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: O4CA99ECU090JDO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • • vs. NO.: 11-9340-CIVIL• DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; •• • • Defendants. • • • NOTICE OF ORDER, DECREE OR JUDGMENT TO: DANIEL J. BEHRENS 44 West Main Street Plainfield, PA 17081 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order Decree or Judgment was entered in the above captioned proceeding on 1``g I 13 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows:$142,447.31 plu osts. hone . Zucker,Goldberg&Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. : NO.: 11-9340-CIVIL DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; • Defendants. • NOTICE OF ORDER, DECREE OR JUDGMENT TO: KIMBERLEE K. BEHRENS 44 West Main Street Plainfield, PA 17081 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on \Ae 113 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $142,447.31 plus costs. • e otary Zucker,Goldberg&Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A., ISSUE NO.: 11-9340-CIVIL Plaintiff, TYPE OF PLEADING vs. AFFIDAVIT OF SERVICE OF DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; COMPLAINT PURSUANT TO Pa.R.C.P.,430 SPECIAL ORDER Defendants. OF COURT CODE: 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 Levy 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@zuckergoldberg.com File No.:XFP-160651/emed IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, NO.: 11-9340-CIVIL vs. DANIEL J. BEHRENS; KIMBERLEE K.BEHRENS; Defendants. • AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT I,Scott A.Dietterick, Esquire,attorney for Plaintiff,Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Complaint in Mortgage Foreclosure on Defendant,, as follows: 1. On or about November 21,2012,an Order of Court was entered granting Plaintiffs Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit"A",attached hereto and made a part hereof. 2. Pursuant to said Order,on or about January 15,2013,Zucker,Goldberg&Ackerman, LLC,the counsel for Plaintiff served Defendants, with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure,via First Class U.S.Mail to the defendant's last known address being 44 West Main Street,Plainfield, PA 17081. A true and correct copy of certificate of mailing are marked Exhibit "B",attached hereto and made a part hereof. 3. Pursuant to said Order,on or about January 18,2013,Zucker,Goldberg&Ackerman, LLC,the counsel for Plaintiff served Defendants, with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure,via Certified Mail, Return Receipt Requested to the defendant's last known address being 44 West Main Street, Plainfield,PA 17081. A true and correct copy of certificate of mailing are marked Exhibit"C",attached hereto and made a part hereof. 4. Pursuant to said Order,on or about January 16,2013,the Sheriff of Cumberland County posted the property subject to the Mortgage,being 44 West Main Street, Plainfield, PA 17081 with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure. A true and correct copy of the Service Form from the Cumberland County Sheriffs Office is marked Exhibit"D",attached hereto and made a part hereof. 4 ZUCKER,GO • : ' o�: :•MAN,LLC iiill-- Dated: 10 W �� By: Al �� Scott A.D e -rick, Esquire; PA I.D.#55650 Kimberly •. B•nner, Esquire; PA I.D.#89705 Joel A.Ac e• an,Esquire; PA I.D.#202729 Ashleigh Levy 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-160651 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908)233-8500;(908)233-1390 FAX Sworn to and subscribed before me this 3 V day of O C(,2013 ()i Notary Pub c MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm.Expires Oct. 16,2076 ID#2280276 State of New Jersey EXHIBIT A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,NA CIVIL DIVISION Plaintiff, NO.:11-9340-CIVIL vs. DANIEL!.BEHRENS;KIMBERLEE K.BEHRENS; Defendant(s). ORDER OF COURT AND NOW,this -a day of ?`!LO'd ,2012,upon consideration of Plaintiffs Motion for Special Service,-it is hereby ORDERED,ADJUDGED AbiD DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale,if necessary,on Defendant(s)DANIEL).BEHRENS and KIMBERLEE K.BEHRENS,by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises,being 44 West Main Street, Plainfield PA 17081, and by mailing a copy,via Certified Mail, no signature required and First Class U.S. Mail,Postage Prepaid, with said service being valid and complete upon such posting and mailinng in accordance with Pa.R.C.P.430. BY THE COURT: 51 (74. X J. • MC° m- z. c r corm - at .. Dc" =- MO C:;C. • --t N) �} • Zucker,Gaidberg&Adcerman,LI.0 XFP-160651 EXHIBIT B ''uNiroos' TES 01 AS • POST- S R � � .. • • liiii,4 3Qntao 004p.4 4#*:0*)knxthalegil 4.x1.6 pmcnuitio4 .i fofPJ►Ip ig Thhfg.Fl •Md.iirteraatiQriiltnll:: .. ... fo• Scott A.Dietterick;i squire= c/a Zucker,Goldberg.;&Ackerman,.LLG • • Ufl Stiefeld'Street,Suite ?1. Mountainside,NJ 009 ! XFP15w t 3f Ei.T B • • 'fob �: str) Here; DANIELI,BE#iRE�fS Pa -.._...... �.K 44•West Main:Street • Plainfield,PA 008 county of:P.Q ,.CU,M$ERLAND_ :.....,::::. F5 Fozm 3$17,.A04 00:4- T+t'$1. 0==004,065 • • • • • • weadeautuar • POSTAL SERVICE ifl ryW iY 4 +YYy 'try 44AmpLFROfil ZIPG4L ETI•M 'Tti7tYkiikvfmk,®ngprrn&[esavWeh4014:ii7eil M1sbeelrPAoEn{Ad • • and.in�srnaWnat m��.; ' Scott A Diettertck,Esquire c/o Zucker.,.Goidber.8.'&Ackerman;'LLC ZOO Shef ield:Street,j5tirte.10 ,t Mbu ttainsirle �1! 07092 . is kkidtotAij 1C1N!BE'RLEe K.ISEHREN5 -Pbstm2rk 4e(B. 44 West M:ait.Street Plainfield,PA 17081 County ofPQ CUMBERLAND FSFOmI:a13 ,Apti12007`PSN7530=02.00&9065: • EXHIBIT C • • • M. rF: O .' S. a 1 co ' 2 S �a: ` Se " k . r V' ...... �y c s ter.. Ry5�1 '� ti - V',wsr� v a _---- ‘A P: i N 1 VVVVV R c T it d ..., . • C0 w =--. o - - a. M M 1491 a - 1, �Z N H'ytHH • ..