HomeMy WebLinkAbout12-0712I
FtLO-OFFICE
Martha E. Von Rosenstiel, P.C. OF THE PROTHONOTARY
Martha E. Von Rosenstiel, Esquire 6
649 South Avenue, Unit #7 2012 FEB
Secane, PA 19018
(610) 328-2887 CUMBERLAND ANUA
Attorney I.D. #52634 P
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-
BACKED CERTIFICATES, SERIES 2007-OPT 1
4650 Regent Blvd
Irving, TX 75063
V.
RANDY LAWRENCE OR OCCUPANTS
5405 Joshua Road
Mechanicsburg, PA 17050
29635-CFC-EM
Attorney for Plaintiff
COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
Plaintiff j?
Defendant(s) :
CIVIL ACTION - EJECTMENT
NOTICE
ADVISO
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
Le han demandado a usted en ]a corte. Si usted quiere defenderse de
estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta a sentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea a visado que si usted no se defiende, la corte toma ra medidas y
puede continuar la demanda en contra suya sin previo aviso o
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones
de esta demanda. Usted puede perder dinero o sus propiedades o
otros de rechos importantes para usted.
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 ELEGIBLE PERSONS AT A REDUCED
FEE OR NO FEE
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN
PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO
. ESTA OFICINA LE PUEDE PROVEER INFORMACION
SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED
NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR
A UN ABOGADO, LE PODEMOS DAR INFORMACION
SOBRE AGENCIAS QUE PROVEEN SERVICIO LEGAL A
PERSONAS ELEGIBLE PARA SERVICIOS A COSTO
REDUCIDO O GRATUITO
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
800-990-9108
a ?l lag7SPQ
C? soak00
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Jacqueline F. McNally, Esquire / No. 201332
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
WELLS FARGO BANK, N.A., AS TRUSTEE FOR
SOUNDVIEW HOME LOAN TRUST 2007-OPT1,
ASSET-BACKED CERTIFICATES, SERIES 2007-
OPT1
4650 Regent Blvd
Irving, TX 75063
V.
Plaintiff
RANDY LAWRENCE OR OCCUPANTS
5405 Joshua Road
Mechanicsburg, PA 17050
29635-CFC-EM
COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
. NO.
Defendant(s) :
CIVIL ACTION - EJECTMENT
1. Plaintiff, Wells Fargo Bank, N.A., as Trustee for Soundview Home Loan Trust 2007-
OPT1, Asset-Backed Certificates, Series 2007-OPT1, is the owner of premises known as 5405
Joshua Road, Mechanicsburg, PA 17050, more fully described in the legal description, a true and
correct copy is attached hereto, made part hereof and marked as Exhibit I.
2. Plaintiff claims title to the aforesaid property by virtue of a Sheriffs sale held on
December 07, 2011, in the execution of a judgment in mortgage foreclosure obtained in the
Court of Common Pleas of Cumberland County, Docket No. 2011-2985 where Plaintiff was the
successful bidder.
3. The Plaintiff became the owner of the said property by a sheriff s deed recorded on
January 12, 2012 in the Office of the Recorder of Cumberland County at Instrument No.
201201123. A true and correct copy is attached hereto, made part hereof and marked as Exhibit
II.
4. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is
entitled to possession thereof. The Defendants Randy Lawrence or Occupants are occupying the
said premises without right, and so far as the Plaintiff is informed, without claim of title.
WHEREFORE, plaintiff demands judgment for possession of 5405 Joshua Road,
Mechanicsburg, PA 17050.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL,[P.C.
BY:/ J / _
N7artha E. Von Rosenstiel, Esquire
Jacqueline F. McNally, Esquire
Attorneys for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing documents are true and correct and are
matters of public record.
I understand that false statements herein are made subject to penalties of 18 Pa C.S.
Section 4904 relating to unsworn falsification to authorities.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, ?.C.
