HomeMy WebLinkAbout12-0166
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Prothonotary
To: Todd A. Barrick
675 North Middle Road
Newville, Pennsylvania 17241
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No. 12-166 Civil Term
NOTICE
Pursuant to Rule 236, you are hereby notified that a JUDGMEN as be ter e abovoproc ng
as
indicated below. Pro nary -
X Judgment by Default
Money Judgment
- Judgment in Replevin
- Judgment for Possession
If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway,
P.C. at (215) 790-1010.
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
Defendant
Attorpgyr ftapw
HONG TA ;
Vii. '?9OERLA?;D COUNTY
._c 1NSYLVAN1A
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 12-166 Civil Term
ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for
failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows:
Principal
Interest from 12/04/11 to 03/06/12
$ 180,622.41
$ 3,825.80
Total $ 184,448.21
V, ?? 'L A ?
TERRENCE J. MCCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorney for Plaintiff
a. M s 14 SD10d 46?
04 1491 ys(
AND NOW, this day of rd 2012, Judgment is entered in favor of Plaintiff, Wells _ff -elie a'7 aI<'S a
t4afi0, (*kJ
Fargo Bank, N.A., as Trustee for Option One Mortgage Loan Trust 2007-FXD2, Asset-Backed Certificates, Series
2007-FXD2 c/o American Home Mortgage Servicing, Inc., and against Defendant, Todd A. Barrick, and damages are
assessed in the amount of $184,448.21, plus interest and costs.
00-.
BY THE P THO R
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
Defendant
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 12-166 Civil Term
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF PHILADELPHIA:
SS.
The undersigned, being duly sworn according to law, deposes and says that the Defendant, Todd A. Barrick,
is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the
Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant, Todd A. Barrick, is
over eighteen (18) years of age, and reside as follows:
Todd A. Barrick
675 North Middle Road
Newville, Pennsylvania 17241
SWORN AND SUBS.#IBED
47 ME THIS DAY
V12
NOTARY PUBLIC
""UNWEALTH OF PENNSYLYANiq
N13TARIAL SEAL
Amanda M. CaAPeUetti - Nota L
O'°fPhiiadelphia, Philadel ryPubliC
MY COMMISSION Phis County
EXPIRES OCT 28, ?015
Iz-
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorney for Plaintiff
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
Todd A. Barrick
Defendant
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Number 12-166 Civil Term
CERTIFICATION
The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law,
deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be
entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the
Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A".
SWORN AND SUBSCRIBED
BEF ME T'H S L DAY
91
0- A 0, 29-12
TARY PUBLIC
COMMONW ALTH OF PENNSTLVANIA
NOTARIAL BEAL
Amanda M. Cappelletti -Notary Public
City of Philadelphia, Philadelphia County
MY COMMISSION EXPIRES T. 28, 2015
TERR NCE J. MCCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorney for Plaintiff
VERIFICATION
The undersigned attorney hereby certifies that he is the Attorney for the Plaintiff in the within action, and
that he is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs
representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to
the best of his knowledge, information and belief and further states that false statements herein are made subject to the
penalties of 18 PA.C.S. §4904 relating to unswom falsification to authorities.
n
TERRE CE J. MCCABE, SQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
Attorney for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS J
Cumberland County Courthouse, Carlisle, Pennsylvania 17013
Curt Long
Prothonotary r?
February 14, 2012
To: Todd A. Barrick
675 North Middle Road
Newville, Pennsylvania 17241
Wells Fargo Bank, N.A., as Trustee for Cumberland County
Option One Mortgage Loan Trust Court of Common Pleas
2007-FXD2, Asset-Backed Certificates,
Series 2007-FXD2 c/o American Home Number 12-166 Civil Term
Mortgage Servicing, Inc.
Vs.
Todd A. Barrick
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU W ITH INFORMATION ABOUT AGENCIES THAT MAYOFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
NOTIFICACION IMPORTANTE
LISTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER
PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA
PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR
ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS
RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA
ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA
NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE
COMPARECER LISTED EN CORTE U OIR PREUBA ALGUNA, DICTAR
SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS
DERECHOSIMPORTANTES.
LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO
INMEDIATAMFNTE. SI USTED NO TIENE A UN ABOGADO, VA A O
TELFFONEA LA OFICINA EXPUSO ABAJo. ESTA OFICINA LO PUEDE
PROPORCIONAR CON INFORMAC16N ACERCA DE EMPLEAR A UN
ABOGADO.
SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO,
ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON
INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS
SERVICIOS LEGALFS A PERSONAS ELEGBLES EN UN HONORARIO
REDUCIDO NI NINGON HONORARIO.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
?pw (800) 99 8
BY:
Attorneys for Plaintiff
TERRENCE J. McCABE, ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
ANDREW L. MARKOWITZ, ESQUIRE
CHRISTINE L. GRAHAM, ESQUIRE
mb
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-166 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-FXD2, ASSET-BACKED CERTIFICATES,
SERIES 2007-FXD2 C/O AMERICAN HOME MORTGAGE SERVICING, INC. Plaintiff (s)
From TODD A. BARRICK
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $184,448.21
Interest FROM 3/07/12 - $5,533.92 AT $30.24
Atty's Comm: %
Arty Paid: $190.25
Plaintiff Paid:
Date: 4/24/2012
(Seal)
L.L.: S.50
Due Prothy: $2.25
Other Costs:
David D. Buell, Prothonotary
Deputy
REQUESTING PARTY:
Name: TERRENCE J. MCCABE, ESQUIRE
Address: MCCABE, WEISBERG AND CONWAY
123 S. BROAD STREET, SUITE 2080
PHILADELPHIA, PA 19109
Attorney for: PLAINTIFF
Telephone: 215-790-1010
Supreme Court ID No. 16496
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Todd A. Barrick
FILE NO.: 12-166 Civil Term Civil Term
AMOUNT DUE: $184,448.21
INTEREST: from 03/07/12
$5,533.92 at $30.24
ATTY'S COMM.:
COSTS:
--,MBERLAND COUNT""
PENNSYLVANIA
TO THE PROTHONOTARY OF SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a
confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following
described property of the defendant(s)
675 North Middle Road, Newville, Pennsylvania 17241
(More fully described as attached)
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing
attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description;
supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in
the attached exhibit.
DATE: l 7117. - -
.
S
of a$
J 01. Ofd
b 3•nS ""
1 6. Sb
O u N
$196 a
Signature:
Print Name: TE 4NCE?J.'NfeCABE, ESQUIRE
MARGARET GAIRO, ESQUIRE
CHRISTINE L. GRAHAM, ESQUIRE
KEVIN T. McQUAIL, ESQUIRE
Attorneys for Plaintiff
Firm: MCCABE, WEISBERG AND CONWAY
Address: 123 S. Broad Street, Suite 2080
Philadelphia, PA 19109
Attorney for: Plaintiff
Telephone: (215) 790 1010
Supreme Court ID No. 16496
?j?i.y oI
LEGAL DESCRIPTION
All that certain tract of land situate in Upper Mifflin Township, Cumberland County, Pennsylvania, bounded and described in
accordance with a Subdivision Plan for Samuel L. and Katie S. Fisher, latest revised August 30, 1989, by Stephen G. Fisher,
PLS, and recorded in Cumberland County Plan Book 59, Page 8, as follows:
Beginning at a P.K. spike at the corner of Lot 7-A as set forth on Subdivision Plan for Samuel L. and Katie S. Fisher dated July
18, 1990, and recorded in Cumberland County Plan Book 61, Page 120, being the center line of Middle Road (T-402); thence by
the center line of Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 259.76 feet to a point; thence by the same and a
curve to the left with a radius of 1,339.72 feet, a chord length of 98.19 feet to a point; thence by the same by a curve to the right
with a radius of 253.39 feet, a cord length of 133.45 feet, to a P.K. spike; thence by the same, North 26 degrees, 19 minutes, 21
seconds West, 30.84 feet to a point; thence by the same and lands now or formerly of Gary L. Smith and wife, North 31 degrees,
3 minutes, 58 seconds West, 100 feet to a point; thence by the same, North 42 degrees, 51 minutes, 58 seconds West, 79.48 feet
to a point; thence by lands now or formerly of Robert G. Zimmerman, North 32 degrees, 49 minutes, 30 seconds East, 7.77 feet
to a point; thence by the same, South 70 degrees (incorrectly stated on prior deeds as 7), 14 minutes, 30 seconds East, 35.73 feet
to a point; thence by the same, South 41 degrees, 14 minutes Bast, 201.60 feet to an iron pin set; thence by the same, North 74
degrees, 21 minutes East, 1,116.70 feet to an iron pin set at corner of Lot Addition "B" on said Plan of Lots; thence by said Lot
Addition "B", South 7 degrees, 50 minutes, 16 seconds East, 285.11 feet to an iron pin set; thence by Lot 6, as shown in Plan
Book 56, Page 141, South 02 degrees East, 63.36 (incorrectly stated on prior deeds as 67.36) feet to an iron pin set at corner of
Lot 7 as shown in Plan Book 59, Page 8; thence by the said Lot 7, South 68 degrees, 33 minutes, 37 seconds West. 570.82 feet to
an iron pin set; thence by the same. South 30 degrees, 8 minutes, 47 seconds West, 134.24 feet to a P.K. spike in the center of the
said Middle Road (T-408); thence by the center of the said Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 183.03
(incorrectly stated on prior deeds as 163.21) feet to a P.K. spike, the place of beginning.