„.... �N _mina r p o _ `. ti w m -:1a z w _ CZ M1 -Yva x U z - U i a • 1g 6�p o . r 'z $&i igl O EXHIBIT D coO ■ \ SHERIFF'S OFFICE OF CUMBERLAND COUNTY 'Ronny R Anderson Sheriff - Jody S Smith G„utn at LeluiGr�fd • Chief Deputy • 6,. : • Richard W Stewart • S o l i c i t o r orFim or.xe shERRIFF • • Wells Fargo Bank,NA vs. Case Number Daniel J.Behrens(et al.) • 2011-9340 SHERIFF'S RETURN OF SERVICE - 01/16/2013 11:05 AM-Deputy William Cline,being duly sworn according to-law,served the requested Complaint in Mortgage Foreclosure upon the within named Defendant,-to wit Daniel J.Behrens,pursuant to Order of Court by°Posting"the premises located at 44 W.Main Street,West Pennsboro Township,Plainfield,PA 17081 with a true and correct copy according to law. • ' - • V • • t - r i' "-CLINE,DE'UTY 01/16/2013 11:05 AM-Deputy-William Cline,being duly sworn according to law,served the requested Complaint in • Mortgage Foreclosure upon the within named Defendant,to wit IGmberlee K.Behrens,pursuant to Order of Court by"Posting"the premises located at 44 W.Main Street,West Pen •oro Township;Plainfield, PA 17081 with a true and correct copy according to law. - • /. — . - ■• IAM CLINE, DEPUTY SHERIFF COST:$62.00 SO ANSWERS, January 17,2013 RONR ANDERSON;SHERIFF V - • • • • (a)CountAu0.o Sheriff.Telecsof.Inc. - 20141-1#1 41110: S9 CfNEcf,' AND PENMSYL Q(1Nr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Wells Fargo Bank, N.A., Plaintiff, vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendants. TO THE PROTHONOTARY OF THE SAID COURT: File No. Amount Due 11 -9340 -CIVIL $142,447.31 Interest from 11/18/2011 to date of sale Costs $17,482.80 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 cutif fi sOpd 111, Vg...gg (D2.60 -.a6 ((/-SO `` 4 gbg...is (I II <. 400 )1Aav4i-(fic 07 Zit-SNP/4 so Lc - Zucker, Goldberg & Ackerman, LLC XFP-160651 n or- 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: zlia 41,1D [4 - Signature: CaLA Print Name: Scott A. Dietterick, Esquire Kimberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh Levy Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, 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.: 55650 89705 202567 201493 202946 Zucker, Goldberg & Ackerman, LLC XFP-160651 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE VILLAGE OF PLAINFIELD, TOWNSHIP OF WEST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE CARLISLE-NEWVILLE STATE ROAD, PENNSYLVANIA ROUTE 641, AT THE CORNER OF LAND FORMERLY OF REBECCA AND ELIZABETH BEAR; THENCE BY THE SAME, SOUTH EIGHTEEN AND THREE-FOURTHS DEGREES WEST (S 18 3/4°W), FOR A DISTANCE OF TWO HUNDRED SIXTEEN FEET SIX INCHES (216'6") TO A POST; THENCE BY THE SAME, SOUTH ONE AND THREE-FOURTHS DEGREES WEST (S 01 3/4°W) FOR A DISTANCE OF TWENTY-EIGHT FEET THREE INCHES (28'3") TO A POINT IN THE CENTER OF A PUBLIC ALLEY; THENCE BY THE CENTERLINE OF SAID PUBLIC ALLEY, NORTH EIGHTY-SIX AND ONE-HALF DEGREES WEST (N 86 1/2° W) FOR A DISTANCE OF THIRTEEN FEET FIVE INCHES (13' 5") TO A POINT; THENCE BY LAND NOW OR FORMERLY OF IMA C. MEYERS, NORTH TWO AND THREE-FOURTHS DEGREES EAST (N 02 3/4° E), FOR A DISTANCE OF ONE HUNDRED EIGHTY-THREE FEET FIVE INCHES (183'5") TO A POST; THENCE BY THE SAME NORTH EIGHTEEN DEGREES EAST (N 18° EAST) FOR A DISTANCE OF SEVENTY-ONE FEET THREE INCHES (71' 3") TO A POINT IN THE CENTER OF SAID PENNSYLVANIA ROUTE 641; THENCE BY THE CENTERLINE OF SAID PENNSYLVANIA ROUTE NO. 641, SOUTH SEVENTY-ONE DEGREES EAST (S 71° E) FOR A DISTANCE OF FIFTY-SIX FEET (56') TO A POINT, SAID POINT MARKING THE PLACE OF BEGINNING). BEING IMPROVED WITH A BUILDING FORMERLY KNOWN AS THE REFORMED MENNONITE CHURCH OF PLAINFIELD, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 44 West Main Street, Plainfield, PA, 17081. BEING the same premises which JONATHAN G. RITCHEY AND SHERRI M. RITCHEY, HIS WIFE, by Deed dated August 6, 2004 and recorded August 11, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 264, Page 3306, granted and conveyed unto DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. Tax Map No.: 18-1394-0088-0000000-46. Zucker, Goldberg & Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendant(s). : CIVIL DIVISION NO.: 11 -9340 -CIVIL 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 44 West Main Street, Plainfield, PA 17081. 1. Name and Address of Owner(s) or Reputed Owner(s): DANIEL J. BEHRENS AND KIMBERLEE K. BEHRENS, HIS WIFE 44 West Main Street Plainfield, PA 17081 2. Name and Address of Defendant(s) in the Judgment: DANIEL J. BEHRENS 44 West Main Street Plainfield, PA 17081 KIMBERLEE K. BEHRENS 44 West Main Street Plainfield, PA 17081 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 MITCHELL GELBAUGH/HEATHER BARBOUR 1137 Shannon Lane Carlisle, PA 17013 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff Zucker, Goldberg & Ackerman, LLC XFP-160651 MERS AS NOMINEE FOR WCS LENDING, LLC 6501 Congress Ave., 3rd Floor, Boca Raton, FL 33487 AND PO Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees Street, Suite C Danville, II 61834 AND 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 44 West Main Street Plainfield, PA 17081 UNKNOWN SPOUSE 44 West Main Street Plainfield, PA 17081 Zucker, Goldberg & Ackerman, LLC XFP-160651 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. Dated: .4l0-h7'4- 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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-160651/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-160651 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE VILLAGE OF PLAINFIELD, TOWNSHIP OF WEST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE CARLISLE-NEWVILLE STATE ROAD, PENNSYLVANIA ROUTE 641, AT THE CORNER OF LAND FORMERLY OF REBECCA AND ELIZABETH BEAR; THENCE BY THE SAME, SOUTH EIGHTEEN AND THREE-FOURTHS DEGREES WEST (S 18 3/4°W), FOR A DISTANCE OF TWO HUNDRED SIXTEEN FEET SIX INCHES (216'6") TO A POST; THENCE BY THE SAME, SOUTH ONE AND THREE-FOURTHS DEGREES WEST (S 01 3/4°W) FOR A DISTANCE OF TWENTY-EIGHT FEET THREE INCHES (28'3") TO A POINT IN THE CENTER OF A PUBLIC ALLEY; THENCE BY THE CENTERLINE OF SAID PUBLIC ALLEY, NORTH EIGHTY-SIX AND ONE-HALF DEGREES WEST (N 86 1/2° W) FOR A DISTANCE OF THIRTEEN FEET FIVE INCHES (13' 5") TO A POINT; THENCE BY LAND NOW OR FORMERLY OF IMA C. MEYERS, NORTH TWO AND THREE-FOURTHS DEGREES EAST (N 02 3/4° E), FOR A DISTANCE OF ONE HUNDRED EIGHTY-THREE FEET