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HomeMy WebLinkAbout12-0633jCt F? -2 fY g. "r 3 1?;1DERLAND COEr N ^ENNSYLVANIA PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 269907 WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING COMPANY 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 V. Plaintiff DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD 4000 TRANQUILITY COURT MONROVIA, MD 21770-9005 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO.pl ej -LP33 l.l?? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 269907 .Y Lj"A %I03.-IS A 71W NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 269907 I . Plaintiff is WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING COMPANY 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD 4000 TRANQUILITY COURT MONROVIA, MD 21770-9005 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/24/2005 DOUGLAS PRITCHARD and MARTHA M. PRITCHARD made, executed and delivered a mortgage upon the premises hereinafter described to MPOINT MORTGAGE SERVICES, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1912, Page 3410. By Assignment of Mortgage recorded 11/09/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument Number 201131253. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01/0 1 /2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 269907 6. The following amounts are due on the mortgage as of 01/03/2012: Principal Balance $60,520.42 Interest $5,271.64 12/01/2010 through 01/03/2012 Late Charges $70.44 Property Inspections $220.00 Escrow Deficit $1,268.59 TOTAL $67,351.09 7. Plaintiff is not seeking a judgment of personal liability (or an in person am judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $67,351.09, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. LLINAN & SCHMIEG, LLP Y: Attorney for Plaintiff Robert W. Cusick, Esquire Id., No, 891.9,1 File #: 269907 LEGAL DESCRIPTION ALL THAT CERTAIN one-half lot of ground situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on East King Street opposite the center of the partition wall dividing the frame double dwelling house erected on the said premises at line of land now or formerly of Thomas L. Fogelsanger and Debra C. Fogelsanger, his wife; thence southward through the center of said partition wall and by land now or formerly of the said Thomas L. Fogelsanger and Debra C. Fogelsanger, his wife, a distance of 292 1/2 feet, more or less, to a point at now or formerly an alley; thence eastward by the said now or formerly alley, a distance of 20 feet, more or less, to a point at land now or formerly of W.W. Kegerreis, now or formerly of James Monos; thence northwardly by the said last mentioned land 292 1/2 feet, more or less, to a point on East King Street; thence westward by the said East King Street, a distance of 20 feet, more or less, to a point, the place of BEGINNING. BEING THE SAME PREMISES which Abram K. Crider, properly know as Abram D. Crider, conveyed unto Abram D. Crider and Lowemae Crider, his wife, and Bryan D. Crider, single man, by deed dated December 26, 2001 and recorded December 26, 2001 in the Recorder's Office in and for Cumberland County, Pa. in Record Book 249, Page 3758. PROPERTY ADDRESS: 476 EAST KING STREET, SHIPPENSBURG, PA 17257-1509 PARCEL # 32-33-1869-103 File #: 269907 VERIFICATION Linda Duncan, hereby states that he he is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter.. that h she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his er information and belief. The undersigned understands that this statement is made subject to the penalties of 13 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: Name: Pritchard File #: 269907 Name: Linda Duncan Title: Vice President Loan Documentation 032-PA-V SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson M Sheriff,;;TFl0i0TAF' 4?`tr Qt tn?br f? i' ! , t Jody SSmith - ? Chief Deputy 20', 2 FF8 13 AM 9. 14 Richard W Stewart I~1?13lwI?LAND COUNTY Solicitor?'?? ` "? PENNSYLVANIA Wells Fargo Bank, N.A. Case Number vs. 2012-633 Douglas Pritchard (et al.) SHERIFF'S RETURN OF SERVICE 02/06/2012 12:22 PM - William Cline, Corporal, who being duly sworn according to law, states that on February 6, 2012 at 1229 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Occupant of 476 E. King Street, Shippensburg, Pennsylvania 17257, by making known unto Mike Matichak, current tenant of 476 E. King Street, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. Current tenants of this address are Mike Matichak d Yasmine Gutshall. IL DAM CLINE, DEPUTY 02/09/2012 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: Douglas Pritchard, 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 Douglas Pritchard. Request for service at 476 E. King Street, Shippensburg, Pennsylvania 17257 the Defendant was not found. Douglas Pritchard is thought to be residing at 4000 Tranquility Court Monrovia, Maryland 21770. 02/09/2012 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: Martha P. Pritchard, 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 Martha P. Pritchard. Request for service at 476 E. King Street, Shippensburg, Pennsylvania 17257 the Defendant was not found. Martha P. Pritchard is thought to be residing at 4000 Tranquility Court, Monrovia, Maryland 21770. SHERIFF COST: $90.00 February 09, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c',:. C'u r"Suite SCe itl le ieos0`t, Irc. Phelan Hallinan & Schmieg, LLP FILED-OFFICE" 1617 JFK Boulevard, Suite 1400 C F THE ROIL ",ONO TA `s One Penn Center Plaza Philadelphia, PA 19103 24 215-563-7000 Attorney for Plaintiff ?BERLAND COUNTY WELLS FARGO BANK, NA, D/B/A AM q N'SY:LVA+NIACourt of Common Pleas SERVICING COMPANY Plaintiff Civil Division VS. CUMBERLAND County DOUGLAS PRITCHARD No. 2012-633-CIVIL A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Defendants MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, L.L.P., moves this Honorable for an Order directing service of the Complaint upon the above-captioned DOUGLAS PRITCHARD and MARTHA M. PRITCHARD, by first class mail to DOUG PRITCHARD and MARTHA M. PRITCHARD at the last known address, TRANQUILITY COURT, MONROVIA, MD 21770, and the mortgaged premises, 476 EA$T KING STREET, SHIPPENSBURG, PA 17257; posting of the mortgaged premises, 476 KING STREET, SHIPPENSBURG, PA 17257; and publication pursuant to Pa. R.C.P. 430, in support thereof avers the following: 1. Attempts to serve Defendants, DOUGLAS PRITCHARD and MARTHA M. PRITCHARD, personally with the Complaint have been unsuccessful. The Sheriff of Cumberland County attempted to serve the Defendants at the mortgaged premises, 476 EAST KING STREET, SHIPPENSBURG, PA 17257. As indicated by the Returns of Service, is not valid as a tenant accepted the Complaint. The Defendants do not reside at said address. True and correct copies of the Returns of Service are attached hereto, made part hereof, and marked as Exhibit "A". 