Containing 8.97 acres gross
Tax ID - 44-05-0411 -011 K
RB5678 675 North Middle Road, Newville, Pennsylvania 17241.
BEING the same premises which VIRGINIA M. KINER, SINGLE WOMAN, AND TODD A. BARRICK, SINGLE MAN by
deed dated November 14, 2006 and recorded December 14, 2006 in the office of the Recorder in and for Cumberland County in
Deed Book 277, Page 4965, granted and conveyed to Todd A. Barrick, single man, in fee.
TAX MAP PARCEL NUMBER: 44-05-0411-011K
MkABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET CAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
Defendant
Attorneys for Plaintiff
.? f Eri_ b nU 1VJ1i Tt'Si4 €
2 l"R 24 A 11: 2u,,
L. u 6
2ERLAN0 COUNT`','
PENNSYLVANIA
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO: 12-166 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129
The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real
property located at: 675 North Middle Road, Newville, Pennsylvania 17241, as of the date the Praecipe for the Writ of
Execution was filed. A copy of the description of said property being attached hereto.
Name and address of Owner or Reputed Owner
Name
Todd A. Barrick
Address
675 North Middle Road
Newville, Pennsylvania 17241
Name and address of Defendant in the judgment:
Name
Todd A. Barrick
Address
675 North Middle Road
Newville, Pennsylvania 17241
Name and last known address of every judgment creditor whose judgment is a record lien on the real property
to be sold:
Name Address
Plaintiff herein
Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
5
Name and address of every other person who has any record lien on the property:
Name
Address
None
6
Name and address of every other person who has any record interest in the property which may be affected by
the sale:
Name
Address
None
7
Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale:
Name Address
Tenants/Occupants 675 North Middle Road
Newville, Pennsylvania 17241
Commonwealth of Pennsylvania Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105
ATTN: Dan Richard
Commonwealth of Pennsylvania 110 North 8`h Street
Inheritance Tax Office Suite #204
Philadelphia, PA 19107
Commonwealth of Pennsylvania 6th Floor, Strawberry Square
Bureau of Individual Tax Department #280601
Inheritance Tax Division Harrisburg, PA 17128
Department of Public Welfare Willow Oak Building
TPL Casualty Unit Estate P.O. Box 8486
Recovery Program Harrisburg, PA 17105-8486
PA Department of Revenue Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Commonwealth of Pennsylvania Clearance Support Department 281230
Department of Revenue Bureau of Harrisburg, PA 17128-1230
Compliance ATTN: Sheriff's Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106
Domestic Relations P.O. Box 320
Cumberland County Carlisle, PA 17013
United States of America
United States of America c/o
Atty General of the United States
United States of America c/o
Atty General of the United States
Name and address of Attorney of record:
Name
None
c/o United States Attorney for the
Middle District of PA
William J. Nealon Federal Bldg.
235 North Washington Avenue, Ste. 311
Scranton, PA 18503
and
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108-1754
U.S. Dept of Justice, Room 51 11
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
U.S. Dept of Justice, Room 4400
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
Address
I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
April 12, 2012
DATE
TERRE CE J. McCABE, ESQUIRE
MARGARET GAIRO, ESQUIRE
CHRISTINE L. GRAHAM, ESQUIRE
KEVIN T. McQUA1L, ESQUIRE
Attorneys for Plaintiff
LEGAL DESCRIPTION
All that certain tract of land situate in Upper Mifflin Township, Cumberland County, Pennsylvania, bounded and described in
accordance with a Subdivision Plan for Samuel L. and Katie S. Fisher, latest revised August 30, 1989, by Stephen G. Fisher,
PLS, and recorded in Cumberland County Plan Book 59, Page 8, as follows:
Beginning at a P.K. spike at the corner of Lot 7-A as set forth on Subdivision Plan for Samuel L. and Katie S. Fisher dated July
18, 1990, and recorded in Cumberland County Plan Book 61, Page 120, being the center line of Middle Road (T-402); thence by
the center line of Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 259.76 feet to a point; thence by the same and a
curve to the left with a radius of 1,339.72 feet, a chord length of 98.19 feet to a point; thence by the same by a curve to the right
with a radius of 253.39 feet, a cord length of 133.45 feet, to a P.K. spike; thence by the same, North 26 degrees, 19 minutes, 21
seconds West, 30.84 feet to a point; thence by the same and lands now or formerly of Gary L. Smith and wife, North 31 degrees,
3 minutes, 58 seconds West, 100 feet to a point; thence by the same, North 42 degrees, 51 minutes, 58 seconds West, 79.48 feet
to a point; thence by lands now or formerly of Robert G. Zimmerman, North 32 degrees, 49 minutes, 30 seconds East, 7.77 feet
to a point; thence by the same, South 70 degrees (incorrectly stated on prior deeds as 7), 14 minutes, 30 seconds East, 35.73 feet
to a point; thence by the same, South 41 degrees, 14 minutes Bast, 201.60 feet to an iron pin set; thence by the same, North 74
degrees, 21 minutes East, 1,116.70 feet to an iron pin set at corner of Lot Addition "B" on said Plan of Lots; thence by said Lot