FIVE INCHES (183'5") TO A POST; THENCE BY THE SAME NORTH EIGHTEEN DEGREES EAST (N 18° EAST) FOR A DISTANCE OF SEVENTY-ONE FEET THREE INCHES (71' 3") TO A POINT IN THE CENTER OF SAID PENNSYLVANIA ROUTE 641; THENCE BY THE CENTERLINE OF SAID PENNSYLVANIA ROUTE NO. 641, SOUTH SEVENTY-ONE DEGREES EAST (S 71° E) FOR A DISTANCE OF FIFTY-SIX FEET (56') TO A POINT, SAID POINT MARKING THE PLACE OF BEGINNING). BEING IMPROVED WITH A BUILDING FORMERLY KNOWN AS THE REFORMED MENNONITE CHURCH OF PLAINFIELD, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 44 West Main Street, Plainfield, PA, 17081. BEING the same premises which JONATHAN G. RITCHEY AND SHERRI M. RITCHEY, HIS WIFE, by Deed dated August 6, 2004 and recorded August 11, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 264, Page 3306, granted and conveyed unto DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. Tax Map No.: 18-1394-0088-0000000-46. Zucker, Goldberg & Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Plaintiff, Defendants. CIVIL DIVISION NO.: 11 -9340 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 KIMBERLEE K. BEHRENS 44 West Main Street Plainfield, PA 17081 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on September 3, 2014 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: 44 West Main Street, Plainfield, PA, 17081 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11 -9340 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Zucker, Goldberg & Ackerman, LLC XFP-160651 DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife 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 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 Sheriff's 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 Zucker, Goldberg & Ackerman, LLC XFP-160651 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. Dated: Li. / s 1 ( j ZUCKER, GOLDBERG & ACKERMAN, LLC BY: Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-160651/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA FILED ORDER OR COURT. Zucker, Goldberg & Ackerman, LLC XFP-160651 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE VILLAGE OF PLAINFIELD, TOWNSHIP OF WEST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE CARLISLE-NEWVILLE STATE ROAD, PENNSYLVANIA ROUTE 641, AT THE CORNER OF LAND FORMERLY OF REBECCA AND ELIZABETH BEAR; THENCE BY THE SAME, SOUTH EIGHTEEN AND THREE-FOURTHS DEGREES WEST (S 18 3/4°W), FOR A DISTANCE OF TWO HUNDRED SIXTEEN FEET SIX INCHES (216'6") TO A POST; THENCE BY THE SAME, SOUTH ONE AND THREE-FOURTHS DEGREES WEST (S 01 3/4°W) FOR A DISTANCE OF TWENTY-EIGHT FEET THREE INCHES (28'3") TO A POINT IN THE CENTER OF A PUBLIC ALLEY; THENCE BY THE CENTERLINE OF SAID PUBLIC ALLEY, NORTH EIGHTY-SIX AND ONE-HALF DEGREES WEST (N 86 1/2° W) FOR A DISTANCE OF THIRTEEN FEET FIVE INCHES (13' 5") TO A POINT; THENCE BY LAND NOW OR FORMERLY OF IMA C. MEYERS, NORTH TWO AND THREE-FOURTHS DEGREES EAST (N 02 3/4° E), FOR A DISTANCE OF ONE HUNDRED EIGHTY-THREE FEET FIVE INCHES (183'5") TO A POST; THENCE BY THE SAME NORTH EIGHTEEN DEGREES EAST (N 18° EAST) FOR A DISTANCE OF SEVENTY-ONE FEET THREE INCHES (71' 3") TO A POINT IN THE CENTER OF SAID PENNSYLVANIA ROUTE 641; THENCE BY THE CENTERLINE OF SAID PENNSYLVANIA ROUTE NO. 641, SOUTH SEVENTY-ONE DEGREES EAST (S 71° E) FOR A DISTANCE OF FIFTY-SIX FEET (56') TO A POINT, SAID POINT MARKING THE PLACE OF BEGINNING). BEING IMPROVED WITH A BUILDING FORMERLY KNOWN AS THE REFORMED MENNONITE CHURCH OF PLAINFIELD, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 44 West Main Street, Plainfield, PA, 17081. BEING the same premises which JONATHAN G. RITCHEY AND SHERRI M. RITCHEY, HIS WIFE, by Deed dated August 6, 2004 and recorded August 11, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 264, Page 3306, granted and conveyed unto DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. Tax Map No.: 18-1394-0088-0000000-46. Zucker, Goldberg & Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA Plaintiff, vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendant(s). Sefr- AND NOW, this —44 day of CIVIL DIVISION NO.: 11 -9340 -CIVIL ORDER OF COURT /Gol) • , 2012, upon consideration of Plaintiffs Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) DANIEL J. BEHRENS and KIM BERLEE K. BEHRENS, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 44 West Main Street, Plainfield PA 17081, and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 430. BY THE COURT: r s� `7'1. X, J. Zucker, Goldberg & Ackerman, I.LC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendants. CIVIL DIVISION NO.: 11 -9340 -CIVIL -- rico Fri NOTICE OF SHERIFF'S SALE U, OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 -� rte, 0 DANIEL J. BEHRENS , 44 West Main Street r-) Plainfield, PA 17081 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on September 3, 2014 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: 44 West Main Street, Plainfield, PA, 17081 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 11 -9340 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife Zucker, Goldberg & Ackerman, LLC XFP-160651 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 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 Sheriff's 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 Zucker, Goldberg & Ackerman, LLC XFP-160651 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. Dated: 4/(2.40_,e q- 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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-160651/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA FILED ORDER OR COURT. Zucker, Goldberg & Ackerman, LLC XFP-160651 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE VILLAGE OF PLAINFIELD, TOWNSHIP OF WEST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE CARLISLE-NEWVILLE STATE ROAD, PENNSYLVANIA ROUTE 641, AT THE CORNER OF LAND FORMERLY OF REBECCA AND ELIZABETH BEAR; THENCE BY THE SAME, SOUTH EIGHTEEN AND THREE-FOURTHS DEGREES WEST (S 18 3/4°W), FOR A DISTANCE OF TWO HUNDRED SIXTEEN FEET SIX INCHES (216'6") TO A POST; THENCE BY THE SAME, SOUTH ONE AND THREE-FOURTHS