2. The Plaintiff's Process Server attempted to serve the Defendants at 4000 TRANQUILITY COURT, MONROVIA, MD 21770. As indicated by the Affidavits of Service no service was made as there was no response to the attempts made by the Plaintiff's Process Server. True and correct copies of the Affidavits of Service are attached hereto, made part hereof, and marked as Exhibit "B". 3. The Plaintiff's Process Server attempted to serve the Defendants at 3327 TIDEWATER COURT, OLNEY, MD 21770. As indicated by the Affidavits of Service, no service was made as the Defendants do not reside at said address. True and correct copies of Affidavits of Service are attached hereto, made part hereof, and marked as Exhibit "C". 4. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendants. A true and correct copy of an affidavit of due diligence setting forth the specific inquiries as to the Defendants' whereabouts and the results thereof is attached hereto, made hereof, and marked as Exhibit "D". Plaintiff contacted the Prothontary's Office and as of July 6, 2012, no Judge has previously entered a ruling in this case. 6. In accordance with CUMBERLAND County Local Rule 208.2(d), Plaintiff sent) a copy of its Proposed Motion for Special Service and Order to the Defendants on July 6, 2012 requested Defendants' concurrence. Plaintiff did not receive any written response from the Defendants. A true and correct copy of Plaintiff's July 6, 2012 letter and postmarked of mailing pursuant to Local Rule 208.2(d) attached hereto, made part hereof, and marked Exhibit "B". 7. Plaintiff has reviewed its internal records and has not been contacted by the Defendants as of July 6, 2012 to bring loan current. 8. Plaintiff submits that it has made a good faith effort to locate the Defendants but has been unable to do so. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail; posting; and publication. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP Date: By: Melissa J. Cantwell, Esq., Id. No. 308912 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA, DB/A AMERICAS SERVICING COMPANY Plaintiff VS. DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Defendants Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 2012-633-CIVIL MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT 1. FACTUAL BACKGROUND Attempts to serve Defendants, DOUGLAS PRITCHARD and MARTHA M. PRITCHARD, with the Complaint have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendants at the mortgaged premises, 476 EAST KING STREET., SHIPPENSBURG, PA 17257. The Plaintiff's Process Server attempted to serve the Defendants at 4000 TRANQUILITY COURT, MONROVIA, MD 21770 and at 3327 TIDEWATER COURT, OLNEY, MD 21770. As indicated by the Returns of Service and the Affidavits of Service, no service was made. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to discover the whereabouts of the Defendants as evidenced by the affidavit due diligence setting forth the specific inquiries as to the Defendants' whereabouts and the thereof. Further, Plaintiff's counsel has reviewed its internal records and has not been by the Defendants as of July 6, 2012 to bring loan current. Consequently, Plaintiff submits that it has made a good faith effort to locate the Defendants but has been unable to do so II. LEGAL AUTHORITY Pennsylvania Rule of Civil Procedure 430(a) specifically states: If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Pa.R.C.P. 430(a) (2009). In particular: An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and employers of the defendant, and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. Id. at 430(a) n. Similarly, the Pennsylvania Superior Court has gone on to explain that, "While by no means exhaustive, this Note is at least indicative of the types of procedures contemplated by the legislature when enacting Rule 430." Deer Park Lumber, Inc. v. Moor, 384 Pa. Super. 625, 633, 559 A.2d 941, 946 (1989), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Only after such proof has been offered is the Court authorized to direct another method of substitute service. id. In the instant case, as indicated by the Return of Service, the Sheriff has been unable serve the Complaint. Plaintiff has made a good faith effort to discover the whereabouts of Defendants as evidenced by the affidavit of due diligence. Therefore, Plaintiff 2 requests an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, posting, and publication. III. CONCLUSION As indicated by the Returns of Service and the Affidavits of Service, the Sheriff and Plaintiffs Process Server have been unable to serve the Complaint upon the Defendants. has made a good faith effort to discover the whereabouts of the Defendants as evidenced by affidavit of due diligence. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, posting, publication. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP Date: ?- By„ Melissa J. Cantwell, Esq., Id. No. 308912 Attorney for Plaintiff Exhibit "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 4160t° of +Cae4ar?hd OFFICE OF THE SHERIFF Fll.f??1-GFi?IC? i dE PROT[IONOTARY 2012 FEB 13 AM 9: Ili CU PENNSYLVANIA TY Wells Fargo Bank, N.A. vs. Douglas Pritchard (et al.) Case Number 2012633 SHERIFF'S RETURN OF SERVICE 02/06/2012 12:22 PM - William Cline, Corporal, who being duly sworn according to law, states that on February 6, 2012 at 1229 hours, he served a true copy of the within Complaint In Mortgage Foreclosure, upon the within named defendant, to wit: Occupant of 476 E. King Street, Shippensburg, Pennsylvania '17257, by making known unto Mike Matichak, current tenant of 476 E. King Street, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. Current tenants of this address are Mike Matichak and Yasmine Gutshall. 