BY:
Martha E. Von Rosenstiel, Esquire
Jacqueline F. McNally, Esquire
Attorneys for Plaintiff
Dated: February 02, 2012
EXHIBIT I
ALL that certain piem parcel or lot of land together with improvenxu, situated to Hampden Township,
nbe rland County Pennsylvania and bounded and described as follows;
BEGINNING at a Point On Western right-of-way lift of Joel Drive (50.00 Ret wide) said point being located at the
Soudwastern conker of Lot No.201; then along said. right-of-way lbt on the are ofa circle curvifis to the lad,
having a radio of 425.00 fibs, and an arc length of7.78 feet, to a. point; dttn Swath 14 degrees 19 minute`s 47
scoonds East, fat a distance of 49.30 fart, to a paint on the are of s circle curving ao the right, having a radius of
25.00 feet, tad so arc length of 35.88 beat, to a point on do Northern right-cif-way Has of Josltua Road (50.00 *d
w idc); dien skmS said r4l&of way lint as Hatt arc of a Cade curving to dae la k, halving, a radius of 475.00 fbet and
an sit tenth of 92.24 font, to a point; Then South 36 dope 46 minwas 43 seconds West, w A through a 15.00 foot
wide dmiaragie essema t, ft a distow of 13.58 feet, to a point in One of preposed Phase VM; then along mid
propond phase VIL laid along the oeaaerline of said 15.00 footer dminage ememenk Nm* 33 degrees 13
rninudasa 17 secoedc West far a distance of 105.04 font, to a point in an existing iron p*, then North 10 degrees 43
n to tos 57 secoada Fast, for a distance of 505 fact, to a point at die Soutiwemm cones of Lot No, 20 I; then
along the Soutlaern boundary line of Lot No. 201 South 72 dt s 16 taimsks 00 sewcoa& Fast, for a distance of
58.89 feet to a point; tom North 83 degrees 54 winutes 38 sccaads Lust, for a distance of 85,00 Pent to a point and
the plant, ofBEGENNTN1NG
This piece, pastel of lot of land contains approximately 15,436,21 square feet oRLnd, bas an ads of 5445 Joshua
Road Medwnlcsb utg, Pennsylvania 17055, and is hum and numbered as Lot No. 362 on the Final vision
Plan for Good Hope Farms South Phase IV - Lot Nor. 201 and 202, which is retarded in t barlsnd County in Plan
Book 91, Pap 66.
Parcel# 10-19.1602-109
Property address, 5405 Joshua Road, Mechanicaburg, PA 17050
Being the sarttt premises which. McN ton Company, by Des dated t)11t29t2PAlo and recorded 16'0212004 in the
ReowdWs C1ffict ofC unibedand County, in Decd book 230 Page Si, granted and oo ytid woo Randy L.
1.awre= and glutton A. Lawry, husband and wife.
AND BEING the same premises which were sold to WELLS FARGO BANK, N.A., AS
TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-OPT1, ASSET-BACKED
CERTIFICATES, SERIES 2007-OPT1, as Trustee by the Sheriff of CUMBERLAND County on
December 07, 2011 in execution of a judgment in mortgage foreclosure entered in the Court of
Common Pleas of CUMBERLAND County Docket No. 2011-2985.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Wells Fargo Bank, N.A.
vs.
Randy L. Lawrence
4??,tix? of ?.oraraGrr/7??
LAN" CJv?r i
Case Number
2012-712
SHERIFF'S RETURN OF SERVICE
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: Occupant for 5405 Joshua Road, Mechanicsburg,
Pennsylvania 17050, but was unable to locate them in his bailiwick. He therefore returns the within
Complaint in Ejectment as not found as to the defendant Occupant. Request for service at 5405 Joshua
Road, Mechanicsburg, Pennsylvania 17050 is vacant.
02/09/2012 01:40 PNI - 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: Randy L. Lawrence, but was unable to
locate him in his bailiwick. He therefore returns the within Complaint in Ejectment as not found as to the
defendant Randy L. Lawrence. Request for service at 5405 Joshua Road, Mechanicsburg, Pennsylvania
17050 is vacant.
SHERIFF COST: $64.00 SO ANSWERS,
February 14, 2012 RON R ANDERSON, SHERIFF
WELLS FARGO BANK, N.A., AS TRUSTEE : COURT OF COMMON PLEAS
FOR SOUNDVIEW HOME LOAN TRUST CUMBERLAND COUNTY
2007-OPT1, ASSET-BACKED :
CERTIFICATES, SERIES 2007-OPT1
Plaintiff
NO: 2012-712-CIVIL
VS.