Addition "B", South 7 degrees, 50 minutes, 16 seconds East, 285.11 feet to an iron pin set; thence by Lot 6, as shown in Plan
Book 56, Page 141, South 02 degrees East, 63.36 (incorrectly stated on prior deeds as 67.36) feet to an iron pin set at corner of
Lot 7 as shown in Plan Book 59, Page 8; thence by the said Lot 7, South 68 degrees, 33 minutes, 37 seconds West. 570.82 feet to
an iron pin set; thence by the same. South 30 degrees, 8 minutes, 47 seconds West, 134.24 feet to a P.K. spike in the center of the
said Middle Road (T-408); thence by the center of the said Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 183.03
(incorrectly stated on prior deeds as 163.21) feet to a P.K. spike, the place of beginning.
Containing 8.97 acres gross
Tax ID - 44-05-0411 -011 K
RB5678 675 North Middle Road, Newville, Pennsylvania 17241.
BEING the same premises which VIRGINIA M. KINER, SINGLE WOMAN, AND TODD A. BARRICK, SINGLE MAN by
deed dated November 14, 2006 and recorded December 14, 2006 in the office of the Recorder in and for Cumberland County in
Deed Book 277, Page 4965, granted and conveyed to Todd A. Barrick, single man, in fee.
TAX MAP PARCEL NUMBER: 44-05-0411-011K
McCABE, WMBERt AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
CIVIL ACTION LAW
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
V.
Todd A. Barrick
Attorneys for Plaintiff
[(? t
r 1iMBERLAPvD
NTY
"ENNS YLV COUANIA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Number 12-166 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Todd A. Barrick
675 North Middle Road
Newville, Pennsylvania 17241
Your house (real estate) at 675 North Middle Road, Newville, Pennsylvania 17241 is scheduled to be sold at
Sheriffs Sale on September 5, 2012 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of
$184,448.21 obtained by Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home Mortgage Servicing, Inc. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be canceled if you pay to Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Loan
Trust 2007-FXD2, Asset-Backed Certificates, Series 2007-FXD2 c/o American Home Mortgage Servicing,
Inc. the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you
must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the
sale. (See the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to
the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this
has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the
sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives
a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of
the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff
within ten (10) days after the posting of the schedule of distribution.
7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
LEGAL DESCRIPTION
All that certain tract of land situate in Upper Mifflin Township, Cumberland County, Pennsylvania, bounded and described in
accordance with a Subdivision Plan for Samuel L. and Katie S. Fisher, latest revised August 30, 1989, by Stephen G. Fisher,
PLS, and recorded in Cumberland County Plan Book 59, Page 8, as follows:
Beginning at a P.K. spike at the corner of Lot 7-A as set forth on Subdivision Plan for Samuel L. and Katie S. Fisher dated July
18, 1990, and recorded in Cumberland County Plan Book 61, Page 120, being the center line of Middle Road (T-402); thence by
the center line of Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 259.76 feet to a point; thence by the same and a
curve to the left with a radius of 1,339.72 feet, a chord length of 98.19 feet to a point; thence by the same by a curve to the right
with a radius of 253.39 feet, a cord length of 133.45 feet, to a P.K. spike; thence by the same, North 26 degrees, 19 minutes, 21
seconds West, 30.84 feet to a point; thence by the same and lands now or formerly of Gary L. Smith and wife, North 31 degrees,
3 minutes, 58 seconds West, 100 feet to a point; thence by the same, North 42 degrees, 51 minutes, 58 seconds West, 79.48 feet
to a point; thence by lands now or formerly of Robert G. Zimmerman, North 32 degrees, 49 minutes, 30 seconds East, 7.77 feet
to a point; thence by the same, South 70 degrees (incorrectly stated on prior deeds as 7), 14 minutes, 30 seconds East, 35.73 feet
to a point; thence by the same, South 41 degrees, 14 minutes Bast, 201.60 feet to an iron pin set; thence by the same, North 74
degrees, 21 minutes East, 1,116.70 feet to an iron pin set at corner of Lot Addition "B" on said Plan of Lots; thence by said Lot
Addition "B", South 7 degrees, 50 minutes, 16 seconds East, 285.11 feet to an iron pin set; thence by Lot 6, as shown in Plan
Book 56, Page 141, South 02 degrees East, 63.36 (incorrectly stated on prior deeds as 67.36) feet to an iron pin set at corner of
Lot 7 as shown in Plan Book 59, Page 8; thence by the said Lot 7, South 68 degrees, 33 minutes, 37 seconds West. 570.82 feet to
an iron pin set; thence by the same. South 30 degrees, 8 minutes, 47 seconds West, 134.24 feet to a P.K. spike in the center of the
said Middle Road (T-408); thence by the center of the said Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 183.03
(incorrectly stated on prior deeds as 163.21) feet to a P.K. spike, the place of beginning.