02/09/2012 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: Douglas Pritchard, 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 Douglas Pritchard. Request for service at 476 E. King Street, Shippensburg, Pennsylvania 17257 the Defendant was not found. Douglas Pritchard is thought to be residing at 4000 Tranquility Court Monrovia, Maryland 21770. 02/09/2012 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: Martha P. Pritchard, 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 Martha P. Pritchard. Request for service at 476 E. King Street, Shippensburg, Pennsylvania 17257 the Defendant was not found. Martha P. Pritchard is thought to be residing at 4000 Tranquility Court, Monrovia, Maryland 21770. SHERIFF COST: $90.00 February 09, 2012 SO ANSWERS, icl CountpSaae SYR.CI,! 7 e11050f( Inc. Exhibit "B" AFFIDAVIT OF SERVICE (FNMA) PI AINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING pHS # 269907 COMPANY DEFENDANT SERVICE TEAM/ O DOUGLAS PRITCHARD A/K1A DOUGLAS T. PRITCHARD COURT NO.: 2012.633-CIVII, MARTHA M. PRITCHARD SERVE DOUGLAS PRITCHARD A/KJA DOUGLAS T. TYPE OF ? OOeclosure PRITCHARD AT: XX Mortgage Action 4000 TRANQUILITY COURT XX Civil MONROVIA, MD 21770-9005 ffRVED Served and made known to DOUGLAS PRITCHA D , Defendant on the ,,,,,Y day of 20 - , ociock _. M., at in the manner described below: Defendant personally served. _ Adult family member with whom Defendant(s) reside(s), Relationship is Adult in charge of Defendants residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: -- Description: Age Height Weight Race Sex Other 1 a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the [Wanner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of __.., 20_. sotary: By` N SERVFi'D Ctn the rtUy r7f ?fN 2Ii ut o'clcfck M., Defendant NOT FOUND because: _ Vacant ses Not Exist tv ovvd Doe.4 Not 14141de (Not acant) 0? ct Answ r cxt at • ;.C1t .- .'c _..? .u _?_! '' .? ? ?M Service Refused Other' Sworn to ands rtbe I hel'+.?r ?t titj _ dt? } t '? rac't.l?Jxdan. I.,ld,Nn.32227 tctc ti. ttutltnti't: ` Id. No. 62695 1 nk l O> 4ciutn«r r ?•, id. No. 62205 r• M. k1(ttdltuct txal..Id. No. 69849 Jutillft J#cxti.en?s.lId, No. 58745 fntir?e R. Davey. Esq.. Id. No. 87077 Lauren P. Tabas,iEsq., Id. No. 93337 Jay 11. Jones, Esq.. Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq, Id. No. 308951 Melissa J. Cantwell, Esq., Id, No. 308912 Mario J. lianyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Id. No, 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik. Esq„ Id. No. 308877 Matthew G. Brushwood, Esq., Id. No. 310592 Dana B. Ostrovsky, Esq., W. No. 83921 One Penn Center at Suburban Station Exhibit "C" AFFIDAVIT OF SERVICE (C UIVIB PLP INTIFF ERI.AND COUNTY WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING pHS # 269907 COMPANY DEFENDANT S RVI , M-02- DOUGLAS PRITCHARD A/WA DOUGLAS T. PRITCHARD COURT NO.: 2012-633-CIVIL MARTHA M PRITCHARD SERVE MARTHA M. PRITCHARD AT: 4000 TRANQUILITY COURT MONROVIA, MD 21770-9005 TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action SERVED Served and made known to MARTHA M. PRITCHARD , Defendant on the _ day of 20 at , o'clock _. M„ at in the manner described below: _ Defendant personally served. _ Adult family member with whom Defendant(s) reside(s). Relationship is __ _ Adult in charge of Defendants residta?tce who refused to give name or relationship. MatutgerlClerk of plate of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual plane of business. an of ices of said DefendanCs company. Other: _ .... _...... __.__.__ ._.__ ___.....___.____...._• Description: Age _ Height _ Weight Race Sex __ Other __- 1 f a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complain( in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _ day of __., 20_ Notary: iiy, tt 'ShitVl"sl3 On the day of S Y . Zl.ir. at tSoltx k , ?I)efendant NOT rC3UND because _ Vacant Xws NtA Exi',r6 _ Mtw IF Does Not Reside (Ntr Vacant) y? No Answer on + _._at J9__..? a1_..tj tX ?' " v Service Refused Other: su . ttxtl ?t Sworn to and lx f c 1e t I Y 4(jay of Notary: 'r?} .• ' ' r I R 'IFh Chrisovalante P Riakos Esq. Id, No, 94620 Esq , Id. No. 32227 rraneis S. I0Tjjn , Esq., Id. No. 62695 Daniel G, tii jr jeos Esq., Id, No. 62205 t Michele M. jiaiacllt*d. Esq.. Id. No. 69849 r. (ta+tlil I ilo?ntiio,Esq., Id. No, 58745 ??(Im EXp?BS I tJl-'3- Rju' i?. 1 rab , Esq., Id. No. 87077 y 11C I aurcn R• Tbas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Courteney R. Dunn, Esq., Trl. No. 206779 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Ilanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., Td. No. 312314 Robert W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No, 308877 Matthew G, Brashwood, Esq., Id. No. 310592 Dana B. Ostrovsky, Esq., ld, No 83921 One Penn Center at Suburban SUAdOll Exhibit "D" AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING COMPANY PHS # 269907 DEFENDANT SERVICE TEAM/ do DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD COURT NO.: 2012-633-CIVII. MARTHA M. PRITCHARD ?r5 fs. SERVE DOUGLAS PRITCHARD A/K/A DOUGLAS T. TYPE OF ACTION PRITCHARD AT: XX Mortgage Foreclosure 3327 TIDEWATER COURT XX Civil Action OLNEY, MD 21770 SERVED Served and made known to DOUGLAS PRITCHARD , Defendant on the _ day of 20 at _ d clock _. M., at _ in the manner described below: _ Defendant personally served. ? Adult family member with whom Defendant(s) reside(s), Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: --- Description: Age Height _ Weight Race Sex Other a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of •_ , 20_. Notary: By: 10 tru;[, - I,[) On the _ day a r 20t 10-1 o'clock M., (:)cien lnt NUi' FOUND beeausc: _ Vacant Does Not Exist Moved Does Not Reside (Not Vacant) No Answer on ..