DEGREES WEST (S 01 3/4°W) FOR A DISTANCE OF TWENTY-EIGHT FEET THREE INCHES (28'3") TO A POINT IN THE CENTER OF A PUBLIC ALLEY; THENCE BY THE CENTERLINE OF SAID PUBLIC ALLEY, NORTH EIGHTY-SIX AND ONE-HALF DEGREES WEST (N 86 1/2° W) FOR A DISTANCE OF THIRTEEN FEET FIVE INCHES (13' 5") TO A POINT; THENCE BY LAND NOW OR FORMERLY OF IMA C. MEYERS, NORTH TWO AND THREE-FOURTHS DEGREES EAST (N 02 3/4° E), FOR A DISTANCE OF ONE HUNDRED EIGHTY-THREE FEET FIVE INCHES (183'5") TO A POST; THENCE BY THE SAME NORTH EIGHTEEN DEGREES EAST (N 18° EAST) FOR A DISTANCE OF SEVENTY-ONE FEET THREE INCHES (71' 3") TO A POINT IN THE CENTER OF SAID PENNSYLVANIA ROUTE 641; THENCE BY THE CENTERLINE OF SAID PENNSYLVANIA ROUTE NO. 641, SOUTH SEVENTY-ONE DEGREES EAST (5 71° E) FOR A DISTANCE OF FIFTY-SIX FEET (56') TO A POINT, SAID POINT MARKING THE PLACE OF BEGINNING). BEING IMPROVED WITH A BUILDING FORMERLY KNOWN AS THE REFORMED MENNONITE CHURCH OF PLAINFIELD, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 44 West Main Street, Plainfield, PA, 17081. BEING the same premises which JONATHAN G. RITCHEY AND SHERRI M. RITCHEY, HIS WIFE, by Deed dated August 6, 2004 and recorded August 11, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 264, Page 3306, granted and conveyed unto DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. Tax Map No.: 18-1394-0088-0000000-46. Zucker, Goldberg & Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. DANIELJ. BEHRENS; KIMBERLEE K. BEHRENS; Defendant(s). Si— AND NOW, this -1 day of NO.: 11-9340-CIVIL ORDER OF COURT lam' , 2012, upon consideration of Plaintiffs Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) DANIELJ. BEHRENS and KIMBERLEE K. BEHRENS, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 44 West Main Street, Plainfield PA 17081, and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 430. BY THE COURT: Zucker, Goldberg & Ackerman, UC XFP-160651 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WELLS FARGO BANK, N.A. Vs. NO 11-9340 Civil Term CIVIL ACTION — LAW DANIEL J. BEHRENS, K1MBERLEE K. BEHRENS WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $142,447.31 L.L.: $.50 Interest FROM 11/18/2011 TO DATE OF SALE - $17,482.80 Atty's Comm: Atty Paid: $368.,75 Plaintiff Paid: Date: 5/21/14 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonotary �. `7p24,_ui Deputy REQUESTING PARTY: Name: DENISE CARLON, 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. 202946 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendant(s). . CIVIL DIVISION NO.: 11 -9340 -CIVIL : Execution No.: AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 44 West Main Street, Plainfield, PA 17081. 1. Name and Address of Owner(s) or Reputed Owner(s): DANIEL J. BEHRENS AND KIMBERLEE K. BEHRENS, HIS WIFE 44 West Main Street Plainfield, PA 17081 2. Name and Address of Defendant(s) in the Judgment: DANIEL J. BEHRENS 44 West Main Street Plainfield, PA 17081 KIMBERLEE K. BEHRENS 44 West Main Street Plainfield, PA 17081 t 77 a rrl W rn c r- r- <o DCD C7 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 MITCHELL GELBAUGH/HEATHER BARBOUR 1137 Shannon Lane Carlisle, PA 17013 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MERS AS NOMINEE FOR WCS LENDING, LLC 6501 Congress Ave., 3rd Floor, Boca Raton, FL 33487 AND PO Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees Street, Suite C Danville, II 61834 AND 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 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 WEST PENNSBORO TWP 2150 NEWVILLE ROAD CARLISLE, PA 17013-7746 AND C/0 DEBORAH PIPER 241 KERRSVILLE ROAD CARLISLE, PA 17015 BIG SPRING SCHOOL DISTRICT 45 Mount Rock Road Newville, PA 17241-9412 AND C/0 DEBORAH PIPER 241 KERRSVILLE ROAD CARLISLE, PA 17015 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 44 West Main Street Plainfield, PA 17081 UNKNOWN SPOUSE 44 West Main Street Plainfield, PA 17081 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Amended Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: BY: ZUCKER, GOLDBE - & ACi$ERMAN, LLC Scott A. D'-tferick, Esq i re; PA I.D. #55650 Kimberl 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 - Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCP-160651/nfe 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE IN THE VILLAGE OF PLAINFIELD, TOWNSHIP OF WEST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE CARLISLE-NEWVILLE STATE ROAD, PENNSYLVANIA ROUTE 641, AT THE CORNER OF LAND FORMERLY OF REBECCA AND ELIZABETH BEAR; THENCE BY THE SAME, SOUTH EIGHTEEN AND THREE-FOURTHS DEGREES WEST (S 18 3/4°W), FOR A DISTANCE OF TWO HUNDRED SIXTEEN FEET SIX INCHES (216'6") TO A POST; THENCE BY THE SAME, SOUTH ONE AND THREE-FOURTHS DEGREES WEST (S 01 3/4°W) FOR A DISTANCE OF TWENTY-EIGHT FEET THREE INCHES (28'3") TO A POINT IN THE CENTER OF A PUBLIC ALLEY; THENCE BY THE CENTERLINE OF SAID PUBLIC ALLEY, NORTH EIGHTY-SIX AND ONE-HALF DEGREES WEST (N 86 1/2° W) FOR A DISTANCE OF THIRTEEN FEET FIVE INCHES (13' 5") TO A POINT; THENCE BY LAND NOW OR FORMERLY OF IMA C. MEYERS, NORTH TWO AND THREE-FOURTHS DEGREES EAST (N 02 3/4° E), FOR A DISTANCE OF ONE HUNDRED EIGHTY-THREE FEET FIVE INCHES (183'5") TO A POST; THENCE BY THE SAME NORTH EIGHTEEN DEGREES EAST (N 18° EAST) FOR A DISTANCE OF SEVENTY-ONE FEET THREE INCHES (71' 3") TO A POINT IN THE CENTER OF SAID PENNSYLVANIA ROUTE 641; THENCE BY THE CENTERLINE OF SAID PENNSYLVANIA ROUTE NO. 641, SOUTH SEVENTY-ONE DEGREES EAST (S 71° E) FOR A DISTANCE OF FIFTY-SIX FEET (56') TO A POINT, SAID POINT MARKING THE PLACE OF BEGINNING). BEING IMPROVED WITH A BUILDING FORMERLY KNOWN AS THE REFORMED MENNONITE CHURCH OF PLAINFIELD, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 44 West Main Street, Plainfield, PA, 17081. BEING the same premises which JONATHAN G. RITCHEY AND SHERRI M. RITCHEY, HIS WIFE, by Deed dated August 6, 2004 and recorded August 11, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 264, Page 3306, granted and conveyed unto DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. Tax Map No.: 18-1394-0088-0000000-46. C7') .1 rn co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVPN 1— Wells Fargo Bank, N.A., CIVIL DIVISION �+ . Zig Plaintiff No.: 11 -9340 -CIVIL c a vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendants TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST 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 Levy Marin, Esquire -PA I.D. #306799 Ralph M. Salvia, Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon, Esquire- PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP- 160651/mag Zucker, Goldberg & Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defendants. CIVIL DIVISION NO.: 11 -9340 -CIVIL Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant(s) Daniel J. Behrens and Kimberlee K. Behrens, his wife, is/are the record owners of the real property. 