Containing 8.97 acres gross
Tax ID - 44-05-0411 -011 K
RB5678 675 North Middle Road, Newville, Pennsylvania 17241.
BEING the same premises which VIRGINIA M. KINER, SINGLE WOMAN, AND TODD A. BARRICK, SINGLE MAN by
deed dated November 14, 2006 and recorded December 14, 2006 in the office of the Recorder in and for Cumberland County in
Deed Book 277, Page 4965, granted and conveyed to Todd A. Barrick, single man, in fee.
TAX MAP PARCEL NUMBER: 44-05-0411-011K
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
?.`L`P? F (t
Wells Fargo Bank, NA
vs.
Todd A Barrick
112 JUL -3 AM g. E
GUMBERLA D COUN i y
PENNSYLVAMA
Case Number
2012-166
SHERIFF'S RETURN OF SERVICE
06/18/2012 07:43 PM - Deputy Michael Barrick, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 675 N. Middle Road, Upper Mifflin Road, Newville, PA 17241, Cumberland
County.
06/18/2012 07:43 PM - Deputy Michael Barrick, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same time
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Todd A
Barrick at 675 N. Middle Road, Upper Mifflin Road, Newville, PA 17241, Cumberland County.
07/02/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",
per letter of instruction from Attorney.
SHERIFF COST: $84.41
July 02, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
S L L F?
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McC-?BE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
Defendant
Attorneys for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO: 12-166 Civil Term
AFFIDAVIT PURSUANT TO RULE 3129
The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real
property located at: 675 North Middle Road, Newville, Pennsylvania 17241, as of the date the Praecipe for the Writ of
Execution was filed. A copy of the description of said property being attached hereto.
Name and address of Owner or Reputed Owner
Name
Todd A. Barrick
Address
675 North Middle Road
Newville, Pennsylvania 17241
2. Name and address of Defendant in the judgment:
Name
Todd A. Barrick
Address
675 North Middle Road
Newville, Pennsylvania 17241
Name and last known address of every judgment creditor whose judgment is a record lien on the real property
to be sold:
Name Address
Plaintiff herein
Name and address of the last recorded holder of every mortgage of record:
Name Address
Plaintiff herein
5. Name and address of every other person who has any record lien on the property:
Name
None
Name
None
6.
Address
Name and address of every other person who has any record interest in the property which may be affected by
the sale:
Address
7
Name and address of every other person of whom the plaintiff has knowledge; who has any interest in the
property which may be affected by the sale:
Name Address
Tenants/Occupants 675 North Middle Road
Newville, Pennsylvania 17241
Commonwealth of Pennsylvania Department of Public Welfare
Bureau of Child Support Enforcement
P.O. Box 2675
Harrisburg, PA 17105
ATTN: Dan Richard
Commonwealth of Pennsylvania 110 North 8`h Street
Inheritance Tax Office Suite #204
Philadelphia, PA 19107
Commonwealth of Pennsylvania 6th Floor, Strawberry Square
Bureau of Individual Tax Department #280601
Inheritance Tax Division Harrisburg, PA 17128
Department of Public Welfare Willow Oak Building
TPL Casualty Unit Estate P.O. Box 8486
Recovery Program Harrisburg, PA 17105-8486
PA Department of Revenue Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
Commonwealth of Pennsylvania Clearance Support Department 281230
Department of Revenue Bureau of Harrisburg, PA 17128-1230
Compliance ATTN: Sheriffs Sales
United States of America Internal Revenue Service
Technical Support Group
William Green Federal Building
Room 3259
600 Arch Street
Philadelphia, PA 19106)
Domestic Relations P.O. Box 320
Cumberland County Carlisle, PA 17013
United States of America
United States of America c/o
Atty General of the United States
United States of America c/o
Atty General of the United States
8. Name and address of Attorney of record:
Name
None
c/o United States Attorney for the
Middle District of PA
William J. Nealon Federal Bldg.