RANDY LAWRENCE OR OCCUPANTS
Defendants
ORDER
AND NOW, this "day of y7 , 2012 upon consideration of Plaintiffs Motion
for Special Service and any response thereto (if any), it is hereby:
ORDERED and DECREED that Plaintiff may obtain service on Randy Lawrence Or
Occupants by mailing a true and correct copy of the Complaint in Ejectment and all subsequent
notices, including, but not limited to, the Writ of Possession, by certified mail and regular, first
class mail at the last known address, 5405 Joshua Road, Mechanicsburg, PA 17050 and by
posting the premises of 5405 Joshua Road, Mechanicsburg, PA 17050.
BY T COURT:
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MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Jacqueline F. McNally, Esquire / No. 201332
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
WELLS FARGO BANK, N.A., AS TRUSTEE
FOR SOUNDVIEW HOME LOAN TRUST
2007-OPT I, ASSET-BACKED
CERTIFICATES, SERIES 2007-OPT1
4650 REGENT BLVD
IRVING, TX 75063
PLAINTIFF
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PEk11 !-SYLV,AN1A
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CASE NO: 2012-712-CIVIL
VS.
RANDY LAWRENCE OR OCCUPANTS
5405 JOSHUA ROAD
MECHANICSBURG, PA 17050
DEFENDANT(S)
PRAECIPE TO REINSTATE COMPLAINT IN EJECTMENT
To the Prothonotary:
Kindly reinstate the Complaint in Ejectment in the above matter.
Respectfully Submitted,
MARTHA E. VON ROSENSTIJL, P.C.
Martha E. Von Rosenstiel, Esquire
Jacqueline F. McNally, Esquire
Attorneys for Plaintiff
Dated: March 26, 2012
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SHERIFF'S OFFICE OF CUMBERLAND COUNT
= rv
Ronny R Anderson Y
Sheriff " rr-"-
Jody S Smith r--Z- -4rD
Chief Deputy
Richard W Stewart C--
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Solicitor c-n
Wells Fargo Bank, N.A.
vs. Case Number
Randy L. Lawrence 2012-712
SHERIFF'S RETURN OF SERVICE
04/19/2012 06:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 19,
2012 at 1810 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Occupant of 5405 Joshua Road, Mechanicsburg, Pennsylvania 17050, pursuant to order
of court by posting the premises located at 5405 Joshua Road, Mechanicsburg, Cumberland County,
Pennsylvania 17050 with a true and correct copy according to law.
RYAN BURGETT, D
04/19/2012 06:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on April 19,
2012 at 1810 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Randy L. Lawrence, pursuant to order of court by posting the premises located at 5405
Joshua Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 with a true and correct copy
according to law.
SHERIFF COST: $66.00
April 26, 2012
RYAN BURGETT, DE
SO ANSWERS,
RON R ANDERSON, SHERIFF
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Jacqueline F. McNally, Esquire / No. 201332
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
WELLS FARGO BANK, N.A., AS COURT OF COMMON PLEAS
TRUSTEE FOR SOUNDVIEW HOME CUMBERLAND COUNTY
LOAN TRUST 2007-OPT1, ASSET-
BACKED CERTIFICATES, SERIES 2007-
OPT I
4650 REGENT BLVD
IRVING TX 75063
VS.
PLAINTIFF
RANDY LAWRENCE OR OCCUPANTS
5405 JOSHUA ROAD
MECHANICSBURG PA 17050
DEFENDANT(S)
CASE NO: 2012-712-CIVIL
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY:
29635CFJ-EM
r-
cr :-
Enter judgment in the above captioned Ejectment action for failure of the above named
defendants to file an answer within twenty days from date of service thereof. I hereby certify that
Notice as provided in Rule 237.5 has been duly given, and that the time limits provided for in that
notice have expired as evidenced by the attached Exhibit I.
Property Address:
5405 JOSHUA ROAD
MECHANICSBURG PA 17050
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
Dated: May 22, 2012
i/4.. SAS
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BY:
M a E. Von Rosenstiel, Esq 're
acqueline F. McNally, Esquire
ttorneys for Plaintiff
Rte- -. 2 1 (?0?/
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MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Jacqueline F. McNally, Esquire / No. 201332
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
WELLS FARGO BANK, N.A., AS COURT OF COMMON PLEAS
TRUSTEE FOR SOUNDVIEW HOME CUMBERLAND COUNTY
LOAN TRUST 2007-OPT1, ASSET-
BACKED CERTIFICATES, SERIES 2007-
OPT1
4650 REGENT BLVD CASE NO: 2012-712-CIVIL
IRVING TX 75063
PLAINTIFF
VS.