2. Pursuant to the Order of Court dated November 21, 2012, the Sheriff of Cumberland County posted Plaintiffs Notice of Sheriff's Sale, at the address of the mortgaged premises, being 44 West Main Street, Plainfield, PA 17081, on or about June 19, 2014. A true and correct copy of said Order of Court and Proof of Posting are marked Exhibit "A", attached hereto and made a part hereof. 3. Pursuant to the Order of Court dated November 21, 2012, Plaintiffs counsel served Defendant(s) Daniel J. Behrens and Kimberlee K. Behrens, with Plaintiffs Notice of Sheriff's Sale, via Certified Mail no signature required, at the address(es) of 44 West Main Street, Plainfield, PA 17081, on June 20, 2014. True and correct copies of said Notices and Proofs of Mailing are marked Exhibit "B", attached hereto and made a part hereof. 4. Pursuant to the Order of Court dated November 21, 2012, Plaintiff's counsel served Defendant(s) Daniel J. Behrens and Kimberlee K. Behrens, with Plaintiffs Notice of Sheriff's Sale, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing, at the address(es) of 44 West Main Zucker, Goldberg & Ackerman, LLC XFP-160651 Street, Plainfield, PA 17081, on June 19, 2014. True and correct copies of said Certificate of Mailing marked is Exhibit "C", attached hereto and made a part hereof. 5. On or about July 17, 2014, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "D", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of Interest were served with Plaintiff's Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated: August ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff , 2014 MARGARE) GYEPONG // Paralegal/Legal Assistant Sworn to and subscribed before me This (3 day of (22(L, , 2014 Notary P lic MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm. Expires Oct. 16, 2016 ID # 2280276 State of New Jersey Zucker, Goldberg & Ackerman, LLC XFP-160651 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-160651 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA Plaintiff, vs. DANIELJ. BEHRENS; KIMBERLEE K. BEHRENS; Defendant(s). ORDER OF COURT AND NOW, this -4' day of rl401)' CIVIL DIVISION NO.: 11-9340-CIVIL , 2012, upon consideration of Plaintiffs Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) DANIELJ. BEHRENS and KIMBERLEE K. BEHRENS, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 44 West Main Street, Plainfield PA 17081, and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 430. BY THE COURT: (74 ae.,,(91 ter; era =•-r d;0 vsc -o r n ..{>, cp --1 . ..<ai. --tx 'V c - 7-1 Dx zC? 'Q Q DW -I • --.i NI, '-< cJ -4 Zucker, Goldberg & Ackerman, LLC XFP-160651 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �wov of Cunbrr4/ OF CE OF THE SHcfill Wells Fargo Bank, NA vs. Daniel J. Behrens (et al.) Case Number 2011-9340 SHERIFF'S RETURN OF SERVICE 06/19/2014 07:42 PM - Deputy Dawn Kell, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 44 West Main Street, West Pennsboro - Township, Plainfield, PA 17081, Cumberland County. 06/19/2014 07:42 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Daniel J. Behrens, pursuant to Order of Court by "Posting" the premises located at 44 W. Main Street, West Pennsboro Township, Plainfield, PA 17081, Cumberland County with a true and correct copy according to law. 06/19/2014 07:42 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Kimberlee K. Behrens, pursuant to Order of Court by "Posting" the premises located at 44 W. Main Street, West Pennsboro Township, Plainfield, PA 17081, Cumberland County with a true and correct copy according to law. SHERIFF COST: $1,053.02 August 12, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. SO ANSWERS, EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-160651 Zucker. Goldberg & Ackerman, LLC PO Boot 1219 Mountainside, NJ 07092-1219 111 111 I I It 9314 7100 1170 0747 8384 50 20140820-102 (nIlIpirII1IIInruIlnII,IIuIIIIIrlhlruu„IIiluIuIII,IuIII DANIEL J. BEHRENS 44 West Main Street Plainfield, PA 17081 PANOSS IN THE COURT OF COMMON PLEAS OF•CUMBERIAND COUNTY, PENNSYLVANIA Wells fargo Bank, N.A. .CIVIL DIVISION VS. DANIEL J. BEHRENS; KIIVIBERLEE K. BEHRENS; Defendants. NO.: 11 -9340 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF avit PROCEDURE 33,29 DANIEL J. BEHRENS 44 West It/lain Street Plainfield, PA 17083. 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 September 3, 2014 at 10:00am prevailing local time. THE :PROPERTy TO :BE SOLD is delineated in detail in a legal description ccinsitting of a :staternent:of the measure(' boundaries of the property, together with a brief mention of the buildlrigs and any other major improvements .erected on the land. (SEE LEGAL DESCRIPTION ATTACHED:AS EXHIBIT 'Al, The LOCATION of your property to be sold is: 44 West Main Street, Plairifieid, PA, 17081 The JUD4MENT under Or pursuant to which your property is being sold is docketed to: No. 11 -9340 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: DANIEL j. BEHRENS and KIMBERLEE K. BEHRENS, his wife Zucker, Goldberg & Ackerman, LLC XFP-160651 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 bedisbursed 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) clays 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 ISA 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 325. 