__-at . ...... .-at ..,._ _ _._..... Service Refused ,. r Other. By: ;. ATTORNEY FOR PLAINTIFF Chrisovalatt ? P. Iliakas, Esq., Id, No. 94620 Lawrence T. Phelan, Esq., Id. No. 32227 Courtenay R. Dunn, Esq., Id. No. 206779 ' Francis S. Hallinan, Esq., Id. No. 62695 Allison F. Wells, Esq., Td. No. 309519 Daniel G. Schmieg, Esq., Id, No. 62205 William E. Miller, Esq., Id. No. 308951 Michele M. Bradford, Esq., Id. No. 69849 Melissu J. Cantwell, Esq., Id. No. 308912 cl?gtq?th T. Romano, Esq., Id. No. 58745 Mario J. Hanyon, Esq., Id. No. 203993 Ir`>f,11' , JI L??((,??lrrlne R, Davey, Esq., Id, No, 87077 Andrew J. Marley, Esq., Id. No. 312314 Lauren R. Tabas, Esq., Id. No. 93337 Robert W. Cusick, Esq., Id. No. 80193 Jay B. Jones, Esq., Id. No. 86657 John M, Kolesnik, Esq., Id. No. 308877 Andrew L. Spivack, Esq., Id. No. 84439 Matthew G. Brushwood, Esq., Id. No. 310592 Dana B. Ostrovsky, Esq., Id. No. 83921 One Penn Center nt Suburban Station Sworn to and str ribed be hx ne ht? clay of _ ::A- NrJ:?? Exhibit "E" AFFIDAVIT OF SERVICE (FNMA) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, NA, DfJ3/A AMERICAS SERVICING pHS # 269907 COMPANY DEFENDANT?FRVICE TEAM/ clo DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD COURT NO.: 2012.633-CIVIL MARTHA M. PRITCHARD SERVE MARTHA M. PRITCHARD AT: 3327 TIDEWATER COURT OI.NEY, MD 21770 SERVED Served and made known La MARTHA M, PRITCHARD , Defendant on the day of o'clock _. M„ at„ _ W, in the manner described below: _ Defendant personally served, Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s), - Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. _ Other: Description: Age Height Weight Race Sex Other _ TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action ,20._,at I a competent adult, being duly sworn according to law, depose and state that .I personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above, Sworn to and subscribed before me this day of 20_, Notary: By; On the '20 all n'clex k Vi ., Tk rct ant NOT FOUND becausc: duyof r ? 1 I Vf-C? _ Vacant „ Does Not Exist _ Mo voxi loos Not Reside (Not Vucano No Answer on :.._..._............... _..... _ ................. at Service Refused Other. a ' w??rrt it) id stds iiscd 1 f In:li Ilu y t1' 4 `° /? t. By: V Notary: ?^ t ?T?j FOR PLAIN fII F t.'irriwc v:dnntc P. Makos, Esq., J& No. 94620 11aI L LwIJLxrT, 'ltelan, l , Id. No. 32227 f ' ? tor;. S. Halhnan Esq., Id. No. 62695 / r, ' rel O. Schmteg ., Id. No, 62205 CC 1 ?° , Michele M. 0 rlrtn'tl I-Nq., Id. No. 69849 Judith's'. Romano, Esq., Id. No. 58745 e ' . ?e y Jenne R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 ;A 1JVIIIIIIWr7Nri LA i f vackl Esq., Id. No. 84439 Courtenay R. Dunn, Esq., Id. No. 206719 Allison F. Wells, Esq., Id No. 309519 William E. Miller, Esq., Id No. 308951 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 Andrew J. Marley, Esq., !d, No. 312314 RuberL W. Cusick, Esq., Id. No. 80193 John M. Kolesnik, Esq., Id. No. 308877 Matthew Cr. Brushwood, Esq., Id. No. 310592 Dona B. Osu•ovsky, Esq., Id. No. 83921 One Penn Center at Suburban Station Exhibit "F" AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number.: 269907 Attorney Firm: Phelan, Hallinan & Schmieg, LLP Subject: Douglas Pritchard & Martha M. Pritchard Current Address: 4000 Tranquility Court, Monrovia, MD 21770 Property Address: 476 East King Street, Shippensburg, PA 17257 Mailing Address: 4000 Tranquility Court, Monrovia, MD 21770 I. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct Douglas Pritchard - xxx-xx-3439 Martha M. Pritchard - xxx-xx-8410 Douglas Pritchard & Martha M. Pritchard - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Douglas Pritchard & Martha M. Pritchard reside(s) at: 4000 Tranquility Court, Monrovia, MD 21770. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which had no listing for Douglas Pritchard & Martha M. Pritchard. B. On 04-17-12 our office made a telephone call to a possible phone number of the subject(s) (301) 949-7621 and received the following information: spoke with an unidentified female who confirmed that Douglas Pritchard & Martha M. Pritchard reside(s) at: 4000 Tranquility Court, Monrovia, MD 21770. IIl. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 04-17-12 we reviewed the National Address database and found the following information: Douglas Pritchard & Martha M. Pritchard - 4000 Tranquility Court, Monrovia, MD 21770. B. ADDITIONAL ACTIVE. MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: no addresses on file. IV. OTHER INQUIRIES A. DEATH RECORDS As of 04-17-12 Vital Records and all public databases have no death record on file for Douglas Pritchard & Martha M. Pritchard. V. ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Douglas Pritchard -1957 Martha M. Pritchard -1958 B. A.K.A. Douglas Thomas Pritchard Martha Marie Pritchard; Martha T. Pritchard; Martha M, Myers " Our accessible databases have been checked and cross-referenced for the above named individual(s). x Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to LhC4 1a1 es_-QUb-.. !??-C -_42Q!U1 9JP u=warn falsification to authgf ics•,,_ The above information fa obtained from available public records and we are only liable for the cost of the affidavit. Exhibit "G" .. t '? .?12 V y p ? a as as ? a 1 L v ? G zdo ?$L5 o N b Hs g a rpO G p, v? N O GVy. OI QQpp O y u O O V Q O w 7 i I C4 w O mu 'p ? H E-+ G a O? w? ? on 01 ?oo ?? ? C7 a p? a C7 pc°?O S0 ?m x in Cf) to Am "t ? z B rn z a? N ax. ? o ? .. N M kn ?D t- oo .a CL. I "fl O W 8 w ? h N O ti a Phi4an Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 Kathleen Lake, Ext 1316 Representing Lenders in Service Department Pennsylvania and New Jersey June 1, 2012 DOUGLAS PRITCHARD 476 EAST KING STREET SHIPPENSBURG, PA 17257 RE, WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING COMPANY v. DOUGLAS PRITCHARD and MARTHA M. PRITCHARD Premises Address: 476 EAST KING STREET, SHIPPENSBURG, PA 17257-1509 CUMBERLAND Comity, No. 2012-633-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, service of the complaint by first class mail and posting of the mortgaged premises. Please respond to me within one week, by June t 1, 2012. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, Allison I`. Fsq., id. No,309519 Attorney for 11 la i n i i I t* 269907 Phelan Hallman & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 Kathleen Lake, Ext 1316 Representing Lenders in Service Department Pennsylvania and New Jersey June 1, 2012 MARTHA M. PRITCHARD 476 EAST KING STREET SHIPPENSBURG, PA 17257 RE: WELLS FARGO BANK, NA, DB/A AMERICAS SERVICING COMPANY v. DOUGLAS PRITCHARD and MARTHA M. PRITCHARD Premises Address: 476 EAST KING STREET, SHIPPENSBURG, PA 17257-1509 CUMBERLAND County, No. 2012-633-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, service of the complaint by first class mail and posting of the mortgaged premises. Please respond to me within one week, by June 11, 2012. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly;- ' Very truly yours, {t?Llrc>n 1 -W8;1~tiq , Id. No.309519 Attorney for Plaintiff 269907 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 Kathleen Lake, Ext 1316 Representing Lenders in Service Department Pennsylvania and New Jersey June 1, 2012 DOUGLAS PRITCHARD 4000 TRANQUILITY COURT MONROVIA, MD 21770 RE: WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING COMPANY v, DOUGLAS PRITCHARD and MARTHA M. PRITCHARD Premises Address: 476 EAST' KING STREET, SHIPPENSBURG, PA 17257-1509 CUMBERLAND County, No. 2012-633-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, service of the complaint by first class mail and posting of the mortgaged premises. Please respond to me within one week, by June 11, 2012. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly.. Very truly your;, Alfi.so n F. Wells, 1 sq-- Id. No.309519 Attorney for Plaintiff 269907 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 Kathleen Lake, Ext 1316 Representing Lenders in Service Department Pennsylvania and New Jersey June 1, 2012 MARTHA M. PRITCHARD 4000 TRANQUILITY COURT MONROVIA, MD 21770-9005 RE: WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING COMPANY v. DOUGLAS PRITCHARD and MARTHA M. PRITCHARD Premises Address: 476 EAST KING STREET, SHIPPENSBURG, PA 17257-1509 CUMBERLAND County, No. 2012-633-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with CUMBERLAND County Local Rule 208.3(9),1 am seeking concurrence with the requested relief that is, service of the complaint by first class mail and posting of the mortgaged premises. Please respond to me within one week, by June 11, 2012. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly Allison--K Me4s, Esq., Id. No.309519 Attorney for Plaintiff 269907 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA, DB/A AMERICAS SERVICING COMPANY Plaintiff vs. DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Defendants No. 2012-633-CIVIL CERTIFICATION OF SERVICE The undersigned hereby certifies that a copy of the Motion for Service Pursuant to Order of Court, Memorandum of Law, Proposed Order and attached exhibits have been sent the individuals as indicated below by first class mail, postage prepaid, on the date listed below. DOUGLAS PRITCHARD and MARTHA M. PRITCHARD at: 476 EAST KING STREET SHIPPENSBURG, PA 17257 4000 TRANQUILITY COURT MONROVIA, MD 21770 The undersigned understands that this statement is made subject to the penalties of 18 C.S. §4904 relating to unsworn falsification to authorities. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP Date: By. Attorney for Plaintiff Attorney for Plaintiff Court of Common Pleas Civil Division CUMBERLAND County Melissa J. CantwyejJ .. ,??. ID 308912 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, DB/A AMERICAS Court of Common Pleas SERVICING COMPANY Plaintiff Civil Division vs. CUMBERLAND County DOUGLAS PRITCHARD No. 2012-633-CIVIL A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Defendants ORDER AND NOW, this l`ogday of ;' 2012, upon consideration of Plaintiff s 7 motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED, that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on the above captioned Defendants, DOUGLAS PRITCHARD and MARTHA M. PRITCHARD, by: 1. Posting of the premises: 476 EAST KING STREET, SHIPPENSBURG, PA 17257-1509 by the Sheriff or a non-party competent adult; and 2. First class mail to DOUGLAS PRITCHARD and MARTHA M. PRITCHARD at the last known address, 4000 TRANQUILITY COURT, MONROVIA, MD 21770, and the mortgaged premises located at 476 EAST KING STREET, SHIPPENSBURG, PA 17257. 3. Publication in accordance with PA. R.C.P. 430. PHS# 269907/KPL It is further'ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to ensure compliance with this Court Order. B THE COURT: J. ? Cc:DOUGLAS PRITCHARD MARTHA M. PRITCHARD 476 EAST KING STREET, ,- SHIPPENSBURG, PA 17257 rn ? DOUGLAS PRITCHARD 9 d MARTHA M. PRITCHARD 77 4000 TRANQUILITY COURT 01 : =~ _= ; c MONROVIA, MD 21770 5; 17? 1 Pkek, Il,ta? ecp-tes ma, -led 7/i A f i? )e?l c PHS# 269907/KPL PHELAN HALLINAN & S IEG, LL~~ ~ ~~q. ~ ~ ~ John M. Kolesnik, Esq., Id. o. 308877 1617 JFK Boulevard, Suite 1400 ~~ ~ ~ ~~~ ~ O One Penn Center Plaza Philadelphia, PA 19103 ~~~~~~ O 215-563-7000 ~~~~ ~,~ WELLS FARGO BANK, NA, DB/A AMERICAS SERVICING COMPANY Plaintiff vs. ~~ ~~ IAF~``+ ~~ !ITY T OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY DOUGLAS PRITCHARD A/K/A DOUGLAS T. No. 2012-633-CIVIL PRITCHARD MARTHA M. PRITCHARD Defendants , TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the captioned matter. PHELAN~LLINAN & SCHMIEG, LLP By:_ J Date: August 16, 2012 jhk/l~pl, Svc Dept. File 269907 Kolesnik, Esq., Id. No. 308877 for Plaintiff gl1.~s C~~ ~~ ~~~~a a~ 3 PHELAN HALLINAN & SCHMIEG, LLP Attorney for Plaintiff Zachary Jones, Esq., Id. No.310721 1617 JFK Boulevard, Suite 1400 r~ .., ~ ."