235 North Washington Avenue, Ste. 311
Scranton, PA 18503
and
Harrisburg Federal Building & Courthouse
228 Walnut Street, Ste. 220
Harrisburg, PA 17108-1754
U.S. Dept of Justice, Room 5111
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
U.S. Dept of Justice, Room 4400
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
Address
I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
April 12, 2012 _
DATE
TERR CE J. McCABE, ESQUIRE
MARGARET GAIRO, ESQUIRE
CHRISTINE L. GRAHAM, ESQUIRE
KEVIN T. McQUAIL, ESQUIRE
Attorneys for Plaintiff
LEGAL DESCRIPTION
All that certain tract of land situate in Upper Mifflin Township, Cumberland County, Pennsylvania, bounded and described in
accordance with a Subdivision Plan for Samuel L. and Katie S. Fisher, latest revised August 30, 1989, by Stephen G. Fisher,
PLS, and recorded in Cumberland County Plan Book 59, Page 8, as follows:
Beginning at a P.K. spike at the corner of Lot 7-A as set forth on Subdivision Plan for Samuel L. and Katie S. Fisher dated July
18, 1990, and recorded in Cumberland County Plan Book 61, Page 120, being the center line of Middle Road (T-402); thence by
the center line of Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 259.76 feet to a point; thence by the same and a
curve to the left with a radius of 1,339.72 feet, a chord length of 98.19 feet to a point; thence by the same by a curve to the right
with a radius of 253.39 feet, a cord length of 133.45 feet, to a P.K. spike; thence by the same, North 26 degrees, 19 minutes, 21
seconds West, 30.84 feet to a point; thence by the same and lands now or formerly of Gary L. Smith and wife, North 31 degrees,
3 minutes, 58 seconds West, 100 feet to a point; thence by the same, North 42 degrees, 51 minutes, 58 seconds West, 79.48 feet
to a point; thence by lands now or fonnerly of Robert G. Zimmerman, North 32 degrees, 49 minutes, 30 seconds East, 7.77 feet
to a point; thence by the same, South 70 degrees (incorrectly stated on prior deeds as 7), 14 minutes, 30 seconds East, 35.73 feet
to a point; thence by the same, South 41 degrees, 14 minutes Bast, 201.60 feet to an iron pin set; thence by the same, North 74
degrees, 21 minutes East, 1,116.70 feet to an iron pin set at corner of Lot Addition "B" on said Plan of Lots; thence by said Lot
Addition "B", South 7 degrees, 50 minutes, 16 seconds East, 285.11 feet to an iron pin set; thence by Lot 6, as shown in Plan
Book 56, Page 141, South 02 degrees East, 63.36 (incorrectly stated on prior deeds as 67.36) feet to an iron pin set at corner of
Lot 7 as shown in Plan Book 59, Page 8; thence by the said Lot 7, South 68 degrees, 33 minutes, 37 seconds West. 570.82 feet to
an iron pin set; thence by the same. South 30 degrees, 8 minutes, 47 seconds West, 134.24 feet to a P.K. spike in the center of the
said Middle Road (T-408); thence by the center of the said Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 183.03
(incorrectly stated on prior deeds as 163.21) feet to a P.K. spike, the place of beginning.
Containing 8.97 acres gross
Tax ID - 44-05-0411-011 K
RB5678 675 North Middle Road, Newville, Pennsylvania 17241.
BEING the same premises which VIRGINIA M. KINER, SINGLE WOMAN, AND TODD A. BARRICK, SINGLE MAN by
deed dated November 14, 2006 and recorded December 14, 2006 in the office of the Recorder in and for Cumberland County in
Deed Book 277, Page 4965, granted and conveyed to Todd A. Barrick, single man, in fee.
TAX MAP PARCEL NUMBER: 44-05-0411-011K
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE j. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. McQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LaMANNA, ESQUIRE - ID # 310321
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Attorneys for Plaintiff
CIVIL ACTION LAW
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
Todd A. Barrick
Number 12•-166 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
To: Todd A. Barrick
675 North Middle Road
Newville, Pennsylvania 17241
Your house (real estate) at 675 North Middle Road, Newville, Pennsylvania 17241 is scheduled to be sold at
Sheriffs Sale on September 5, 2012 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of
$184,448.21 obtained by Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home Mortgage Servicing, Inc. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be canceled if you pay to 'Wells Fargo Bank, N.A., as Trustee for Option One Mortgage Loan
Trust 2007-FXD2, Asset-Backed Certificates, Series 2007-FXD2 c/o American Home Mortgage Servicing,
Inc. the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you
must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the
sale. (See the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
` EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to
the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this
has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.