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 sarne 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. 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 Zucker, Goldberg & Ackerman, LLC XFP-160651. 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 preseritatiOn Of the petition to the Court. Dated: lafaz ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. •Bonner, -Esquire; PA ID. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D.. #306799 Ralph M. Salvia, Esquire; PA ID. 202946 Jaime R. Ackerman, Esquire; PAI.D. #311032 Jana Fridfinnsdottir, Esquire; PA ID. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA ID. #317226 Attorneys for Plaintiff XFP-160651/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg,com VIA FILED ORDER. OR COURT. ZuckttuG9latert& Ackerman, LLC XP -160651 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE:IMPROVE M ENTSTHEREON €RECTED, SITUATE IN THE VILLAGE OF PLAINFIELD; TOWNSHIP OF WEST PENNSBORO; COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA; BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE CARLISLE-NEWVILLE STATEROAD,.PENNSYLVAN1A ROUTE 641, AT THE CORNER OF LAND FORMERLY OF fiESEco.:k AND ELIZABETH BEAR; THENCE BY THE SAME; SOUTH EIGHTEEN AND THREErFOURTHS DEGREES WEST (S18.3/4°W); FOR A DISTANCE OF TWO HUNDRED SIXTEEN FEET SIX INCHES (216'61 TO A POST; THENCE BY THE SAME, SOUTH. ONE AND .THREE-FOURTHS DEGREES WEST (S 013/4'W)FOR A D1STANCE.OF: TWENTY,EIGHT FEET THREE INCHES (28'3) TO A POINT IN ME CENTER OF A PUBLIC ALLEY; THENCE BY.THE CENTERLINE OF SAID PUBUC ALLEY, NORTH EIGHTY-SIX AND ONE-HALF DEGREESWES1 (N 86 1/2* W) FORA DISTANCEOF THIRTEEN :FEET FIVE. INCHES (13' S") TO A POINT; THENCE BY LAND NOW OR.FORMERLY OF IMA C. IVIEYERS, NORTH TWO AND THREE-FOURTHS DEGREES EAST (N 023/40 E), FOR:A DISTANCE OF ONE HUNDRED EIGHTY-THREE FEET FIVE INCHES (183'Sif) TO A POST; THENCE BY THE SAME NORTH EIGHTEEN DEGREES EAST (N 18 EAST) FOR A DISTANCE OF SEVENTY-ONE FEET THREE INCHES(71' :3)TO A POINT IN THE .CENTER OF SAID PENNSYLVANIA ROOTE641; THENCE.BY THE CENTERLINE OF SAID PENNSYLVANIA . ROUTE NO..641, SOUTH SEVENTY-ONE DEGREES EAST ($71° E) FOR A DISTANCE OF F1FTY-SIX FEET I56") TO A POINT, SAID POINT MARKING THEPIACE OF BEGINNING). BEING IMPROVED WITH A BUILDING FORMERLY KNOWN AS -n-1E REFORMED MENNONITE CHURCH OF PLAINFIELD, PENNSYLVANIA. HAVING. thereon erected a dwelling house being known and numbered as 44 West Main Street,. Plainfield„ Pk 17081. BEING the same premises which JONATHAN G. wain' ANtt SHERRI M. RITCHEY, HIS WIFE, by Deed dated August 6,. 2004 and recorded August 11, 2004 in and for.C.umberfand County, Pennsylvania, in Deed Book Volume 264, Page 3306, granted and conveyed unto DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. TO Map NO.; 184394-0088-0000000-46: Zucker. Goldberg. & Ackerman, ItC XFP-16065.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; PENNSYLVANIA Wells Fargo Sark NA, Plaintiff; vs. DANIEL J. BEHRENS; KIMBERLEE K. BEHRENS; Defenclant(s). : CIVIL DIVISION NO,: 3.1.934a-aviL • ORDER OF COURT SO - AND NOw; this -44 day of YirfrO* „ 20/2, upon consideration of Mai ref Motion for Spetial Salvia:4R ishereby ORDERED, ADJUDGED AND DECILEED that Plaintiff shall serve its Contplaint in Mcirtgage foreclosure and NOtice of Sale, if necessary, on Defendant(s)DANIELL BEHRENS and ItImaERLEE K. SEHREN5, by instructing the Sheriff -of Cumberland County to MST a copy of sante on the Mortgaged Premises, being 44 West Main Street, Plainfield PA 17081, and :by =Meg a cam via Certified Mail,. 714) signature required and Sat Class U.S. (vial!, Postage Prepaid, with said service beirg •yalid ancl corpoiev upon such i indnjTncco,danewJth.PaR.P.43O.. BY THE COURT: if/ fri.. X el.ft,a452.. Zuclar, GrOberg 114erman,•1.1-C vp-1,6065/ Zucker, Goldberg & Ackerman, LLC PO Box 1219 Mountainside, NJ 07092-1219 1 1 1 9314 7100 1170 0747 8384 36 20140620-102 •II.III'III'11IIIIiIiI��.1IIlIIIIuilIIII IIII�IIIIulIlll'1IIsIi11 KIMBERLEE K. BEHRENS 44 West Main Street Plainfield, PA 17081 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND couNni, PENNSYLVANIA Weils:Fato vs: DANIEL J, BEHRENS; KIMBERLEE K. BEHRENS; PENN Plaintiff, Defendants, CML DIVISION NO.: 11 -9340 -CIVIL NOTICE OF SHERIFF'S SALE OF .REAL PROPERTY PURSUANT TO.. SYLVANIA RULE OF CML PROCEDURE 3129 KIMBERLEE K. BEHRENS 44 Weg Main Street Plainfield, PA 17081 TAKE NOTICE: That the Sheriff's. Sale of Real Property (Real Estate) will be held at the Cumberland •County Courthouse, 1 Courthouse Square, Carlisle, PA 17013• on September 3, 2014 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal destription consisting of a statement of the measured boundaries of the property, together With a brief mention of the buildings and any other major improvernerits erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT • The LOCATION of your property to be sold is: 44 West Nlaln Street, Plainfield, PA, :17081 The JUDGMENT under or pursuant to which your property is being sold Is docketed to: No. 11 -930 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(5) OF THIS PROPERTY ARE: 240cer, Goldbett& Ackerrnan,-LLC XFP4606.51 DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. A SCHEDULE OF DISTRIBUTION, beinga list of the persons and/or governmental or corporate entities or agencies beingentitled to receive part of the proceeds of the sate received and to be disbursed by the Sheriff (for exarnple to banks that hoed 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 dateit 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.. 15 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 T1115 PAPER TO YOUR LAWYER,AT ONCE. GO TO OR TELEPH- r'4E THS. 