-' One Penn Center Plaza c ~? ~ „r; ~ Philadelphia, PA 19103 ~ t~ ~ -~- ~ 215-563-7000 ~ ~ ° ~ n ~~„ ~ dC1 WELLS FARGO BANK, NA, DB/A CUMBERLAND COUNTY ~ a ti AMERICAS SERVICING COMPANY i ~ ~. ~ ° ~~ COURT OF COMMON PLE~~ ~? °r i vs. ~ CIVIL DIVISION ~ c~ `~'' ~ DOUGLAS PRITCHARD . A/K/A DOUGLAS T. PRITCHARD No. 2012-633-CIVIL MARTHA M. PRITCHARD PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD and MARTHA M. PRITCHARD, Defendants for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint TOTAL $67,351.09 $67,351.09 I hereby certify that (1) the Defendants' last known addresses are 4000 TRANQUILITY COURT, MONROVIA, MD 21770-9005 and 476 EAST KING STREET, SHIPPENSBURG, PA 17257-1509, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date / ~~ ! DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ! /d PROTHONOTARY ~IIo,50 PD A7T( G'~1a4~~ e~o~8o147'j Nol+c~ Maileal 269907 PHELAN HALLINAN & SCHMIEG, LLP Zachary Jones, Esq., Id. No.310721 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, NA, D/B/A AMERICAS SERVICING COMPANY vs. DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.2012-633-CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRTTCHARD is over 18 years of age and resides at 4000 TRANQUILITY COURT, MONROVIA, MD 21770-9005 and 476 EAST KING STREET, SHIPPENSBURG, PA 17257- 1509. (c) that defendant MARTHA M. PRTTCHARD is over 18 years of age and resides at 476 EAST KING STREET, SHIPPENSBURG, PA 17257-1509 and 4000 TRANQUILITY COURT, MONROVIA, MD 21770-9005. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~.. - v Date 269907 WELLS FARGO BANK, NA, DB/A AMERICAS COURT OF COMMON PLEAS SERVICING COavIPANY CIVIL DIVISION Plaintiff v• NO. 2012-633-CIVIL DOUGLAS PRITCHARD, A/K/A DOUGLAS T. PRITCHARD CUMBERLAND COUNTY MARTHA M. PRITCHARD Defendant(s) TO: DOUGLAS PRTTCHARD, A/K/A DOUGLAS T. PRTTCHARD 4000 TRANQUILITY COURT MONROVIA, MD 21770-9005 DATE OF NOTICE: I ~ ~„~, THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRII"TEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717}240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 269907 WELLS FARGO BANK, NA, DBlA AMERICAS COURT OF COMMON PLEAS SERVICING COMPANY CNIL DNISION Plaintiff v. NO. 2012-633-CN1L DOUGLAS PRTI'CHARD, A/K/A DOUGLAS T. PRTTCHARD CUMBERLA~1D COUNTY MARTHA M. PRITCHARD Defendant(s) TO: DOUGLAS PRITCHARD, A/K/A DOUGLAS T. PRTTCHARD 476 EAST KING STREET SHIPPENSBURG, PA 17G257-1509 DATE OF NOTICE:. F ~~ ~ ~+0 ~ ~~ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WII.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 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 HIl2ING 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 EI..IGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717)240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (7~7) 249-3166 BYE'}~. ~ ~ ~?~.t.~~~--~' Meredith Wooters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 269907 WELLS FARGO BANK, NA, DB/A AMERICAS COURT OF COMMON PLEAS SERVICING COMPANY' CIVIL DIVISION Plaintiff v. DOUGLAS PRITCHARD, A/KJA DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Defendant(s) TO. MARTHA M. PRITCHARD 476 EAST KING STREET SHIPPENSBURG, PA ].7257-1509 DATE OF NOTICE: __~. NO. 2012-633-CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII.ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WTTH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 WTTH 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. Office of the Prothonotary' Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717)240-6195 CUMBERLAND COL'N'TY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 ``~~ jj,,~~(~~717) 249-31b6 BY1t~~~~ ~~ .1~,~ Meredith bloaters, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK $oulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 269907 WELLS FARGO BANK, NA, DB/A AMERICAS SERVICING COMPANY Plaintiff v. DOUGLAS PRITCHARD, A/K/A DOUGLAS T. PRTTCHARD MARTHA M. PRITCHARD Defendant(s) TO: MARTHA M. PRTI'CHARD 4000 TRANQUII.TTY COURT MONROVIA, MD 21770-9005 DATE OF NOTICE: ,,,,~~_~~~~~- COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-633-CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WII.L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IIVIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIIZING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGI$LE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 .Meredith Woofers, Esq., Id. No.307207 Attorney for Plaintiff Phelan Hallman & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 269907 (Rule of Civil Procedure No. 236) -Revised WELLS FARGO BANK, NA, DB/A AMERICAS SERVICING COMPANY vs. DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.2012-633-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on ! If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Zachary Jones, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. 269907 ' r AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK,NA,D/B/A AMERICAS SERVICINGta COMPANY PHS#269907 'v DEFENDANT SERVICE TEA NV Ixh DOUGLAS PRITCHARD A/K/A DOUGLAS T.PRITCHARD COURT NO.:2012-633-CIVIL-a� �. MARTHA M.PRITCHARD c -SERVE DOUGLAS PRITCHARD AWA DOUGLAST: TYPE OF ACTION PRITCHARD AT: XX Notice of Sheriffs Sale -x c 4000 TRANQUILI'T'Y COURT SALE DATE: June 5,2013 MONROVIA,MD 21770-9005 SERVED Served and made known to DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCIARD, Defendant on` the v1 day f F" 20!3,at :�� o'clock .M.,at G 6V,e CeS S in the manner described below: ,/Defendant ifersonally served. Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship, Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business, an officer of said Defendant's company. Other: Description: Age Height "Jt�l Weight J'�Race_(A.,—) Sex M Other I, )411?A�_ ,a competent adult,being duly sworn according to law,depose and state that I personally handed a tote and corr py of the Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. Sworn to and su 'bed before a is da of 2 • NOT SERVED On 20_,at o'clock�.M.,I, a competent adult hereby stat a en ause: _Vacant,,' • •' l�i0t E Moved Does Not Reside(Not Vacant) _LJogn 'if.` at her: Sworn to and l�ciibi6d .•'• before me this ti day:.,.••°'�r� of r1; ,ITali} Notary: '" " ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 t AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK,NA,D/B/A AMERICAS SERVICING t COMPANY PHS#269907 c� DEFENDANT SERVICE TEAM/1xh DOUGLAS PRITCHARD A/K/A DOUGLAS T.PRITCHARD COURT NO.:2012-633-CIVIL:x:.