RANDY LAWRENCE OR OCCUPANTS
5405 JOSHUA ROAD
MECHANICSBURG PA 17050
DEFENDANT(S)
AFFIDAVIT OF NON MILITARY SERVICE
29635CFJ-EM
MARTHA E. VON ROSENSTIEL, being duly sworn according to law deposes and says that
she is the attorney for the plaintiff herein; that she is duly authorized to take this affidavit in behalf of
the plaintiff, and 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 Soldiers' and Sailors' Civil Relief Act of Congress of
1940, as amended;
That Randy Lawrence or Occupants, Defendant(s) is/are over 21 years old and reside(s) at 5405
Joshua Road Mechanicsburg PA 17050.
I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section
4904 relating to unsworn falsification to authorities.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
BY:
E. Von Rosenstiel, squ e
J cqueline F. McNally, Esquire
Attorneys for Plaintiff
Dated: May 22, 2012
MARTHA E. VON ROSENSTIEL, P.C.
Martha E. Von Rosenstiel, Esquire / No. 52634
Jacqueline F. McNally, Esquire / No. 201332
649 South Avenue, Suite 7
Secane, PA 19018
(610) 328-2887
Attorneys for Plaintiff
WELLS FARGO BANK, N.A., AS TRUSTEE: COURT OF COMMON PLEAS
FOR SOUNDVIEW HOME LOAN TRUST CUMBERLAND COUNTY
2007-OPT1, ASSET-BACKED
CERTIFICATES, SERIES 2007-OPT1
Plaintiff
: No: 2012-712-CIVIL
VS.
RANDY LAWRENCE OR OCCUPANTS
Defendants
CERTIFICATE OF SERVICE
29635CFJ-EM
Martha E. Von Rosenstiel, Esquire hereby certifies that she is the attorney for the Plaintiff
herein, and that service of the praecipe to enter judgment in the above matter was made upon the
following:
RANDY LAWRENCE OR OCCUPANTS
5405 Joshua Road
Mechanicsburg, PA 17050
by regular first class mail, postage prepaid, deposited with the United States Postal Service on
5/22/2012.
This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
Dated: 5/22/2012
BY: cam. J
?E. Von Rosenstiel, Esq e
Ja queline F. McNally, Esquire
ttorneys for Plaintiff
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Court House, 1 Courthouse Square, Carlisle, PA 17013
David D. Buell, Prothonotary
Randy Lawrence or Occupants
5405 Joshua Road
Mechanicsburg, PA 17050
WELLS FARGO BANK, N.A., AS TRUSTEE: COURT OF COMMON PLEAS
FOR SOUNDVIEW HOME LOAN TRUST CUMBERLAND COUNTY
2007-OPT1, ASSET-BACKED
CERTIFICATES, SERIES 2007-OPT1
PLAINTIFF
VS.
RANDY LAWRENCE OR OCCUPANTS
DEFENDANT(S)
: NO: 2012-712-CIVIL
Notice
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment for possession has been entered against you in the above proceeding as indicated
below:
of
a Judgment by Default
F1 Money Judgment
F1 Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Court Findings
If you have any questions concerning this notice, please call: Attorney Martha E. Von
Rosenstiel, Esquire at this telephone number: 610-328-2887.
29635CFJ-EM
29635CPG-EM
Praecipe for Writ of Possession
(Pa.R. C.P. 3160-3165)
COUNTY OF CUMBERLAND
WELLS FARGO BANK, N.A., AS TRUSTEE FOR COURT OF COMMON PLEAS
SOUNDVIEW HOME LOAN TRUST 2007-0PT1, ASSET-
BACKED CERTIFICATES, SERIES 2007-OPT1 DOCKET NO. 2012-712-CIVIL
V.