4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the
sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives
a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of
the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule
will state who will be receiving that money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff
within ten (10) days after the posting of the schedule of distribution.
7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE
YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
ASSOCIATION DE LICENCIDADOS
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(800) 990-9108
LEGAL DESCRIPTION
All that certain tract of land situate in Upper Mifflin Township, Cumberland County, Pennsylvania, bounded and described in
accordance with a Subdivision Plan for Samuel L. and Katie S. Fisher, latest revised August 30, 1989, by Stephen G. Fisher,
PLS, and recorded in Cumberland County Plan Book 59, Page 8, as follows:
Beginning at a P.K. spike at the corner of Lot 7-A as set forth on Subdivision Plan for Samuel L. and Katie S. Fisher dated July
18, 1990, and recorded in Cumberland County Plan Book 61, Page 120, being the center line of Middle Road (T-402); thence by
the center line of Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 259.76 feet to a point; thence by the same and a
curve to the left with a radius of 1,339.72 feet, a chord length of 98.19 feet to a point; thence by the same by a curve to the right
with a radius of 253.39 feet, a cord length of 133.45 feet, to a P.K. spike; thence by the same, North 26 degrees, 19 minutes, 21
seconds West, 30.84 feet to a point; thence by the same and lands now or formerly of Gary L. Smith and wife, North 31 degrees,
3 minutes, 58 seconds West, 100 feet to a point; thence by the same, North 42 degrees, 51 minutes, 58 seconds West, 79.48 feet
to a point; thence by lands now or formerly of Robert G. Zimmerman, North 32 degrees, 49 minutes, 30 seconds East, 7.77 feet
to a point; thence by the same, South 70 degrees (incorrectly stated on prior deeds as 7), 14 minutes, 30 seconds East, 35.73 feet
to a point; thence by the same, South 41 degrees, 14 minutes Bast, 201.60 feet to an iron pin set; thence by the same, North 74
degrees, 21 minutes East, 1,116.70 feet to an iron pin set at corner of Lot Addition "B" on said Plan of Lots; thence by said Lot
Addition "B", South 7 degrees, 50 minutes, 16 seconds East, 285.11 feet to an iron pin set; thence by Lot 6, as shown in Plan
Book 56, Page 141, South 02 degrees East, 63.36 (incorrectly stated on prior deeds as 67.36) feet to an iron pin set at corner of
Lot 7 as shown in Plan Book 59, Page 8; thence by the said Lot 7, South 68 degrees, 33 minutes, 37 seconds West. 570.82 feet to
an iron pin set; thence by the same. South 30 degrees, 8 minutes, 47 seconds West, 134.24 feet to a P.K. spike in the center of the
said Middle Road (T-408); thence by the center of the said Middle Road, North 59 degrees, 51 minutes, 13 seconds West, 183.03
(incorrectly stated on prior deeds as 163.21) feet to a P.K. spike, the place of beginning.
Containing 8.97 acres gross
Tax ID - 44-05-0411-011 K
RB5678 675 North Middle Road, Newville, Pennsylvania 17241.
BEING the same premises which VIRGINIA M. KINER, SINGLE WOMAN, AND TODD A. BARRICK, SINGLE MAN by
deed dated November 14, 2006 and recorded December 14, 2006 in the office of the Recorder in and for Cumberland County in
Deed Book 277, Page 4965, granted and conveyed to Todd A. Barrick, single man, in fee.
TAX MAP PARCEL NUMBER: 44-05-0411-011 K
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-166 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., AS TRUSTEE FOR
OPTION ONE MORTGAGE LOAN TRUST 2007-FXD2, ASSET-BACKED CERTIFICATES,
SERIES 2007-FXD2 C/O AMERICAN HOME MORTGAGE SERVICING, INC. Plaintiff (s)
From TODD A. BARRICK
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as allows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $184,448.21
Interest: FROM 3/07/12 - $5,533.92 AT $30.24
Atty's Comm: %
Arty Paid: $190.25
Plaintiff Paid:
Date: 4/24/2012
(Seal)
REQUESTING PARTY:
Name: TERRENCE J. MCCABE, ESQUIRE
L.L.: $.50
Due Prothy: $2.25
Other Costs:
David D. Buell, Prothonotary
Deputy
Address: MCCABE, WEISBERG AND CONWAY
123 S. BROAD STREET, SUITE 2080
PHILADELPHIA, PA 19109
Attorney for: PLAINTIFF
Telephone: 215-790-1010
Supreme Court ID No. 16496
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the seal of sald Cc3u at Carlisle, Pay.