-- MARTHA M.PRITCHARD c!s r SERVE MARTHA M.PRITCHARD AT:"' ' . ' TYPE OF ACTION 4000 TRANQUILITY COURT XX Notice of Sheriff's Sale `C-) MONROVIA,MD 21770-9005 SALE DATE: June 5,2013 SERVED c° Served and made known to MARTHA M.PRITCHARD,Defendant on the,.2 day of � 20 ,at "I o'clock p M.,at at &6 v,-- li e:,in the manner described below: Defendant personally served. Adult family member with whom Defendant(s)reside(s). Relationship is)k4 . _Adult in charge of Defendant's residence who refused to give name or relationship. _Manager/Clerk of place of lodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _Other: Description: Age Height o,4 tj Weight Jr� Race_LL) Sex 41 Other I, #4 /,f a competent adult,being duty sworn according to law,depose and state that I personally handed a true and Corr "O copy of the Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. Sworn to ands cribed before m is day of ,20 y NOT SERVED ` On the 0_,at o'clock M.,I, a competent adult hereby state th use: — � r� LP,n _Moved Does Not Reside(Not Vacant) No tt er'( �^At at —Servi Refried Other: `- Sworn to and s scribed before me this payq , Y Of Notarjr: ,, ORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 3FK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 Ir....._ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, NA, D/B/A AMERICAS : Court of Common Pleas SERVICING COMPANY Plaintiff : Civil Division v. • CUMBERLAND County i DOUGLAS PRITCHARD No.: 2012-633-CIVIL A/K/A DOUGLAS T. PRITCHARD : MARTHA M. PRITCHARD Defendants RULE AND NOW, this day of 4069 / 2013, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendants shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY . COURT J. r-, ∎; y-' 1 i:;f:- 1 - C..' r-- _.i _: P 269907 Phelan Hallinan, LLP Jonathan M.Etkowicz, Esq., Id. No.208786 ATTORNEY FOR PLAINTIFF 161.7 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonatlian.etkowicz@phelanhallinan.com 21.5-563-7000 WELLS FARGO BANK,NA, D/B/A AMERICAS Court of Common Pleas SERVICING COMPANY CD Plaintiff Civil Division , vs. CUMBERLAND Cft -bm DOUGLAS PRITCHARD No.: 2012-633-CIVII�> cn acs A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD r-j .=C:) Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's April 4, 2013 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. DOUGLAS PRITCHARD DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD MARTHA M. PRITCHARD 4000 TRANQUILITY COURT 476 EAST KING STREET MONROVIA, MD 21770-9005 SHIPPENSBURG, PA 17257-1509 DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD 3327 TIDEWATER COURT OLNEY,MD 21770 Phe19p DATE: l3 By: Jona M. owicz,Esq., Id.No.208786 Attoi ey for Plaintiff 269907 Il.ED-0F t=ICE Phelan Hallinan, LLP OF THE PR0THUNOTAR Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 2013 APR 30 AM 10: 18 One Penn Center Plaza CUMBERLAND COUNTY Philadelphia, PA 19103 PENNSYLVANIA Jonathan.Lobb@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, NA, D/B/A AMERICAS : Court of Common Pleas SERVICING COMPANY Plaintiff • Civil Division • vs. • CUMBERLAND County DOUGLAS PRITCHARD : No.: 2012-633-CIVIL • A/K/A DOUGLAS T. PRITCHARD • MARTHA M. PRITCHARD Defendants MOTION TO MAKE RULE ABSOLUTE WELLS FARGO BANK,NA, D/B/A AMERICAS SERVICING COMPANY, by and through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. A Motion to Reassess Damages was filed with the Court on April 1, 2013. 2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendants on March 25, 2013 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A. 3. A Rule was issued by the Honorable Albert H. Masland on or about April 4, 2013 directing the Defendants to show cause by April 24, 2013 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B. 4. The Rule to Show Cause was timely served upon all parties on April 12, 2013 in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit C. 269907 5. Defendants failed to respond or otherwise plead by the Rule Returnable date of April 24, 2013. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. Phelan Hallinan, LLP DATE: 41/2q I,3 By: Jo athan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 269907 Exhibit "A" 269907 PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia,PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan, LLP Representing Lenders in Pennsylvania and New Jersey March 25th 2013 DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD 4000 TRANQUILITY COURT MONROVIA, MD 21770-9005 RE: WELLS FARGO BANK,NA,D/B/A AMERICAS SERVICING COMPANY v. DOUGLAS PRITCHARD,A/K/A DOUGLAS T. PRITCHARD and MARTHA M. PRITCHARD Premises Address: 476 EAST KING STREET SHIPPENSBURG,PA 17257 CUMBERLAND County CCP,No. 2012-633-CIVIL Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is,increasing the amount of the judgment.Please respond to me within 5 days, by 3/30/2013. Should you have further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. Very truly yours, ai! f hathan Lobb,Esq.,Id.No.312174 Attorney for Plaintiff Enclosure 269907 • t-'- C) CZN 0\ • (N CtJi vf avA, t. Td t'O'COO $ - -I- • -„, , , = •k. in3 0 1b-)i ,GVt_r:r) _ ,".€.. - 4 ta? 7 = egi-E !LI ff7'.-8 0IE - i; 4*IE ,FA Cr 9.8413 4t 'c--o ,...., 2 ;:x.■ -0..:;t44'. :4 :a., .1 E o 0 z 4 ..° E—, 44 i • 7 r, u) > ea et t .. (.7 , ...0 . 0 1 13- .., a. E a4 ,.. ".., to tes 0\ IA c 0 05 w 5 a, in g 7:3 E-. tel 0 . cp 0 C ■:---' as ,.., :4 E- el = ,---- = ._, H - - © c..:, c4 •. a. - ts4 -' ' ' E"' E.* rq () ..' Jr) ' C.' """ t- . 4. .2. cN e ) -. Ei' (.. F.. p4 W t- 0 ,_. ,cs gi. -- w) E.." :4 ." p. c) ae .. ow F- * Q0 g 8 ; 1,15 < t R' 0 :5 ° Ea 2 D C4 • .."1 rl 't " °'e cf-:s' 15 0' 43 ao :5 01- '0* ; y AO ;' ; t g: '-• tk t o`th (5 -.4' :::)..d 4*d 4 7 ""-'-' 7 .1.rn- Cl) cz 7 r''' C •,.-, I , z C..> 0 -0 7 1' Z )1: % X 1' St , k a) ■. -o cn 4.4 N N E i 1-72 en -ci t -et 1 g 3 E z . a) 4) a.) - ' - 0 0 :': ..174. 