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 315. Bedford Street Carllslet 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. Sheriff's Sale, you may file a petition with the Court. of Common Pleas of Cumberland. County to set asidethe sale for a grossly inadequate price or for other proper cause. Tills 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 Zucker. Goldberg & Ackerman, LLC X P -i6 651 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. Dated: j' ZLJCKER,.GOLQBERG &.ACKERMAN, LLC Scott A. Dietterick, Esquire; PA 1.D. #55650 Kimberly A. Banner, Esquire; PA I:D. #89705 Joel A. Ackerman, Esquire; PA I.Q. #202729 Ashleigh L. Marin, Esquire;. PA I.Q. #306799 Ralph M. Salvia, Esquire PA I.Q. #202946 Jaime R. Ackerman, Esquire; PA I.D. ##311032 Jana Fridfirtnsdottir, Esquire; PA ID. #315944 Brian Nicholas, Esquire; PA I.Q. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-160651/sde 200 Sheffield. Street, Suite 101 Mountainside NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@ zuckergoldberg:com VIA FILED ORDER OR COURT. Zucker, Goldberg & Ackerman, LLC XFP-160651 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SMJATE IN THE VILLAGE OF PLAINFIELD, TOWNSHIP QF WEST PENNSBORO, COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE CARLISLE-NEWVILLE :STATE ROAD, PENNSYLVANIA ROUTE 641, AT THE CORNER OF LAND FORM:ERLY OF REBECCA AND EUZABETH BEAR; THENCE BY THE SAME, SOUTH .EIGHTEEN AND THREE-FOURTHS DEGREES WEST (S.18.3/4°W), FORA DISTANCE OF TWO HUNDRED SIXTEEN FEET SIX INCHES {216'6")TO A POST; THENCE.BYTHE SAME, SOUTH ONE AND THREE-FOURTHS DEGREES WEST (S01 3/44W) FOR A DISTANCE OF TWENTY-EIGHT FEET THREE INCHES: 128'..34) TO A POINT IN THE CENTER OFA PUBLIC ALLEY; THENCE BY THE CENTERLINE OF SAID PUBLIC ALLEY, NORTH EIGHTY-SIX AND ONE. -HALF DEGREES WEST (N 861/2' W) FOR A DISTANCE OF THIRTEEN FEET FIVE INCHES (13' 5") TOA. POINT; THENCE, BY LAND NOW OR FORMERLY.OF IMA :C. MEYERS, NORTH TWO AND THREE-FOURTHS DEGREES:EAST (N 02 3/4' E), FORA DISTANCE OF ONE HUNDRED EIGHTY-THREE FEET FIVE)NCHES (183'31 TO A POST; THENCE BY THE SAME NORTH EIGHTEEN DEGREES EAST (N 18° EAST) FOR A DISTANCE OF SEVENTY-ONE FEET THREE INCHES (71' 3")TOA POINT IN THE CENTER OF SAID PENNSYLVANIA ROUTE 641; THENCE BY THE CENTERLINE OF SAID PENNSYLVANIA ROUTE. NO, 641, SOUTH SEVENTY-ONE DEGREES:E:AST (S 71' E)'FOR A DISTANCE OFFIFTY-SIX FEET (S61) TO A POINT, SAID POINT MARKING THE PLACE OF BEGINNING). BEING IMPROVEDWITH A BUILDING FORMERLY KNOWN AS THE REFORMED MENNONITE CHURCH OF PLAINFIELD, PENNSYLVANIA. HAVING thereon erected a dwelling house being known and numbered as 44 West Main Street, Plainfield, PA, 17081. BEING the:same premises which JONATHAN G. RITCHEY AND SHERRI M. RITCHEY, HIS WIFE, by Deed dated August 6, 2004 and.recorded August 11, 2004.in.and for Cuiriberland County, Pennsylvania, in Deed Book Volume 264, Page 3306, granted and conveyed unto DANIEL J. BEHRENS and KIMBERLEE K. BEHRENS, his wife. Tax Map :No.:18-.1394-0088.0000000.46. Zucker, Goldberg & Ackerman, LLC • XFP-160651. IN THE couRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fango Bank, NA. CIVIL DMSI0N Plaintiff, DANIEL). BEH ENS: KIMBERL El K. BEHRENS; Defendangs). opEft. QF puirt NC1.4-11-ia340-CML ,11 AND NOW, this day of ,2032, upon consideration of Plaintiffs MdtiOn for Special Service, it is hereby ORDERIA ADJUD003 AND DECREED that Plaintiff shall serve its Complaint in Nicktgage Foreclosure ancl Notice of Sale, if necessary, on Defendant/4 DANIEL). I3EKRENS and KIMBERLEE K. BEHRENS, by instructing the Sheriff of Cumberland County to POST a copy of same or the Mortgaged Ptendses, being 44 West Main Street, Plainfield PA 17083, and by mailing a copy, via Certified Malt, no signature required and Hitt Class U.S. Mal, Postage Prepaid„ with said service beim( aNixtrwiplitt! upon such Dostirg and mapine_in accordance with Pa,RAP. 430, ENTRE COURT: ,11 clOf arevIte 3. Tr: AtikeGt4tilSberg %1Zicernlan!.1:C *FP -•/60631 EXHIBIT C Zucker, Goldberg & Ackerman, LLC XFP-160651 NOS CERT UNITED STATES POSTAL SERVICE Certificate 0 Mailing U S POSTAGE } PITNEY BOWES This Certificate of Mailing provides evidence that mag has been presented to USPS* for mailing. This form may be used for domestic and International mall. Pr°m" Denise Carlon, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/pn TEAM- C - PA T°` DANIEL J. BEHRENS 44 West Main Street Plainfield, PA 17081 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 --'�J UNITED STATES POSTdLSERVICE@ Certificate Of Mailing This Certificate of Mailing provides evidence that mall has bean presented to USPS• for malting. This form may be used for domestic and International mall. From: Denise Carlon, Esquire 1200 00013E37430 JUN 19 2014 To pay fee, affix stamps or meter postage here. c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Postmark 1 404 To pay tee, affix stamps or meter postage here, XFP-160651/pn TEAM- C - PAcL51 KIMBERLEE K. BEHRENS 44 West Main Street Plainfield, PA 17081 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 `Irq i Nrli"OEVL.8Ef000 I000 $Z60Li0 riIZO i3r,+i.f ADhald 3OV1 SOd S fl P Page 1 of 1 EXHIBIT D Zucker, Goldberg & ------�- Ackerman, LLC XFP-160651 NTL Page 1 of 8 UNITED STATES Cita POSTAL SERVICE® Certificate 0 Mailing US POSTAGE D}PITNEY BOWES This Certificate of Melling provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. rr°T' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Tot CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND XFP-160651/nfe TEAM- C ZIP 02 07092 $ 001.200 0001387430JUL 17 2014 To pay fee, affix stamps or meter postage here. PS Form 3817, April 2007 PSN 7530-02-000-9065 �""� UNITED STATES POSTAL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS' for mailing. This form may be used for domestic and International mall. rromo Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C T°' COMMONWEALTH OF PENNSYLVANIA 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 t'L0 Lt lflr0£tL8£6000 }fir €C7 ?64Z0 c117 SMC'3 A3N11d «1OVISOd S fl To pay fee, affix stamps or meter postage here. Postmark Here NTL Page 2 of 8 UNITED STATES POSTAL SERVICE® Certificate i Mailing U S POSTAGE 3}PITNEY BOWES This Certificate of Mailing provides evidence that mall has been presented to USPS, for mailing. This form may be used for domestic and international mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman C 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C