RANDY LAWRENCE OR OCCUPANTS
TO THE PROTHONOTARY:
ATTORNEY I.D. #52634
Kindly issue Writ of Possession in the above Ejectment matter
5405 Joshua Road
Mechanicsburg, PA 17050
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Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
BY:
IJ ate? E. Von Rosenstiel,Esgte
cqueline F. McNally, Esquire
Attorneys for Plaintiff
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I of 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., AS TRUSTEE
FOR SOUNDVIEW HOME LOAN TRUST
2007-OPT1, ASSET-BACKED CERTIFICATES,
SERIES 2007-OPT I
VS.
No. 12-712 Civil Term
RANDY LAWRENCE OR OCCUPANTS
Costs
Attorney's $ 290.50
Plaintiff's $
Prothonotary $ 2.25
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
WELLFARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-
OPTI, ASSET-BACKED CERTIFICATES, SERIES 2007-OPTI
being: (Premises as follows):
5405 JOSHUA ROAD, MECHANICSBURG, PA 17050
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
7 ?1?2 ?- -
David D. Buell, Prothonotary,
Common Pleas Court of Cumberland County,
_
Date 6/l/12
(Seel)
2 of 2
No 12-712 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME
LOAN TRUST 2007-OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPTI
4650 REGENT BLVD
IRVING, TX 75063
vs.
RANDY LAWRENCE OR OCCUPANTS
5405 JOSHUA ROAD
MECHANICSBURG, PA 17050
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 290.50
Plff (s) $
Prothy $ 2.25
Sheriff $
Plaintiff (s) attorney name and address:
JACQUELINE F. MCNALLY, ESQ.
MARTHA E. VON ROSENSTIEL, P.C.
649 SOUTH AVENUE, SUITE 7
SECANE, PA 19018
Attorney for Plaintiff (s)
By virtue of this writ, on the
named
appurtenances, and
Where papers may be served
day of . I caused the within
_, to have possession of the premises described with the
Sworn and subscribed to before me this
Day of _
So Answers,
By
Sheriff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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OFFICE ..,F T--r S-fERIFF
S1,1 14 P11 2: !'
Wells Fargo Bank, N.A.
vs. Case Number
.
Randy L. Lawrence 2012-712
SHERIFF'S RETURN OF SERVICE
06/13/2012 10:35 AM - Tim Black, Deputy Sheriff, being duly sworn according to law, states that on June 13, 2012 at
1035 hours, he posted one true and attested copy of the within Writ of Possession directed to
"OCCUPANT" upon Real Estate located at 5405 Joshua Road, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
06/13/2012 10:35 AM - Tim Black, Deputy Sheriff, being duly sworn according to law, states that on June 13, 2012 at
1035 hours, he posted one true and attested copy of the within Writ of Possession directed to "RANDY L.
LAWRENCE" upon Real Estate located at 5405 Joshua Road, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
SHERIFF COST: $52.25 SO ANSWERS,
June 14, 2012 RON R ANDERSON, SHERIFF
(9, CowitySufte Sheriff. Te eosoft. Inc
Ronny 3 Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
u
?)Fx . ? --R;FF
2911 JUN 29 AM 8: 27
can aye COUNTY
Pn:vaHia
Wells Fargo Bank, N.A.
vs.
Randy L. Lawrence
Case Number
2012-712
SHERIFF'S RETURN OF SERVICE
06/13/2012 10:35 AM - Tim Black, Deputy Sheriff, being duly sworn according to law, states that on June 13, 2012 at
1035 hours, he posted one true and attested copy of the within Writ of Possession directed to
"OCCUPANT" upon Real Estate located at 5405 Joshua Road, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
06/13/2012 10:35 AM - Tim Black, Deputy Sheriff, being duly sworn according to law, states that on June 13, 2012 at
1035 hours, he posted one true and attested copy of the within Writ of Possession directed to "RANDY L.
LAWRENCE" upon Real Estate located at 5405 Joshua Road, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
06/27/2012 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of
the premises described as 5405 Joshua Road, Mechanicsburg, PA 17050.
SHERIFF COST: $104.75
June 28, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R-?, 7 Nl?
46-
lof 2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., AS TRUSTEE
FOR SOUNDVIEW HOME LOAN TRUST
2007-OPT1, ASSET-BACKED CERTIFICATES,
SERIES 2007-OPT I
VS.