This ry -4 day of 20-1 :2
Prothonotary
?f.? C, S4QA/> b?Al
On April 26, 2012 the Sheriff levied upon the defendant's
interest in the real property situated in Upper Mifflin
Township, Cumberland County, PA, known and
numbered 675 North Middle Road, Newville, PA 17241
more fully described on Exhibit "A" filed with this writ
and by this reference incorporated herein.
Date: April 26, 2012
r
BY: ?I ? WdA 4--- &uIt46/1
Claudia Brewbaker, Real Estate Coordinator
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorney for Plaintiff
MARC S. WEISBERG, ESQUIRE - ID # 17616 C `i
EDWARD D. CONWAY, ESQUIRE - ID # 34687 r.a -'
MARGARET GAIRO, ESQUIRE - ID # 34419 maw ? r '
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 X r 'vim
HEIDI R. SPIVAK, ESQUIRE - ID #74770 -<D
MARISA J. COHEN, ESQUIRE - ID # 87830 r"-Z
KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 mn ==C
CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 C) c
BRIAN T. LAMANNA, ESQUIRE - ID# 310321
123 South Broad Street, Suite 1400 o
Philadelphia, Pennsylvania 19109 1
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
No. 12-166 Civil Term
Defendant
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate, upon payment of your costs only, the default judgment entered in the above-captioned
against defendant TODD A. BARRICK on March 8, 2012. This praecipe to vacate is filed without prejudice to
rights in this matter and is without prejudice to plaintiffs right of recovery against defendant on the underlying
DATE: 7/ vZ?O?d ??j
CQ
TERRENCE J. McC , ESQUIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
ANDREW L. MARKOWITZ, ESQUIRE
HEIDI R. SPIVAK, ESQUIRE
MARISA J. COHEN, ESQUIRE
KEVIN T. MCQUAIL, ESQUIRE
T<CHRISTINE L. GRAHAM, ESQUIRE
BRIAN T. LAMANNA, ESQUIRE awA
ATTORNEY FOR PLAINTIFF Nth'"
ID JJ
I -
ffs
(a9 ;N8
)-7591
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET CAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. MCQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480
BRIAN T. LAMANNA, ESQUIRE - ID# 310321
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
Defendant
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
No. 12-166 Civil Term
CERTIFICATE OF SERVICE
(_ ?r?S??nR.. L. G?
II` Attorney for Plaintiff, hereby certifies that a true and correct copy of the
Praecipe to Discontinue and End, as well as Praecipe to Vacate Judgment, was served on the below person(s) by
first class mail, postage prepaid, on the Jr.aday oP012.
Todd A. Barrick
675 North Middle Road
Newville, Pennsylvania 17241
DATE:
/_1
TERRENCE J. MICA E, SQUIRE
MARC S. WEISBERG, QUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
ANDREW L. MARKOWITZ, ESQUIRE
HEIDI R. SPIVAK, ESQUIRE
MARISA J. COHEN, ESQUIRE
KEVIN T. MCQUAIL, ESQUIRE
CHRISTINE L. GRAHAM, ESQUIRE
BRIAN T. LAMANNA, ESQUIRE
ATTORNEY FOR PLAINTIFF
MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET CAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. MCQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480
BRIAN T. LAMANNA, ESQUIRE - ID# 310321
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., as Trustee for Option One
Mortgage Loan Trust 2007-FXD2, Asset-Backed
Certificates, Series 2007-FXD2 c/o American Home
Mortgage Servicing, Inc.
Plaintiff
V.
Todd A. Barrick
Defendant
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
No. 12-166 Civil Term
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
C ?
ca t
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o
Kindly mark the above-captioned matter as Discontinued and Ended, without prejudice, upon
payment of your costs only.
TERRENCE J. McCABE, S UIRE
MARC S. WEISBERG, ESQUIRE
EDWARD D. CONWAY, ESQUIRE
MARGARET GAIRO, ESQUIRE
ANDREW L. MARKOWITZ, ESQUIRE
HEIDI R. SPIVAK, ESQUIRE
MARISA J. COHEN, ESQUIRE
KEVIN T. MCQUAIL, ESQUIRE
xCHRISTINE L. GRAHAM, ESQUIRE
BRIAN T. LAMANNA, ESQUIRE
ATTORNEY FOR PLAINTIFF
Attorney for Plaintiff'