T°` UNKNOWN TENANT OR TENANTS 44 West Main Street Plainfield, PA 17081 s X 9210012O 0001387430JUL 17 2014 To pay fee, affix stamps or meter Postage hers. County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 UNITEDSTi1TES MN POSTAL SERVICE, Certificate Of Mailing Postmark Here To pay fee, afld stamps or mater pestle, here. This Certificate of Melling provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LCC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C T°` MITCHELL GELBAUGH/HEATH E Ft BARBOUR 1137 Shannon Lane Carlisle, PA 17013 r Postmark Here County of P.Q.: CUMBERLAM D PS Form 3817, April 2007 PSN 7530-02-04=H3-9065 t'L0Z Li 1flr oc7L8ct000 00Z1•00 $ Z60L0 dIZ malwrgaMM,St. Ir-04.00.2WZ, S3MC3A3Nlid«30VISOd'Sf NTL Page 3 of 8 UNITED STATES arta POSTAL SERVICE® U S POSTAGE »> PIT NEY'BOWES Certificate 0 Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS* 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 XFP-160651/nfe TEAM- C To: WEST PENNSBORO TWP 2150 NEWVILLE ROAD CARLISLE, PA 17013-7746 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USW for mailing. This form may be used for domestic and international mag. Prem: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C To' WEST PENNSBORO TWP C/O DEBORAH PIPER 241 KERRSVILLE ROAD CARLISLE, PA 17015 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 b�0z Li lflf oct' c oo0 o0t100 $ Z60LO dIZ S3ra,-)81A3Nlld (C 3OVjSOd'S (1 '4 raiMENNALW.ONMiegt040,' Amsswwww, "wow, ZIP 07092 $ 001.200 02 1YV 0001387430 JUL 17 2014 To pay fee, affix stamps or meter postage here. Postmark Here To pay fee, affix stamps or meter postage here. Postmark Here NTL Page 4of8 �+ UNITED STATES POSTAL SERVICE Certificate Of Mailing U S POSTAGE »} PITNEY BOWES #0.,. This Certificate of Mailing provides evidence that mall has been presented to USW for mailing. This form may be used for domestic and International mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C To' BIG SPRING SCHOOL DISTRICT 45 Mount Rock Road Newville, PA 17241-9412 ZIP 07°92 $ 001.200 02 1YY 0001387430 Jul_ 17 2014 To pay fee, affix stamps or meter postage here. Postmark Here County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SFRVICE6 Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to U5P5a for mailing. This form may be used for domestic and International mall. Prem' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C BIG SPRING SCHOOL DISTRICT C/0 DEBORAH PIPER 241 KERRSVILLE ROAD CARLISLE, PA 17015 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 P 10c'. Li in(' 0£17L2E 1.000 MI ZO Z60L0 dIZ 00Z'.00 $ m ,maxXmow. 17:444. '40failynt.:33, S3h1:0ABNlldf''3JVISOd Sn To pay fee, affix stamps or mater postage here. NTL Page 5 of 8 UNITED STATES Mg POST/JL SERVICE Certificate 0 Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and Intarnattonai'mail. pram` Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C T°' MERS AS NOMINEE FOR WCS LENDING, LLC 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES Cita POST/11 SERVICE Certificate Of Mailing This Certificate of Malang provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall Fr m Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C Tat MERS AS NOMINEE FOR WCS LENDING, LLC 1901 E. Voorhees Street, Suite C Danville, II 61834 County of P.Q.; CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Li lfti 06PL9£1000 .po{�. coO $ Z60Lo dIZ sa'4°35a3NrC< 40VISOCI s n 2IPOt0r'2. 00120° *2 1T'f 0001387430 JUL 17 ''1014 To pay fee, affix stamps or mater postage here. Postmark Here :jut rIby To pay fee, affix stamps or meter postage here. Postmark Hire ,•.-.,-1P 5 NTL Page 6 of 8 UNITED STATES POSTAL SERVICE® US POSTAGE;,? PITNEY BOWES F w ZIP 07092 $ 001 20° 02 1Y4 0001387430 ,JUL 17 2014 Certificate 0 Mailing This Certificate of Malting provides evidence that mall has been presented to USPS' for mailing. This form may be used for domestic and international mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C To: MERS AS NOMINEE FOR WCS LENDING, LLC PO Box 2026 Flint, MI 48501-2026 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE® Certificate Of Mailing This Certificate of Melling provides evidence that mall has been presented to USPS, 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 XFP-160651/nfe TEAM- C To: MERS AS NOMINEE FOR WCS LENDING, LLC 6501 Congress Ave., 3rd Floor, Boca Raton, FL 33487 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 trio: Ll i(lf OCtLBC1000 zo 001100 $ Z6OL0 dIZ S3MOSFA3NAd <{ JOVISOd ST1 To pay fee, affix stamps or meter postage here. Postmark Here To pay fee, affix stamps or meter ppstege.. here: Postmark Here NTL Page 7 of 8 UNITED STATES POST/JL SERVICE. Certificate Of Mailing U S POSTAGE »»PITNEYEOWES m This Certificate of Mailing provides evidence that mall has bean presented to USPS for mailing. This form may be used for domestic and international mail. Fm"': Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C Tor CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 ZIP 07092 $ 001.200 02 1w 0001387430 JUL 17 2014 To pay fee, affix stamps or meter postage here. Ptist County of P.Q.: CUMBERLAND acv ¢ PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE Certificate Of Mailing This Certificate of Melling provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and intametlonal mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe 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 ,t0? L1 lflr0£iL0£t000 tt1 Ger L'00Z°>020 d17 ;Z. s3mczA3Kaid<<30VISOci S fl To pay fee, affil stamps or meter postage here. Postmark Here NTL Page 8 of 8 UNITED STATES Mig POSTAL SERVICE® Certificate Of Mailing US POSTAGE '» PITNEY BOWES This Certificate of Malang provides evidence that mall has been presented to USPS' for mailing. This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-160651/nfe TEAM- C T°` UNKNOWN SPOUSE 44 West Main Street Plainfield, PA 17081 0 Z1P2 °t rr7°92 $ 001.200 0001387430JUL 17 2014 To pay fee, affix stamps or meter postage here, Postmark Here County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065