6" , ,,, en 40 Z -t 0 ' 37 . . Exhibit "B" 269907 IN THE COURT OF COMMON O MON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, NA, D/B/A AMERICAS : Court of Common Pleas SERVICING COMPANY : Plaintiff • Civil Division • v. CUMBERLAND County DOUGLAS PRITCHARD : No.: 2012-633-CIVIL A/K/A DOUGLAS T. PRITCHARD - MARTHA M. PRITCHARD Defendants RULE AND NOW,this day of 9 /2013, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendants shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY COURT r - . ^4 r , 269907 Exhibit "C" 269907 Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.ekowicz @phelanhallinan.corn 215-563-7000 WELLS FARGO BANK,NA, D/B/A AMERICAS Court of Common Pleas SERVICING COMPANY Plaintiff Civil Division vs. CUMBERLAND County DOUGLAS PRITCHARD No.: 2012-633-CIVIL A/KJA DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's April 4,2013 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. DOUGLAS PRITCHARD DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M.PRITCHARD MARTHA M. PRITCHARD 4000 TRANQUILITY COURT 476 EAST KING STREET MONROVIA,MD 21770-9005 SHIPPENSBURG,PA 17257-1509 DOUGLAS PRITCIARD A/K/A DOUGLAS T.PRITCHARD MARTHA M. PRITCHARD 3327 TIDEWATER COURT OLNEY, MD 21770 Phela . 11in .31( Ai if i DATE: __ _ _.._ BY' ' 1 .(«na 1 MP_I; otiwicrr EN., Id. No.208786 aA,(IN t ;'v for Plaintiff 269907 Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb @phelanhallinan.com 215-563-7000 WELLS FARGO BANK,NA, D/B/A AMERICAS : Court of Common Pleas SERVICING COMPANY Plaintiff • Civil Division • vs. • CUMBERLAND County • DOUGLAS PRITCHARD • No.: 2012-633-CIVIL A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Motion to Make Rule Absolute was served upon the following individuals on the date indicated below. DOUGLAS PRITCHARD DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD MARTHA M. PRITCHARD 4000 TRANQUILITY COURT 476 EAST KING STREET MONROVIA, MD 21770-9005 SHIPPENSBURG, PA 17257-1509 DOUGLAS PRITCHARD A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD 3327 TIDEWATER COURT OLNEY,MD 21770 Phelan Hallinan, LLP DATE: yl29 f[3 By: Jon an Lobb,Esq., Id. No.312174 Attorney for Plaintiff 269907 C> PHELAN HALLINAN,LLP Attorney for Plaintiff c_ `} Meredith Wooters,Esq.,Id. No.307207 - � -' y 1617 JFK Boulevard,Suite 1400 rnM -0 One Penn Center Plaza = -0� Philadelphia,PA 19103D o C 215-563-7000 "' -r ° 332 O C..) = x— IN THE COURT OF COMMON PLEAS C OF CUMBERLAND COUNTY,PENNSYLVANIA ' D WELLS FARGO BANK,NA,DB/A AMERICAS CUMBERLAND COUNTY SERVICING COMPANY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION DOUGLAS PRITCHARD A/K/A DOUGLAS T. No.: 2012-633-CIVIL PRITCHARD MARTHA M.PRITCHARD Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a)Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c)on each of the persons or parties named,at that address,set forth on the Affidavit and as amended if applicable.A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S.Postal Service is attached hereto Exhibit"A". Meredith Wooters,Esq.,Id.No.307207 Date: a (v 3 Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS#269907 Na-.q and Phelan Hallinan.LLP Address y 1617 JFK Boulevard,Suite 1409 Of Sender One Penn Center Plaza Iw Philadelphia.PA 19103 AxICf1'AP-06/95,r20I3 SALE Lire Arsicle Number Name of Addrrzsec,Streei and Post Office Address Pnct>a e 6 1 •W"W I EAIANTIOCCUPANT 50144 476 EAST K.14\.G STREET SHIPPENSBURG,PA 17257-1509 a 2 """• DOMESTIC RELATIONS OF $0.44 CUMBERLAND COUNTY cn a 13 NORTH HANOVER STREET y =' 0S CARLISLE,PA_17013 _ }t 3 **"' _.. COMMONWEALTH OF PENNSYLVANIA $0.44 '7 WIPARTYIEN`T OF WELFARE P.O.BOX 2675 HARRISBURG PA 17105 rii!• 4 •WWW INTERNAL.REVENUE SERVICE ADVISORY $11.44 1000 LIBERTY AVr NOE ROOM 704 x PITTSBURGH,.P.A 15222 5 •'W' U.S.DEPARTMENT OFJUb-rICE - S0,44 U.S.ATTORNEY FOR THE I IDDLE DISTRICT OF PA. FEDERAL BUILDING 228 WALNUT STREET,SUITE 220 PO BOX 11754 HARRISBURG PA 1710&1754 _ IREMOUGL'ASTPRITCHARt)'OAKIA DOUCLAS T.PRITCHARD(CUMBERS?AND)VWR "#;]6f) 52 0. Palmy, WtitiCra otil N=W Of oal Nmbtr o Atm pmrava um or da amioa Odwalrc WfeVina ca ah dcm�IndlManatiaosl ttOskrcd rnsil,The mv=m irW mmty Fytldr . Ticw Elated by Seada, Ri 6e ad X PW Office ntsds ht Earyigx) for the reurestwion of nonnesovlabk dxunetts uidn Gv ,=Nail dzsmmt i— cs u$50,000 pa p;c:•ec-vhjrel tna lmit nfS50J,eKO p�.e..reurence.Thema.imam imkmmry p:+ysTh.m=specs Mal merelfndisek SSW. The mucimum indaaniiy ptryatsk is S25AOO fa reg7siaed nail,sat tsith optional inforaaOt.Ste Dan:Aie Pict Aimuil RS�p<.91J and 557t for Imimimu of a� Form 3877 Facsimile IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA WELLS FARGO BANK,NA, D/B/A AMERICAS Court of Common Pleas SERVICING COMPANY Plaintiff Civil Division vs. CUMBERLAND Court o DOUGLAS PRITCHARD No.: 2012-633-CIV92r t, j!! A/K/A DOUGLAS T. PRITCHARD MARTHA M. PRITCHARD 8? Defendants C)-n -4> <-5 ORDER < AND NOW, this day of 2013,upon consideration of Plaintiff's Motion to Make Rule Absolute,it is hereby ORDERED and DECREED,that the Rule entered upon Defendants shall be and is hereby made absolute and Plaintiff s Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ minc pro tunc as follows: Principal Balance $60,520.42 Interest Through April 5,2013 $11,350.22 Late Charges $70.44 Legal fees $1,300.00 Cost of Suit and Title $1,403.39 Property Inspections $435.00. Escrow to be paid prior to June 5,2013 $436.10 Escrow Deficit $3,319.68 TOTAL $78,835.25 Plus interest at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. BYT4E COURT: 269907 SHERIFF'S OFFICE OF CUMBERLAND COUNTY , Ronny R Anderson 3 —' Sheriff r.+1 rn _ �outxtr at i[1plrr+4j14 Jody S Smith 2v:r11.7) Chief Deputy - Y) G C$11 Q Richard W Stewart -r+ Solicitor OFFICE OF THE SHERIFF • mac; Wells Fargo Bank, N.A. Case Number vs. 2012-633 Douglas Pritchard (et al.) SHERIFF'S RETURN OF SERVICE 04/02/2013 06:57 PM -Deputy Shawn Gutshall, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 476 East King Street, Shippensburg Borough, Shippensburg, PA 17257, Cumberland County. 06/05/2013 As directed by Joseph Schalk,Attorney for the Plaintiff, Sheriffs Sale Continued to 8/7/2013 08/07/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle PA on August 7, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney David Fein, on behalf of, Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $931.07 SO ANSWERS, October 03, 2013 RONNY R ANDERSON, SHERIFF (cj County/Suite Sheriff,Teleosoft,Inc.