No. 12-712 Civil Term-
RANDY LAWRENCE OR OCCUPANTS
Costs
Attorney's $ 290.50
Plaintiff's $
Prothonotary $ 2.25
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
WELLFARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME LOAN TRUST 2007-
OPT1, ASSET-BACKED CERTIFICATES, SERIES 2007-OPT1
being: (Premises as follows):
5405 JOSHUA ROAD, MECHANICSBURG, PA 17050
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sel I his/her (or their) interest therein.
12dlk?1
David D. Buell, Prothonotary,
Common Pleas Court of Cumberland County,
Date 6/1/12 i
(Seal)
TRUE COPY FROM RECORD
In Testimony wherso`, I here unto set my hand
and the s ai of sal` L rt at Carlisle, Pa.
This day rfC ?.?
Prothonota
2of2
No 12-712 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., AS TRUSTEE FOR SOUNDVIEW HOME
LOAN TRUST 2007-OPTI, ASSET-BACKED CERTIFICATES, SERIES 2007-OPTI
4650 REGENT BLVD
IRVING, TX 75063
vs.
RANDY LAWRENCE OR OCCUPANTS
5405 JOSHUA ROAD
MECHANICSBURG, PA 17050
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 290.50
Plff (s) $
Prothy $ 2.25
Sheriff $
Plaintiff (s) attorney name and address:
JACQUELINE F. MCNALLY, ESQ.
MARTHA E. VON ROSENSTIEL, P.C.
649 SOUTH AVENUE, SUITE 7
SECANE, PA 19018
Attorney for Plaintiff (s)
By virtue of this writ, on the
named
appurtenances, and
Where papers may be served
day of I caused the within
_, to have possession of the premises described with the
Sworn and subscribed to before me this
Day of
So Answers,
By
Sheriff
29635- CPG -EM (vacate)
Martha E. Von Rosenstiel, P.C.
Martha E. Von Rosenstiel, Esquire/ Attorney I.D. # 52634
Heather Riloff, Esquire/ Attorney I.D. 309906
649 South Avenue, Unit 6
Secane, PA 19018
610 328-2887
Attorney for Plaintiff
'?_ THE RJTNONOTAR i
: COURT OF COMMON PLEAS
WELLS FARGO BANK, N.A., AS TRUSTEE: CUMBERLAND COUNTY
FOR SOUNDVIEW HOME LOAN TRUST
2007-OPT1, ASSET-BACKED
CERTIFICATES, SERIES 2007-OPT1
PLAINTIFF
VS.
RANDY LAWRENCE OR OCCUPANTS
DEFENDANTS
: NO: 2012-712-CIVIL
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate the judgment in the above-referenced action.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
Nrartha E. Von Rosenstiel, Esquire
Heather Riloff, Esquire
Attorneys for Plaintiff
Dated: August 2, 2012
2012 Aud -7 AM 9: 20
LAND COUNTY
iSYLVANIA
aq}qq, odd aN?
Ck.? asst
RW ??rtp 7
Martha E. Von Rosenstiel, P.C.
Martha E. Von Rosenstiel, Esquire/ Attorney I.D. # 52634
Heather Riloff, Esquire/ Attorney I.D. #309906
649 South Avenue, Unit 6
S cane PA 19018
29635- CPG -EM (disc & eno)
Attorney for Plaintiff
610 328-2887
COURT OF COMMON PLEAW s?
WELLS FARGO BANK, N.A., AS TRUSTEE: CUMBERLAND COUNTY
FOR SOUNDVIEW HOME LOAN TRUSTp .i
2007-OPT1, ASSET-BACKED
CERTIFICATES, SERIES 2007-OPT1
NO: 2012-712-CIVIL C__ `•°
PLAINTIFF
VS.
RANDY LAWRENCE OR OCCUPANTS
DEFENDANTS
PRAECIPE TO MARK CASE DISCONTINUED AND ENDED
TO THE PROTHONOTARY:
Kindly mark this action discontinued and ended without prejudice.
Respectfully Submitted,
MARTHA E. VON ROSENSTIEL, P.C.
BY
MVrtha E. Von Rosenstiel, Esquire
Heather Riloff, Esquire
Attorneys for Plaintiff
r
Dated: August 2, 2012